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Privacy Policy

Surreal Coach App

Effective Date: 28th May 2026

Welcome to Surreal Coach App (“we,” “our,” “us”). We are a small, mission-driven startup building this App with care for the people who use it. We are committed to protecting your privacy and to handling your data with the minimum footprint possible.

For the purposes of UK GDPR and EU GDPR, Surreal Digital LTD (registered in England and Wales, with offices at 85 Great Portland Street, W1W 7LT, London, UK) is the data controller responsible for your personal data. You can contact us at surreal@surrealexperiments.com about anything in this policy.

We currently store some of the data you create in the App so that we can operate it and improve our coaches over time. We use this data only internally — we do not sell it, we do not share it with advertisers, and we do not use it to train any third-party AI model. You have the right to request deletion of your data at any time, and we will action that request within 30 days.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the “App”). Please read it carefully. If you do not agree with these terms, please do not use the App.

1. Information We Collect

We may collect information about you in various ways. The information we may collect via the App includes:

Personal Data: When you register with the App or use certain features, we may collect personally identifiable information, such as your name, email address, and other contact information.

Usage Data: We may automatically collect certain information when you access the App, including your device type, operating system, IP address, browsing actions, and product analytics events (which screens you visit, which features you use, error rates) so we can understand how the App is performing and where it needs improvement.

User-Generated Content: Any insights, content, or other materials you create or upload within the App.

2. How We Use Your Information

We use the information we collect only for the following internal purposes:

  • To provide, operate, and maintain the App
  • To improve our coaches and the quality of the insights they generate over time
  • To understand how the App is being used and identify bugs or quality issues
  • To send you push notifications about your sessions (which you can opt out of any time)
  • To process your transactions and manage your account
  • To meet legal, accounting, and security obligations

We do NOT:

  • Sell your personal information to any third party
  • Share your data with advertisers or for marketing by anyone other than us
  • Use your conversations, transcripts, or insights to train any third-party AI model
  • Use your data for any purpose unrelated to operating and improving the App

Access to your data inside the company is restricted to a small number of team members who need it to operate and improve the App.

3. Lawful Basis Under GDPR

Under UK GDPR and EU GDPR, we must tell you the lawful basis we rely on for each use of your personal data. Here’s the breakdown:

  • Running coaching sessions and delivering insights — Performance of a contract (Article 6(1)(b)). You ask us to coach you and we deliver the experience.
  • Account management and subscription billing — Performance of a contract (Article 6(1)(b)).
  • Improving our coaches and the AI insight quality — Our legitimate interests (Article 6(1)(f)). We only use pseudonymised or aggregated data for this purpose, never your identifying information.
  • Product analytics — understanding how the App is used and improving the experience — Our legitimate interests (Article 6(1)(f)). We use pseudonymous identifiers, not your name or email, for analytics events. You can opt out by contacting us at surreal@surrealexperiments.com.
  • Sending push notifications about your sessions — Your consent (Article 6(1)(a)), which you can withdraw at any time in the App settings or on your device.
  • Security, fraud prevention, and keeping the App running — Our legitimate interests (Article 6(1)(f)) in protecting our users and our service.
  • Meeting legal obligations (such as keeping payment records for tax purposes) — Legal obligation (Article 6(1)(c)).

We never sell your personal information. Your conversations and insights are confidential.

4. AI Analysis and Profiling

Your coach responses, transcripts, and after-session insights are generated by AI models (currently OpenAI). The insights summarise patterns from what you said during the session. This is a form of profiling under UK and EU GDPR: we use automated processing to surface personal patterns and produce a personalised reflection.

We do not use this profiling to make decisions that produce legal or similarly significant effects about you. The insights are reflective tools for personal insight only. They are not clinical diagnoses, they do not constitute mental health treatment, and they do not determine your access to services, employment, credit, insurance, or anything else.

You have the right to object to this profiling at any time. If you’d prefer not to receive AI-generated insights, contact us at surreal@surrealexperiments.com and we’ll stop generating insights for your future sessions and delete any already generated.

5. Sensitive Information

Our coaches will explore emotions, patterns, and decisions with you. Please use your judgment about what you share. We do not ask about, and we do not want to collect, special-category data under GDPR — including information about your physical or mental health diagnoses, racial or ethnic origin, religious or political beliefs, sexual orientation, trade union membership, or biometric identifiers.

If you do share such information in a session (it’s a coaching app — we understand this happens), you can ask us to delete that specific session, or your entire account, at any time. See Section 8 for how to request deletion.

6. Disclosure of Your Information

We may share your information in the following situations:

With Service Providers: We may share your information with third-party vendors and service providers that perform services on our behalf.

For Legal Purposes: We may disclose your information if required by law or in response to valid requests by public authorities.

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.

With Your Consent: We may disclose your personal information for any other purpose with your consent.

7. Security of Your Information

We use administrative, technical, and physical security measures to protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

8. Your Data Protection Rights (including GDPR)

You have the following rights regarding your personal information, regardless of where you live. If you are in the UK or EEA, these rights are guaranteed under the General Data Protection Regulation (GDPR). If you are in California, equivalent rights are guaranteed under the CCPA.

  • The right to deletion – You may request that we permanently delete your account and all associated data at any time. We will action this request within 30 days. To request deletion, email surreal@surrealexperiments.com with the subject line “Delete my data”, or use the in-app “Delete Account” button in Settings.
  • The right to access – You can request a copy of the personal data we hold about you.
  • The right to rectification – You can request that we correct any information you believe is inaccurate.
  • The right to restrict processing – You can request that we limit how we use your data.
  • The right to data portability – You can request that we transfer your data to you or to another service in a structured, machine-readable format.
  • The right to object – You can object to certain uses of your data.

