Privacy Policy

Last Updated: April 2026

Habitual Labs LLC, a New Jersey limited liability company ("Habitual Labs," "we," "us," or "our"), operates the Elesa mobile application (the "App"). This Privacy Policy ("Policy") describes how we collect, use, disclose, and protect personal information when you use the App.

By using the App, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, do not use the App.

1. Scope

This Policy applies to personal information we collect through the App. It does not apply to third-party services you may access through the App (such as the Apple App Store or third-party content). Please review the privacy policies of those services separately.

The App is currently available to users in the United States only and is not directed at users outside the United States.

2. Information We Collect

2.1 Information You Provide Directly

• Account and onboarding information: name, email address, password (stored in hashed form), partner pairing information, and onboarding responses (such as goals, preferences, or relationship context)
• Message content: messages you send in Individual Chat, Group Chat (Couples Mode), and Private Mode, including text, reflections, and any content you choose to share with the AI or your partner
• Information about third parties: when you discuss your partner, ex-partner, family members, friends, or other individuals in your messages, those inputs may contain personal information about those third parties
• Support communications: if you contact us, we collect the contents of your communication and any information you provide

2.2 Information Collected Automatically

• Device information: device type, operating system and version, device identifiers, language settings, and time zone
• Usage data: features accessed, session duration, interaction patterns, and engagement metrics
• Performance and diagnostic data: crash logs, error reports, and performance metrics
• IP address and approximate location (derived from IP address only; we do not collect precise GPS location)
• Push notification tokens (if you enable notifications)

2.3 Information from Third Parties

• Payment and subscription status: we receive confirmation of subscription purchases and renewal status from the Apple App Store; we do not collect or store your credit card or bank account information
• Authentication providers: if you sign in using a third-party authentication service, we receive basic account identifiers from that service

2.4 Sensitive Personal Information

You acknowledge that the nature of the App means you may voluntarily share information that could be considered sensitive personal information under applicable privacy laws, including content that reveals:

• Emotional or psychological state
• Details about your relationships and interpersonal dynamics
• Personal struggles, conflicts, or difficult experiences

We treat this content with heightened care and only use it for the purposes described in Section 3. You have the right to limit our use of sensitive personal information as described in Section 9.

3. How We Use Information

We use the information we collect for the following purposes:

• Providing the App: creating and maintaining your account, enabling Individual Chat and Group Chat, pairing partners, delivering AI-generated responses, and maintaining conversation continuity
• AI response generation: transmitting your messages to our third-party AI provider (currently OpenAI) to generate coaching responses
• Account authentication and security: verifying your identity, detecting fraud or unauthorized access, and enforcing our Terms of Use and EULA
• Customer support: responding to inquiries, troubleshooting, and providing assistance
• Product improvement: analyzing usage patterns in aggregated or de-identified form to improve features, performance, and reliability
• Communications: sending transactional messages such as account notifications, billing notices, service updates, and security alerts
• Safety and abuse prevention: detecting and preventing misuse, harassment, abusive behavior, and activity that violates our policies or applicable law
• Legal compliance: complying with legal obligations, responding to lawful requests, and protecting our rights and the rights of users

We do not use your message content to train AI models. We do not sell personal information, and we do not use personal information for targeted advertising.

4. AI Processing and Third-Party AI Providers

4.1 How AI Processing Works

To generate coaching responses, we transmit your message content (and relevant conversation context) to a third-party AI provider. We currently use OpenAI as our AI provider. Your messages are processed through OpenAI's API.

4.2 OpenAI's Handling of Your Data

Based on OpenAI's API data usage policies as of the date of this Policy:

• OpenAI does not use data submitted via its API to train or improve its models
• OpenAI retains API inputs and outputs for a limited period (typically up to 30 days) for abuse monitoring and compliance purposes, after which they are deleted

OpenAI's practices are governed by its own privacy policy and terms, which may change. You should review OpenAI's current policies at https://openai.com/policies.

4.3 Memory and Context

To provide conversational continuity, we generate and store summarized context from your prior messages. This context is maintained separately for Individual Chat and Group Chat — memory from Individual Chat is not shared with Group Chat, and vice versa.

4.4 Changes to AI Providers

We may change or add AI providers in the future. We will update this Policy to reflect any such changes.

5. How We Share Information

We do not sell your personal information. We share information only in the following circumstances:

5.1 Service Providers

We share information with third-party service providers that help us operate the App. These providers are contractually limited to processing data on our behalf and for the purposes we specify. Categories include:

• AI processing: OpenAI
• Application platform and hosting: Adalo (no-code mobile app platform)
• Workflow automation: Make.com (processing and maintaining conversation memory)
• App distribution and billing: Apple, Inc. (via the Apple App Store)
• Analytics, diagnostics, crash reporting, and communications tools as we add them

5.2 Within a Couple's Group Chat

Messages you send in Group Chat (Couples Mode), other than Private Mode messages, are shared with your partner by design. Private Mode messages are sent to the AI only and are not displayed to your partner, though you acknowledge the AI may incorporate Private Mode context into its responses in ways that could indirectly reveal information.

