Privacy Policy

1.INTRODUCTION

This Privacy Policy explains how Social Media Group SRL ("we", "us", "our") collects, uses, stores and protects your personal data when you use the TruthMirror mobile app and website (the "App", the "Service").

We are the data controller for your data. Actual storage and processing is carried out through trusted infrastructure providers acting as processors on our behalf and on our instructions (see section 6). As we are established in the European Union (Romania), the appointment of a representative under Article 27 GDPR is not required.

We are committed to protecting your privacy and to complying with the General Data Protection Regulation (GDPR), Romanian Law 190/2018 and applicable data protection legislation.

Data controller:

Social Media Group SRL

Bd. Decebal 12, București, România

Company ID (CUI): 42636861 · Trade Register: J40/6444/2020

Email: support@truthmirror.net

2.WHAT DATA WE COLLECT

2.1Account data (stored through our backend provider, in the EU):

To create and secure your account, we collect:

• Your email address (needed for passwordless code-based sign-in);
• Your date of birth (needed to verify that you are at least 18);
• An identifier of your device (used for security and to prevent reactivation of blocked accounts);
• An irreversible cryptographic version (hash) of your email address (used for security and ban enforcement — see section 7.3);
• The date you verified your age;
• Your language preference;
• The date your account was last used (used for automatic expiry of inactive sessions and for security);
• An indicator of your subscription plan (see 2.6 for subscription management).

2.2Usage data (stored through our backend provider, content-free):

• The date and time of each question you send — recorded WITHOUT any message content — solely to enforce the daily question limits according to your plan;
• An indicator of whether a request was the free daily question ("TruthQuestion") or a regular question, together with its date (never any content).

When the mirror replies with crisis resources (see the Terms of Service, section 4), no usage record is created for that exchange. If you keep writing in such a conversation after reaching your daily limit, the App sends a technical flag with your message so that the limit does not interrupt the conversation; this flag is not stored.

Our server also keeps short-lived technical logs without any message content (for example error codes, or the fact that a safety reply was sent), retained by our backend provider for a limited period (at most 28 days) to operate and secure the Service.

2.3Data stored ONLY on your device (never stored in our infrastructure; the text of your messages only passes through our server transiently, to reach the AI provider — see 5.3):

• The text content of your conversations with the AI;
• The AI's replies to your messages;
• The detected behavioral pattern tags (e.g. "avoidance", "intellectualizing");
• The clarity score and statistics calculated from your conversations;
• The app lock PIN (stored encrypted, never transmitted);
• Records of your consent and app settings;
• The local daily-question journal (which days were answered or skipped) — used for the in-app history;
• A marker on the mirror's crisis replies, kept only on your device, used to show the helplines button under them and to leave those exchanges out of your scores.

2.4Anonymous usage analytics:

We use Aptabase (with servers in the European Union) for strictly anonymous usage statistics — for example, how many people open the app or which language they use. These events contain ONLY anonymous technical data: the event name and properties such as the language, the plan and billing period, the tone you selected, the category of the active conversation context (for example "Work" or "Health") or the screen an action started from. They do NOT contain your email, an account identifier, the content of your conversations or the mirror's replies, or data that can personally identify you.

2.5Data we do NOT collect:

• The content of your conversations or the AI replies (they stay on your device);
• Your statistics or clarity score (they stay on your device, except the summary figures sent for the weekly report — see 5.3);
• Your real name (unless you voluntarily include it in conversation text);
• Your precise location;
• Contacts, photos or other device data;
• Payment card details (handled entirely by Apple/Google and the subscription processor — see 2.6).

2.6Subscriptions:

Subscriptions and payments are handled by Apple (App Store) or Google (Google Play), together with RevenueCat, a specialized subscription management provider. They process the transaction and only tell us your subscription status (active/inactive and plan), which we use to grant you the correct access. We NEVER receive or store your bank card details.

3.HOW WE USE YOUR DATA

We process your data to:

(a) provide the core Service — generate AI replies (the AI also suggests the pattern tags for each reply) and calculate statistics (calculated and stored on your device);

(b) create and secure your account through email code sign-in;

(c) verify that you meet the 18+ age requirement;

(d) enforce daily question limits according to your subscription;

(e) protect the Service and other users, including preventing reactivation of blocked accounts (especially for the protection of minors);

(f) let you keep and review your conversation history and progress, on your device;

(g) provide support when you contact us;

(h) comply with legal obligations.

