Privacy Policy

1. Who we are and what this policy covers

Groundly ("Groundly", "we", "us") is operated from Portugal. We are the data controller for the personal data described in this policy.

This policy covers the Groundly mobile app, our websites (including groundlyapp.com, groundly.online, groundly.site and groundly.space) and the onboarding questionnaire you can complete on the web before you ever create an account.

You can reach us about anything in this policy at support@groundlyapp.com.

2. The short version

Groundly is a self-regulation and grounding app. Using it means telling us things about how you feel, and we want to be exact about where that goes.

• What you write in the chat is sent to Google and, as a fallback, to OpenAI, so the assistant can reply. It is also stored on our servers so your conversation continues between sessions.
• If you dictate instead of typing, your voice is transcribed by your phone's operating system, which sends the audio to Apple or Google.
• We derive an ongoing profile of your state from what you write, and we show it back to you as your insights and statistics.
• We do not show ads, we do not sell your data, and we do not share it with anyone for their own marketing.
• You can delete your account from inside the app at any time.

The rest of this policy is the detail behind those five points. Nothing in this summary replaces it.

3. The data we collect

Account and profile

When you register we store your email address, your display name, your profile photo URL if you sign in with Google or Apple, and which sign-in method you used. If you register with a password we store a cryptographic hash of it, never the password itself.

Your onboarding answers

The questionnaire asks your age range, what you want to feel more of, your first instinct when you feel off, what slips first, how you feel right now, what you use to reset, and how long recovery usually takes. You can complete this on the web before creating an account; in that case the answers are processed to produce your score and are not stored against a user record unless you go on to register.

The mobile app works differently, and we want to be plain about it. There the questionnaire has two further questions — how your environment has felt lately, and what you need most when you feel off — and each answer is sent to our servers as you give it, from the first question onwards and before you have an account. The answers are stored under a random identifier created on your device, together with how far through onboarding you got and which platform, app version and release channel sent them. Until you register, that record is not linked to a name or an email address, and we do not look these records up individually. The same identifier is used elsewhere, though: the app sends it again if you redeem a promotional code and when you register or sign in, and we store it with that redemption and with your account. We use the onboarding record to produce aggregate statistics about how people answer and at which point they stop. If you go on to register or sign in, the record is attached to your account.

Health-related data

This is the category that matters most, and the previous version of this policy did not name it at all. The following is data about your mental and emotional state, and we treat it as sensitive:

• The full text of your conversations with the Groundly assistant, kept so the conversation has continuity.
• A running summary of older conversations, generated automatically once a conversation gets long.
• Your self-reported state check-ins — a 0-100 rating of how grounded you feel, recorded over the course of a day.
• Free-text feedback you leave on individual exercises.
• A derived profile of your nervous system and current state, inferred from what you write. It includes short excerpts of your own words retained as the basis for each inference.
• Daily scores for emotional containment, somatic stability, mental load, sensory load and direction support, plus the behaviour patterns and insights generated from them.

Voice

If you use dictation, your speech is captured only while you are actively dictating. We do not record, store or transmit the audio ourselves — see section 6 for what your operating system does with it. Only the resulting text reaches us, and only if you send it.

Subscriptions

We store your subscription status, product, store, trial and renewal state, and a history of subscription events received from our subscription provider. That history includes the raw event payload, which contains your email address and an identifier assigned by that provider. We never receive or store your card number or payment credentials.

Device, app and diagnostic data

We collect your device model and operating system, app version, language, time zone, crash reports and diagnostic logs, a push notification token if you enable notifications, and analytics events describing how you move through the app. On Android the app currently requests access to the advertising identifier; we do not use it to show or target advertising.

Important correction to our previous policy: this analytics and crash data is linked to your account identifier, so it is not anonymous. We previously described it as data that does not identify individual users. That was inaccurate.

Website data

Our websites record standard analytics about your visit and store a temporary identifier in your browser so the onboarding flow can resume. If you submit the early-access form, we store the email address you enter together with your questionnaire answers so we can contact you about the app.

4. Why we process your data, and on what legal basis

If you are in the EU or the UK, these are our purposes and the legal bases we rely on:

• To provide the app, your account and your subscription — performance of our contract with you.
• To operate the assistant, generate your insights and statistics, and maintain your state profile — your explicit consent, because this involves health-related data.
• To keep the service secure, prevent abuse, fix crashes and understand which features are used — our legitimate interests in running a reliable service.
• To send you push notifications and marketing email — your consent, which you can withdraw at any time.
• To meet our legal, accounting and tax obligations — compliance with a legal obligation.

Where we rely on consent, you can withdraw it at any time. Withdrawing consent for health-related processing means the assistant, insights and statistics can no longer be provided, because they cannot function without that data. It does not affect processing we carried out before you withdrew.

We do not use your data to make decisions with legal or similarly significant effects about you.

