Privacy Policy — Realygn

Last updated: [DATE] Version: 1.0

In short (non-binding summary). To build your energetic profile, Realygn needs precise personal data: your birth name, date, time, and place of birth. What you write in the Chat and your Alignment Plans stays private. We never sell your data, we show no ads, and we do not use your conversations to train AI models. You can delete your account and all your data at any time, directly from the app.

1. Who we are

Realygn is operated by:

Realygn Inc. 311 Baltic Street, Brooklyn, NY 11201, USA Email: support@realygn.app

Realygn Inc. is the "data controller" (or "business" under U.S. state privacy laws) responsible for your personal data.

For users located in the European Economic Area (EEA), the United Kingdom, or Switzerland: [EU/UK REPRESENTATIVE UNDER GDPR ART. 27 — TO BE APPOINTED AND COMPLETED].

This policy applies to the Realygn mobile application (iOS and Android), its related services, and the website realygn.app.

2. What data we collect, and why

2.1 Account data

• Email address — to create your account, sign you in, secure your access, and send service communications (confirmation, password reset, important subscription notices).

• Password — stored only in encrypted (hashed) form. We never have access to it in plain text.

• [IF APPLE/GOOGLE SIGN-IN IS OFFERED: a technical identifier provided by Apple or Google when you sign in with "Sign in with Apple" or "Google Sign-In".]

2.2 Data required to build your energetic profile

This is the core of the service. To generate your profile, we collect:

• Your birth first and last name (used by the numerology module);

• Your date of birth;

• Your time of birth;

• Your place of birth (city and country).

Our servers use this data to compute your profile (astrology, numerology, Human Design) and all the personalized content built on it. Without it, the service cannot work.

2.3 Content you create in the app

• Your conversations with the AI Chat (your messages and the generated replies);

• Your Alignment Plans: the topic you choose, the vision you describe, the actions you check off, and your progress;

• Your preferences and interactions in the app (content viewed, items marked as resonating, your current active gesture).

⚠️ Important — free-form content. The Chat and the Plans let you express yourself freely. You may, if you choose, mention topics touching on your emotional well-being, relationships, or mental health. We never ask for this information; if you choose to share it, it is handled with the protections described in Section 4.

2.4 Data about other people (the "Energy Match" feature)

The Energy Match lets you cross your profile with another person's (a friend, partner, or colleague). To do so, you may enter that person's birth data: first/last name, date, time, and place of birth.

Your commitments when using the Match:

• You confirm that you have informed that person and obtained their permission to enter their data into Realygn;

• You agree not to use the Match to judge that person or cause them harm.

Our commitments:

• The other person's data is used only to generate the Match you requested;

• It is never used for marketing, never shared, and does not create an account for that person;

• The Match sheds light on a relational dynamic: it never produces a compatibility verdict, a prediction, or any assessment of that person;

• Anyone whose data has been entered into Realygn may request its deletion by writing to support@realygn.app (see Section 9);

• This data is deleted according to the retention periods in Section 8.

2.5 Subscription and purchase data

Subscriptions and the 7-day free trial are handled by Apple (App Store) or Google (Google Play). We never collect or store your payment card details. We only receive technical transaction information (subscription status, anonymized transaction identifier, renewal date) needed to unlock paid features for you. [IF A SUBSCRIPTION MANAGEMENT TOOL IS USED (e.g., RevenueCat): the provider [NAME] processes this transaction information on our behalf.]

2.6 Technical and usage data

• Device data: model, operating system, language, technical device identifiers;

• Connection data and logs: timestamps, IP address, technical events, crash reports;

• Aggregated usage data: screens viewed, features used — to understand what works and improve the product. [ANALYTICS AND CRASH-REPORTING TOOLS TO BE LISTED — e.g., Firebase, Amplitude, Sentry — TO BE COMPLETED.]

2.7 Support and communications

When you contact us (email, form), we keep your message and our exchanges to handle your request.

We do not collect: your real-time location, your phone contacts, your photos, or any device data unrelated to the service.

