Privacy Policy

1. About this notice

Cognaris Ltd (“Cognaris”, “we”, “our” or “us”) provides RelateWise AI — an AI‑powered coaching and learning platform for people navigating relationships.

This Privacy Policy explains how and why we collect, use, share and safeguard your personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Who is the data controller?

3. What personal data do we collect?

• Account data: name, email, hashed password, subscription tier
• Profile data: relationship context, learning goals, language, time‑zone
• Content data: chat messages, uploaded files, coaching notes
• Usage data: page views, feature use, session duration
• Device data: IP address, browser type & version, operating system
• Payment data: last 4 digits of card, transaction ID, billing country (via Stripe / App Store / Google Play)
• Marketing preferences: opt‑in status, timestamps
• Support data: tickets, call recordings, chat transcripts

4. How and why do we use personal data?

We use your data only where a lawful basis applies:

• Contractual necessity – create your account, deliver content and provide support
• Legitimate interests – operate, improve and secure the Service (balanced against your rights)
• Consent – send marketing emails and enable optional features (you may withdraw at any time)
• Legal obligations – keep accounting records, detect fraud and comply with law‑enforcement requests

5. AI data processing

When you use RelateWise AI’s coaching features, your chat messages are sent to our AI provider (OpenAI) for processing. We do not use your conversations to train AI models. Your data is processed under our data processing agreement with OpenAI and is subject to their enterprise privacy commitments.

6. Cookies & analytics

We use essential cookies for security and sign‑in, analytics cookies to understand usage, and preference cookies to remember settings.

7. Sharing your data

We disclose data only to trusted processors under written agreement:

• Supabase (EU) – database hosting & authentication
• Vercel (EU/UK) – hosting & CDN
• OpenAI Ireland – AI processing of chat prompts
• Stripe Payments UK – payment processing
• RevenueCat – mobile in‑app purchase management
• MailerSend (EU) – transactional email
• Professional advisers & authorities where required by law

We never sell your personal data.

8. International transfers

Where data leaves the UK we rely on adequacy regulations or Standard Contractual Clauses plus technical safeguards such as encryption and access controls.

9. Data retention

• Account & profile: life of account → 24 months after closure
• Chat history: life of account → 12 months after closure
• Payments: 7 years (statutory)
• Support records: 3 years from resolution
• Marketing consents: until withdrawn + 6 months
• Back‑ups: auto‑purged after 35 days

10. Security measures

• TLS 1.3 encryption in transit; AES‑256 at rest
• MFA for staff and zero‑trust cloud perimeter
• Annual penetration tests & continuous vulnerability scanning
• Incident‑response plan with breach notification within 72 hours

11. Your rights

You can exercise the following rights free of charge:

• Access, rectification, erasure, restriction, portability, objection
• Withdraw consent
• Request human review of automated decisions

Email hello@cognaris.ai. We aim to respond within one month.

12. Marketing

We send marketing emails only if you opt‑in or under the PECR soft opt‑in. You can unsubscribe at any time from the email footer or by contacting us.

13. Changes to this notice

We will email or display an in‑app banner at least 14 days before material changes take effect. The version at /privacy is always current.

14. Contact

Data Protection Officer – hello@cognaris.ai

15. Complaints

If you are dissatisfied, please contact us first. You have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

ico.org.uk · 0303 123 1113 · Wycliffe House, Water Lane, Wilmslow, SK9 5AF