Privacy Policy — Align

Last Updated: March 31, 2026

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1. Introduction

Welcome to Align ("the App"). Your privacy is important to us. This Privacy Policy explains how we collect, use, and protect your information when you use our mobile application.

By using Align, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the App.

2. Information We Collect

2.1 Information You Provide

When you use Align, you may provide the following information directly within the App:

• Focus areas — categories you select during onboarding (e.g., Abundance, Self-love, Confidence)
• Wake-up time — your preferred time for daily notifications
• Emotional check-ins — mood selections and post-session mood ratings
• Intention text — a personal belief or intention you enter to personalize your sessions
• Weekly focus — an optional weekly intention you set
• Saved affirmations — affirmations you choose to save as favorites
• Custom affirmations — affirmations you write yourself

2.2 Automatically Collected Information

• Practice streak data — your consecutive days of app usage
• Session history — a rolling history of recently generated affirmations (stored locally for content personalization)
• Device information — basic device identifiers used by our subscription management and push notification services

2.3 Information We Do NOT Collect

• We do not require you to create an account
• We do not collect your name, email address, or any personal contact information
• We do not track your location
• We do not sell, share, or rent your personal data to third parties for marketing purposes

3. How Your Data Is Stored

• All personal data is stored on-device using local storage (shared preferences and local database)
• Optional backup is available through your device's native cloud storage (iCloud on iOS, Google Drive on Android), which is governed by Apple's and Google's respective privacy policies
• We do not have access to your cloud backups

4. How We Use Your Information

We use the information you provide solely to:

• Personalize your experience — your focus areas, intention text, mood ratings, and session history are sent to our AI service to generate personalized affirmation content tailored to you
• Deliver daily sessions — your wake-up time is used to schedule push notifications at your preferred time
• Improve content quality — mood data and affirmation history help avoid repetition and adapt content to your emotional state
• Pre-generate content — the App may generate tomorrow's session content in the background so it is ready when you need it

5. Third-Party Services

Align uses the following third-party services to operate:

5.1 AI Content Generation (Anthropic)

Your focus areas, intention text, mood rating, practice day count, and recent affirmation history are sent to Anthropic's API (via our secure server proxy) to generate personalized session content. No personally identifiable information (name, email, etc.) is transmitted. Anthropic's privacy policy is available at anthropic.com/privacy.

5.2 Subscription Management (RevenueCat)

We use RevenueCat to manage in-app subscriptions and purchases. RevenueCat may collect device identifiers and purchase data as described in their privacy policy at revenuecat.com/privacy.

5.3 Push Notifications (Firebase Cloud Messaging)

We use Firebase Cloud Messaging to deliver daily push notifications. Firebase may collect device tokens and basic device information. Google's privacy policy is available at policies.google.com/privacy.

5.4 App Store Platforms

The App is distributed through the Apple App Store and Google Play Store, each of which has its own privacy practices:

• Apple: apple.com/privacy
• Google: policies.google.com/privacy

6. Data Security

We take reasonable measures to protect your information:

• All API communications between the App and our server proxy are encrypted using HTTPS/TLS
• Your API keys and credentials are stored securely on our server — never in the app itself
• Personal data remains on your device and is not stored on our servers

However, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

7. Children's Privacy

Align is not directed to children under the age of 13 (or under the age of 16 in certain jurisdictions). We do not knowingly collect personal information from children under these ages. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@alignaffirm.com so we can take appropriate action to delete such information.

In compliance with Brazil's Federal Law No. 15.211/2025 (Digital Statute of the Child and Adolescent), we implement age-appropriate safeguards in our digital products.

8. Legal Basis for Processing (LGPD — Brazil)

Under Brazil's Lei Geral de Proteção de Dados (LGPD — Law No. 13.709/2018), we process personal data based on the following legal grounds:

• Consent (Art. 7, I) — You provide explicit consent during onboarding when entering your intention text, selecting focus areas, and agreeing to these terms. You may withdraw consent at any time by deleting the App or clearing its data.
• Performance of contract (Art. 7, V) — Processing is necessary to deliver the subscription service you purchased, including generating personalized affirmation content.
• Legitimate interest (Art. 7, IX) — We use anonymized session context (mood rating, day count) to improve content quality and avoid repetition. This processing does not override your fundamental rights.

Sensitive Data Notice

Mood and emotional check-in data may constitute sensitive personal data under LGPD (Art. 11). We process this data solely based on your explicit consent, provided when you interact with mood selection features. This data is stored locally on your device and is only transmitted (without personal identifiers) to our AI service for content personalization.