3. How we use your data (purposes and legal grounds)

Processing Purpose / legal ground Account creation and management, energetic profile generation, AI Chat, Plans, Match, subscription management Performance of our contract with you — these are the services you request (GDPR Art. 6.1.b for EEA/UK users) Processing free-form content that may reveal information about your health or intimate life (Chat, Plans) Your explicit consent — collected before your first use of the Chat and Plans, withdrawable at any time (GDPR Art. 9.2.a) Safety gate at the entrance of the Alignment Plan (detecting signals of significant distress in order to point you toward human help instead of generating a plan) Your explicit consent, and protection of vital interests in serious situations Product improvement, usage statistics, security, and fraud prevention Our legitimate interest in providing a reliable service and improving it, using minimized or aggregated data whenever possible Marketing communications (only if you opt in) Your consent — withdrawable at any time, with an unsubscribe link in every email Retention of certain billing records and logs Compliance with legal obligations

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

4. Sensitive data and well-being: our specific commitments

Realygn is a self-knowledge and well-being tool. It is not a medical device, a healthcare service, or therapy.

• We never solicit information about your health, religious beliefs, sexual orientation, or any other sensitive data;

• If you choose to raise such topics in the Chat or a Plan, that content is processed only to respond to you in the conversation or generate your plan — never for advertising profiles, never shared for commercial purposes;

• The Alignment Plan's safety gate analyzes the topic you describe solely to detect signals of significant distress. If detected, the app does not generate a plan and gently points you toward human help. This gate makes no diagnosis, creates no persistent "mental health score," and has no other consequence;

• The energetic profile and generated content are well-being and introspection content: they never constitute medical, psychological, legal, or financial advice.

5. Artificial intelligence: how your data is used

Realygn uses artificial intelligence models to generate your profile, your analyses, the mirror Chat, Matches, and Plans.

• What the AI does: it reads the data computed by our servers (signs, numbers, gates, facets) and renders it in clear, personalized language. It does not "recalculate" anything and does not invent data about you.

• AI service provider: requests are processed by [AI MODEL PROVIDER — TO BE COMPLETED, e.g., Anthropic / OpenAI], acting as our service provider under a data processing agreement (DPA).

• No training on your data: your conversations and your profile are not used to train AI models, neither by us nor by our providers [TO BE CONTRACTUALLY GUARANTEED IN THE PROVIDER'S DPA].

• No automated decision-making with legal effects: no Realygn processing produces decisions with legal or similarly significant effects on you (within the meaning of GDPR Art. 22). Your profile is self-reading content, not an evaluation conditioning any right or access.

6. Who we share your data with

We never sell your data. We show no ads. No third party buys access to your information. We do not "sell" or "share" personal information as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA).

Your data is accessible only to:

1. Our technical service providers, strictly necessary to run the service, bound by data processing agreements:

   • Hosting and infrastructure: [HOSTING PROVIDER — TO BE COMPLETED];

   • AI model provider: [TO BE COMPLETED];

   • Analytics and crash reporting: [TO BE COMPLETED];

   • Transactional email: [TO BE COMPLETED];

   • Subscription management: Apple, Google [+ any additional provider — TO BE COMPLETED].

2. Public authorities, only where the law requires it;

3. A potential acquirer, in the event of a merger, acquisition, or asset sale — you would be informed and your rights preserved.

Profiles shared via the sharing feature ("to share," story) contain only the excerpts you explicitly choose to share.

7. Where your data is stored; international transfers

Realygn Inc. is based in the United States, and your data is processed there and stored on servers located in [SERVER LOCATION — TO BE COMPLETED].

For users in the EEA, UK, or Switzerland: where personal data is transferred outside your region, we rely on:

• an adequacy decision (including the EU–U.S. Data Privacy Framework for certified providers [IF REALYGN INC. CERTIFIES — RECOMMENDED]), or

• the European Commission's Standard Contractual Clauses, supplemented with additional safeguards where needed.

You may obtain a copy of the applicable safeguards by writing to support@realygn.app.

