Noah AI : Your Emotional Coach

I. INTRODUCTION & OVERVIEW

FEELGOOD LABS PTE. LTD. ("us," "we," or "our") is deeply committed to protecting and respecting your privacy when you use our website, www.heynoah.ai (the "Website"), our applications ("Apps"), and other related products, services, and features (collectively, the "Products" or "Services"). This Privacy Policy explains in detail how we collect, use, store, process, and protect your information.

By accessing, downloading, installing, or using our Products, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. Given the sensitive nature of emotional wellness data and the artificial intelligence (AI) component of Noah AI, we want to ensure you are fully informed about our data practices.

Who We Are (Data Controller): FEELGOOD LABS PTE. LTD. is a company incorporated under the laws of Singapore, and we are the data controller responsible for the processing of your personal data under this Privacy Policy.

Scope of This Policy: This Privacy Policy applies to all information collected through your use of our Website, our App (including the Noah AI emotional wellness coach), and any other related products, services, and features that link to or expressly reference this policy.

For any privacy-related questions or concerns, please contact us at sophia@heynoah.ai.

II. INFORMATION WE COLLECT

We collect various categories of information from you to provide, maintain, and improve our Service.

A. Information You Provide Directly:

Account Registration Data: During registration, we primarily collect your phone number for account creation, secure login via One-Time Password (OTP), and account-related communications. You may also create a nickname, responses to standardized questionnaires (like PHQ4, GAD 7 or PHQ9) for personalization within the app. We explicitly state that we do not collect other personal identifiers for account creation, such as your full name, physical address, date of birth, or email address.
Interactions with Noah AI (User Content): When you interact with Noah AI, our AI-powered emotional support companion, through text or voice, we collect your conversational data, which includes:
- Text chat transcripts.
- Transcriptions of voice interactions.
  This data is collected and securely stored to provide the core Service.
Optional Profile Information: You may choose to provide additional information to personalize your experience, such as specific emotional wellness goals or preferences.
Correspondence and Support: When you contact us for customer service, technical support, or submit feedback, we collect the content of your communications and any information you provide relating to your inquiry.
Payment Information: For in-app purchases, payment transactions are handled securely by Apple (App Store) and Google (Google Play Store) via their respective platforms. For website-based transactions, our third-party payment processor collects and processes payment details. FEELGOOD LABS PTE. LTD. does not collect, store, or process your credit or debit card information or other sensitive payment data directly on our servers. We only receive transaction confirmation details from these payment processors.

B. Information Collected Automatically:

When you access and use Noah AI, certain information is automatically collected through tracking technologies.

Usage Data: We collect information about how you interact with the Service, including the features you use, the duration of your sessions, the frequency of your use, and the content you view or engage with. This helps us understand user behavior and preferences.
Device Information: We collect data about the device you use to access Noah AI, such as your operating system version, device type, unique device identifiers, and system performance data.
Limited Location Information: We track the country of our users based on the phone number extension used during registration or IP address. We do not track your precise geographical location.
Technical Log Data: As with most websites and applications, we gather certain data and store it in log files. This may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We also collect error reports and crash data.
Mobile Analytics Data: We use mobile analytics software to better understand the functionality of our mobile software on your phone, including how often you engage with the Products, events that occur within the Products, and aggregated usage and performance data. We may link this data to any personal data you submit within the mobile application.

C. Information from Third Parties:

App Store Providers: We receive basic transaction confirmation details and certain account information from Apple (App Store) and Google (Google Play Store) related to your subscriptions and use of the App.
Social Media Services: If you choose to connect your Noah AI account with your social media accounts (e.g., Facebook, Google for account creation), we may access certain personal information that your privacy settings on those services allow us to access, such as your name and email address. Your interactions with social media features are governed by the privacy statement of the company providing them.
Payment Processors: As mentioned above, we receive confirmation details, but not sensitive payment data, from our third-party payment processors.

III. HOW WE USE YOUR INFORMATION (PURPOSE LIMITATION & LAWFUL BASIS)

We use the collected information for the following specific purposes, based on appropriate legal bases as required by global data protection regulations (e.g., GDPR Article 6).

