Privacy Policy

    Effective date: 10 October 2026 · Version: 1.3

    1. Who we are

    HEYLINA AI LTD (“HeyLina”, “we”, “us”) is the “controller” of personal data processed via the Service. Registered office: 96 Gilbert Road, Chafford Hundred, Grays, England RM16 6NJ. Contact: team@heylina.ai.

    2. What this policy covers

    This policy explains how we collect, use, store, and share personal data when you use our App or Website. Use of the Service is also subject to our Terms of Service.

    3. How we collect your data

    We collect personal data through the following channels:

    • Directly from you: when you sign up, complete onboarding, send messages to Lina, record audio, log a mood check-in, contact support, or complete any in-app or Website form.
    • Automatically via SDKs in the App: Firebase (authentication, database, file storage, push notifications, crash reporting), Google Sign-In, and PostHog product analytics.
    • Server logs: when our backend (Firebase Cloud Functions) processes a request, we generate logs containing request metadata, identifiers, and timestamps.
    • Push notification services: when you enable notifications, we receive a device push token from Apple Push Notification service or Firebase Cloud Messaging.
    • Cookies and similar technologies on the Website: see our Cookie Policy for the full list.
    • App stores and payment platforms: Apple App Store, Google Play, and RevenueCat send us limited subscription and purchase events.

    4. Data we collect

    We collect the following categories of personal data:

    A. Account and identity

    • Email address (used for sign-in and account recovery).
    • Password (stored only by Firebase Auth, in hashed form; we never see your password).
    • Google sign-in credential, if you choose to sign in with Google.
    • A unique account identifier we generate for your account.
    • Profile fields you provide during onboarding: full name, gender, birth date.

    B. Conversation content

    • The text of messages you send to Lina.
    • Audio recordings you submit when you choose to speak to Lina.
    • Transcripts of those audio recordings.
    • Conversation metadata (message IDs, timestamps, session identifiers).
    • Your onboarding responses and the personal growth plans you choose to set.

    C. App usage and behavioural data

    • Daily mood check-ins and mood nuance selections.
    • Streak and badge events.
    • Subscription state and purchase events.
    • Screen views and feature interactions.
    • Account lifecycle events (sign-in, sign-out, data deletion, account deletion).
    • Authentication events, including error codes when sign-in fails.
    • Profile change events (which field was updated).

    D. Device and technical data

    • Device model, operating system and version, app version, language, and timezone.
    • Push notification tokens, where you have enabled notifications.
    • Crash reports and stack traces (via Firebase Crashlytics).

    E. Website data (cookies and similar technologies)

    • Pages viewed, clicks, referral sources, cookie identifiers, and advertising/analytics signals (where enabled). See our Cookie Policy.

    F. Subscription and transaction data

    • Subscription status received from Apple App Store, Google Play, and RevenueCat.
    • We do not receive your full card details from Apple, Google, or any payment provider.

    G. Support and feedback

    • Messages you send to support, bug reports, and survey responses.

    5. Sensitive information

    Your messages may contain highly sensitive content (for example, information about your sex life, sexual orientation, emotional state, or relationship circumstances). Please consider carefully what you share.

    We use this information only to provide the Service and, where applicable, to improve safety and quality, in line with this policy and your settings/choices.

    6. How we use your data

    We use your data to:

    • Provide the Service — create and manage your account; generate Lina responses and deliver features; customer support and troubleshooting.
    • Safety and trust — detect and respond to high-risk signals (for example, self-harm language) and apply safety behaviours.
    • Improve and develop — monitor performance, fix bugs, and improve features; analyse aggregated usage patterns.
    • Marketing (optional) — send product updates or newsletters if you opt in; measure marketing performance on the Website using cookies/pixels, where you consent.

    7. Our lawful bases (UK GDPR)

    We rely on the following lawful bases, depending on the activity:

    • Contract: to provide the Service you request.
    • Legitimate interests: to secure and improve the Service, prevent fraud/abuse, and understand product performance (balanced against your rights).
    • Consent: for non-essential cookies/pixels and, where required, for certain marketing communications.
    • Legal obligation: where we must comply with law.

