Privacy Policy
Effective Date: September [ ], 2026
Provider: TENSORIS TECHNOLOGY (HK) LIMITED | Privacy Contact: hello@withelira.com
Thank you for using our products. TENSORIS TECHNOLOGY (HK) LIMITED and its affiliates (collectively, “we,” “us,” or “our”) place a high priority on protecting your privacy. This Privacy Policy explains the rules governing our collection, use, storage, and sharing of personal information when you access or use the Elira mobile application and related services (collectively, the “Service”), as well as the privacy rights available to you. If the laws applicable where you are located provide additional data rights, we will respect and protect those rights as required by law.
For purposes of this Privacy Policy, “personal information” means information that can directly or indirectly identify you. Please read this Policy carefully before using the Service. This Privacy Policy itself is not a contract requiring you to consent to every data-processing activity. Where applicable law requires separate consent for the processing of sensitive data, cross-app tracking, or other activities, we will obtain your authorization separately through permission prompts or other appropriate means.
By tapping “Agree & Continue” in the App, you acknowledge that: (i) you have read, understood, and agreed to this Privacy Policy, and you consent to our processing of your personal information in accordance with the terms described herein; and (ii) you are at least 18 years of age. If you do not accept this Privacy Policy, do not agree to the foregoing data-processing authorization, or cannot make the foregoing representations, you are not permitted to use the Service. In that event, you should: (i) stop using the Service and contact us to request deletion of your data; and (ii) cancel all subscriptions through Apple (if you use iOS), any other app store that may be made available from time to time, or any cancellation functionality that we provide.
1. Service and Scope
Elira is an AI-assisted tool for personal expression, listening, and reflection. This version supports text input only. Core features include text-based expression, selection of a listening style, reflection generation, private Journal storage, and links to external crisis resources. The Service is available only to users who are 18 years of age or older and is not offered to minors.
IMPORTANT NOTICE: Elira provides only AI-assisted expression, listening, and reflection features. It does not provide medical diagnosis, psychotherapy, medical advice, or emergency response services. The Service is not subject to the U.S. Health Insurance Portability and Accountability Act (HIPAA). AI-generated content is for informational and reflective purposes only and is not a substitute for advice from qualified professionals.
If you or another person is in immediate danger, contact the emergency services available in your location and take appropriate emergency measures. In the United States, you may call 911 or call or text the 988 Suicide & Crisis Lifeline. The crisis-support page within Elira only provides links to external support resources. It does not provide real-time follow-up or monitoring of your safety, is not an emergency-response service, and cannot replace assistance from medical or mental-health professionals.
2. Personal Data We Process
2.1 Content You Submit
When you use the expression, listening, and reflection features, we may process: (1) text you voluntarily enter; (2) your selected input and listening methods; (3) session topics and key points; (4) Journal content you choose to save; and (5) feedback or customer-support messages you choose to submit.
This content may concern your personal experiences, emotions, psychological feelings, relationships, life circumstances, health-related matters, or other sensitive topics. Please do not submit passwords, full payment-card information, government identification numbers, detailed medical records, or personal data about third parties that is unnecessary for providing the Service or that you do not have the right to provide.
2.2 AI-Generated and Inferred Data
To provide listening, reflection, and safety features, automated systems within Elira may generate or infer from content you voluntarily submit: (1) the topic of the current session; (2) emotional or feeling-related cues; (3) important excerpts from your expression; (4) a Key Thought; (5) whether a session has sufficient context for reflection; (6) perspectives that may be worth further consideration; (7) whether crisis-support resources should be displayed; and (8) AI responses and a Final Reflection.
These outputs are used only to maintain normal session interactions and support the operation of Service features. They are not definitive determinations about your identity, personality, mental state, or medical condition. We do not use these inferences to determine your eligibility for employment, housing, education, credit, insurance, health care, or other services that may produce legal or similarly significant effects. Your session content and Journal content will not be used to train general-purpose AI models.
2.3 Journal and On-Device Data
Under Elira’s current product design, Journal entries, reflection results, and related records that you choose to save are primarily stored locally on your device. Local data may include: (1) saved session records; (2) Final Reflections; (3) Key Thoughts; (4) Reflection Constellations; (5) Journal text; (6) default input methods; and (7) app preferences.
