Polarity Plan™ Data Privacy Policy

Last updated: 2025-09-23

Polarity Plan, Inc respects your privacy and is committed to protecting your personal data. This policy explains what information we collect when you use the Polarity Plan™ app, why we collect it, how we use it, and your rights under the EU General Data Protection Regulation (GDPR) and other applicable regional data protection regulations.

Who We Are

• Controller: Polarity Plan, Inc, https://app.polarityplan.ai/
• Contact for privacy matters: privacy@polarityplan.com
• Data Protection Lead: Topher Hunt

What Data We Collect

• Name and email address (for account creation and secure login)
• Chatbot messages you write (core functionality of the app)
• IP address (recorded in system logs for security and troubleshooting)

Why We Collect Data (Lawful Basis)

• Contractual necessity: to provide you with the services you signed up for (e.g. enabling account login, chatbot interactions).
• Consent: for optional demographic questions, used to improve our research and services.
• Legitimate interest: to maintain security, prevent abuse, and debug our systems.

How We Use Your Data

• To deliver the services you request (chatbot interactions, coaching support).
• To communicate with you about your account.
• To improve our platforms and conduct research (when you have consented).
• To ensure the security and stability of our systems.

We do not sell or share your data with advertisers.

Where Your Data Is Stored

• We use secure, US-based cloud providers (e.g. Heroku, Mailgun, SolarWinds, OpenAI, Google).
• Transfers from the EU to the US are protected by the EU–US Data Privacy Framework or Standard Contractual Clauses.
• All data is encrypted in transit (TLS 1.2+) and at rest (AES-256 or equivalent).

How Long We Keep Your Data

• While your account is active.
• Deleted or anonymized within 12 months after account closure, or within 30 days of your written deletion request.
• Server logs (including IP addresses) are retained for up to 1 year.
• Staff/contractor records are kept as required by tax and compliance law.

Your Rights Under GDPR

You have the right to:

• Access your personal data
• Request corrections
• Request deletion (“right to be forgotten”)
• Restrict or object to processing
• Request a copy of your data in a portable format

To exercise these rights, contact us at privacy@polarityplan.com. We will respond within one month.

Data Security

We take appropriate technical and organizational measures to protect your data, including:

• Encryption in transit and at rest
• Role-based access control (only authorized staff can access data)
• SSO or MFA authentication for admin accounts
• Regular security reviews and incident response procedures

Changes to This Policy

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