Legal bases under GDPR (Article 6):

• Performance of a contract (providing the Service you subscribed to);
• Your consent (given on first launch, which you can withdraw at any time);
• Our legitimate interests (securing the Service, protecting minors, preventing abuse);
• Compliance with legal obligations.

4.WE DO NOT TRAIN AI ON YOUR DATA

We do NOT use the content of your conversations to train, fine-tune or improve any AI model. We do NOT sell, rent or share the content of your conversations with advertisers or data brokers.

5.DATA STORAGE AND LOCATION

5.1On your device: Conversation history, AI replies, pattern tags, statistics, clarity score, PIN and consent records are stored locally on your device. They are never stored in our infrastructure (the messages you send only pass through our server transiently — see 5.3).

5.2Through our backend provider: Account data (section 2.1) and content-free usage records (section 2.2) are hosted by Supabase in the European Union (Frankfurt, Germany), on our behalf. The content of your conversations, the AI replies and your statistics are NOT stored there.

5.3AI processing: When you send a message, its text — together with up to the 10 most recent messages of the same conversation, which the AI needs as context — is transmitted (transiently, without being stored by us) through our processing server to Anthropic PBC (United States), the provider of the Claude AI model, solely to generate a reply, which is then returned to your device. See section 6(b) for how long Anthropic keeps this data and section 12 on international transfers. If you request the weekly insights report (Mirror plan), only summary figures are sent the same way — active days, number of questions, start and end score, streak, and pattern names with their counts — never conversation text.

5.4Emails: We use Resend (with servers in the European Union, Ireland) solely to send you the sign-in code by email. Resend processes your email address only to deliver that message.

6.PROCESSORS

We share data only with the following processors, strictly to operate the Service, each acting on our behalf:

(a) Supabase — database, authentication and backend hosting (EU, Frankfurt). Stores the account data and usage counter described in sections 2.1–2.2. Does NOT store the content of your conversations.

(b) Anthropic PBC — AI model provider (US). Receives, transiently, the text of your message and of the recent messages of the same conversation (and, for the weekly report, the summary figures described in 5.3), to generate a reply. Anthropic does not use data received through its API to train its models. Under Anthropic's data retention policy for its API, inputs and outputs are automatically deleted within 30 days of receipt or generation. Messages that Anthropic's safety systems flag as possibly violating its usage policies may be kept for up to 2 years, and the related safety classification scores for up to 7 years, under Anthropic's own terms.

(c) Resend — transactional email provider (EU, Ireland). Receives your email address solely to deliver the sign-in code.

(d) Aptabase — anonymous usage analytics (EU). Receives only anonymous technical events, no data that can identify you.

(e) RevenueCat (US), Apple and Google — subscription and payment management and processing. We never receive your full card details.

(f) The hosting provider of our website (truthmirror.net) — stores and serves the website; like any web server, it processes visitors' IP addresses in technical logs, solely to deliver and secure the site.

Each processor is bound by a data processing agreement under Article 28 GDPR.

7.DATA RETENTION

7.1On your device: Conversation history, statistics and scores exist only on your device, under your control. The in-app history view shows the last 7 days on the free plan (Glimpse) and the full history on paid plans. You can export (on paid plans) or delete everything at any time, and deleting the App removes this data.

7.2Account data: We keep it as long as your account is active. You can delete your account at any time directly in the App (Settings → "Delete account") or via our account-deletion page at https://www.truthmirror.net/delete-account, which removes the associated data (email, date of birth, device identifier, preferences, usage counter), except as described in section 7.3. If an account stays inactive for 24 months, we delete the associated data.

7.3Exception for protection of minors and abuse prevention: If an account is blocked (for example because it belongs to a person under 18 or for abuse), we keep the irreversible cryptographic version (hash) of the email address and the device identifier on a block list, even after the account is deleted. This is strictly necessary to prevent reactivation of a blocked account and to protect minors. This list does NOT contain your email in clear text and cannot be used to contact you or for marketing. The legal basis is our legitimate interest in protecting minors and the integrity of the Service (Article 6(1)(f) GDPR). Separately, and for the same purpose of abuse prevention, we keep a device identifier together with the date on which that device first used the Service. This is strictly necessary so that a one-time introductory allowance cannot be claimed repeatedly by deleting and recreating accounts on the same device, and it is therefore kept even after an account is deleted. This record contains no email address, no name and no conversation content, is not used to identify you and is never used for marketing. The legal basis is the same legitimate interest in the integrity of the Service (Article 6(1)(f) GDPR).