5.3 Legal and Safety

We may disclose information when we believe in good faith that disclosure is necessary to:

• Comply with applicable law, regulation, legal process, or governmental request
• Enforce our Terms of Use, EULA, or this Policy
• Protect the rights, property, or safety of Habitual Labs, our users, or others
• Investigate and prevent fraud, security issues, or harmful conduct

5.4 Business Transfers

If Habitual Labs is involved in a merger, acquisition, financing, sale of assets, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction. We will notify users of any such change in ownership or control of their personal information.

5.5 With Your Consent

We may share information for other purposes with your consent.

6. Data Involving Third Parties Mentioned in Your Messages

When you share information about other individuals (such as your partner, ex-partners, family members, or friends) through the App, that information is treated as part of your User Content. Those individuals have not consented to this processing directly, and you are responsible for ensuring your inputs do not violate their privacy or other rights. We do not independently verify, correct, or notify third parties about information shared in your messages.

If you are a non-user and believe information about you has been shared in the App, please contact us at support@elesa.app and we will address your request consistent with applicable law and the rights of our users.

7. Couples and Shared Data

Group Chat (Couples Mode) creates data that is contributed by two users and shared between them. This raises considerations unique to couples-based products:

• Joint visibility: non-Private Mode messages in Group Chat are visible to both partners
• Account deletion by one partner: if one partner deletes their account, the other partner may still have access to the shared Group Chat history up to that point; we will handle such situations in accordance with applicable law and our internal policies
• Data access requests: when you submit a privacy rights request, we will provide or delete data attributable to your account; in shared Group Chat contexts, we may be unable to remove messages you sent without affecting your partner's access to the conversation, and we will balance these interests in a reasonable manner
• Dispute between partners: we are not able to mediate disputes between partners regarding shared data and generally will not remove one partner's contributions at the request of the other

8. Data Retention

We retain personal information only as long as necessary for the purposes described in this Policy, or as required by law. Retention periods vary by data category:

• Account information: retained for the life of your account and for a reasonable period (typically up to 12 months) after account deletion for legal, security, and operational purposes
• Message content: retained while your account is active; deleted or de-identified following account deletion, subject to the couples-data considerations in Section 7
• Diagnostic and usage data: retained for a limited period (typically up to 24 months) for analytics and product improvement
• Support communications: retained as needed to resolve your inquiry and for reasonable record-keeping
• Legal and compliance records: retained as required by applicable law

When information is no longer needed, we delete or de-identify it. De-identified data may be retained indefinitely.

9. Your Privacy Rights

Depending on where you live, you may have the following rights regarding your personal information:

9.1 Rights Available to All U.S. Users

• Access: request a copy of the personal information we hold about you
• Deletion: request deletion of your personal information
• Correction: request correction of inaccurate information

9.2 Additional Rights Under State Privacy Laws

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, or another state with a comprehensive privacy law, you may also have the right to:

• Opt out of the "sale" or "sharing" of personal information. We do not sell personal information and do not share it for cross-context behavioral advertising
• Limit the use of sensitive personal information. You may request that we limit the use of sensitive personal information to purposes necessary to provide the App
• Data portability: receive your personal information in a portable format
• Opt out of profiling / automated decision-making that produces legal or similarly significant effects (we do not currently engage in such profiling)
• Non-discrimination: you will not be discriminated against for exercising your privacy rights
• Appeal: if we deny your request, you may appeal our decision by replying to our response email, and we will respond within the time required by applicable law

9.3 How to Exercise Your Rights

To exercise any of these rights, email us at support@elesa.app with the subject line "Privacy Request." We will respond within the timeframe required by applicable law (generally 45 days). We may need to verify your identity before fulfilling your request.

9.4 Authorized Agents

You may designate an authorized agent to make requests on your behalf. We may require written authorization and verification of the agent's authority.

9.5 Global Privacy Control

We recognize the Global Privacy Control (GPC) signal where required by applicable law.

10. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information, including:

• Encryption of data in transit
• Access controls and authentication for our systems
• Monitoring for unauthorized access and suspicious activity

No method of transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials. If you believe your account has been compromised, contact us immediately at support@elesa.app.

10.1 Breach Notification

In the event of a data breach affecting your personal information, we will notify you and applicable authorities as required by law.

11. International Data Transfers

The App is offered in the United States and data is primarily processed in the United States. Some of our service providers may process data in other jurisdictions. By using the App, you consent to the transfer of your information to the United States and other jurisdictions as described in this Policy.

12. Children's Privacy

The App is not intended for, and may not be used by, individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from an individual under 18, we will delete that information promptly. If you believe we may have collected information from someone under 18, please contact us at support@elesa.app.

13. Third-Party Links and Services

The App may reference or link to third-party content or services. This Policy does not apply to third parties, and we are not responsible for their privacy practices. Please review the privacy policies of any third parties you interact with.

14. Changes to This Policy

We may update this Policy from time to time. When we make material changes, we will provide reasonable notice through the App or by other means, and update the "Last Updated" date at the top. Your continued use of the App after changes take effect constitutes acceptance of the updated Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Policy or your personal information, contact us at:

Habitual Labs LLC Email: support@elesa.app