Privacy Policy

SoulMemo
Effective Date: March 30, 2026
Last Updated: March 30, 2026

1. Who We Are

SoulMemo is operated by CARDIGITAL FZCO, registered at IFZA, Dubai Silicon Oasis, United Arab Emirates.

Contact: hello@soulmemo.app

2. What Data We Collect

SoulMemo is a mental health journaling app that processes sensitive personal data. We collect and process the following categories:

Data you provide directly:

• Voice recordings (audio files of journal entries)
• Transcripts generated from your voice recordings
• Medication names and dosages you enter
• Profile information (email address, display name)

Data generated through analysis:

• Mood scores, valence, and arousal measurements
• Clinical tags (symptoms, triggers, coping strategies, activities)
• Sleep quality assessments
• Linguistic markers (speech patterns, word usage ratios)
• Safety and crisis risk assessments
• AI-generated summaries and reflection prompts

Technical data:

• Authentication tokens and session data
• Device type and operating system (for app functionality)
• Timestamps of entries and interactions

3. Special Category Data (Health Data)

Much of the data SoulMemo processes qualifies as special category data under GDPR Article 9 — specifically, data concerning health and mental health.

We process this data based on your explicit consent, which you provide when you create an account and begin recording entries. You may withdraw consent at any time by deleting your account, which will remove all your data from active systems.

4. How We Use Your Data

We use your data exclusively to:

• Transcribe your voice recordings into text
• Analyze your journal entries for mood, patterns, and safety signals
• Provide personalized reflection prompts and insights
• Track your medication mentions and changes over time
• Build your personal baseline for detecting deviations
• Display your mood history and trends

We do not use your data for advertising, profiling for third parties, or any purpose unrelated to the journaling service.

5. Third-Party Processors

Your data is processed by third-party services acting as data processors under our instruction. Details are available upon request.

Important: Audio recordings are sent to speech-to-text services for transcription. Transcripts (never audio) are sent to AI models for analysis. No third party retains your data beyond the processing window unless required by their terms.

6. Data Retention

• Active data: Retained as long as your account exists. You control your data — you can delete individual entries or your entire account at any time.
• Backups: Deleted data may persist in encrypted backups for up to 30 days before permanent removal.
• AI processors: Third-party processors process data in real-time and do not retain inputs after processing is complete.

7. Your Rights Under GDPR

If you are in the European Economic Area, United Kingdom, or a jurisdiction with similar protections, you have the following rights:

• Access: Request a copy of all data we hold about you.
• Rectification: Correct inaccurate personal data.
• Erasure: Request deletion of your data (“right to be forgotten”).
• Portability: Receive your data in a structured, machine-readable format.
• Objection: Object to processing of your data.
• Restriction: Request that we limit how we process your data.
• Withdraw Consent: Withdraw your consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at hello@soulmemo.app. We will respond within 30 days.

8. Data Security

We implement robust security measures including encryption in transit and at rest, row-level security, and server-side key storage.

9. International Transfers

Your data may be transferred to and processed in countries outside your country of residence. These transfers are necessary to provide the service and are conducted with appropriate safeguards.

10. Children

SoulMemo is not intended for use by anyone under the age of 18. We do not knowingly collect data from minors.

11. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated through the app.

12. Contact

Email: hello@soulmemo.app
Entity: CARDIGITAL FZCO, IFZA, Dubai Silicon Oasis, UAE