Privacy Policy

This Privacy Policy explains how WelQu (“WelQu”, “we”, “us”, or “our”) collects, uses, discloses, and protects personal information when you use our mobile application, website, and related services (together, the “Services”). It also describes your rights and the choices available to you. By using the Services, you agree to the practices described in this Policy.

For the purposes of applicable data protection law, WelQu is the controller responsible for your personal information.

1. Information we collect

We collect the following categories of personal information:

• Information you provide. Account details (your name, email address, and a password, which we store only in hashed form); profile and preference settings; wellness inputs such as mood check-ins, sessions you complete, and messages you send to the AI companion; and any information you include when you contact us.
• Payment information. If you purchase a subscription, your payment card details are collected and processed directly by a PCI DSS-compliant third-party payment processor. We do not receive or store your full card number; we retain only a billing reference and your subscription status.
• Information collected automatically. Limited technical and usage data such as device type, operating system, app version, general interactions with the Services, and diagnostic or crash information, used to operate, secure, and improve the Services. We do not use advertising or cross-site tracking technologies.

2. How we use your information

We use personal information to:

• provide, maintain, and personalize the Services, including saving your progress and generating AI-companion responses;
• process subscriptions, payments, and related billing;
• respond to your requests and provide customer support;
• secure the Services, prevent fraud and abuse, and diagnose and fix problems;
• send you service-related communications and, where permitted, optional product updates you can opt out of at any time;
• comply with our legal obligations and enforce our Terms of Service.

Where required by law (including the EU/UK GDPR), we rely on the following legal bases for processing: performance of our contract with you; your consent (which you may withdraw at any time); our legitimate interests in operating, securing, and improving the Services; and compliance with our legal obligations.

3. How we share information

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We do not share your wellness or practice data with employers, insurers, or advertisers. We disclose personal information only in the following limited circumstances:

• Service providers. Trusted vendors who process information on our behalf under contract, in categories such as cloud hosting and storage, payment processing, email delivery, AI processing for the companion feature, and security and diagnostics. They may use your information only to provide services to us.
• Legal and safety. Where reasonably necessary to comply with applicable law or legal process, or to protect the rights, property, safety, and security of our users, the public, or WelQu.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, in which case this Policy will continue to apply to your information.

Your conversations with the AI companion are processed by an AI service provider solely to generate responses to you. They are not sold, and they are not used to train publicly available AI models.

4. Storage, security, and international transfers

Your information is encrypted in transit and at rest and held on security-audited, industry-standard cloud infrastructure. Payment information is handled exclusively by a PCI DSS-compliant processor. While no method of transmission or storage is completely secure, we maintain administrative, technical, and physical safeguards designed to protect your information.

We and our service providers may process and store your information in countries other than the one in which you live. Where we transfer personal information internationally — including from the EEA, the United Kingdom, or Switzerland — we use appropriate safeguards, such as Standard Contractual Clauses.

5. Data retention

We keep personal information only for as long as necessary to provide the Services and for the purposes described in this Policy, or as required by law. When you delete your account, we delete or anonymize your personal information within a reasonable period (generally around 30 days), except where we must retain limited records to meet legal, tax, accounting, or security obligations.

6. Your privacy rights

Depending on where you live, you may have the right to access, correct, update, delete, or receive a copy of your personal information; to object to or restrict certain processing; and to withdraw consent. You can manage and delete your account from within the app, and you can exercise any of these rights using our contact form. We will not discriminate against you for exercising your rights, and we will respond within the timeframes required by applicable law.

7. California residents (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect and how we use and disclose it; to request access to, correction of, or deletion of your personal information; and to opt out of the “sale” or “sharing” of personal information. We do not sell or share your personal information as those terms are defined under California law. You may exercise these rights through our contact form, including via an authorized agent, and we will not discriminate against you for doing so.

8. EEA, UK, and Switzerland (GDPR)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the rights described in Section 6, including the rights of access, rectification, erasure, restriction of processing, data portability, and objection, as well as the right to withdraw consent at any time. WelQu is the data controller for your personal information, and the legal bases on which we process it are described in Section 2. You also have the right to lodge a complaint with your local data protection supervisory authority.

9. Canada (PIPEDA)

If you are located in Canada, you have the right to access and request correction of your personal information and to withdraw consent, subject to legal and contractual restrictions. We collect, use, and disclose personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws. You may contact us through our contact form, and you have the right to make a complaint to the Office of the Privacy Commissioner of Canada.

10. Children’s privacy

WelQu is intended for users aged 13 and older and is not directed to children under 13, and we do not knowingly collect personal information from them. Where a higher minimum age of digital consent applies (for example, 16 in parts of the EEA/UK), you must meet that age to use the Services. If you believe a child has provided us with personal information, please contact us and we will delete it.

11. Third-party links and services

The Services may link to third-party websites or services that we do not operate or control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their policies before providing them with personal information.

12. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will notify you by email or through the app before they take effect. Your continued use of the Services after the effective date constitutes acceptance of the updated Policy.

13. How to contact us

If you have any questions about this Policy or how we handle your personal information, or if you wish to exercise your rights, please send us a message and we will respond by email.