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Privacy Policy

Effective Date: [INSERT DATE, e.g., June 1, 2026] Last Updated: [INSERT DATE]

This Privacy Policy describes how [YOUR LEGAL NAME / COMPANY NAME] (“Cogent,” “we,” “us,” or “our”) collects, uses, stores, and shares your personal information when you use the Cogent mobile application (the “App”) and related services (collectively, the “Service”).

By using the Service, you agree to the practices described in this Policy. If you do not agree, please do not use the Service.


1. Who We Are

Cogent is an AI-powered decision coach that helps users pause before impulsive choices through Socratic dialogue and behavioral-economics techniques.

If you are a resident of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the data controller for your information is the entity named above.


2. Information We Collect

2.1 Information You Provide

Category Examples Purpose
Account information Email address, display name, profile photo URL, authentication provider (Google / Apple / email) Create and secure your account
Decision content “Brain dumps” you type or speak, your chat messages with the AI coach, your stated goals (“Pillars”), past-decision outcomes (“Regret Ledger”), post-mortem ratings Provide the core Service
Voice recordings Audio captured when you use voice features Transcribed in real time to text via our speech-to-text provider; the raw audio is not retained after transcription
Subscription information Subscription tier, status, trial end date, purchase receipts (handled by Apple / Google / RevenueCat) Manage entitlements and billing
Support correspondence Messages you send us Respond to your inquiries

2.2 Information Collected Automatically

Category Examples Purpose
Device information Device model, operating system, app version, language, time zone Diagnose issues, improve compatibility
Usage data Features used, screens viewed, session timestamps, error logs Understand product usage, fix bugs
Identifiers Anonymous Firebase user ID, RevenueCat customer ID, anonymized device identifier Link your sessions and entitlements securely

We do not use third-party advertising identifiers (IDFA / AAID) and do not show ads.

2.3 Information from Third Parties

If you sign in with Google or Apple, we receive your email, name, and a unique user identifier from that provider, in accordance with the permissions you granted at sign-in.


3. How We Use Your Information

We use your information to:

  1. Operate the Service — create your account, save your decisions, run the AI coaching pipeline.
  2. Personalize coaching — feed your stated goals (Pillars), past outcomes (Regret Ledger), and decision style (Persona) to the AI models so responses reflect your context.
  3. Process payments and subscriptions — through Apple, Google, and RevenueCat.
  4. Communicate with you — service notifications, security alerts, support replies. We do not send marketing emails unless you have explicitly opted in.
  5. Improve and secure the Service — diagnose bugs, prevent abuse, monitor system health.
  6. Comply with law — respond to lawful requests and enforce our Terms.

Legal bases (GDPR/UK GDPR users): We rely on (a) performance of a contract (to deliver the Service), (b) legitimate interests (security, fraud prevention, product improvement), (c) consent (where required, such as for voice processing), and (d) legal obligations.


4. AI Processing — Important Disclosures

Cogent’s core functionality relies on third-party large-language-model (“LLM”) providers. When you submit a decision or chat message:

You should not enter sensitive personal information (e.g., government IDs, financial account numbers, health diagnoses, information about other identifiable individuals) into your decisions or chats.


5. How We Share Your Information

We do not sell your personal information. We share it only with the following categories of recipients:

Recipient Role Data Shared Location
Google Firebase (Google LLC) Authentication, push notifications Email, display name, auth tokens USA
Railway Corp. Database and server hosting (PostgreSQL + Node.js) All Service data we store USA
RevenueCat, Inc. Subscription management Pseudonymous user ID, email, display name, purchase events USA
Anthropic, PBC LLM inference (Claude) Decision text, chat messages, pseudonymous session ID USA
Google LLC (Gemini API) LLM inference (classification, gatekeeping) Decision text, pseudonymous session ID USA
Deepgram, Inc. Speech-to-text and text-to-speech Voice audio (transient), text strings USA
Apple Inc. / Google LLC App distribution, in-app purchase processing Purchase receipts, anonymized device identifier USA

We may also disclose information:


6. International Data Transfers

Cogent is operated from [YOUR COUNTRY], and our servers and subprocessors are primarily located in the United States. If you access the Service from the EEA, UK, Switzerland, or any other jurisdiction with data-protection laws different from those of the U.S., your information will be transferred to and processed in the U.S.

For transfers from the EEA/UK/Switzerland, we rely on the European Commission’s Standard Contractual Clauses (SCCs) and equivalent UK/Swiss safeguards entered into with our subprocessors.


7. Data Retention

Data Retention period
Account data Until you delete your account, then permanently deleted within 30 days
Decision content and chat history Same as above
Voice audio Not retained — discarded immediately after transcription
Subscription / payment records Retained for 7 years to comply with tax and accounting law
Anonymized logs and analytics Up to 90 days

You can delete your account at any time from the App’s Profile → Delete Account option, or by emailing [YOUR SUPPORT EMAIL].


8. Your Rights

Depending on your jurisdiction, you may have the following rights:

California residents (CCPA/CPRA): You have the right to know, delete, correct, and opt out of “sale” or “sharing” of personal information. We do not sell or share personal information as defined by California law.

To exercise any right, email [YOUR SUPPORT EMAIL]. We will respond within 30 days (45 days for California requests, extendable as permitted by law). We may need to verify your identity before fulfilling the request.


9. Children’s Privacy

Cogent is not directed to children under 13 (or under 16 in the EEA/UK). We do not knowingly collect personal information from children. If you believe a child has provided us with information, please contact us and we will delete it.


10. Security

We implement industry-standard security measures, including:

No system is 100% secure. If we become aware of a security incident affecting your data, we will notify you in accordance with applicable law.


11. Changes to This Policy

We may update this Policy from time to time. When we make material changes, we will notify you via in-app notice or email and update the “Last Updated” date above. Continued use of the Service after such changes constitutes acceptance.


12. Contact Us

For privacy questions or to exercise your rights:

Email: [YOUR SUPPORT EMAIL] Postal: [YOUR BUSINESS ADDRESS]


This Privacy Policy is provided as a starting template. It is not legal advice. Consider having it reviewed by a licensed attorney before publishing.