You may delete individual records or all Journal entries through App features, or clear App data or uninstall the App through your device settings. Data stored only on your device is not automatically uploaded to us. Because we cannot access data that exists solely on your device, we cannot remotely view, export, restore, or delete that data from our servers. Loss of your device, hardware failure, uninstalling the App, system cleanup, or changing devices may result in permanent loss of local Journal data, and we cannot restore such data. If we later add account functionality, cloud synchronization, cloud backup, or cross-device restoration, we will update this Policy before those features are enabled and provide any legally required notice or consent options.
2.4 Device and Technical Data
When you use the Service, we may automatically process: (1) device type and model; (2) operating system and version; (3) language and time zone; (4) network connection status; (5) IP address; and (6) request timestamps and response status.
Even if this data does not include your name, it may still be considered personal data under applicable law.
2.5 Product Usage and Analytics Data
To maintain the Service, troubleshoot issues, and improve the product, we may record limited functional events, such as: (1) page visits; (2) starting or ending a session; (3) input-method selections; (4) listening-style selections; (5) AI-response generation status; (6) Final Reflection generation status; (7) Journal page visits; (8) Settings page visits; (9) subscription-plan selections; and (10) purchase success, cancellation, or failure.
2.6 Subscription and Transaction Data
When you purchase, cancel, or restore a subscription through the Apple App Store or another authorized app store, we may receive: (1) the subscription plan you selected; (2) monthly or annual plan information; (3) subscription status; (4) purchase success, cancellation, or failure status; (5) transaction or receipt identifiers; (6) subscription start and expiration dates; and (7) verification information provided by the app store.
Full payment-card numbers, bank-account information, and payment credentials are processed by Apple or the applicable payment platform, and we generally do not receive that information.
2.7 Support Data
When you voluntarily submit a support request, we may process: (1) the email address you provide; (2) your description of the issue; (3) the time the request was submitted; (4) the status of the request; and (5) device and App information necessary to investigate the issue.
The support form does not automatically attach your private sessions, AI responses, Final Reflections, or Journal text unless you expressly choose to submit that content.
2.8 Consent and Privacy-Request Records
To comply with law and document how we have handled your choices, we may retain: (1) the version of the Privacy Policy; (2) the time of consent or withdrawal of consent; (3) request outcomes; (4) appeal records; and (5) communications relating to privacy requests.
2.9 Data We Do Not Proactively Collect
Under Elira’s current product design, we do not require you to provide the following information to use the primary features: (1) name; (2) username; (3) profile photo; (4) contacts; (5) precise geolocation; (6) facial-recognition information; or (7) government identification numbers.
If future product features require processing any of this data, we will update this Policy before collection and obtain any authorization required by applicable law.
2.10 Purposes for Processing Personal Data
We may process personal data for the following purposes:
(1) To provide the Service you request, including receiving text; generating AI listening responses; providing different listening styles; maintaining the context of the current session; generating Key Thoughts, Reflection Constellations, and Final Reflections; saving and displaying Journal entries you choose to save; and saving input and listening preferences.
(2) To operate subscriptions and free-use allowances, including calculating free-use eligibility, verifying subscription status, and providing subscription support.
(3) To maintain safety and Service integrity, including detecting fraud, abuse, and attacks; identifying software errors; performing content-safety checks; determining whether crisis-support resources should be displayed; and protecting the rights and safety of users, the public, us, and third parties.
(4) To provide customer support, including receiving and responding to inquiries, troubleshooting technical issues, handling complaints, and addressing subscription-related matters.
(5) To analyze and improve the Service, including understanding whether features operate properly, fixing crashes and performance issues, improving interfaces and product flows, and generating aggregated or de-identified statistics. We do not read or record the text of your private sessions or Journal entries for product analytics.
(6) To comply with law and protect legitimate interests, including satisfying applicable legal obligations, responding to governmental, court, or regulatory requirements, handling disputes and legal requests, preventing clear and imminent serious bodily harm, and protecting our legal rights.
3. Legal Bases for Processing Personal Data
3.1 Service Agreement
Where processing is necessary to provide text entry, AI responses, session reflections, Journal functionality, subscriptions, or customer service that you actively request, we process personal data on the basis of the Service Agreement.
3.2 Your Consent
We may rely on your consent in circumstances including: (1) processing data defined by law as sensitive data; (2) using non-essential analytics technologies; (3) engaging in cross-app tracking; (4) sending marketing communications; and (5) other processing activities for which applicable law requires separate authorization.
You may withdraw consent. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal, but it may prevent certain related features from continuing to function.