7.4Local exports (PDF and share cards): Both the PDF export of your conversations (available on paid plans) and the share cards (images containing a reply of the mirror) are generated entirely on your device. A share card contains only the mirror's reply — never your messages, your name, or the selected context. The PDF contains your conversations as they exist locally on your device. Neither of these files is ever transmitted to our servers, and neither leaves your device except through your explicit action via the operating system's share menu. What you choose to do with them afterwards is entirely under your control (see also the Terms of Service, section 11).

8.YOUR RIGHTS UNDER GDPR

You have the right to:

(a) ACCESS — request a copy of your personal data;

(b) RECTIFICATION — correct inaccurate data;

(c) ERASURE — request deletion of your data ("right to be forgotten");

(d) RESTRICTION — limit how we process your data;

(e) PORTABILITY — receive your data in a portable format;

(f) OBJECTION — object to processing based on legitimate interests;

(g) WITHDRAWAL OF CONSENT — at any time, without affecting prior lawful processing.

You can exercise the right to erasure (c) directly in the App or from our website:

• Settings → "Delete account" permanently deletes your account, the account data at our backend provider (email, date of birth, device identifier, preferences, usage counter) AND all data on your device (conversations, statistics, score, PIN).
• From the web: our account-deletion page at https://www.truthmirror.net/delete-account explains how to delete your account, including by email if you cannot access the App.
• Settings → "Delete all my data" deletes only the data on your device (conversations, statistics), keeping the account.
• PDF export (on paid plans) covers portability (e) of the data on your device (conversations, statistics). For a copy of the account data stored on the server (email, date of birth, language preference, subscription plan), write to support@truthmirror.net.

For any other right (access, rectification, restriction, objection), write to support@truthmirror.net. We respond within 30 days. Note that, for the protection of minors, the block list described in section 7.3 may be kept even after the account is deleted, based on legitimate interest.

You also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP) or your local supervisory authority.

9.DATA SECURITY

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

• Encryption in transit (HTTPS/TLS) for all data exchanged between the App, our providers and the AI provider;
• Your conversations are stored locally on your device and are not kept in our infrastructure;
• The PIN is stored encrypted on the device, never transmitted;
• Backend data is protected by access controls and encrypted at rest by the hosting provider;
• The email on the block list is kept only as an irreversible hash, never in clear text;
• Our AI provider key is stored only on the server, never in the App;
• Backups you create are encrypted on your device with a recovery code that only you hold — we never receive or store the backup or the code;
• The ability to lock the app with a PIN or biometrics (Face ID / fingerprint);
• Biometric unlock (Face ID / fingerprint) is processed entirely by the device's operating system; the App only receives a success confirmation and never collects, stores or transmits biometric data;
• Periodic security review of our infrastructure.

No system is completely secure. We recommend that you avoid including highly sensitive identifying details (full name, address, ID numbers) in conversation text.

10.CHILDREN'S PRIVACY

TruthMirror is intended strictly for users aged 18 and over. We verify age at account creation through the date of birth. We do not knowingly collect data from anyone under 18. If we discover that a user is under 18, the account is blocked and the associated personal data is deleted, keeping only the minimal elements on the block list (section 7.3) strictly to prevent re-creation of the account.

11.PROFILING AND AUTOMATED DECISIONS

The App performs an automated calculation of behavioral pattern statistics (for example, the frequency of patterns such as "avoidance" or "intellectualizing") to show you your evolution over time. These calculations happen on your device and do not produce legal decisions or similarly significant effects on you within the meaning of Article 22 of the GDPR. The results are purely informational — you always keep full control over how you interpret or act on them.

12.INTERNATIONAL TRANSFERS

Most of your data (account, usage, email, analytics) is processed in the European Union. There are two exceptions: (1) the text of your messages and of the recent messages of the same conversation (and, if you request the weekly report, the summary figures described in 5.3), which is transmitted to Anthropic in the United States to generate the AI reply — we do not store it, and Anthropic keeps it only as described in section 6(b); and (2) subscription data processed by RevenueCat in the United States (a pseudonymous account identifier and the status and history of your purchases — never your card details). Both transfers are carried out on the basis of the Standard Contractual Clauses approved by the European Commission, the recognized legal mechanism for transferring data outside the EU. For questions about these transfers, you can contact us at support@truthmirror.net.

13.CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of important changes through the App. The "Version" date at the top indicates the most recent revision.

14.CONTACT

For privacy questions or to exercise your GDPR rights, contact:

Social Media Group SRL

Bucharest, Romania

support@truthmirror.net

Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP):

www.dataprotection.ro

B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, Bucharest, Romania