    8. Automated processing and AI

    HeyLina is an AI-powered service. When you message Lina, your input is processed by automated systems to generate a response.

    Specifically:

    • Your text (or the transcript of your voice message) is sent to Google Cloud (Vertex AI, Gemini models) in the EU to generate Lina’s reply.
    • Voice recordings are transcribed by Google Cloud Speech-to-Text in the EU. Lina’s spoken replies are made by ElevenLabs in the United States from the text of her reply, or by Google Cloud Text-to-Speech in the EU when ElevenLabs is unavailable.
    • Lina’s memory of earlier conversations is kept in our Google Cloud database in the EU. Until 2 October 2026 conversation memory was also kept with Pinecone in the United States; we stopped sending data to Pinecone on that date and are deleting everything it holds.
    • On the Website, the Ick Audit verdict and the Message Translator are generated by Anthropic (Claude). Anthropic receives the quiz answers and free text you write in the Ick Audit, or the message you paste into the Translator. It does not receive your app conversations.

    We do not train AI models on your data. Our AI providers (Google Cloud for the App, Anthropic for the Website tools and ElevenLabs for Lina’s voice) do not use your data to train their models under the terms on which we use them.

    The Service does not make decisions about you that produce legal or similarly significant effects within the meaning of UK GDPR Article 22. Lina’s responses are conversational guidance only; you remain responsible for your decisions and actions. See our Terms of Service for the full AI output disclaimer.

    9. Who we share data with

    We use the following processors to deliver the Service. Each receives only the categories of data needed for its specific purpose.

    • Firebase / Google Cloud (Google LLC): authentication, database (Firestore), file storage, push notifications, server-side processing (Cloud Functions), and the AI services that write Lina’s replies (Vertex AI), transcribe your voice (Cloud Speech-to-Text) and voice Lina’s replies when ElevenLabs is unavailable (Cloud Text-to-Speech). Receives account credentials, your messages and Lina’s replies, voice recordings and their transcripts, conversation memory and push tokens. Your conversations, files and the AI processing stay in Google Cloud’s EU locations; sign-in (Firebase Authentication) runs in the United States, and push notifications use a global Google service.
    • ElevenLabs (United States): synthesises Lina’s voice replies. Receives the text of Lina’s replies, which can refer to what you have told her. It does not receive your messages or recordings.
    • Pinecone (United States): until 2 October 2026, stored vector representations of your conversations and accompanying text fragments for Lina’s long-term memory. It receives no new data, and the data it holds is being deleted.
    • RevenueCat: manages subscription state across Apple App Store and Google Play. Receives your account identifier, email, display name, and purchase events.
    • PostHog: product analytics (hosted in the EU). Receives event telemetry, screen views, and feature usage. We do not send conversation content, full names, or sensitive profile fields to PostHog.
    • Google Sign-In: optional social sign-in. Receives the OAuth credential only.
    • Apple App Store / Google Play: subscription billing and platform-managed purchase events.
    • Supabase: database and serverless functions behind the Website. Receives waitlist and quiz sign-ups, including the free text you write in the Ick Audit, and your marketing consent record.
    • Anthropic: writes your personalised Ick Audit verdict and powers the Message Translator. Receives your quiz answers and the text you write, or the message you paste into the Translator.
    • Brevo: sends your Ick Audit result email and manages our marketing contact list. Receives your email address, your name where given, and your audit outcome, never the free text you wrote.
    • Website advertising and analytics partners: Google (including Google Tag Manager and Google Ads), Microsoft (Bing Ads), Meta, Reddit, Spotify, TikTok, and Fathom. See our Cookie Policy for details and opt-out controls.
    • Professional advisers: lawyers, accountants, and insurers, where necessary.
    • Authorities: where required by law.

    Former processors: OpenAI (United States) wrote Lina’s replies until 30 September 2026 and transcribed voice recordings until 9 October 2026. It receives no App data now. Under its standard terms it may keep request logs for up to 30 days for abuse monitoring.

    For the current full subprocessor list with regions and data categories, see our Subprocessor List.

