Overview

This Privacy Policy explains how Sophon Labs, Inc. ("Sophon Labs", "we", "us", or "our") collects, uses, shares, and protects personal information when you use Shadow, our service that helps you manage day-to-day tasks.

If you have questions or want to exercise your privacy rights, contact us at help@hal-e.io.

Scope

This Policy applies to Shadow, our website, our WhatsApp-based experience, our account and payment flows, and related support services.

Shadow is intended for adults. You must be at least 18 years old, or the age of majority where you live, to use Shadow. We do not knowingly offer Shadow to children.

Information We Collect

We collect information you provide directly, information generated when you use Shadow, and information we receive from service providers.

Information you provide may include:

• Your phone number, name, account identifiers, profile information, and authentication information.
• Messages, instructions, tasks, preferences, and other content you send to Shadow.
• Support requests and other communications with us.
• Billing details needed to manage subscriptions or purchases. Full payment card details are handled by Stripe, not by Sophon Labs.

Information collected automatically may include:

• Usage data, such as message timestamps, product events, errors, logs, and feature usage.
• Device, browser, network, and approximate location information, where available from your device, browser, or service providers.
• Security and diagnostic logs used to operate and protect Shadow.

Information from service providers may include:

• WhatsApp and Meta account, messaging, authentication, and delivery information.
• Payment status, subscription status, invoices, and transaction identifiers from Stripe.
• Hosting, observability, analytics, and security information from infrastructure providers.

Conversations and Human Review

Shadow processes your conversation content so the service can respond to you, manage your tasks, maintain context, troubleshoot issues, and protect the service.

We do not review conversations by default. Authorized Sophon Labs founders may access conversation content only for limited purposes:

• To provide support you requested.
• To investigate or fix a specific bug, failure, or reliability issue.
• To protect users, Sophon Labs, or others from abuse, fraud, security threats, or misuse.
• To comply with legal obligations.
• To improve Shadow where you have given optional consent for product-improvement review.

We do not use your conversation content to train AI models.

For more detail, see our Conversation and Human Review Policy.

How We Use Information

We use personal information to:

• Provide, maintain, and improve Shadow.
• Understand and respond to your messages and task-management requests.
• Maintain conversation history and user preferences.
• Authenticate users and manage accounts.
• Process payments and subscriptions.
• Provide support and respond to requests.
• Monitor reliability, debug errors, and improve service quality.
• Detect, prevent, and investigate abuse, fraud, security incidents, and policy violations.
• Send service-related notices.
• Comply with legal obligations and enforce our terms.

Where required by law, we rely on the following legal bases:

• Contract: to provide Shadow and related account, support, and payment features.
• Legitimate interests: to secure, maintain, debug, and improve the service, and to prevent abuse, provided those interests are not overridden by your rights.
• Consent: for optional product-improvement review of conversation content and for other optional uses where consent is required.
• Legal obligation: where we must retain, disclose, or process information to comply with law.

Product Improvement

We want to improve Shadow, but conversation content is sensitive. We may use aggregated, de-identified, or minimized usage information to understand product performance and improve reliability.

We will ask for your optional consent before using identifiable conversation content for product-improvement review by our founding team. You can decline or withdraw that optional consent without losing access to Shadow.

How We Share Information

We share information with service providers that help us operate Shadow, including:

• Cloud hosting and infrastructure providers, including AWS.
• AI model providers, such as OpenAI, Anthropic, and similar providers we use to generate responses and operate Shadow.
• Messaging, authentication, and account providers, including WhatsApp and Meta.
• Payment providers, including Stripe.
• Support, security, analytics, and operational vendors.

These providers may process personal information only as needed to provide their services to us, subject to their own terms and data-processing commitments.

We may also disclose information if necessary to comply with law, enforce our terms, protect rights and safety, investigate security or abuse, or as part of a merger, acquisition, financing, or sale of assets.

We do not sell personal information. We do not share personal information for cross-context behavioral advertising.

International Transfers

Sophon Labs is a Delaware C-corporation. We and our service providers may process information in the United States, the European Union, Latin America, and other countries. Where required, we use appropriate safeguards for international transfers, such as contractual protections.

Retention

We keep conversation history and account information until you delete it or request deletion, unless we need to retain certain information for security, legal, billing, dispute-resolution, or service-integrity reasons.

After deletion, some information may remain for a limited time in backups, audit logs, or security records before it is overwritten or deleted through normal processes.

Security

We use reasonable technical and organizational measures to protect personal information, including access controls, limited internal access, secure infrastructure, and separation of sensitive payment flows through Stripe. No online service is completely secure, so you should avoid sending passwords, payment card numbers, government IDs, health information, financial secrets, or other highly sensitive information to Shadow unless necessary.

Your Choices and Rights

Depending on where you live, you may have rights to access, correct, delete, export, restrict, or object to processing of your personal information. You may also withdraw optional consent, including optional consent for product-improvement review.

California residents may have rights to know, access, correct, delete, opt out of sale or sharing, limit certain uses of sensitive personal information, and not be discriminated against for exercising privacy rights. We do not sell personal information or share it for cross-context behavioral advertising.

European Economic Area, United Kingdom, and Swiss users may have rights to access, rectify, erase, restrict, port, or object to processing, and to lodge a complaint with a supervisory authority.

To make a request, email help@hal-e.io. We may need to verify your identity before responding.

Third-Party Services

Shadow may depend on third-party services such as WhatsApp, Meta, Stripe, AI model providers, and cloud infrastructure providers. Your use of those services may also be governed by their own terms and privacy policies.

Changes

We may update this Policy from time to time. If we make material changes, we will provide notice through Shadow, our website, email, WhatsApp, or another reasonable method. The updated Policy will be effective when posted unless we say otherwise.

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