Privacy Policy

Effective Date: 12 August 2025

Kleia is a product of Stepsailor UG (haftungsbeschränkt)

How We Handle Your Data

Thank you for choosing Kleia ("Company," "we," "us," or "our"). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI voice companion wellness platform, website, and related services (collectively, the "Services").

1. Scope and Application

This Privacy Policy applies to all users ("you" or "your") of our Services. By accessing or using our Services, you agree to the collection and use of your personal data in accordance with this Privacy Policy. If you do not agree with the terms outlined here, please do not use our Services.

Important: Kleia is designed as a wellness tool to help you log your thoughts and gain personal insights. It is not a medical device, mental health treatment, therapy service, or substitute for professional healthcare.

2. Information We Collect

We collect information that can be used to identify you directly or indirectly ("Personal Data"). This includes:

2.1 Account and Profile Information

  • Name, email address, and other optional profile information you choose to provide
  • Account preferences and settings
  • Subscription and payment information

2.2 Voice and Conversation Data

  • Audio recordings of your voice conversations with our AI companion
  • Transcriptions of your voice conversations
  • Text-based interactions and conversations with our AI
  • Generated summaries of your conversations
  • Personal insights generated from your interactions
  • AI-generated daily reminders and personalized wellness content based on your conversation history

2.3 Usage and Technical Information

  • Device information (device type, operating system, unique device identifiers)
  • IP address and general location information
  • App usage data, session duration, and feature usage
  • Log files and diagnostic information
  • Cookies and similar tracking technologies

2.4 Wellness Information

  • Self-reported wellness information you choose to share
  • Progress tracking data and wellness metrics
  • Mood and emotional state information you provide

2.5 Payment Information

  • Payment card details and billing information (processed through third-party payment processors)
  • Transaction history and subscription details

3. How We Use Your Information

We use your Personal Data for the following purposes:

3.1 Service Provision and Functionality

  • To provide and maintain our AI voice companion wellness platform
  • To generate transcriptions of your voice conversations
  • To create summaries and personal insights from your interactions
  • To personalize your experience and improve service quality
  • To process payments and manage your subscription

3.2 Communication and Support

  • To respond to your inquiries and provide customer support
  • To send service-related communications and updates
  • To generate and send personalized daily reminders and wellness content using AI analysis of your conversation data
  • To send other wellness-related content if you have opted to receive it (you may opt out at any time)

3.3 Analytics and Improvement

  • To analyze usage patterns and improve our Services
  • To develop and enhance our AI models and algorithms
  • To conduct research and analytics to improve user experience

3.4 Legal and Business Operations

  • To comply with legal obligations and respond to lawful requests
  • To protect our rights, property, and safety, and that of our users
  • To prevent fraud, abuse, or unauthorized use of our Services

4. How We Share Your Information

We may share your Personal Data in the following circumstances:

4.1 Service Providers and Vendors

We share your data with trusted third-party service providers who help us operate our Services, including:

  • OpenAI (openai.com) – AI services for natural language processing, conversation analysis, and insight generation
  • Claude/Anthropic (anthropic.com) – AI services for natural language processing and conversation analysis
  • Stripe (stripe.com) – Payment processing and subscription management
  • Vercel (vercel.com) – Hosting infrastructure and platform services
  • Neon (neon.tech) – Database services for data storage
  • TallyForm (tally.so) – Form collection and processing
  • PostHog (posthog.com) – Product analytics and user behavior analysis
  • Vercel Analytics (vercel.com) – Website analytics for our marketing website
  • Notion (notion.so) – Internal documentation and knowledge management
  • Audio transcription and speech recognition service providers
  • Cloud storage and hosting providers

These service providers are contractually obligated to protect your data and use it only for the specific purposes we authorize.

4.2 Business Transfers

In connection with any merger, sale of assets, financing, or acquisition of all or part of our business, your information may be transferred to the acquiring entity.

4.3 Legal Requirements

We may disclose your information when required by law, court order, or other legal process, or when we believe disclosure is necessary to protect our rights or the rights of others.

4.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you.

We do not sell, rent, or lease your personal information to third parties. We never sell your personal data to third parties for any purpose, including marketing, advertising, or commercial use.

5. Data Security

We implement appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Secure data transmission protocols
  • Access controls and authentication measures
  • Regular security assessments and monitoring
  • Secure data storage practices
  • Employee training on data protection

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your Personal Data, we cannot guarantee absolute security.