    We do not sell personal data to data brokers, and we do not exchange your conversations or profile information for money. Some advertising and analytics cookies on our Website (see Cookie Policy) involve limited data sharing with marketing partners. Under certain US state privacy laws (for example, the California Consumer Privacy Act/CPRA), this kind of cookie-based sharing may be classified as “selling” or “sharing” personal information. You can opt out at any time via our cookie banner or your browser controls.

    10. International transfers

    The Service is operated from the United Kingdom. Some of our processors store or process data outside the UK:

    • United States: ElevenLabs (Lina’s voice), RevenueCat (subscriptions), Anthropic (Website Ick Audit and Message Translator only), Pinecone (older conversation memory: no new data since 2 October 2026, being deleted), and Google LLC for Firebase Authentication, Google Sign-In and push notifications.
    • European Union: Google Cloud (our database, file storage and server processing, and the AI services that write Lina’s replies, transcribe your voice and provide her back-up voice), PostHog (EU-hosted instance) and Brevo.
    • United Kingdom: Supabase (London region). No transfer out of the UK applies.

    Where data is transferred outside the UK, we rely on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses (SCCs) with our processors, supplemented by appropriate technical and organisational measures.

    11. Data retention

    We retain personal data for the periods set out below.

    • Account and profile data: while your account is active.
    • Voice recordings (raw audio you submit): stored in the EU and deleted once Lina has replied, and in any case within 7 days.
    • Lina’s voice replies (TTS audio): stored in the EU and deleted within 48 hours.
    • Chat text and conversation metadata: kept while your account is active, to provide context for ongoing conversations.
    • Long-term conversation memory: kept in Google Cloud in the EU while your account is active, then deleted on account closure. Memory previously held by Pinecone in the United States (no new data since 2 October 2026) is being deleted in full.
    • Analytics data (PostHog, Crashlytics): retained per processor defaults and your consent settings.
    • Subscription and billing records: retained as required by tax and accounting law (typically 6–7 years in the UK).

    Account deletion safety window: when you request account deletion, your account enters a recoverable “pending deletion” state for 3 months. During that period you can restore your account by contacting us at team@heylina.ai. After 3 months, we permanently purge your data across our systems (our Google Cloud database and file storage, Lina’s memory store, any remaining Pinecone records, PostHog, and RevenueCat where permitted), other than records we are legally required to retain.

    12. Security

    We apply reasonable technical and organisational measures designed to protect data (access controls, encryption in transit, least-privilege access).

    No system is perfectly secure, but we design for minimising access to sensitive data.

    13. Your rights

    Depending on your situation, you may have rights to:

    • access your data
    • correct inaccurate data
    • delete your data
    • restrict or object to certain processing
    • data portability
    • withdraw consent (where processing is based on consent)

    You can exercise these rights by contacting team@heylina.ai.

    14. Cookies and tracking choices

    On the Website, we use a consent mechanism for non-essential cookies/pixels. You can change your preferences at any time via our Cookie Policy. Cookie consent rules under PECR require consent for non-essential cookies and similar technologies.

    15. Marketing preferences

    If you opt in to marketing, you can opt out at any time using the unsubscribe link in emails or by contacting us. Rules for electronic mail marketing require appropriate consent in many cases.

    16. Children and age requirements

    The Service is intended only for users aged 18 and over. We do not knowingly collect personal data from anyone under 18.

    When you create an account, you confirm that you are at least 18 years old. If we become aware that an account belongs to someone under 18, we will terminate that account and delete the associated personal data.

    The Service is not intended for and should not be used by minors. We do not target our services at children or teenagers under 18.

    17. Complaints

    If you have concerns, contact us first at team@heylina.ai. You can also complain to the UK regulator, the Information Commissioner’s Office (ICO).

    18. Changes

    We may update this policy. We will update the effective date above and may notify you if changes are material.

    Version history

    • Version 1.3 (10 October 2026): Lina’s replies, voice transcription and back-up voice now run on Google Cloud in the EU, where your account, conversations and files have been stored since 2 October 2026. OpenAI stopped receiving App data on 9 October 2026 and Pinecone on 2 October 2026; the data Pinecone holds is being deleted. Voice recordings are deleted within 7 days and Lina’s voice replies within 48 hours.
    • Version 1.2 (30 August 2026): Earlier version.
    • Version 1.1 (17 June 2026): Earlier version.
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