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Privacy Policy

Effective date: October 27, 2026 • Compliant with GDPR (EU), CCPA (US), and International Privacy Standards

Zero-Knowledge Privacy Commitment

Your emotional vulnerability is strictly confidential.

We believe that mental wellness requires unconditional privacy. All session dialogues are encrypted in transit via TLS 1.3 and at rest with AES-256. User emails are irreversibly hashed and masked from administration panels. We never sell, rent, or monetize your personal conversations.

1. Data Controller Information

The data controller responsible for the processing of your personal data is ОсОО "НОВАПЭЙ", registered under registration number 175671-3301-ООО, located at 62 Kievskaya St., Sverdlovsky District, Bishkek, Kyrgyz Republic.

Contact email for data protection inquiries: support@mirapsy.app.

2. Categories of Data We Process

  • Account Credentials: If you choose to register, we collect your email address and a password hash. Email addresses are pseudonymized and masked into anonymous user IDs (UUIDs) across our internal support and administrative systems.
  • Session Dialogues: Text messages and audio transcripts shared during your interactive sessions. These messages are processed in real-time solely to generate psychological responses and are encrypted at rest with AES-256.
  • Payment & Transaction Data: When purchasing session packages, financial transactions are handled securely by our licensed payment partners (Freemius, Inc. and bank payment gateways). We never store raw credit card numbers or CVV codes on our servers.
  • Technical Diagnostics: Minimal technical metadata (IP address, browser user-agent, error logs) processed temporarily to safeguard platform integrity and protect against malicious abuse.

3. Legal Basis for Processing (GDPR Article 6)

We process personal data under the following legal bases:

  • Performance of Contract: To provide access to the conversational platform and process payments.
  • Explicit Consent: For participating in AI self-reflection sessions and analyzing emotional patterns.
  • Legitimate Interests: To prevent fraud, secure network infrastructure, and comply with tax and legal requirements.

4. Third-Party Service Providers

We partner only with industry-leading infrastructure providers that maintain strict international security certifications (SOC 2, ISO 27001):

  • Payment Processing: Freemius, Inc. (for international credit card and PayPal payments) and Fast Payment System (SBP).
  • Cloud Hosting & CDN: Vercel and secure edge networks with automatic TLS encryption.
  • Speech Processing: Enterprise-grade neural speech synthesis and recognition engines operated under Zero Data Retention agreements.

5. Your Privacy Rights (GDPR & CCPA)

Under international data protection regulations, you hold the following rights:

  • Right of Access & Rectification: Inspect the data stored about you and request corrections.
  • Right to Erasure ("Right to be Forgotten"): Instantly delete your entire account, session history, and cached identifiers directly from your account dashboard or by emailing support@mirapsy.app.
  • Right to Data Portability: Request an export of your session logs in a machine-readable format.
  • Right to Object & Restrict Processing: Withdraw consent for non-essential processing at any time.

6. Cookies & Tracking

Mira uses strictly necessary first-party session cookies to maintain your login status and authentication tokens. We do not use third-party behavioral advertising cookies or cross-site tracking trackers.

7. Data Retention & Instant Deletion

You maintain total control over your conversational history. Clicking "Delete Account & All Data" in your dashboard initiates an immediate, irreversible cryptographic purge of your records from our live databases within seconds.

8. Changes to this Privacy Policy

We may update this policy periodically to reflect evolving legal frameworks and technological safeguards. We will notify users of material modifications by updating the effective date at the top of this document.