PersonaWise Privacy Policy

1. Introduction

Lytle Solutions LLC ("Company," "we," "us," or "our") operates PersonaWise, an AI-powered self-reflection and personal growth platform. This Privacy Policy explains how we collect, use, protect, and disclose your information when you use our website, mobile application, and services (collectively, the "Service").

By creating an account or using PersonaWise, you agree to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not use our Service.

2. Information We Collect

3. How We Use Your Information

We use your information exclusively to:

• Provide persona conversations: Your life experience data is used to generate AI personas that reflect different periods of your life
• Power AI therapeutic validation: Persona responses are filtered through evidence-based therapeutic frameworks (CBT, DBT, ACT) to ensure emotional safety
• Enable journaling & mood tracking: Your journal entries and mood data are stored to provide reflection history and mood trend analysis
• Generate self-care checklists: Personalized daily wellness items are created based on your goals and persona insights
• Create personalized insights: Your data helps our AI provide more relevant, personal, and therapeutically sound conversations
• Process payments: Subscription billing is handled securely through Stripe
• Detect crises: We scan messages for crisis keywords to display emergency resources (see Section 9)
• Improve our service: Aggregated, anonymized usage data helps us improve features

5. Data Sharing & Disclosure

Your data is used exclusively to provide the PersonaWise service. We may share limited information only in these specific circumstances:

• Payment processing: Stripe processes your payment information. We never store your full credit card number
• AI processing: Your conversation messages are sent to OpenAI for generating persona responses. Messages are processed in real-time and are subject to OpenAI's data usage policies
• Legal requirements: We may disclose information if required by law, court order, or valid legal process
• Safety: We may disclose information to protect the safety of our users or the public, in accordance with applicable law

6. Device Permissions (Android/Mobile)

The PersonaWise Android application may request the following device permissions:

• READ_PHONE_STATE: This permission is used by the Android wrapper (Trusted Web Activity) for device identification purposes only. No phone calls are made, monitored, or recorded. No phone number data is collected or transmitted.
• INTERNET: Required to communicate with our servers and provide the service
• Camera/Storage (optional): Only requested if you choose to upload a persona photo. Photos are stored encrypted and are never shared

7. CCPA/CPRA Compliance (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), per Cal. Civ. Code §1798.100 et seq.:

• Right to Know: You can request a copy of all personal information we have collected about you
• Right to Delete: You can request permanent deletion of all your personal data
• Right to Opt-Out: You can opt out of the sale of personal information. Note: We do not sell personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights
• Right to Correct: You can request correction of inaccurate personal information
• Right to Limit: You can limit the use of sensitive personal information

To exercise any of these rights, contact us at privacy@personawise.app. We will respond within 45 days as required by law.

8. Data Retention & Deletion

We retain your personal information for as long as your account is active and as needed to provide our services.

Upon account deletion, all data is purged from our databases within 30 days. Encrypted backups are purged within 90 days.

9. Crisis Detection & Safety

PersonaWise includes an automated crisis detection system that scans user messages for keywords that may indicate a mental health emergency (e.g., self-harm, suicidal ideation). When crisis language is detected:

• The user is immediately shown crisis resources including the 988 Suicide & Crisis Lifeline and Crisis Text Line
• A crisis flag is logged in our system for safety review purposes
• No conversation data is shared with crisis services or any external party. The crisis detection is purely for displaying resources to the user
• Users can continue using the app after acknowledging the crisis resources

10. Children's Privacy

PersonaWise is not designed for or directed at children under 18 years of age. We do not knowingly collect personal information from anyone under 18. Our onboarding system requires a date of birth and enforces a minimum age of 11 for account creation. If we discover that a child under 18 has provided us with personal information, we will promptly delete that information. If you are a parent or guardian and believe your child has used PersonaWise, please contact us at privacy@personawise.app.

11. Cookies & Tracking

We use the following cookies and similar technologies:

• Authentication cookies: Essential session cookies to keep you logged in securely (httpOnly, secure)
• Preference cookies: To remember your settings and preferences (e.g., theme, last active persona)
• Analytics: We use minimal, privacy-respecting analytics to understand aggregate usage patterns. We do not use Google Analytics or any invasive tracking

We do not use cookies for advertising, retargeting, or cross-site tracking.

12. Third-Party Services

PersonaWise integrates with the following third-party services:

• OpenAI: Powers AI persona conversations and therapeutic validation. Messages are processed in real-time per OpenAI's usage policies
• Stripe: Handles subscription payment processing. We never store full credit card details
• Totalum: Database infrastructure provider. All data is encrypted before storage

Each of these services has their own privacy policies governing their use of data.

13. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have data protection laws that differ from your jurisdiction. By using PersonaWise, you consent to the transfer of your information to these countries. We ensure appropriate safeguards are in place to protect your data.

14. Your Rights

Regardless of your location, you have the following rights:

• Access: Request a copy of all personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request permanent deletion of all your data (available in-app or via email)
• Portability: Request your data in a portable, machine-readable format
• Objection: Object to specific types of data processing
• Withdrawal of Consent: Withdraw your consent at any time by deleting your account

15. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you via email at the address associated with your account and update the "Last updated" date at the top of this page. Continued use of the Service after changes constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

16. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the State of California and the State of Arizona, without regard to conflict of law provisions. Any disputes arising under this policy shall be resolved exclusively in the state or federal courts located in California or Arizona, at the Company's election.

17. Contact Us

If you have any questions about this Privacy Policy, your data, or wish to exercise your privacy rights, please contact us: