Privacy Policy

1. Introduction and Scope

Scaleswift Digital Services LLP ("we," "us," or "our") operates Kael, an AI-powered personal mentoring application ("Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

By accessing or using Kael, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, you must immediately discontinue use of the Service.

This Policy applies to all users worldwide. Additional rights and disclosures for users in specific jurisdictions (including California, the EEA, and the UK) are set out in Section 13.

2. How We Obtain Your Consent

By signing up for and using Kael, you consent to the collection, processing, and use of your personal data as described in this Privacy Policy, including the collection of sensitive personal information such as psychological disclosures, emotional patterns, behavioral tendencies, and the derived profile data described in Section 3.3.

You may withdraw consent at any time by deleting your account or contacting us at hello@kaelai.life. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

3. Information We Collect

3.1 Information You Provide Directly

We collect information you actively provide to us, including:

• Account registration information (name, email address, password)
• Biographical and personal context you share during sessions, including your name, age, occupation, relationships, location preferences, and personal background
• Conversational content — the full text of your interactions with Kael
• Psychological and behavioral disclosures, including beliefs, emotional patterns, behavioral tendencies, personal goals, coping mechanisms, and interpersonal dynamics
• Commitments and tasks you agree to undertake
• Feedback, survey responses, and support communications

3.2 Information Automatically Collected

We automatically collect certain technical information when you use the Service:

• Device information (device type, operating system, unique device identifiers)
• Usage data (session duration, feature interactions, access timestamps)
• Log data (IP address, browser type, referring URLs, crash reports)
• In-app behavior analytics (navigation patterns, response timing)

3.3 Information Derived by the Service (Memory System)

Kael's core functionality involves building and maintaining an ongoing psychological understanding of you. This is what makes Kael a persistent mentor rather than a stateless chatbot. The memory system includes:

• User Profile: Stable personal facts compiled over time (life circumstances, relationships, professional context)
• Coach's Read: The system's synthesized working model of your current psychological state — what is active, what is pending, what patterns have been identified
• Event Log: A weighted log of significant disclosures, behavioral insights, commitments, breakthroughs, setbacks, and cross-session connections
• Conversation History: The content of recent sessions used to maintain continuity

3.4 Information from Third Parties

We may receive information from third-party services you connect to your account (e.g., Google or Apple for authentication). We collect only what is necessary for account creation and authentication.

4. How We Use Your Information

4.1 Service Delivery

• To provide, operate, and improve the Kael mentoring experience
• To maintain conversational and psychological continuity across sessions
• To personalize Kael's responses based on your history and profile
• To track commitments and follow up on behavioral tasks

4.2 Account and Safety

• To create and manage your account
• To verify identity and prevent fraud or unauthorized access
• To enforce our Terms of Service
• To detect and address technical issues or abuse

4.3 Communications

• To send transactional communications (receipts, password resets, security alerts)
• To send product updates or changes to this Policy — with your consent where required by law
• To respond to your inquiries and support requests

4.4 Research and Improvement

• To analyze aggregated, de-identified usage patterns to improve our Service
• To train and improve AI models, using only de-identified or anonymized data. We do not use your identifiable personal data for model training without your separate, explicit opt-in consent
• To conduct internal research on user engagement and service quality

4.5 Legal and Compliance

• To comply with applicable laws, regulations, and legal processes
• To respond to lawful requests from public authorities
• To protect our legal rights and interests

5. Legal Bases for Processing

We process your personal data only when we have a lawful basis to do so:

• Contract Performance: Processing necessary to deliver the Service you have signed up for
• Legitimate Interests: Fraud prevention, security, and understanding how the Service is used in order to improve it (aggregate analytics). We have assessed these interests against your rights and found them proportionate. Where we rely on legitimate interests, you have the right to object at any time
• Explicit Consent: Collection and processing of sensitive psychological data (Section 3.3), inferred data, and any use for AI model training. Consent is obtained as described in Section 2 and may be withdrawn at any time
• Legal Obligation: Processing required by applicable law

6. How We Disclose Your Information

6.1 Named Service Providers

We share data with vetted third-party vendors to operate the Service. Key providers include:

Other service providers include:

• Cloud infrastructure and hosting providers (data storage and compute)
• Analytics and error monitoring services (de-identified usage data only)
• Customer support platforms
• Payment processors (billing information only — they do not receive session content)

All service providers are bound by data processing agreements restricting their use of your data to the stated purpose.

6.2 Business Transfers

In the event of a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent in-app notice promptly following the completion of any such transaction if it results in a material change to how your data is handled.

6.3 Legal Requirements

We may disclose your information if we believe in good faith that disclosure is necessary to: (a) comply with applicable law or legal process; (b) protect the rights, property, or safety of ourselves, our users, or the public; or (c) enforce our Terms of Service.

6.4 With Your Consent

We may share your information for any other purpose with your explicit prior consent.

6.5 What We Do Not Do

• We do not sell your personal data to any third party
• We do not share your conversation content or psychological profile with advertisers
• We do not disclose your information to employers, insurers, or government entities except as required by law
• We do not use your identifiable sensitive data to train AI models without your separate, explicit consent

7. AI Processing and Sensitive Personal Data

Kael processes information that qualifies as sensitive personal data under applicable law, including information relating to mental health, emotional state, personal relationships, and psychological beliefs.

We apply the following protections specific to this data:

• Sensitive conversational content is stored with enhanced access controls and encryption at rest
• Access to identifiable session content is restricted to personnel and systems necessary to deliver the Service
• We do not use identifiable sensitive data to train AI models without your specific, separate opt-in consent
• Where we use conversation data for model improvement, we apply de-identification and aggregation before any such use
• Inferred psychological data (Coach's Read, Event Log entries) is treated with the same protections as directly disclosed sensitive data

By signing up for Kael as described in Section 2, you explicitly consent to the processing of sensitive personal data as described in this Policy.

8. Data Retention

We retain your data for defined periods tied to the purpose of collection:

• Conversation history: Retained for the life of your account to support Kael's memory features. Sessions older than 36 months may be automatically purged unless you contact us to request extended retention
• User Profile, Coach's Read, and Event Log: Retained for the life of your account
• Account data (email, billing): Retained for 7 years after account closure for tax and legal compliance
• Technical logs (IP, device data): Retained for 90 days
• Upon account deletion: Personal data deleted or anonymized within 30 days, except data subject to legal hold
• De-identified or aggregated data: May be retained indefinitely

You may request deletion of specific data elements at any time (Section 9). Deleting your memory data will reset Kael's understanding of you and materially degrade the Service.

9. Your Rights and Choices

9.1 Access and Portability

You may request a copy of all personal data we hold about you — including conversation history, User Profile, Coach's Read, Event Log, and inferred data — in a machine-readable format.

9.2 Correction

You may request correction of inaccurate or incomplete personal data.

9.3 Deletion

You may request deletion of your account and all associated personal data. We will honor such requests within 30 days except where retention is required by law.

9.4 Restriction and Objection

You may request restriction of processing or object to certain processing activities. We will honor such requests to the extent required by applicable law.

9.5 Withdrawal of Consent

You may withdraw consent to sensitive data processing at any time by contacting hello@kaelai.life or deleting your account. Withdrawal does not affect the lawfulness of prior processing.

9.6 Do Not Sell / Opt-Out (California)

We do not sell personal data. California residents may also opt out of sharing for cross-context behavioral advertising by contacting hello@kaelai.life.

9.7 How to Exercise Your Rights

Contact us at hello@kaelai.life. We will respond within 30 days (45 days for California requests). We may verify your identity before processing your request. You may designate an authorized agent to submit requests on your behalf with written authorization.

10. Data Security

We implement administrative, technical, and physical safeguards designed to protect your data, including:

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
• Access controls limiting internal access to personal data on a strict need-to-know basis
• Regular security assessments and penetration testing
• Incident response and breach notification procedures

No method of electronic transmission or storage is 100% secure. In the event of a data breach affecting your rights, we will notify you as required by applicable law, including within 72 hours for EEA users where feasible.

11. Children's Privacy

Kael is not directed at children under the age of 13 (or 16 in jurisdictions where a higher minimum age applies). We do not knowingly collect personal data from children below the applicable age. If you believe your child has provided us with personal data, contact us at hello@kaelai.life and we will delete it within 5 business days of verifying your identity and relationship to the child.

12. International Data Transfers

We are incorporated in India. However, our service infrastructure and the third-party providers we use to deliver the Service, including cloud hosting and AI model providers, are primarily located in the United States. By using the Service, your data will be transferred to, stored, and processed in the United States.

For EEA, UK, and Swiss users: We rely on Standard Contractual Clauses (SCCs) as the legal basis for international transfers. A copy of applicable transfer mechanisms is available on request at hello@kaelai.life.

For users in other jurisdictions: By using the Service, you consent to the transfer of your data to the United States where data protection laws may differ from those in your country.

13. Jurisdiction-Specific Disclosures

13.1 California (CCPA / CPRA)

California residents have the following rights:

• Right to Know: Categories and specific pieces of personal data collected, sources, purposes, and third-party disclosures
• Right to Delete: Deletion of personal data we have collected
• Right to Correct: Correction of inaccurate personal data
• Right to Opt Out of Sale/Sharing: We do not sell personal data and do not share it for cross-context behavioral advertising
• Right to Limit Use of Sensitive Personal Information: You may limit our use of sensitive data to purposes necessary to deliver the Service
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

To submit a request, contact hello@kaelai.life. We will respond within 45 days. Authorized agents may submit requests with written authorization and identity verification.

13.2 EEA, United Kingdom, and Switzerland (GDPR / UK GDPR)

In addition to the rights in Section 9, EEA/UK/Swiss users have:

• Right to lodge a complaint with a supervisory authority in your country of residence
• Rights related to automated decision-making and profiling (Article 22 GDPR)

Our legal bases for processing are set out in Section 5. In summary: contract performance (service delivery), legitimate interests (fraud prevention, security, and service improvement), and explicit consent (sensitive data, inferred data, model training).

Data controller: Scaleswift Digital Services LLP. For GDPR inquiries: hello@kaelai.life.

Data Protection Officer (DPO): We have assessed our processing activities and have determined that we are not currently required to appoint a mandatory DPO under GDPR Article 37. Should our processing scale or nature change such that appointment becomes mandatory, we will designate a DPO and publish their contact details here. Users may direct data protection inquiries to hello@kaelai.life in the interim.

13.3 Other US States

Users in Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), and other states with comprehensive privacy laws have rights similar to those in Section 9. Contact us at hello@kaelai.life to exercise your rights.

13.4 Other Jurisdictions

We comply with applicable privacy laws in all jurisdictions where we operate. Contact hello@kaelai.life for questions about your rights under local law.

14. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve the Service:

• Strictly necessary cookies: Required for authentication and core functionality. Cannot be disabled.
• Analytics cookies: Used to understand usage patterns. You may opt out via browser settings or our in-app cookie preferences center.
• Preference cookies: Used to remember your settings.

We do not use third-party advertising cookies. Disabling certain cookies may affect Service functionality.

15. Important Disclaimers

If you are experiencing a mental health emergency, please contact your local emergency services (911 in the US, 112 in the EU, 999 in the UK, 112 in India) or a crisis helpline such as the 988 Suicide & Crisis Lifeline (call or text 988 in the US), iCall in India (+91-9152987821), or the equivalent service in your country.

16. Governing Law and Dispute Resolution

This Privacy Policy and any disputes arising from it are governed by the laws of the State of Delaware, United States, without regard to conflict of law principles. For users outside the United States, mandatory consumer protection and privacy laws of your country of residence may also apply to the extent required by local law.

Any dispute, claim, or controversy arising out of or relating to this Privacy Policy that cannot be resolved through good-faith negotiation shall be resolved by binding arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, except that either party may seek injunctive or other equitable relief in a court of competent jurisdiction.

CLASS ACTION WAIVER: You agree that any arbitration or proceeding shall be limited to the dispute between us individually. To the fullest extent permitted by law, you waive the right to participate in a class action lawsuit or class-wide arbitration.

ARBITRATION OPT-OUT: You may opt out of the arbitration and class action waiver provisions above by notifying us in writing at hello@kaelai.life within 30 days of first creating your account. Your notice must include your name and a clear statement that you wish to opt out of arbitration. Opting out does not affect any other provision of this Policy.

For EEA/UK users: Nothing in this section limits your right to bring a complaint before your local supervisory authority or to bring claims in your local courts pursuant to applicable law.

17. Changes to This Policy

We may update this Privacy Policy from time to time.

For material changes — meaning changes that affect what data we collect, how we use it, or who we share it with — we will: (a) notify you by email at least 30 days before the change takes effect; and (b) require your affirmative re-consent within the app before you can continue using the Service. Continued use alone does not constitute acceptance of material changes to how your sensitive data is handled.

For non-material changes (clarifications, corrections, formatting), we will update the "Last Updated" date and notify you by email. Continued use after such changes constitutes acceptance.

18. Contact Us

For questions, requests, or concerns regarding this Policy or our data practices:

We will respond to all inquiries within 30 days.