Privacy Policy

1. Introduction

Labrax Technologies Limited ("we", "us", "our") operates the Eolas mobile application ("the App"), an AI-powered coaching platform available on iOS and Android. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our App.

We are committed to protecting your privacy in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Irish Data Protection Act 2018, and other applicable data protection laws.

2. Data Controller

The data controller for the purposes of GDPR is:

3. Data We Collect

3.1 Account Information

When you create an account, we collect:

• Email address — used for authentication and account communications
• Display name — your chosen name shown within the App
• Profile avatar — your optional profile image, stored in Firebase Cloud Storage
• Authentication method — whether you signed up via email/password, Apple Sign-In, or Google Sign-In
• Platform — whether you use iOS or Android

3.2 Coaching Data

When you use the App's coaching features, we collect:

• Conversation messages — text messages exchanged between you and AI coaches
• Audio recordings — voice messages you record during coaching sessions, which are transcribed and stored
• Goals — goals you create, their status (active, completed, abandoned), and associated coach
• Coach preferences — which coaches you interact with and your selected coaching team

3.3 Usage & Engagement Data

We collect data about how you use the App:

• Engagement metrics — streaks, session frequency, messages sent
• App version — the version of the App you are running
• Onboarding progress — completion status of onboarding steps
• Feature usage — which features you access (e.g. voice chat, weekly reflections, goal tracking)

3.4 Analytics Events

We collect approximately 30 analytics events covering:

• Authentication actions (sign-up, login, logout, password reset)
• Onboarding progress (steps completed, coaches selected, goals set)
• Chat interactions (messages sent, voice usage, coach switches)
• Goal management (creation, completion, abandonment)
• Subscription events (paywall views, purchases, cancellations)
• Premium feature engagement (reflections views, cross-coach insights)

Analytics collection is disabled in development environments. In production, events are collected via Firebase Analytics (see Section 5.1).

3.5 Subscription & Payment Data

• Subscription tier — free or premium
• Subscription status — active, expired, trial period, renewal status
• Expiration date — when your current subscription period ends
• Product identifier — which subscription product you purchased

We do not collect or store your payment card details, bank account information, or other financial data. All payment processing is handled by Apple (App Store) or Google (Google Play) via RevenueCat (see Section 5.5).

3.6 Device & Technical Data

• Push notification tokens — Firebase Cloud Messaging (FCM) tokens for delivering notifications
• Platform identifiers — device platform information used for app functionality

3.7 Preferences

• Voice settings — auto-play voice toggle, preferred voice interactions
• Notification preferences — your notification opt-in/out choices
• Display preferences — dark mode setting
• Cross-coach insights — whether you allow coaches to share context about your progress with each other

4. Lawful Bases for Processing

Under GDPR, we process your personal data on the following lawful bases:

5. Third-Party Services & International Data Transfers

We use the following third-party services to operate the App. Where these services involve transferring your data outside the European Economic Area (EEA), we rely on appropriate safeguards as described below.

5.1 Firebase (Google LLC) — United States

• Services used: Firebase Authentication, Cloud Firestore (database), Cloud Storage (file storage), Cloud Messaging (push notifications), Firebase Analytics
• Data shared: Account information, coaching data, goals, engagement data, push tokens, analytics events
• Transfer mechanism: EU Standard Contractual Clauses (SCCs) as adopted by Google
• Privacy policy: firebase.google.com/support/privacy

5.2 Anthropic (Anthropic PBC) — United States

• Service used: Claude API for AI coaching conversations
• Data shared: Your conversation messages and contextual information (e.g. goals, coach system prompts) are sent to the Anthropic API to generate coaching responses
• Transfer mechanism: Standard Contractual Clauses (SCCs)
• Privacy policy: anthropic.com/privacy

5.3 ElevenLabs (ElevenLabs Inc.) — United States

• Service used: Text-to-speech voice generation for coach responses
• Data shared: Coach response text is sent to ElevenLabs to generate audio
• Note: Your personal messages are not sent to ElevenLabs; only the AI-generated coach response text is transmitted
• Transfer mechanism: Standard Contractual Clauses (SCCs)
• Privacy policy: elevenlabs.io/privacy

5.4 RevenueCat (RevenueCat Inc.) — United States

• Service used: Subscription and in-app purchase management
• Data shared: Anonymous user identifier, subscription status, purchase history
• Transfer mechanism: Standard Contractual Clauses (SCCs)
• Privacy policy: revenuecat.com/privacy