A. To Provide and Maintain the Service (Performance of Contract / Legitimate Interest):

To deliver Noah AI's core functionality, including processing your conversational inputs to generate relevant AI Output.
To manage your account, subscriptions, and access to the Service.
To ensure the Service operates correctly and efficiently across various devices and platforms.
To answer your questions or requests for information or handle your complaints and provide customer support.
To carry out our obligations arising from any agreements between you and us.
To allow you to participate in interactive features of the Products when you choose to do so.

B. For Product Improvement and AI Model Training (Legitimate Interest / Consent):

To continuously train, refine, and improve the accuracy, safety, and performance of Noah AI's underlying models and algorithms, as well as other FEELGOOD LABS products and services.
For this purpose, we primarily use aggregated and de-identified User Content and interaction data. We employ robust anonymization and de-identification techniques to ensure that data used for AI training does not directly identify you and cannot be reasonably reconstructed to identify you as an individual.
To analyze emotional states and offer customized recommendations to enhance the personalized and effective emotional well-being support provided by Noah AI.
To conduct research (using anonymized data only) to study mental and emotional health trends while ensuring user privacy.

C. For Communication (Legitimate Interest / Consent):

To send you important service-related notices (e.g., updates, security alerts, changes to Product features and content).
To provide promotional communications, such as email newsletters and push notifications, where you have provided consent. You can opt-out of email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at sophia@heynoah.ai. Push notifications can be managed at the device level.
To provide you with the SMS Service (if you have provided consent for receiving SMS messages).
If you are an existing customer, we may contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you, except if you opt-out of such communications.
To notify you about updates or changes to Product features and content.
To request that you participate in Product surveys to better understand your needs and expectations.

D. For Safety, Security, and Fraud Prevention (Legitimate Interest / Legal Obligation):

To monitor for and prevent fraudulent or unauthorized activity, and to detect and address security incidents.
To enforce our Terms and Conditions and other policies.
To protect the rights, property, or safety of FEELGOOD LABS PTE. LTD., our customers, or others.
To protect against unplanned downtime or errors in the Products.

E. For Analytics and Research (Legitimate Interest):

To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state, or country).
To understand how people are using the Products, including via mobile analytics software and log files, to improve our user experience and ensure content is presented effectively.
To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Website.
To measure advertising effectiveness and to serve our advertisements to you through third-party platforms (like Facebook or Google) on other sites and apps, or across your devices, to the extent that you have provided consent for such uses under applicable law.

F. For Legal and Regulatory Compliance (Legal Obligation):

To comply with our legal obligations, such as maintaining accurate financial records, responding to legal requests (e.g., court orders, subpoenas, bankruptcy proceedings), and cooperating with law enforcement authorities.

G. In Connection with Business Transfers (Legitimate Interest):

In the event of a merger, acquisition, asset sale, or similar transaction, your data may be transferred to the prospective seller or buyer of such business or assets as part of due diligence or the transaction itself.

IV. HOW WE SHARE YOUR INFORMATION (RECIPIENTS)

We are committed to protecting your privacy. FEELGOOD LABS PTE. LTD. DOES NOT SELL YOUR PERSONAL DATA, INCLUDING SENSITIVE USER CONTENT, TO THIRD PARTIES FOR ADVERTISING, MARKETING, OR OTHER COMMERCIAL PURPOSES.

We may disclose or share your data in the following limited circumstances:

A. Within Our Corporate Group:
* We may disclose your data to any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries, where necessary for operational purposes and service provision.

B. With Service Providers:
* We engage trusted third-party service providers who perform functions on our behalf and help us operate, provide, and improve the Service. These may include providers for:
* Cloud hosting and infrastructure (e.g., secure servers in Singapore).
* IT maintenance and support.
* Payment processing (as detailed in Section II.A).
* Analytics and advertising partners (for aggregated, de-identified data or with your explicit consent where required for advertising purposes).
* Customer support platforms.
* We require all service providers to agree to maintain the confidentiality and security of your data and to process it only for specified purposes and in accordance with our instructions and applicable laws.

C. With Your Consent:
* In some circumstances, based on your specific requests or explicit consent, we may need to disclose your data to a third party to enable them to provide a service you have requested (e.g., if we were to offer an integrated SMS service and you explicitly consented to share your phone number for that purpose).
* We may also disclose data to third parties that offer and provide goods or services complementary to our own, where you have provided explicit consent for such practices.

