Soundswire LLC, a Delaware limited liability company ("Counsy", "we", "us" or "our"), operates the Counsy AI mobile application and the website at counsy.app (together, the "Service"). This Policy explains what personal information we collect, why, who it is shared with, how long it is kept, and the rights you can exercise.
We do not sell your personal information. We do not share it with advertisers, data brokers, insurers or employers. We do not run third-party advertising in the Service. We do not use your conversations to train foundation models, for us or for anyone else.
Your conversations may describe your mental or emotional state. In the EU and UK that is a special category of personal data under Article 9 GDPR, and in several U.S. states it is "consumer health data". We treat it accordingly, and we process it on the basis of your explicit consent, which you may withdraw at any time by deleting your account.
This Policy aligns with the App Privacy label we publish on the App Store. If anything there conflicts with this Policy, this Policy controls.
Who is responsible for your data
Soundswire LLC is the data controller. For any privacy question, request or complaint, write to privacy@counsy.app. We do not currently maintain a separate EU or UK representative and will appoint one if our processing footprint requires it.
What we collect
Account data
Your name or chosen handle, the email address returned by Sign in with Apple or Google (which may be Apple's private relay address), your language and time zone, and your subscription status. We never receive your Apple or Google password.
Conversation data
The audio of what you say while the talk button is held, the text transcription of it, the replies Counsy generates, and any messages you type. Audio is captured only while you are actively holding the button. The Service does not listen in the background, does not record ambient audio, and does not access your microphone when you are not holding the button.
Derived wellbeing signals
A coarse emotional label per check-in, derived by a language model from what you said, plus streak and usage counts. These are reflections for your own charts, not clinical assessments — see the Terms.
Technical and usage data
Device model, operating-system version, app version, locale, crash reports, and coarse event logs such as "a voice turn started". We do not collect precise location, contacts, photos, calendar, health-app data, or your device advertising identifier.
Payment data
Purchases are processed by Apple or Google. We receive a subscription status and a store transaction identifier through RevenueCat. We never receive or store your card number, CVC or billing address.
Why we process it, and on what legal basis
- To provide the Service — transcribe what you said, generate a reply, speak it back, and show you your own history. Basis: performance of our contract with you, and your explicit consent for the health-related content within it.
- To operate subscriptions — verify entitlement and usage allowances. Basis: contract.
- To keep the Service working and safe — diagnose crashes, prevent abuse and fraud, enforce limits. Basis: our legitimate interests in a functioning, non-abused product.
- To comply with law — tax, accounting, and responses to lawful requests. Basis: legal obligation.
We do not process your data for profiling, behavioural advertising, credit or insurance decisions, or any automated decision producing legal or similarly significant effects.
Who processes your data on our behalf
We use a small number of service providers, each bound by contract to process only on our instructions and prohibited from using your data for their own purposes:
- Deepgram — converts your recorded utterance to text. Audio is sent for transcription and is not retained by them for model training.
- OpenAI (via Cloudflare AI Gateway) — generates the companion's replies from the conversation. Processed under terms that exclude training on our data.
- Cartesia — converts the reply text into the spoken voice.
- Cloudflare — hosting, network, and the database that stores your account and history.
- RevenueCat — subscription status and receipt validation.
- Apple and Google — authentication, app distribution and payment.
We may also disclose data if required by valid legal process, to protect our rights or someone's safety, or to a successor in a merger or acquisition — in which case this Policy continues to apply until you are notified otherwise.
How long we keep it
- Audio recordings — used to produce a transcript and then discarded. We do not build a library of your voice.
- Transcripts, replies and mood history — kept while your account exists, because they are what your history and charts are made of.
- Account and subscription records — kept while your account exists, and afterwards only as long as needed for tax and accounting obligations.
- Crash and diagnostic logs — a short rolling window, typically under 90 days.
On deletion, your account and conversation data are removed from our live systems. Residual copies may persist in encrypted backups for a limited period before being overwritten.
Your rights and choices
Depending on where you live, you may have the right to access, correct, delete, restrict or object to our processing of your data, to receive a portable copy, and to withdraw consent. In the United States, residents of California and other states with comparable laws have rights of access, deletion, correction and to opt out of sale or sharing — and we do not sell or share your data.
You can delete your account and its data from within the app at any time. For any other request write to privacy@counsy.app; we respond within the time your law requires, and within 30 days by default. We will not discriminate against you for exercising a right.
If you are in the EEA or UK you may lodge a complaint with your supervisory authority.
International transfers
We and our providers operate in the United States and other countries. Where data leaves the EEA or the UK we rely on the European Commission's Standard Contractual Clauses and the UK Addendum, together with technical measures including encryption in transit and at rest.
Security
Data is encrypted in transit with TLS and at rest by our hosting provider. Access to production systems is limited to personnel who need it. Payment credentials never reach us. No system is perfectly secure, and we cannot guarantee absolute security. If a breach affects your data we will notify you and the relevant authorities as required by law.
Children
The Service is not directed to children under 13 and we do not knowingly collect their information. Users must be 17 or older, or the age of digital consent in their country if higher. If you believe a child has provided us information, write to privacy@counsy.app and we will delete it.
This is not a medical record
Counsy is not a covered entity or business associate under HIPAA, and the data you enter is not a medical record. Do not use Counsy to store information you need for medical, legal or insurance purposes, and do not treat your history as a clinical record. Counsy provides no medical, psychological or therapeutic service — see the Terms of Service.
Changes to this Policy
We may update this Policy. Material changes will be notified in the app or by email before they take effect, and the date at the top of this page always reflects the current version.
Questions about this document? Write to privacy@counsy.app.