Elaia Privacy Policy
Version 2.0 of 24 October 2026
Previous version: July 31, 2026
1. General
1.1. This Policy explains what personal data is processed when you use the Elaia mobile app (listed in the App Store as "Elaia Mirror"), the web app at elaia.one and the website elaia.space (together, the "Service"), why, for how long, who receives it, and what rights you have.
1.2. Because the controller is established in Mexico, all processing of personal data in the Service is governed by Mexico's Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP, DOF 20 March 2025) and its implementing rules. For users located in the EU/EEA, the EU General Data Protection Regulation (GDPR) also applies.
1.3. The Service is a tool for self-observation and personal reflection. It does not provide medical care or psychological or psychotherapeutic services, does not diagnose, does not collect medical data, and does not replace a doctor or other professional. In a crisis, contact emergency services or a helpline: elaia.space/help.
1.4. At sign-up you accept the Terms of Use, confirm that you have read this Policy, and agree to your messages being sent to the AI provider (section 6). The Policy is information about processing, not a contract.
2. Data controller
2.1. The controller (responsable) is Margarita Khan (MARGARITA KHAN, as registered with the SAT), an individual carrying on business in Mexico (persona física con actividad empresarial), RFC: KAMA9406095F5.
Address (domicilio): Av. Aldea Zama, Manzana 1, Lote 10, Departamento I 301 N 2, Col. Aldea Zama, C.P. 77760, Tulum, Quintana Roo, México.
Phone: +52 984 203 7428.
2.2. The person responsible for personal data is Margarita Khan. Contact: margaritahan0@gmail.com, subject line "Personal data request".
3. Definitions
3.1. Personal data — any information relating to an identified or identifiable natural person.
3.2. Processing — any operation on personal data: collection, recording, organisation, accumulation, storage, adaptation (updating, alteration), retrieval, use, disclosure (making available, access), pseudonymisation, restriction, erasure or destruction.
3.3. Anonymisation — processing after which the data can no longer be attributed to an individual by any means reasonably likely to be used, including additional information held by us. Pseudonymisation — removing or replacing direct identifiers (name, email, account IDs). Pseudonymisation does not make data anonymous; pseudonymised data remains personal data.
3.4. Processor — a party that processes data on behalf of the controller under a contract (encargado under the LFPDPPP; processor under the GDPR).
3.5. International transfer — a transfer of personal data to another country.
3.6. User — a natural person with legal capacity aged 18 or over who uses the Service.
4. Data we process
4.1. Data you provide
| Category | Data | When |
|---|---|---|
| Account | email, name, password (stored only as a hash) | email sign-up |
| Profile | gender, age, country, preferred form of address | at sign-up: age to confirm 18+, gender to address you correctly, country for prices and taxes |
| Conversation | your messages, the Service's replies, saved fragments | when you use the chat |
| Voice | voice message recordings and their transcripts | when you send a voice message |
| Payment | billing country, customer and subscription IDs, subscription status. We never receive or store your card details | when you pay |
| Tax invoice (CFDI) | RFC, full name or legal name, tax regime, postal code, CFDI use | if you request a factura in Mexico |
| Partner programme | referral code | if you arrived via a partner link |
| Support | your correspondence with support by email (Gmail) or via our Telegram support bot | if you contact us |
4.2. Sign in with Apple or Google
Email (or Apple's private relay address), your account ID with the provider, and your name if the provider shares it.
4.3. Technical data
User ID, platform (web, iOS), usage events (analytics), IP address, browser and device type, cookies and local storage (web app), service logs. Analytics events record interface actions (for example, opening a screen, sending a message, purchasing) and do not contain message text, audio or transcripts.
4.4. If you write about how you feel
The Service does not ask for health information and is not intended for it. If you choose to write about your condition or wellbeing in the chat, that information is processed only to generate a reply and keep your conversation history. It is not used for anything else: not for analysis for other purposes, not for profiling, not for training models and not for advertising (section 9).
Please do not share information about other people that could identify them. If such information appears in a conversation, it is processed only to reply to you and is deleted with your history.
