Last updated: [28-09-2026]
This Privacy Policy explains what data Cognaru collects, why we collect it, how it is stored, and your rights
under applicable law — including the UK/EU GDPR and California's CCPA.
1. Introduction
Cognaru ("we," "us," "our") is committed to protecting your privacy. This policy covers the Cognaru app and
website, and explains our practices around the data you share with us.
Legal entity: [Philip John Sabin]
2. Data We Collect
Data you provide
- Account information (email address, name)
- Voice recordings (Mind-Body Affirmations, Body Scan, Self-Hypnosis scripts)
- Script text you enter or upload
- Headphone profile names
- Payment information (processed by Stripe — we do not store card details)
Data collected automatically
- Device information (model, OS version)
- App usage data (sessions, modes used, duration)
- Session history
- Token usage
- Crash reports and analytics [ Firebase, Google Analytics]
- IP address (if transmitted by our servers)
Data we do NOT collect
- Location data
- Contacts
- Photos
- Health data beyond what you explicitly enter
3. Voice Recordings — Special Disclosure
Important: Cognaru records and stores voice data when you use recording features. In some
jurisdictions, voice recordings may be treated as biometric or special category data — this
policy treats them with the stricter protections that apply.
- Purpose: to play back your recordings during sessions
- Storage location: [locally on device / cloud sync via Supabase]
- Retention: kept until you delete them or uninstall the app
- Consent: explicit consent is obtained before microphone access
- Sharing: not shared with third parties unless cloud sync is enabled
4. How We Use Your Data
We use your data to:
- Provide the service (play sessions, restore settings)
- Personalise your experience (calibration, preferences)
- Process payments and manage subscriptions
- Improve the app (aggregate analytics only)
- Communicate with you (support, updates)
We do NOT:
- Sell your data
- Use your voice recordings to train AI models
- Share recordings with advertisers
5. Legal Basis for Processing (GDPR)
- Contract: to provide the service you have signed up for
- Consent: for voice recordings and marketing communications
- Legitimate interest: for app improvement and fraud prevention
6. Data Sharing
We share data only with the following categories of third parties:
- Payment processors: Stripe, RevenueCat
- Analytics: [none]
- App stores: Google Play, Apple App Store
- Legal requirements: if required by law
We do not sell personal data.
7. Data Storage & Security
- Data is encrypted in transit and at rest.
- Voice recordings are stored [locally on device / cloud].
- If Supabase sync is enabled, this section will be updated to describe the data synced.
- Access to production systems is restricted and logged.
8. Data Retention
- Account data: retained while your account is active
- Voice recordings: until you delete them
- Session history: until you delete it
- Payment records: as required by law (typically 7 years)
- Analytics: anonymised after [24 months]
9. Your Rights
Under GDPR and CCPA, you have the right to:
- Access a copy of your data
- Rectify inaccurate data
- Erase your data ("right to be forgotten")
- Port your data to another service
- Restrict processing
- Object to processing
- Withdraw consent (for voice recordings, marketing)
To exercise any of these rights, email
info@cognaru.com. We respond within 30 days.
10. Children's Privacy
Cognaru is not intended for children under 13 (or under 16 where local law requires). We do not knowingly
collect data from children. If you believe a child has provided us with personal data, contact us and we will
delete it.
11. International Data Transfers
If your data is stored or processed outside the UK/EEA, we ensure appropriate safeguards are in place, such as
Standard Contractual Clauses approved by the European Commission.
12. Cookies & Tracking
Our website may use cookies for essential functionality and analytics. The Cognaru app may use analytics tracking
as described in Section 2. You can control cookies via your browser settings.
13. Third-Party Links
Our app or website may link to third-party resources (e.g., Louise Hay's book). We are not responsible for the
privacy practices of those third parties.
14. Changes to This Policy
We may update this policy from time to time. We will notify you of material changes via the app or email. The
"Last updated" date at the top of this page reflects the latest revision.
For privacy questions, or to lodge a complaint:
- Data protection contact: info@cognaru.com
- Supervisory authority: You have the right to lodge a complaint with your local data protection authority (in the UK, the ICO).