9. Your Rights Under Applicable Law

For All Users

• Delete your data — All data is stored locally on your device. Delete it at any time by uninstalling the App or clearing the App's data in your device settings.
• Manage notifications — Disable push notifications at any time through your device's notification settings.
• Manage subscriptions — Manage or cancel your subscription through the App Store (iOS) or Google Play Store (Android).
• Cloud backups — Manage or delete cloud backups through your iCloud or Google Drive settings.

For Users in Brazil (LGPD Rights — Art. 18)

As a data subject under LGPD, you have the right to:

• Confirmation and access — Confirm whether we process your data, and access a copy of it.
• Correction — Request correction of incomplete, inaccurate, or outdated data (you can do this directly in Settings).
• Anonymization, blocking, or deletion — Request anonymization or deletion of unnecessary or excessive data.
• Data portability — Request transfer of your data to another service provider (where technically feasible).
• Deletion of data processed with consent — Request deletion of personal data processed on the basis of your consent.
• Information about sharing — Know which third parties have access to your data (see Section 5).
• Withdrawal of consent — Withdraw consent at any time. This does not affect the lawfulness of processing carried out prior to withdrawal.
• Filing a complaint — File a complaint with the Brazilian National Data Protection Authority (ANPD) at gov.br/anpd.

To exercise any of these rights, contact us at support@alignaffirm.com. We will respond within 15 days as required by LGPD.

For Users in the European Economic Area (GDPR Rights)

If you are located in the EEA, you have the right to: access, rectify, erase, restrict processing, data portability, and object to processing of your personal data. You may also lodge a complaint with your local data protection supervisory authority. To exercise these rights, contact us at support@alignaffirm.com.

For Users in California, USA (CCPA/CPRA Rights)

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and disclose.
• Delete your personal information.
• Opt-out of sale — We do not sell your personal information.
• Non-discrimination — We will not discriminate against you for exercising your privacy rights.

We do not sell personal information as defined by the California Consumer Privacy Act. We do not use or share personal information for cross-context behavioral advertising.

10. Data Retention

• On-device data — Retained on your device until you uninstall the App or clear its data. We do not control retention of on-device data.
• Affirmation history — A rolling 7-day history (up to 21 affirmations) is maintained locally for anti-repetition purposes. Older entries are automatically overwritten.
• Cloud backups — Retained according to your iCloud or Google Drive settings. We have no access to or control over these backups.
• AI-transmitted data — Session context sent to our AI provider is processed in real time and is not stored on our servers or the AI provider's servers beyond the duration of the API request.

11. International Data Transfers

Align is available globally. When you use the App, limited session context data (as described in Section 5.1) is transmitted to servers operated by our AI provider (Anthropic), which may be located in the United States or other countries outside your country of residence.

These transfers are necessary to provide the core functionality of the App (personalized content generation). We ensure that appropriate safeguards are in place:

• Data transmitted contains no personally identifiable information (no name, email, phone, or device ID)
• Data is transmitted over encrypted connections (HTTPS/TLS)
• Data is processed in real time and not stored by the AI provider beyond the API request

For users in Brazil: international transfers comply with LGPD Art. 33, based on the adequacy of the recipient country's data protection framework and on your explicit consent.

For users in the EEA: transfers are conducted in compliance with GDPR Chapter V, relying on adequacy decisions or standard contractual clauses where applicable.

12. AI Transparency Disclosure

Align uses artificial intelligence (specifically, Anthropic's Claude language model) to generate personalized affirmation and session content. In accordance with Apple's AI transparency requirements:

• The App uses an external AI service to generate text content
• Your session context (focus areas, intention, mood, day count, recent history) is sent to this service without personal identifiers
• AI-generated content is for wellness and motivational purposes only and is not professional advice
• You can regenerate content at any time if AI output is not suitable

13. Google Play Data Safety Alignment

For Google Play users, the following summarizes our data practices as disclosed in the Google Play Data Safety section:

• Data collected: Device identifiers (for subscriptions/push), app usage data (locally stored)
• Data shared with third parties: Anonymized session context with AI provider; device identifiers with subscription/notification services
• Data encryption: All data in transit is encrypted
• Data deletion: Users can delete all data by uninstalling the App
• No data sold to third parties

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by updating the "Last Updated" date at the top of this page and, where appropriate, through an in-app notification.

Your continued use of the App after any changes constitutes your acceptance of the updated policy.

15. Data Protection Contact

For any questions, concerns, or requests related to this Privacy Policy or your data rights, please contact our Data Protection representative:

Email: support@alignaffirm.com

Response times:

• LGPD requests (Brazil): within 15 days
• GDPR requests (EEA): within 30 days
• All other requests: within 30 days

If you believe your data protection rights have been violated, you have the right to lodge a complaint with:

• Brazil: Autoridade Nacional de Proteção de Dados (ANPD) — gov.br/anpd
• EEA: Your local data protection supervisory authority
• USA: Federal Trade Commission (FTC) — ftc.gov