5. Purposes and legal bases
5.1. Purposes, data and legal bases:
| Purpose | Data | Type of purpose (Mexico) | Legal basis (EU — GDPR) |
|---|---|---|---|
| Sign-up, sign-in, account | account data, Apple/Google data, profile | primary | performance of contract (Terms of Use) |
| Chat: replies, history, saved fragments | conversation, profile | primary | performance of contract |
| Sending messages to the AI provider for replies and voice transcription | conversation, voice, name, gender | primary | performance of contract; checkbox at sign-up (section 6) |
| Showing helpline contacts when a message shows signs of a crisis (section 6.6) | text of the current message | primary | performance of contract; vital interests |
| Addressing you by name and with the right grammatical gender | name, gender | primary | performance of contract |
| Payments and subscription management | payment data | primary | performance of contract |
| Keeping payment and tax records | payment data, CFDI | primary | obligation under Mexican tax law; for the EU — legitimate interest (5.2) |
| Communication: password reset, renewal reminders, important notices, support replies | email, phone (if you gave it), correspondence | primary | performance of contract |
| Service security and abuse prevention | logs, tokens | primary | legitimate interest (5.2) |
| Legal compliance | data required by law | primary | legal obligation |
| Usage analytics | technical data, usage events and counters without text (section 9) | secondary | cookie consent in the web app; legitimate interest otherwise |
| Partner programme | referral code, partner-link cookie | secondary | cookie consent in the web app; legitimate interest otherwise |
5.2. Our legitimate interests (for EU users, GDPR Art. 6(1)(f)): protecting the Service and users from attacks and fraud; keeping payment records under Mexican tax law that binds us; understanding how the Service's features are used, without message text. You may object at any time to processing based on legitimate interest (section 12).
5.3. Primary and secondary purposes (Mexico). Primary purposes are necessary for the relationship between you and the controller (Art. 9 IV LFPDPPP). Secondary purposes are not needed to provide the Service. You can opt out of them at sign-up or at any time by emailing margaritahan0@gmail.com; opting out applies for the future and does not affect your access to the Service.
5.4. We do not send marketing emails. If we start, we will ask for separate consent.
6. Artificial intelligence
6.1. You are chatting with an artificial intelligence program, not a human. Replies are generated by a language model. Neither the author nor anyone else converses on behalf of the Service.
6.2. To generate a reply, the request is sent to OpenRouter, Inc. (USA), which routes it to the model provider (currently the Qwen model, developed by Alibaba Cloud). OpenRouter selects the specific provider and country of processing from providers that meet the conditions in 6.5; the current list is available on request. The request contains the current conversation, saved fragments where relevant, and the name (form of address) and gender from your profile so that the reply is phrased correctly. Your email, password, age, payment data and account identifiers are not sent. Messages are sent only after you consent at sign-up.
6.3. Voice messages are transcribed by a speech recognition model (currently Whisper, developed by OpenAI) via OpenRouter. The recording is sent only for transcription, and the terms in section 6.5 apply.
6.4. We do not use your messages, recordings, transcripts or other data to train or fine-tune AI models, and we do not share them with third parties for that purpose.
6.5. Requests are sent through OpenRouter with settings that route them only to providers whose published terms state that request data is not used for training. Providers may briefly retain request data for security, abuse prevention or legal compliance under their own terms. We review those terms when choosing a provider but do not control providers' internal processes.
6.6. Crisis messages. If a message shows signs of a crisis, self-harm or suicidal thoughts, the Service automatically recognises this while generating the reply and shows helpline contacts. This has no medical purpose, does not diagnose, does not build a user profile and can make mistakes. The Service does not monitor you continuously, does not contact emergency services and does not connect you with a human professional. We keep only a counter of such cases, without message text (9.3). How it works: elaia.space/safety.
6.7. Automated processing in the Service does not lead to decisions with legal or similarly significant effects on you (GDPR Art. 22).
6.8. Models and providers may change. If the provider or country of processing changes, we update the list in section 7 and notify users in advance (section 16).