We will not charge you for exercising these rights and will not discriminate against you for doing so.

If you believe we’ve mishandled your data, you have the right to complain to a data protection authority. In the UK, that’s the Information Commissioner’s Office (ICO) at ico.org.uk. If you’re in the EU, you can contact your local supervisory authority. We’d appreciate the chance to address your concern directly first — please email us before escalating if you can.

9. Children’s Privacy

Surreal Coach is not intended for users under the age of 18. The App explores emotional and reflective material that requires adult judgment. We do not knowingly collect personally identifiable information from users under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at surreal@surrealexperiments.com and we will delete the account and all associated data.

10. Sub-processors and Third-Party Services

We use the following processors to operate the App. Each processes data on our instructions under a data processing agreement:

  • Vapi (United States) — Orchestrates voice calls, routes audio between the transcriber, model, and voice provider, and temporarily holds session state during the call. Vapi does not retain audio after the session ends.
  • OpenAI (United States) — Powers the AI coaches (gpt-4o-mini / gpt-4o) and the routing classifier. OpenAI processes API data on our instructions and does not train its models on customer API data.
  • Deepgram (United States) — Speech-to-text transcription for voice sessions. Zero audio retention enabled — no audio is stored by Deepgram.
  • Voice synthesis (varies by coach) — Vapi, Cartesia, or OpenAI provide text-to-speech depending on which coach you selected. None of these providers retain your generated audio for training.
  • Supabase (EU, Ireland) — Secure database storage of your conversations, insights, and account data. Our database is hosted in the EU.
  • Apple StoreKit — Payment processing for subscriptions. We do not see or store your card details; Apple handles all payment information.
  • Mixpanel (United States) — Product analytics. Receives pseudonymous event data about how you use the App (which screens you visit, which features you tap, error events) so we can identify bugs and improve the experience. We do not send your conversation content, transcripts, or insights to Mixpanel. When you delete your account, we also instruct Mixpanel to delete the associated event history.

If you’d like a copy of the specific data processing agreement we have with a particular processor, contact us at surreal@surrealexperiments.com.

11. International Data Transfers

Some of the processors above (Vapi, OpenAI, Deepgram, Apple, Mixpanel) are based outside the UK and the EEA, primarily in the United States. When we transfer your personal data outside the UK or EEA, we rely on appropriate safeguards as required by UK GDPR and EU GDPR:

  • UK International Data Transfer Agreements (IDTAs) and the UK Addendum to the EU Standard Contractual Clauses (SCCs), where the recipient has signed them with us.
  • EU Standard Contractual Clauses (SCCs) for EU-origin data, where applicable.
  • The UK-US Data Bridge and EU-US Data Privacy Framework, for recipients certified under those schemes.

If you’d like a copy of the specific safeguard for a particular transfer, contact us and we’ll share it.

12. Data Retention

We keep your data only as long as we have a reason to. Specific retention periods:

  • Session transcripts and insights: kept while your account is active, then deleted within 24 months of account closure or your last login.
  • Account email and profile: kept while your account is active, then deleted after 36 months of inactivity.
  • Payment records (Apple receipts and tax records): kept for 7 years from the transaction date, as required by UK tax law.
  • Support correspondence: kept for 36 months from your last contact.
  • Authentication and security logs: kept for 12 months.
  • Coach routing logs (your inputs to “What’s on your mind?”): kept while your account is active, deleted with your account.

You can ask us to delete your data sooner at any time (see Section 8).

13. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

  • The right to know what personal information we collect, use, disclose, and sell
  • The right to request deletion of your personal information
  • The right to opt-out of the sale of your personal information
  • The right to non-discrimination for exercising your privacy rights

14. Push Notifications

We may send you push notifications through the App. You can opt out of receiving these notifications by changing your notification settings on your device or within the App settings.

15. Location Information

We may request access to your device’s location information to provide location-based features. You can disable location services in your device settings, but this may limit certain App functionality.

16. Our Commitment to Minimal Data

Surreal Coach is built by a small team that believes coaching should be a private, intimate experience. We currently store your conversations, insights, and account information on Supabase (a database service hosted in the EU) so that we can:

  • show your past sessions back to you in the App, and
  • improve our coaches over time based on patterns we see across the user base.

We treat this data with care: access is restricted to a small number of team members, all communication with our database is encrypted in transit, and we never share your individual conversations outside the company.

Our intent is to need less of your data over time, not more. As we grow, we are actively exploring architectures that would let us deliver the same coaching experience while storing less — or eventually none — of your data on our servers. This is an aspiration we are working toward, not a current guarantee. We will update this Privacy Policy as those changes ship.

If at any point you no longer want us to hold your data, see Section 8 to request deletion.

17. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Effective Date” at the top. You are advised to review this Privacy Policy periodically for any changes.

18. Do Not Track Signals

We do not currently respond to Do Not Track (DNT) browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

19. Contact Us

If you have questions or comments about this Privacy Policy, or want to request deletion of your data, please contact us at:

Surreal Coach App
Email: surreal@surrealexperiments.com
Address: Surreal Digital LTD, First Floor, 85 Great Portland Street, W1W 7LT, London, UK

20. Acceptance of This Policy

By using the App, you signify your acceptance of this Privacy Policy. If you do not agree to this policy, please do not use our App. Your continued use of the App following the posting of changes to this policy will be deemed your acceptance of those changes.

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