3.3 Legitimate Interests
Where those interests are not overridden by your rights and interests, we may process limited data based on legitimate interests such as: (1) maintaining Service security; (2) preventing fraud and abuse; (3) repairing technical failures; (4) improving product performance; and (5) protecting our rights and the rights of users.
3.4 Legal Obligations
We may process information as necessary to comply with consumer-protection, data-security, compliance, and other applicable legal obligations.
3.5 Vital Interests
Where permitted by law and in urgent circumstances, we may process necessary information to protect the life or serious personal safety of a user or another person.
4. Sensitive Personal Data and Consumer Health Data
Your private expression, emotional or psychological content, and related cues generated by automated systems may be considered sensitive personal data, special-category personal data, or consumer health data in certain jurisdictions. Please note that the Service is not a medical service and does not create medical records.
We process such data only for the following purposes: providing the expression, listening, and reflection features you request; generating AI responses and reflection results; performing safety checks; displaying crisis-support resources; saving content you choose to save; maintaining Service security; and complying with applicable legal obligations.
Unless separately authorized where required by law, we do not: sell sensitive personal data or consumer health data; provide it to data brokers; use it for targeted advertising; use it for commercial profiling unrelated to the Service; use precise location or geofencing to identify whether you have visited a health-care facility; use it to determine your eligibility for employment, housing, credit, insurance, education, or health care; or use it for model training unrelated to the Service you requested.
5. Service Providers and Other Recipients
5.1 AI Service Providers
AI service providers may receive text you voluntarily submit, necessary session context, and processing instructions to generate results such as Key Thoughts, Reflection Constellations, or Final Reflections.
5.2 Cloud Infrastructure and Security Providers
Cloud service providers may process data necessary to deliver the Service, provide security protections, route requests, and maintain technical logs.
5.3 Analytics and Error-Monitoring Providers
If enabled, analytics or error-monitoring providers may receive only limited, non-content event data and technical data. They must not receive the text of private sessions or Journal entries.
5.4 Support Providers
Support providers may process the email address, message, and necessary technical information that you voluntarily submit.
5.5 Apple and Other App Stores
Apple or other app stores independently process payment, purchase, refund, and subscription-account information. We may receive subscription status necessary to validate your subscription. Information collected independently by Apple is subject to Apple’s own privacy policy.
5.6 Professional Advisers and Parties to Corporate Transactions
Where necessary, we may disclose limited information to lawyers, accountants, auditors, or parties involved in a corporate transaction who are subject to confidentiality obligations. If a merger, acquisition, asset sale, or similar business change occurs, personal data may be transferred with the business, and we will provide advance notice to the extent required or permitted by law.
5.7 Government Authorities and Legal Requests
We may disclose information where necessary to comply with law, enforce the Terms of Service, investigate fraud, protect legal rights, or prevent clear and imminent serious bodily harm. We will not proactively disclose user information to law-enforcement authorities solely because of general emotional expression or ordinary psychological distress.
5.8 Sale, Sharing, Advertising, and Tracking
We do not sell your personal data for money. We do not sell or provide to data brokers: (1) private sessions; (2) AI responses; (3) Final Reflections; (4) Journal entries; (5) emotional or psychological data; (6) crisis-related expressions; or (7) consumer health data. We do not use such content for targeted advertising or cross-context behavioral advertising. Under Elira’s current product design, we do not track your activity across other companies’ apps, websites, or offline locations for advertising purposes.
5.9 Data Storage Locations
The locations where data is stored and processed depend on the infrastructure locations used by us and our service providers. Journal entries and related data that are stored only locally remain on your device.
Information processed to provide AI responses, support, subscription verification, or safety features may be stored and processed in the United States or other countries or regions.
6. Data Retention
We retain personal data only for as long as necessary to accomplish the purposes described in this Policy, taking into account the type of data, purpose of processing, and applicable legal requirements. Except as described below, when the retention period expires or the data is no longer needed, we will delete or anonymize it.
1. Journal entries, sessions, and reflection results stored only on your device: retained on your device until you delete them through the App or uninstall the App; we cannot remotely delete or restore them from our servers.
2. Session and AI-processing content: processed for the period necessary to provide listening and reflection features for the current session; unsaved content is generally deleted when the session ends.
3. Subscription and transaction records: retained for periods required by applicable tax, accounting, consumer-protection, and similar laws, such as legally required bookkeeping and record-retention periods.