7. Who receives your data
7.1. We do not sell personal data.
7.2. Processors — act on our instructions under a contract:
| Recipient | Country | Purpose | EU transfer mechanism |
|---|---|---|---|
| DigitalOcean, LLC | servers — Netherlands; company — USA | hosting the database, files and backups | EU-US Data Privacy Framework (DPF) |
| OpenRouter, Inc. | USA | routing requests to models: chat replies, speech transcription | EU Standard Contractual Clauses (SCC) |
| Model providers to which OpenRouter routes the request | USA and other countries | generating replies, transcribing speech | SCC within the OpenRouter agreement |
| Amplitude, Inc. | USA | usage analytics (secondary purpose; in the web app — with your consent) | DPF |
| Rewardful Inc. | USA | partner programme tracking: referral code, partner-link cookie, email and payment status to calculate partner commission (secondary purpose) | SCC (data processing agreement) |
| Google LLC (Gmail) | USA | our mailbox: support requests and replies | DPF |
| SendGrid (Twilio Inc.) | USA | password reset and notification emails | DPF |
7.3. Independent recipients — process data for their own services under their own privacy policies:
| Recipient | Country | What they receive and why |
|---|---|---|
| Apple (for the EU — Apple Distribution International Ltd, Ireland; otherwise — Apple Inc., USA) | Ireland / USA | App Store purchases, Sign in with Apple |
| Google LLC | USA | Sign in with Google |
| Stripe (Stripe group; for the Mexican account — Stripe Payments Mexico, S. de R.L. de C.V.) | USA / Mexico | web payments, fraud prevention |
| Telegram | UAE | support requests, if you write to our Telegram support bot |
| The partner whose link you used | — | the fact of sign-up and payment, never conversation content |
| Public authorities | — | only on a lawful request and within its scope |
7.4. We share data only with processors that are contractually required to protect it to the same or an equivalent standard as described in this Policy and to use it only to provide services to us.
7.5. Under Mexican law, the transfers in 7.3 are necessary for our contract with you or required by law, so your consent is not required (Art. 36 LFPDPPP). If your email or name is ever to be shared with a partner, we will ask for separate consent.
7.6. The website elaia.space does not use cookies, analytics or forms and does not collect personal data, except web server logs (IP address, request time), which are kept for up to 30 days.
8. International transfers
8.1. Data is stored on servers in the Netherlands (DigitalOcean) and transferred to the USA and the other countries listed in section 7.
8.2. For EU users, transfers to the USA rely on the European Commission adequacy decision on the EU-US Data Privacy Framework for certified recipients, and on EU Standard Contractual Clauses (Decision 2021/914) for the others, as shown in the table in 7.2. You can request a copy of the relevant safeguards at margaritahan0@gmail.com.
8.3. Under Mexican law, transfers to the processors in 7.2 do not require your consent; processors act on our behalf and on our instructions.
9. How message texts are used
9.1. The text of your messages and your voice recordings are used only to generate a reply and keep your conversation history for you.
9.2. They are not analysed for other purposes, not used to train AI models, not used for profiling or advertising, and not shared with anyone except the providers in section 6 that generate the reply.
9.3. For analytics and improving the Service we use only technical data and counters without text: the number and length of messages, which reply route was triggered (for example, showing helpline contacts), and usage events (section 4.3).
9.4. If we later add a way for you to share a specific reply with us, it will happen only when you choose to do so and with separate consent for that text.
10. Retention
10.1. Your account, profile and conversation history are kept while your account exists.
10.2. When you delete your account (Profile → Delete account), data is removed from the live database immediately, except records we must keep by law (10.3), which are blocked and deleted when that period ends. In backups, deleted data remains until the backups are overwritten on schedule: daily backups — up to 30 days; server snapshots — no longer than 90 days. Backups are not used to run the Service; if a backup has to be restored, deleted data is deleted again. We confirm deletion to your account email.
10.3. Payment and tax records (including CFDI) are kept as long as Mexican tax law requires: at least 5 years from the filing date of the related tax return, and longer where the law so provides. During this period the records are blocked and used only to meet tax obligations.
10.4. Service logs are kept for up to 30 days; analytics events for no more than 24 months.
10.5. Support correspondence (email, Telegram) is kept for 12 months after your last message.
10.6. Records of accepted documents and consents (document version, date, time, account ID) are kept while your account exists and, after deletion, for as long as needed to prove the acceptance or consent, but no longer than 5 years.
11. Security
11.1. Data is transmitted over HTTPS/TLS; passwords are stored only as hashes; access to servers and the database is restricted; backups are made daily; backups stored off the main server are encrypted.
11.2. We do not view users' conversations except where: (a) you ask us to when contacting support; (b) it is necessary to fix a technical fault affecting a specific conversation; or (c) the law requires it. Any such access is limited to what is necessary.
11.3. If a security breach significantly affects your rights, we will notify you without delay, together with steps you can take, and notify the supervisory authority where applicable law requires it.
