Privacy Policy

Last Updated: September 2026 · Contact: hello@holistictalks.com

1. Introduction

Welcome to HolisticTalks ("we," "our," "us"). Your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our website, mobile application, and services (collectively, the "Service").

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use the Service.

2. Information We Collect

We collect the following types of information:

a) Information You Provide Directly:

• Account Information: Your name (or username), email address, and password (hashed).
• Payment Information: Processed securely by our payment processor (Paddle). We do not store your full payment card details.
• Conversation Content: The questions you ask and the AI-generated responses you receive.
• Preferences: Your language preference and subscription plan selections.
• Communications: Any messages you send to us via email or through the Service.

b) Information Collected Automatically:

• Usage Data: How you interact with the Service, including pages visited, time spent, features used, and number of conversations.
• Device Information: IP address, browser type, operating system, device model, and unique device identifiers.
• Cookies and Similar Technologies: We use cookies to remember your preferences, analyze usage, and improve your experience. You can manage cookie preferences in your browser settings.

3. How We Use Your Information

We use your information for the following purposes:

• To Provide and Operate the Service: Create and manage your account, authenticate your identity, process payments, and deliver conversation responses.
• To Improve and Personalize the Service: Analyze usage patterns to enhance content quality, optimize AI responses, and tailor the user experience.
• To Communicate with You: Send service-related emails (e.g., account approval, payment receipts, subscription renewals, password resets) and, only with your explicit consent, marketing communications about new speakers, features, or special offers.
• To Ensure Security and Compliance: Detect and prevent fraudulent activity, enforce our Terms of Service, and comply with legal obligations.
• For AI Training and Improvement (Aggregated Data): We may use anonymized and aggregated conversation data to improve the quality of our AI models. This data does not identify you personally.

4. Legal Basis for Processing (GDPR Compliance)

We process your personal data based on the following legal grounds:

• Account creation and Service delivery — Contractual necessity: to fulfill our agreement with you.
• Payment processing and fraud prevention — Contractual necessity and legitimate interest.
• Service improvement and analytics — Legitimate interest: to improve our Service.
• Marketing communications — Consent: you must explicitly opt-in.
• Compliance with legal obligations — Legal obligation: e.g., tax laws, court orders.

You have the right to withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

5. AI Processing and Third-Party Providers

To deliver the conversation feature, your questions and the generated responses are processed by our AI service providers. We currently use:

• Base44: Our primary platform provider. Your data is stored and processed on Base44's secure infrastructure. Base44 maintains ISO 27001 certification and GDPR compliance.
• Google Gemini API: Our AI model provider. Your conversation data is sent to Google's servers to generate responses.

Important: Your conversations with AI simulations are not used to train public AI models. They are used solely to provide you with the Service and for internal quality improvement (in aggregated, anonymized form). For more information about how our providers handle data, please refer to their privacy policies:

• Base44 Privacy Policy
• Google Privacy Policy

6. Data Retention

We retain your personal data for as long as necessary to provide the Service and fulfill the purposes outlined in this Privacy Policy.

• Active Accounts: Your account and conversation data are retained while your account is active.
• Deleted Accounts: When you request account deletion, we will delete your personal data within 30 days, except where we are required to retain it for legal, tax, or regulatory reasons (e.g., payment records for accounting purposes, which are retained for up to 7 years as required by law).
• Anonymized Data: Aggregated and anonymized data may be retained indefinitely for analytical purposes.

7. Sharing Your Information

We do not sell, trade, or rent your personal information to third parties. We may share your data with:

• Service Providers: Trusted third parties that help us operate the Service (e.g., Base44, Google Gemini API, Paddle). They are contractually obligated to protect your data and use it only for the services they provide to us.
• Payment Processors: Paddle processes your payment information as merchant of record. We do not store your full payment card details.
• Legal and Regulatory Authorities: If required by law, court order, or government regulation, we may disclose your information to comply with legal obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new owner, subject to the same privacy protections.

8. Your Rights (GDPR and Data Protection)

Depending on your location, you have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to Be Forgotten"): Request deletion of your personal data, subject to legal retention requirements.
• Right to Restrict Processing: Request that we limit how we process your data.
• Right to Data Portability: Request a copy of your data in a structured, commonly used, and machine-readable format.
• Right to Object: Object to the processing of your data for marketing purposes or based on legitimate interests.
• Right to Withdraw Consent: Withdraw your consent for marketing communications at any time.

To exercise any of these rights, please contact us at hello@holistictalks.com. We will respond to your request within 30 days.

9. Security

We implement reasonable technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These measures include:

• Encryption: Data is encrypted in transit (using SSL/TLS) and at rest.
• Access Controls: Only authorized personnel have access to user data.
• Regular Security Reviews: We monitor and update our security practices to address emerging threats.

However, no method of transmission over the internet is 100% secure. You are responsible for safeguarding your account credentials and using the Service securely.

10. Children's Privacy

Our Service is not intended for children under the age of 16 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children. If you believe we have inadvertently collected data from a child, please contact us, and we will delete it promptly.

11. International Data Transfers

Your data may be processed in countries outside your country of residence, including the United States and the European Union. We ensure that any such transfers comply with applicable data protection laws, using mechanisms such as:

• Standard Contractual Clauses (SCCs): Approved by the European Commission to ensure adequate data protection.
• EU-US Data Privacy Framework: For transfers to certified US entities.

By using our Service, you consent to the transfer of your data to these jurisdictions, which may have different data protection standards than your country.

12. Cookies

We use cookies and similar tracking technologies to enhance your experience. You can manage cookie preferences in your browser settings. For more detailed information, please see our Cookie Policy (available on our website).

13. Third-Party Links

Our Service may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to read their privacy policies before providing any personal information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Service. Material changes will be communicated through the Service (e.g., via email or a prominent notice in the app) at least 30 days before they take effect.

The updated version will be identified by the "Last Updated" date at the top of this page. Please review this Privacy Policy periodically.

15. EU AI Act Transparency (2026)

In accordance with the EU AI Act (effective August 2, 2026), we inform you that:

• AI Interaction: You are interacting with an AI system that simulates historical figures based on their writings and notes.
• Purpose: The AI is designed for educational and informational purposes only. It is not a diagnostic or therapeutic tool.
• Transparency: We clearly indicate when you are interacting with AI. For more information, please refer to our AI Transparency Notice available in the app.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

HolisticTalks Email: hello@holistictalks.com Website: https://holistictalks.com Response Time: We will respond to your inquiry within 30 days.

17. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Serbia. If you are located in the EU or the UK, you also have the right to lodge a complaint with your local data protection authority.

By using HolisticTalks, you acknowledge that you have read, understood, and agree to this Privacy Policy.