5. AI features and the providers behind them

The Groundly assistant is powered by large language models operated by third parties. We do not run these models ourselves.

• Google LLC — Gemini models. This is the primary provider for every AI feature.
• OpenAI, L.L.C. — GPT models. These are used as a fallback when the primary provider is unavailable, overloaded or out of quota.

Because the fallback is automatic, the same message may be handled by either provider depending on availability at that moment. We cannot tell you in advance which one will handle a given message.

What is sent to them

• The message you write, and the conversation history for that day, so the reply has context.
• A description of your current derived state, which forms part of the instructions sent with your message.
• Older conversation text, when it is summarised to keep the conversation manageable.
• Your day's grounding activity, exercise feedback and self-reported state ratings, when your statistics and insights are generated.
• Your onboarding answers, when they are analysed.

We do not send your name, email address or account identifier to these providers. The content itself, however, is your own free text about how you are feeling, and it may identify you if you write identifying things in it.

If you would rather your reflections were not processed by a third-party model, do not use the chat. The exercises, games, check-ins and streaks do not depend on it and remain fully available.

What the assistant is, and is not

Replies are generated by a language model. They are not written or reviewed by a clinician, they can be wrong, and they are not medical, psychological or therapeutic advice. Please read section 4 of the Terms of Use before relying on anything the assistant says.

We do not train any model of our own on your content, and we do not sell it or give it to anyone to use for their own purposes. The providers above receive it in order to produce a reply for you, and handle it under the API terms that apply to our account with them.

6. Voice dictation

You can speak instead of typing. When you do, transcription is performed by your device's operating system — Apple's speech recognition on iOS, Google's on Android.

This transcription is not performed entirely on your device. Your audio is sent to Apple's or Google's servers and handled under their privacy policies, not ours. In practice this means spoken reflections about how you are feeling leave your phone before they ever reach us.

The audio is not written to storage on your device and we never receive it. We receive only the text, and only when you send the message. If you would rather your voice was not processed this way, type instead.

7. Who we share your data with

We do not sell your personal data, we do not share it for anyone else's marketing, and we do not show advertising. A previous version of this policy described advertising through Google AdMob. That was never accurate — Groundly has never contained advertising — and it has been removed.

We do share data with the service providers that make the product work. Each of them processes it only on our instructions:

• Google LLC — Gemini (assistant and analysis), Firebase authentication, analytics, crash reporting and device attestation, Google Sign-In, and speech recognition on Android.
• OpenAI, L.L.C. — fallback language models for the assistant and analysis.
• Apple Inc. — Sign in with Apple, App Store purchases, push delivery and speech recognition on iOS.
• Adapty Tech Inc. — subscription management and paywall configuration. Receives your account identifier and purchase events.
• Expo (650 Industries, Inc.) — push notification delivery and over-the-air app updates. Notification content passes through Expo on its way to Apple and Google.
• Resend, Inc. — transactional email such as verification and password reset. Receives your email address and the message content.
• MongoDB, Inc. (Atlas) — our primary database.
• Salesforce, Inc. (Heroku) and QuotaGuard — application hosting and the network path between our servers and the database.
• Amazon Web Services — storage for exercise media and downloadable content.
• Functional Software, Inc. (Sentry) — server-side error monitoring, configured to scrub identifiers and tokens.
• Vercel Inc. — website hosting.

Our staff can access account records — including your email address and display name — to provide support, investigate abuse and operate the service. Access is limited to what the job requires and administrative actions are logged.

We may also disclose data where we are legally required to, or to establish or defend legal claims, and we would transfer data to a buyer if the business were sold, in which case this policy would continue to apply until you were told otherwise.

If you use a sharing feature to post a card or image to another app, that transfer is initiated by you and is governed by whichever service you send it to.

8. Where your data is processed

We are established in Portugal, inside the European Union. Several of the providers that run the service are not, so your data does travel outside the EU.

Specifically: our database is hosted on Amazon Web Services in Northern Virginia (us-east-1) in the United States, and Google, OpenAI, Adapty, Expo, Resend and our application hosting also process data in the United States. Our error monitoring provider processes data inside the European Union.

Where data leaves the European Economic Area or the United Kingdom, we rely on the European Commission's Standard Contractual Clauses — with the UK Addendum where the transfer concerns UK users — together with the additional safeguards those clauses require, or on an adequacy decision where one covers that provider. Ask us and we will tell you which mechanism applies to a particular provider.