12. Your rights
12.1. You have the right to:
- find out what data about you is processed and who receives it, including abroad (access);
- correct inaccurate or incomplete data;
- delete your account and data — in the app (Profile → Delete account) or on request;
- restrict processing (for example, while the accuracy of data is checked);
- object to processing, including processing based on legitimate interest and for secondary purposes;
- withdraw your consent to sending messages to the AI provider without deleting your account (12.4);
- receive your data in a machine-readable format (portability) — for data processed on the basis of consent or contract;
- not be subject to a decision based solely on automated processing that has legal or similarly significant effects on you;
- complain to a supervisory authority (12.5).
These rights are available to all users, wherever they live.
Right to object. You may object at any time to processing based on legitimate interest — write to margaritahan0@gmail.com.
12.2. How to make a request (including ARCO rights under Mexican law: access, rectification, cancellation, objection). Requests are handled by Margarita Khan, the person responsible for personal data: email margaritahan0@gmail.com, subject "Personal data request". Please include: your name and an email for the reply; which right you are exercising and for which data; for rectification, the changes required. We verify identity by a message from your account email or another reasonable method; a representative must provide proof of authority. Access is provided electronically (file by email). Requests are free of charge.
12.3. Response times:
- Mexico and the general time limit: decision within 20 business days of receipt; implementation within 15 business days after the reply; each period may be extended once by the same length, with reasons.
- EU: without undue delay and within one month of receipt; for complex or numerous requests, up to two further months, which we will tell you about within the first month, with reasons.
If more than one time limit applies to you, we follow the shortest.
12.4. Withdrawing consent. You can withdraw consent to sending messages to the AI provider in your profile settings or by emailing margaritahan0@gmail.com under 12.2. You do not need to delete your account. Without sending messages to the AI provider the Service cannot generate replies, so after you withdraw that consent the chat stops working; your history is deleted or kept until you delete it, as you choose. Processing under a withdrawn consent stops no later than 30 days after we receive the withdrawal, subject to 10.2. Withdrawal does not affect the lawfulness of processing before it.
12.5. Complaints:
- Mexico: to the Secretaría Anticorrupción y Buen Gobierno (Ministry of Anti-Corruption and Good Governance), through the rights protection procedure (procedimiento de protección de derechos), within 15 business days of receiving our reply or of the reply deadline expiring;
- EU: to the supervisory authority of the Member State of your habitual residence, place of work or place of the alleged infringement (list: edpb.europa.eu/about-edpb/about-edpb/members_en);
- in other countries — to the data protection authority or a court, where the law of your country so provides.
13. Cookies and local storage
13.1. Strictly necessary cookies and local storage (sign-in, language, settings) are used without consent, as the web app cannot work without them.
13.2. Analytics (Amplitude) and partner-tracking (Rewardful) cookies and identifiers in the web app at elaia.one are used only with your consent, which you give or refuse in the banner on your first visit and can change at any time via the "Cookie settings" link at the bottom of the page. They collect an identifier, usage events, IP address and device information for analytics and partner programme tracking.
13.3. The list of cookies and their lifetimes is shown in the "Cookie settings" window.
13.4. The mobile app stores sign-in tokens and settings on your device.
14. Microphone and voice messages
The microphone is used only after you allow it and only to record a voice message that you choose to send. You can revoke this permission in your device settings.
15. Minors
The Service is for people aged 18 or over. You confirm your age at sign-up. We do not knowingly collect data from anyone under 18; if we find such data, we close the account and delete the data.
16. Changes to this Policy
16.1. We may update this Policy. The new version is published in the Service and at elaia.space/privacy with its effective date.
16.2. We give advance notice of material changes (new purposes, new recipients or countries) by email or in the Service. Where new purposes or transfers require consent, we publish a new version and ask for your consent before such processing begins.
17. Contact
Margarita Khan (MARGARITA KHAN), persona física con actividad empresarial, RFC KAMA9406095F5
Address: Av. Aldea Zama, Manzana 1, Lote 10, Departamento I 301 N 2, Col. Aldea Zama, C.P. 77760, Tulum, Quintana Roo, México
Phone: +52 984 203 7428
Email: margaritahan0@gmail.com
Website: elaia.space
18. Languages
This Policy is published in Russian and English; a Spanish version is published separately. For users in Mexico, the Spanish text prevails. In case of any discrepancy, the interpretation more favourable to the user applies.