6. Data Retention

We retain your Personal Data for as long as necessary to:

  • Provide you with our Services
  • Comply with legal obligations
  • Resolve disputes and enforce agreements
  • Fulfill the purposes described in this Privacy Policy

When we no longer need your Personal Data, we will securely delete or anonymize it in accordance with our data retention policies and applicable law.

7. International Data Transfers

Our Services are operated globally, and your information may be transferred to and processed in countries other than your country of residence, including the United States and European Union. These countries may have different data protection laws than your country.

When we transfer your Personal Data internationally, we ensure appropriate safeguards are in place through:

  • Standard contractual clauses approved by relevant authorities
  • Adequacy decisions by competent authorities
  • Other legally recognized transfer mechanisms

8. Your Privacy Rights

Depending on your location, you may have certain rights regarding your Personal Data:

8.1 General Rights

  • Access: Request information about how we process your Personal Data
  • Rectification: Request correction of inaccurate or incomplete data
  • Deletion: Request deletion of your Personal Data (subject to legal exceptions)
  • Objection: Object to processing based on legitimate interests
  • Restriction: Request limitation of processing under certain circumstances
  • Portability: Request transfer of your data in a portable format

8.2 Additional Rights for EU/EEA Residents

If you are in the European Economic Area, you also have the right to lodge a complaint with your local data protection authority.

8.3 Additional Rights for California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including:

  • Right to know what Personal Data we collect and how it's used
  • Right to delete Personal Data (subject to exceptions)
  • Right to opt-out of sale (though we do not sell Personal Data)
  • Right to non-discrimination for exercising your privacy rights

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Remember your preferences and settings
  • Analyze how you use our Services
  • Provide and improve our Services
  • Ensure security and prevent fraud

You can control cookies through your browser settings, though some features may not function properly if you disable them.

10. Third-Party Links and Services

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.

11. AI Processing and Voice Data

11.1 Voice Processing

  • Your voice recordings are processed to generate accurate transcriptions
  • We use third-party AI services to analyze conversation content and generate insights
  • Voice data is processed to improve speech recognition accuracy and service quality

11.2 AI-Generated Content

  • Our AI generates summaries and insights based on your conversations
  • We generate personalized daily reminders and wellness content by analyzing your conversation history and patterns
  • These generated insights and reminders are stored in your account for your reference
  • We may use aggregated, anonymized conversation patterns to improve our AI models

11.3 Data Sharing with AI Providers

  • We share conversation data with AI service providers (OpenAI, Anthropic) to generate transcriptions, summaries, insights, and personalized daily reminders
  • This data sharing is necessary for providing core functionality of our Services, including personalized wellness content
  • Our AI providers are contractually bound to protect your data and use it only for authorized purposes

12. Children's Privacy

Our Services are not intended for individuals under 16 years of age. We do not knowingly collect Personal Data from children under 16. If you believe we have collected such information, please contact us immediately so we can delete it.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or business operations. We will:

  • Post the updated policy on our website
  • Update the "Effective Date" at the top of this policy
  • Notify you of material changes via email or prominent notice in our Services
  • For significant changes, we may require your consent to continue using our Services

We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.

14. Legal Basis for Processing (EU/EEA Users)

For users in the European Economic Area, our legal basis for processing your Personal Data includes:

  • Contract Performance: Processing necessary to provide our Services to you
  • Legitimate Interests: Processing for analytics, security, and service improvement
  • Consent: Where you have provided specific consent (which you may withdraw at any time)
  • Legal Obligation: Processing required by applicable law

15. Important Disclaimers

15.1 Wellness Tool Disclaimer

Kleia is designed as a wellness and self-reflection tool. It is not intended to:

  • Provide medical advice, diagnosis, or treatment
  • Replace professional healthcare or mental health services
  • Serve as therapy or counseling
  • Handle crisis situations or emergencies

15.2 Emergency Situations

If you are experiencing a medical emergency or mental health crisis, immediately contact:

  • Emergency services (911 in the US, 112 in EU)
  • Your healthcare provider
  • A mental health crisis hotline
  • Local emergency services

Do not rely on Kleia for emergency assistance or crisis intervention.

15.3 AI Limitations

Our AI-generated insights and summaries are based on automated analysis and may not always be accurate or complete. They should be considered as supplemental information for your personal reflection, not as professional advice.

16. Contact Information

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

Email: yagmur@psycheholistic.com

Company: Stepsailor UG (haftungsbeschränkt)

Address: Karlsbaderstraße 13, 86899 Landsberg am Lech, Germany

Response Time: We will respond to privacy requests within 30 days (or as required by applicable law).

By using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

Last Updated: 12 August 2025