8. How long we keep your data

Data Retention period Account, energetic profile, content (chats, plans) For the life of your account After you delete your account Erased or anonymized within 30 days (technical backups purged within [90 days max — TO BE CONFIRMED]) A third party's birth data entered for a Match Life of your account, or upon the third party's deletion request; deleted along with your account Inactive accounts Deleted after [24/36 months — TO BE DEFINED] of inactivity, preceded by a warning email Technical and connection logs 12 months maximum Transaction records (accounting and tax obligations) Applicable statutory periods Support exchanges 3 years after last contact Consent records Duration of the processing + 3 years

9. Your rights

9.1 All users

Regardless of where you live, you can:

• Access the data we hold about you and receive a copy;

• Correct inaccurate data (for example, your time of birth);

• Delete your account and data;

• Export your data in a structured, machine-readable format [IF AVAILABLE — RECOMMENDED];

• Opt out of marketing communications at any time.

How to exercise your rights:

• Directly in the app: Settings → Account → Delete my account (immediate and permanent deletion of your account and associated data, as required by Apple and Google); Settings → Export my data [IF AVAILABLE];

• By email: support@realygn.app. We respond within the timeframes required by applicable law (one month for GDPR requests, 45 days for CCPA requests, each extendable with prior notice). We may ask for proportionate identity verification. You will not be discriminated against for exercising your rights.

If you are not the account holder but your birth data was entered by a user (Energy Match), you may request its deletion at the same address.

9.2 U.S. state privacy rights (California and other states)

If you reside in California or another U.S. state with a comprehensive privacy law (Virginia, Colorado, Connecticut, Utah, Texas, etc.), you have the rights to know, access, correct, delete, and obtain a portable copy of your personal information, and to opt out of "sales," "sharing," and targeted advertising. Realygn does not sell or share personal information and does not engage in targeted advertising, so there is nothing to opt out of. We do not use or disclose sensitive personal information for purposes other than providing the services you request. You may designate an authorized agent to submit requests on your behalf. California residents: we do not respond differently to "Do Not Track" signals because we do not track users across third-party sites; we honor opt-out preference signals where legally required.

9.3 EEA, UK, and Swiss users (GDPR)

You additionally have the rights to restrict processing, to object to processing based on our legitimate interests, to withdraw consent at any time, and to lodge a complaint with your local supervisory authority (for France: the CNIL, www.cnil.fr).

10. Children

Realygn is intended for adults. The app is not directed to children under 13, and we do not knowingly collect personal information from children under 13 (COPPA). Moreover, you must be at least [16] years old to create an account [THRESHOLD TO BE VALIDATED — recommendation: 16 or 18 given the introspective content; note that EU users under 15/16 require parental consent depending on the country]. If you believe a child has created an account, write to support@realygn.app and the account and data will be deleted.

11. Security

We implement technical and organizational measures appropriate to the sensitivity of the data we process, including:

• Encryption of data in transit (TLS) and at rest;

• Password hashing;

• Internal access controls following the principle of least privilege;

• Access logging and security monitoring;

• Confidentiality and data processing agreements with all our service providers;

• A data breach procedure: where a breach is likely to create a risk to your rights, we notify the competent authorities within the legally required timeframes (including 72 hours under GDPR) and inform you directly where the risk is high.

12. Cookies and trackers

In the app, we use only technical identifiers necessary for operation (session, authentication) and usage measurement tools [SUBJECT TO CONSENT WHERE REQUIRED — depends on the tools chosen, TO BE COMPLETED]. No advertising trackers.

On realygn.app, a consent banner lets you accept or refuse non-essential trackers, with equally simple choices either way. [WEBSITE COOKIE DETAILS — TO BE COMPLETED.]

13. Changes to this policy

We may update this policy to reflect changes in the service or in the law. In the event of a material change (new purposes, new recipients), you will be informed in the app or by email before it takes effect, and your consent will be collected again where the law requires it. The "last updated" date appears at the top of this document, and previous versions are available on request.

14. Contact us

For any question about your personal data:

Realygn Inc. 311 Baltic Street, Brooklyn, NY 11201, USA Email: support@realygn.app

Realygn is a self-knowledge and well-being tool. It is not a substitute for medical, psychological, or therapeutic advice. If you are going through a difficult time, please reach out to a healthcare professional or a support service.