4. Consent and privacy-request records: retained for the period necessary to satisfy applicable legal obligations, demonstrate compliance, and handle follow-up requests.
5. De-identified or aggregated statistical information: may be retained for longer periods provided that it can no longer identify an individual.
7. Data Security
We use reasonable technical, organizational, and administrative safeguards appropriate to the type, volume, and risk level of the personal data we process. These measures may include encryption in transit, access controls, least-privilege principles, filtering of sensitive content from logs, data-retention controls, service-provider security reviews, vulnerability and patch management, security monitoring, and access logging and audit mechanisms where necessary.
No method of electronic transmission or storage is completely secure. If a data-security incident occurs that is subject to notification requirements under applicable law, we will notify affected users, regulators, and other relevant parties as required by law.
8. Automated Processing and AI Decision-Making
The Service uses automated systems to perform functions including AI listening responses, session-topic identification, generation of Key Thoughts and Reflection Constellations, generation of Final Reflections, determination of whether a session is ready for reflection, identification of safety-risk signals, and display of crisis-support resources.
This automated processing is used only to provide the Service features you request and is not used to make decisions that produce legal or similarly significant effects concerning you. Where applicable law provides corresponding rights, you may request basic information about automated processing or object to certain profiling used to make significant decisions. Because AI-related features depend on automated processing, refusing such processing may prevent AI responses, session reflection, and safety-related features from functioning properly.
9. Your Privacy Rights
Depending on your location and applicable law, you may have some or all of the following rights:
1. Right to Know: You may request information about the categories of personal data we collect, sources of data, purposes of processing, retention periods, and recipients.
2. Right to Confirm and Access: You may ask us to confirm whether we process personal data about you and request access to data we actually hold. For Journal entries or sessions stored only on your device, we cannot access or provide copies through our servers; you can view that content directly in the App.
3. Right to a Copy and Data Portability: To the extent required by applicable law, you may request a copy of personal data we hold in a usable format. This right generally applies to information you provide and data collected by automated means, but may not apply to our trade secrets, data about other people, or data that exists only on your device.
4. Right to Correction: You may request correction of inaccurate personal data we hold, such as an email address or privacy-request information. AI-generated responses, topics, or reflection results are automated outputs. The right to correction does not necessarily require us to replace an AI output with wording you specify, but you may delete related content or submit new expression.
5. Right to Deletion: You may request deletion of personal data we control, subject to information that applicable law permits or requires us to retain. For on-device Journal data, you must use the App’s deletion function, device settings, or uninstall the App. Because we cannot access data stored only on your device, we cannot remotely delete or restore that content. We may retain information necessary to satisfy legal obligations, process transactions, resolve disputes, prevent fraud, maintain security, or demonstrate compliance.
6. Right to Restrict Processing: Where provided by applicable law, you may request temporary restriction of processing, for example while you dispute the accuracy of data or object to certain processing. Restricting processing may temporarily make some features unavailable.
7. Right to Object: If we process personal data based on legitimate interests, you may object based on your particular circumstances. We will stop the relevant processing unless we have compelling legitimate grounds that override your rights or the processing is necessary to establish, exercise, or defend legal claims.
8. Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time, for example by changing privacy choices in the App or contacting us to withdraw a specific authorization. Withdrawal does not affect the lawfulness of processing before withdrawal, but may prevent features that rely on the relevant data from continuing to function.
9. Right to Opt Out of Sale, Sharing, or Targeted Advertising: Where applicable law provides such rights, you may opt out of the sale or sharing of personal data or its use for targeted advertising. The current Service does not sell personal data and does not use private sessions or Journal entries for targeted advertising.
10. Right to Limit Use of Sensitive Data: Where applicable law provides such rights, you may request limits on certain uses of sensitive personal data or consumer health data. We already limit processing of such data to what is necessary for providing the Service, safety protection, and legal compliance. If you ask us to stop processing that is necessary for a feature, AI responses, reflection features, or safety-related functions may become unavailable.
11. Right to Object to Certain Profiling and Automated Decisions: If automated processing is used to make a decision that produces legal or similarly significant effects, you may have the right to opt out of that processing, request human review, or challenge the decision. The current Service does not use AI outputs to make such significant decisions.
12. Right to Appeal: If we deny your privacy request and applicable law provides a right to appeal, you may request that we review the decision. We will provide the result within the applicable period and, where required by law, explain how you may submit a complaint to a regulator.