9. How long we keep your data

• Account data, conversations, check-ins and your derived profile: kept while your account is open, and erased when you delete your account.
• Subscription records: kept while your account is open, and afterwards only where we need them for tax and accounting purposes.
• Crash and diagnostic data: retained by our monitoring providers on their standard schedules, typically no more than 90 days.
• Analytics data: retained on our analytics providers' standard schedules.
• Early-access form submissions: kept until you ask us to remove them, or until we stop running the early-access list.
• Onboarding answers the mobile app sent before you registered: if you register or sign in, they are attached to your account. When you delete your account we erase the onboarding record attached to it, including one created on that installation of the app before you registered. If you never register, the record is kept under its random identifier and used only for aggregate statistics; it is not linked to a name or an email address, and we do not look these records up individually. We do not currently apply an expiry date to these unregistered records.
• Email verification and password reset tokens: short-lived, and expire automatically.

We do not currently apply an automatic age limit to conversation history — it is kept until you delete your account or delete the data. If you want older conversations removed sooner, contact us.

10. Your privacy rights

Depending on where you live, you have some or all of the following rights: to access a copy of your data; to correct it; to have it erased; to restrict or object to how we use it; to receive it in a portable format; and to withdraw consent you previously gave.

You can delete your account and its data yourself: open the app, go to Settings and choose Delete Account. For anything else — including a copy of your data — email support@groundlyapp.com and we will respond within one month. We do not currently offer a self-service data export, so please ask us and we will produce one.

We will not charge you for exercising these rights or treat you differently for doing so.

If you are in the EEA or the UK, you can complain to your local data protection authority. Because we are established in Portugal, our lead authority is the Comissão Nacional de Proteção de Dados (CNPD), Portugal's data protection authority. We would appreciate the chance to put things right first.

11. Additional information for US residents

This section applies if you live in California or another US state with a comprehensive privacy law.

In the twelve months before this policy was published we collected the categories of data described in section 3: identifiers, customer records, commercial information, internet and device activity, audio-derived text, and — most significantly — sensitive personal information, namely data concerning your mental health.

We do not sell personal information and we do not share it for cross-context behavioural advertising, as those terms are defined under California law. We have not done so in the past twelve months. We do not knowingly collect personal information from anyone under 18, so we do not sell or share the personal information of minors.

We use sensitive personal information only to provide the service you asked for and for the purposes described in section 4. We do not use it to infer characteristics about you for any purpose other than showing you your own insights.

You have the right to know, delete, correct and to limit our use of sensitive personal information, and the right not to be discriminated against for exercising them. Use Delete Account in the app, or email support@groundlyapp.com. An authorised agent may submit a request on your behalf if they provide proof of authorisation.

12. Consumer health data

This section applies if you live in Washington, Nevada, Connecticut or another state with a consumer health data law, and it applies to the health-related data described in section 3.

We collect consumer health data — your conversations about how you are feeling, your state check-ins, and the profile derived from them — in order to provide the assistant, exercises, insights and statistics you asked for. We collect it only with your consent.

We share this data only with the service providers named in section 7, and only so they can perform those functions for us. We do not sell consumer health data, and we would not do so without obtaining your separate written authorisation as those laws require.

Our staff may access this data only where necessary to operate the service or provide support you have requested.

You have the right to confirm whether we are collecting your consumer health data, to access it, to withdraw your consent to its collection and sharing, and to have it deleted — including from our backups on their normal cycle. Email support@groundlyapp.com to exercise any of these, or delete your account in the app.

13. Cookies, local storage and website analytics

Our websites use Google Analytics to understand traffic and how people move through the pages. This sets cookies in your browser and sends Google information about your visit.

The web onboarding flow also stores a temporary identifier in your browser's local storage so that your progress and score survive a page reload. This is not used for advertising or tracking across other sites.

Analytics is deliberately not loaded on the password reset and email verification pages, because those pages carry a token in the URL.

You can block or delete cookies in your browser settings, and you can opt out of Google Analytics using Google's browser add-on. Doing so does not affect your ability to use the site.

The mobile app does not use cookies. It uses on-device storage to keep you signed in and to remember your preferences, and encrypts the sensitive parts of that storage.

14. Age requirement

Groundly is for adults. You must be at least 18 to create an account, and our onboarding only offers age ranges from 18 upwards.

We do not knowingly collect data from anyone under 18. If you believe a child has given us personal data, email support@groundlyapp.com and we will delete it.

15. How we protect your data

We encrypt data in transit, hash passwords, encrypt the sensitive parts of on-device storage, restrict administrative access and require two-factor authentication for our admin tools, and log administrative actions.

No service can promise perfect security, and we are not going to. If a breach affects your personal data and puts you at risk, we will notify you and the relevant regulator as the law requires.

16. Changes to this policy

We will update this policy when the product changes. The date and version at the top of the page always reflect the current text.

If a change materially affects how we use your data, we will tell you in the app or by email before it takes effect, and where the law requires it we will ask for your consent again rather than assuming it.

17. How to contact us

Email support@groundlyapp.com for any privacy question, to exercise your rights, or to ask about anything in this document.

Groundly is operated from Portugal. Email is the fastest way to reach us, and we answer every message.