D. For Legal and Compliance Reasons:
* We may disclose your data if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation (e.g., in response to a subpoena, court order, or other legal process).
* To protect the rights, property, or safety of FEELGOOD LABS PTE. LTD., our customers, or others, including exchanging data with other companies and organizations for fraud protection and credit risk reduction.

E. In Connection with Business Transfers:
* If FEELGOOD LABS PTE. LTD. sells or buys any business or assets, or if substantially all of our assets are acquired by a third party, your personal data held by us about our customers may be one of the transferred assets.

F. Data Not Shared:
* We do not share your raw conversational data or other sensitive User Content with any third party for any purpose other than to provide and improve the Noah AI service (via anonymization/de-identification for AI model enhancement) or as explicitly permitted by your direct consent.

V. DATA RETENTION

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, and to comply with our legal obligations.

Account Data: Your account data will be retained until you choose to delete your account. If you delete your account, all associated data is permanently removed from our servers, except for aggregated and anonymized data used for AI improvement.
Conversational Data (User Content): Your conversational data is retained until you choose to delete it. We do not automatically erase this data unless you take action (e.g., clearing chat history or deleting your account).
Transactional Data: Data relating to your purchases and financial transactions is kept for the entire period of the contractual relationship and then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is not stored by FEELGOOD LABS PTE. LTD.
Marketing Communication Data: Data collected based on your consent to receive marketing communications will be used until you withdraw consent or applicable law requires that such data is no longer used.
Requests/Queries Data: Data collected in the context of requests or queries is kept for the period necessary to process and reply to such requests or queries.
Cookies and Tracking Data: When cookies or other trackers are placed on your terminal, they are kept for a period of up to 12 months, or as otherwise specified in our Cookie Policy.
Other Data: Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.

VI. DATA SECURITY

We prioritize the security of your information and follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and after we receive it.

Encryption: All user conversations are encrypted, including End-to-End Encryption where technically feasible, for maximum privacy. Payment transactions are encrypted using SSL technology.
De-identification and Anonymization: We implement de-identification and anonymization techniques to ensure that your data, especially conversational data, remains anonymous where used for AI model enhancement, ensuring it cannot be reconstructed to identify you as an individual.
Secure Storage: Conversational data is stored using unique User IDs (randomly generated identifiers) instead of personal details. All data is stored on our secure servers located in Singapore.
Limited Access: We employ strict access controls, ensuring that only authorized employees and third-party vendors with a legitimate business need have access to user data. Any analysis of sensitive data is primarily conducted on aggregated and anonymized data.
Transcription on User Device: For voice interactions, transcription typically occurs on your device, meaning the raw audio is generally never stored on our servers.
HIPAA Compliance: We follow Health Insurance Portability and Accountability Act (HIPAA) standards where applicable to protect your health information.

Acknowledgement of Inherent Risks: While we implement commercially reasonable security measures to protect your data, you acknowledge that no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Therefore, we cannot guarantee the absolute security of any information you transmit to or receive from Noah AI, and you do so at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

VII. YOUR DATA PROTECTION RIGHTS

As required under applicable data protection laws, including the Singapore PDPA, EU GDPR, and other relevant global regulations, you have certain rights concerning your personal data. We are committed to helping you exercise these rights.

Right to Access: You have the right to obtain confirmation as to whether personal data concerning you are processed and, if processed, to obtain access to such data and a copy thereof.
Right to Rectification/Correction: You have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to Erasure ("Right to be Forgotten"): In some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, FEELGOOD LABS PTE. LTD. will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and FEELGOOD LABS PTE. LTD. may have legal or legitimate grounds for keeping certain data.
Right to Restriction of Processing: In some cases, you have the right to obtain restriction of the processing of your personal data.
Right to Data Portability: You have the right to receive the personal data concerning you which you have provided to FEELGOOD LABS PTE. LTD. in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from FEELGOOD LABS PTE. LTD. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
Right to Object to Processing: You have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of FEELGOOD LABS PTE. LTD. FEELGOOD LABS PTE. LTD. may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by mailing us at sophia@heynoah.ai.
Right to Lodge a Complaint: You have the right to contact the competent supervisory authority (e.g., the Personal Data Protection Commission (PDPC) in Singapore, or the relevant Data Protection Authority in your jurisdiction) to complain about FEELGOOD LABS PTE. LTD.'s personal data protection practices.
Right to Give Instructions Concerning the Use of Your Data After Your Death: As required by applicable law, you may have the right to give FEELGOOD LABS PTE. LTD. instructions concerning the use of your personal data after your death.