13. Right to Non-Discrimination: We will not unlawfully deny services or reduce service quality because you exercise privacy rights available under applicable law. However, if a feature genuinely requires certain data, we may be unable to continue providing that feature. For example, refusing AI processing may prevent AI responses from being generated; deleting a session prevents restoration of that content; and deleting subscription-verification records may affect our ability to verify subscription benefits.
10. How to Submit a Privacy Request
You may submit a request through our privacy email at hello@withelira.com. To protect your personal data, we may ask you to provide reasonable information to verify your identity. Because the Service does not use a persistent user-account system, information available for identity verification may include the email address used to submit the request, device and App information, and other information reasonably related to the request.
We will not collect additional sensitive information unrelated to identity verification. If an authorized agent submits a request on your behalf, we may require valid proof of authorization and may contact you directly to verify the authenticity of that authorization. We will respond within 45 days after receiving a request. If an extension is necessary, we will notify you as required by law (typically for an additional 45 days).
11. Supplemental Terms for Specific Jurisdictions
11.1 California
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), California residents may have the right to: (1) know about personal information collected, used, and disclosed; (2) access and obtain a copy; (3) correct; (4) delete; (5) opt out of sale or sharing; (6) limit certain uses of sensitive personal information; and (7) be free from discrimination.
We do not sell personal information for money or other consideration, do not sell or share private sessions, Journal entries, or consumer health data, and do not offer financial-incentive programs in exchange for personal information.
11.2 Other U.S. States
Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, New Jersey, Delaware, and other applicable states may have rights under the laws of those states to access, correct, delete, or obtain copies of personal data; opt out of targeted advertising, data sales, or certain profiling; and appeal certain privacy decisions. Whether a particular right applies depends on whether the relevant law applies to the Service and to the particular processing activity.
11.3 European Economic Area, United Kingdom, and Switzerland
If the GDPR, UK GDPR, or Swiss data-protection law applies to you, you may exercise rights to access, correct, delete, restrict processing, object to processing, data portability, and withdrawal of consent. You may also lodge a complaint with the data-protection authority in your place of residence.
A list of supervisory authorities in the European Economic Area is available through the European Data Protection Board. UK residents may submit complaints to the UK Information Commissioner’s Office. If we transfer personal data to a country or region that has not received an adequacy determination, we will use appropriate transfer safeguards, which may include an adequacy decision where applicable and accompanying technical and organizational safeguards. You may contact us for information about the transfer safeguards applicable to your data.
11.4 Other Jurisdictions
Depending on your location, you may have rights under local law to access, correct, delete, withdraw consent, object to processing, restrict processing, obtain data portability, and submit complaints, including under Brazil’s General Data Protection Law (LGPD); applicable federal and provincial privacy laws in Canada; Australia’s Privacy Act; New Zealand’s Privacy Act; Japan’s Act on the Protection of Personal Information; South Korea’s Personal Information Protection Act; Singapore’s Personal Data Protection Act; and other applicable data-protection laws.
If this Policy conflicts with mandatory applicable law, the mandatory applicable law will control.
12. Children and Minors
Elira is available only to users who are at least 18 years of age and is not designed for children. We do not offer the Service to minors. If we inadvertently collect personal data from a minor, we will delete or restrict processing of that data in accordance with applicable law within 15 business days after we receive notice or otherwise discover the issue.
We do not knowingly sell or share personal data of minors under 16 years of age. If you believe a child has submitted personal data to us, please contact us at hello@withelira.com. After verification, we will delete or restrict processing of the relevant data in accordance with applicable law.
13. Third-Party Links and Crisis Resources
The Service may contain links to the Apple App Store, 911, 988, local crisis hotlines, or other third-party services. Those third parties independently determine how they process data and apply their own privacy policies and terms of service.
We recommend that you review the privacy policies of third-party services before using them. We will manage service providers that process data on our behalf in accordance with applicable law, but we do not control or assume responsibility for independent third-party services that you choose to access.
14. Changes to This Policy
We may update this Policy because of changes in product features, legal requirements, technical architecture, service providers, or our business. Material changes may be communicated through in-App notices or other appropriate means.
If a change involves new processing of sensitive data or consumer health data, cross-app tracking, targeted advertising, or another activity for which consent is required by law, we will obtain the required consent before implementing that processing.
15. How to Contact Us
If you have questions about this Policy or our processing of personal data, or if you wish to exercise your privacy rights, please contact us at: hello@withelira.com.