5.5 Apple / Google — United States

• Services used: Apple Sign-In, Google Sign-In (authentication); App Store / Google Play (in-app purchases)
• Data shared: Authentication tokens, purchase transactions
• Note: Payment processing is handled entirely by Apple/Google; we do not receive your payment details
• Transfer mechanism: EU-U.S. Data Privacy Framework (Apple, Google)

6. How We Use Your Data

We use your data for the following purposes:

1. Providing the coaching service — delivering AI coaching conversations, generating voice responses, tracking your goals and progress
2. Account management — authenticating you, managing your profile and preferences
3. Subscription management — verifying your subscription tier, unlocking premium features (all 15 coaches, unlimited messages, weekly reflections, cross-coach insights)
4. Notifications — sending push notifications about coaching reminders and updates (with your consent)
5. Improving the App — analysing usage patterns to improve features, fix issues, and enhance user experience
6. Security — protecting against unauthorised access, fraud, and abuse

7. Data Retention

• Account and coaching data is retained for as long as your account is active.
• Conversation messages are compressed after approximately 40 messages per conversation to manage storage, but earlier messages may be summarised rather than deleted.
• Audio recordings are stored in Firebase Cloud Storage for the duration of your account.
• Analytics data is retained in accordance with Firebase Analytics' default retention periods.
• Upon account deletion, all your data is permanently removed (see Section 9.2).

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption in transit — all data transmitted between the App and our servers uses TLS encryption
• Authentication tokens — Firebase Auth tokens secure all API requests
• Signed URLs — temporary, signed URLs are used for accessing stored files (e.g. audio, avatars)
• Cloud Functions — server-side operations run in secure Firebase Cloud Functions environments
• Access controls — Firestore security rules restrict data access to authenticated users accessing their own data

9. Your Rights Under GDPR

As an EEA data subject, you have the following rights:

9.1 Right of Access (Art. 15)

You may request a copy of the personal data we hold about you. Contact us at ash@labraxtech.com.

9.2 Right to Erasure / Account Deletion (Art. 17)

You can delete your account directly from the App:

1. Go to Profile > Delete Account
2. Confirm your identity (password required for email accounts)
3. All your data is permanently and irreversibly deleted, including:
   • Your authentication account
   • All conversations and messages
   • All goals and progress data
   • Your profile information and preferences
   • Audio recordings and uploaded files
   • Subscription association (note: active subscriptions should be cancelled via App Store/Google Play before deletion)

This deletion is performed by a server-side Cloud Function that removes all associated data.

9.3 Right to Rectification (Art. 16)

You can update your display name, email, and password directly in the App's Profile settings. For other corrections, contact us at ash@labraxtech.com.

9.4 Right to Data Portability (Art. 20)

You may request a machine-readable export of your personal data. Contact us at ash@labraxtech.com.

9.5 Right to Restrict Processing (Art. 18)

You may request that we restrict the processing of your data in certain circumstances. Contact us at ash@labraxtech.com.

9.6 Right to Object (Art. 21)

You have the right to object to processing based on legitimate interests (e.g. analytics). Contact us at ash@labraxtech.com.

9.7 Right to Withdraw Consent (Art. 7)

Where processing is based on consent (e.g. voice features, push notifications), you may withdraw consent at any time:

• Voice features — simply stop using voice messaging
• Push notifications — disable in your device settings or the App's notification preferences
• Cross-coach insights — toggle off in Profile settings

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

9.8 Right to Lodge a Complaint

If you are not satisfied with how we handle your data, you have the right to lodge a complaint with:

You may also lodge a complaint with your local supervisory authority if you are based in another EEA member state.

10. Children's Privacy

The App is not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have collected data from a child under 13, we will take steps to delete that data promptly.

If you are between 13 and 16 years of age (or the applicable age of digital consent in your country), you may need parental or guardian consent to use the App, in accordance with GDPR Article 8.

11. Automated Decision-Making

The App uses AI (Anthropic's Claude) to generate coaching responses. These responses are generated automatically based on your conversation history, goals, and coach configuration. This automated processing:

• Does not produce legal or similarly significant effects on you
• Is part of the core service you have agreed to use
• Can be reviewed or overridden — you can disregard any coaching suggestion

The AI coaching is not a substitute for professional advice in areas including but not limited to mental health, medical, financial, or legal matters.

12. Cookies and Tracking

The App is a native mobile application and does not use cookies. Analytics are collected via Firebase Analytics as described in Section 3.4.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Updating the "Last Updated" date at the top of this policy
• Providing in-app notification for significant changes

We encourage you to review this policy periodically. Continued use of the App after changes constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, contact us at:

For data protection enquiries, please include "Data Protection" in your subject line.