How to Exercise Your Rights: To exercise one or more of these rights, you can email sophia@heynoah.ai. You may also access your data to modify or update it at any time by emailing sophia@heynoah.ai. We will respond to your request in a reasonable timeframe by applicable law and subject to identity verification.

VIII. INTERNATIONAL DATA TRANSFERS

You agree that all Personal Information collected via or by FEELGOOD LABS PTE. LTD. may be transferred, processed, and stored anywhere in the world, including but not limited to, Singapore, the United States, and the European Union. This transfer may occur on our servers, on the servers of our affiliates, or the servers of our service providers.

Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request in the jurisdictions where the data is processed or stored. By providing information to FEELGOOD LABS PTE. LTD., you explicitly consent to the storage and processing of your Personal Information in these locations and acknowledge the potential for access by local authorities as described.

When transferring data outside of your country of residence, we implement appropriate safeguards to ensure that your personal data receives a level of protection consistent with applicable laws. These safeguards may include reliance on adequacy decisions, standard contractual clauses, or other legally recognized transfer mechanisms.

IX. CHILDREN'S PRIVACY

Noah AI is generally intended for individuals who are at least eighteen (18) years of age or the age of legal majority in their jurisdiction of residence. Individuals under the age of eighteen (18), or the applicable age of majority, may utilize the Products only with the involvement and consent of a parent or legal guardian, under such a person's account, as explicitly stated in our Terms and Conditions.

If we become aware that we have collected personal data from a child under the age of 18 without verifiable parental consent, we will take reasonable steps to delete it as quickly as possible. If you believe that we might have any information from or about a child under this age, please contact us at sophia@heynoah.ai.

X. COOKIES AND OTHER TRACKING TECHNOLOGIES

FEELGOOD LABS PTE. LTD. and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable service functionality and improve user experience.

What are Cookies: Cookies are small data files placed on your device. We also use local storage, such as HTML5, to store content data and preferences.
How We Use Them:
- Functionality: To recognize your device so you don't have to provide the same data multiple times, to recognize that you may have already given a username and password, and to store your preferences.
- Analytics: To measure how people are using the Products, gather statistical data (e.g., number of visitors, usage volumes), and understand user behavior to optimize content and services. We use Google Analytics for these purposes.
- Advertising: We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms and across your other devices based on your past visits to our Website. Our third-party partners may use technologies such as cookies to gather data about your activities within the Products to deliver such advertising to you, such as retargeting ads.
- Log Files: We gather certain data and store it in log files, including IP addresses, browser type, ISP, referring/exit pages, OS, and clickstream data, which helps us understand user popularity and make decisions about content.
Your Choices: We will acquire consent from you in order to use such trackers to the extent required by applicable law. Various browsers and devices offer management tools for removing cookies and local storage. Please note that opting out of interest-based advertising does not opt you out of being served generic ads. You may adjust your ad preferences in your Google or Facebook account.

XI. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or service offerings. If we make any material changes, we will notify you by an in-Product message, email (sent to the email address specified in your account), or by means of a notice on the Website or App prior to the change becoming effective.

We encourage you to periodically review this page for the latest information on our privacy practices. It is your responsibility to maintain a valid email address as a registered user. If you opt out of communications from us, you may not receive these notifications; however, the updated Privacy Policy will still govern your use of the Service, and you are responsible for checking for any changes. Your continued use of the Site or the Service after changes become effective indicates your agreement to abide by and be bound by the modified Privacy Policy.

XII. CONTACT US

If you have any questions, comments, or requests regarding this Privacy Policy, your data rights, or our data practices, please contact us at:

FEELGOOD LABS PTE. LTD.
Address: 160 ROBINSON ROAD, #14-04, SINGAPORE BUSINESS FEDERATION CENTER, SINGAPORE 068914
Email: sophia@heynoah.ai