Updated October 22, 2025

Welcome to Reflect, your thinking partner with perfect memory.

Solo Eleven LLC ("Reflect," "we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and protect your data when you use the Reflect mobile application and related services (collectively, the "Services"). BY USING REFLECT, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT USE OUR SERVICES.

TABLE OF CONTENTS

1. What Reflect Is (And Isn't)

2. Information We Collect

3. How We Use Your Information

4. How We Share Your Information

5. Data Retention and Deletion

6. Your Privacy Rights

7. Security

8. International Data Transfers

9. Children's Privacy

10. Changes to This Policy

11. Contact Us

1. WHAT REFLECT IS (AND ISN'T)

Reflect is a conversational AI thinking partner designed for decision-makers, creators, and professionals who process by talking through ideas. We help you think clearly through decisions, explore possibilities, and maintain perfect memory of your conversations.

IMPORTANT LIMITATIONS:

• NOT MEDICAL/MENTAL HEALTH CARE: Reflect is not a healthcare service, mental health treatment, or crisis intervention tool. We are not licensed healthcare providers and do not provide medical advice, diagnosis, or treatment.

• NOT PROFESSIONAL ADVICE: Reflect is not a substitute for professional legal, financial, business, or investment advice. All conversations are for thinking and exploration purposes only.

• NOT PRIVILEGED COMMUNICATION: Conversations with Reflect are not protected by attorney-client privilege, doctor-patient confidentiality, or any other legal privilege.

• NOT A CRISIS SERVICE: If you are experiencing a crisis, call 911 (US), 988 (US Suicide & Crisis Lifeline), or your local emergency services immediately.

• AI LIMITATIONS: Reflect uses AI that may produce inaccurate, incomplete, or inappropriate responses. You are solely responsible for evaluating all output and making your own decisions.

2. INFORMATION WE COLLECT

INFORMATION YOU PROVIDE DIRECTLY:

Account Information:
• Name and email address
• Account credentials (password is encrypted)
• Profile information you choose to provide
• Subscription and payment information (processed by Apple App Store)

Conversation Content:
• Text messages you send to Reflect
• Voice input you provide (converted to text, audio not stored)
• Files, images, or other content you upload
• AI-generated responses you save

Communication with Us:
• Support requests and feedback
• Survey responses
• Communications via email or in-app messaging

INFORMATION WE COLLECT AUTOMATICALLY:

Technical Information:
• Device type, operating system, and version
• IP address and general location (city/region, not precise GPS)
• App usage data (features used, session duration, frequency)
• Log data (timestamps, error reports, performance data)

Analytics Information:
• How you interact with Reflect
• Which features you use
• Patterns of usage (aggregated and anonymized)

INFORMATION FROM THIRD PARTIES:

Apple App Store:
• Subscription status and renewal dates
• Transaction confirmations
• Refund status
We do not receive your payment card details from Apple.

AI Service Providers:
When you use Reflect's AI features, we share your conversation content with:

OpenAI (for AI responses and optional voice features)

• Retains data for up to 30 days for safety monitoring only

• Does NOT train models on your data

• Privacy Policy: https://openai.com/privacy

Apple (for optional speech-to-text features)

• Does not retain audio by default

• If "Improve Siri & Dictation" enabled, may retain samples up to 6 months

• Privacy Policy: https://www.apple.com/legal/privacy

Firebase/Google Cloud (infrastructure):

• Hosts your conversations and account data
• Provides authentication and security services
• Servers located in United States (us-central region)

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

TO PROVIDE THE SERVICES:
• Generate AI responses to your conversations
• Maintain conversation continuity and context awareness
• Sync your data across your devices
• Process your account and subscription

TO IMPROVE REFLECT:
• Analyze usage patterns (in aggregate/anonymized form)
• Test and develop new features
• Improve AI response quality and relevance
• Identify and fix technical issues

TO COMMUNICATE WITH YOU:
• Send service updates and announcements
• Respond to your support requests
• Send subscription and billing information
• Provide tips and educational content (with your consent)

TO ENSURE SAFETY AND SECURITY:
• Detect and prevent fraud and abuse
• Enforce our Terms of Use
• Protect against security threats
• Comply with legal obligations

TO MEET LEGAL REQUIREMENTS:
• Respond to lawful requests from authorities
• Comply with applicable laws and regulations
• Establish, exercise, or defend legal rights
• Protect vital interests of users or others

IMPORTANT: AI TRAINING POLICY

Your personal conversations are NEVER used to train AI models without your explicit opt-in consent.

• OpenAI does NOT train its models on data sent through our API
• We do NOT sell your data to third parties
• We do NOT use your conversations for advertising
• We may use aggregated, anonymized data for improvements (e.g., "users discussing X prefer format Y")

You can opt out of any aggregated analysis by contacting privacy@reflect.chat.

4. HOW WE SHARE YOUR INFORMATION

We share your information only in the following circumstances:

SERVICE PROVIDERS:
We share data with trusted third-party service providers who help us operate Reflect:

• OpenAI (AI response generation)
• Apple (speech-to-text services, if you enable voice features)
• Google Firebase (hosting, database, authentication, analytics)
• Cloud infrastructure providers (data storage and security)

These providers are contractually required to:
• Use your data only to provide services to us
• Protect your data with appropriate security measures
• Not use your data for their own purposes

BUSINESS TRANSFERS:
If Reflect is involved in a merger, acquisition, sale of assets, or bankruptcy:
• Your data may be transferred to the acquiring entity
• We will notify you before your data is transferred
• The new entity must honor this Privacy Policy or obtain your consent for changes

LEGAL REQUIREMENTS:
We may disclose your information if required to:
• Comply with a subpoena, court order, or legal process
• Respond to lawful government requests
• Enforce our Terms of Use
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or others
• Investigate fraud or security issues

CORPORATE ACCOUNTS:
If you use Reflect with an organization-provided email:
• We may notify that organization of your account
• The organization may convert your account to a corporate account
• Organization administrators may access your conversation content
• You will be notified before this occurs and can opt out

WITH YOUR CONSENT:
We may share information with third parties if you explicitly direct us to do so (e.g., sharing a conversation via link, exporting to another service).

WE DO NOT:
• Sell your personal data for monetary consideration
• Share your data for third-party advertising
• Use your conversations for marketing purposes
• Share your data with data brokers

5. DATA RETENTION AND DELETION

HOW LONG WE KEEP YOUR DATA:

Active Accounts:
• Conversation data: Retained while your account is active
• Account information: Retained while your account is active
• Usage logs: Retained for up to 90 days for security/troubleshooting

After Account Deletion:
• We delete or anonymize your personal data within 30 days
• Some data may remain in backups for up to 90 days
• After anonymization, we cannot identify or restore your data

Third-Party Retention:
• OpenAI: Retains conversation data for up to 30 days for safety monitoring, then deletes
• Apple: Does not retain audio by default; if "Improve Siri" enabled, up to 6 months for audio samples, 24 months for de-identified transcripts

Legal Holds:
• Data subject to litigation hold will be preserved as legally required
• We will notify you if your data is subject to a legal hold (unless prohibited by law)
• You cannot request deletion of data under legal hold

CONTINUOUS CONVERSATION ARCHITECTURE:

Reflect is designed to maintain conversational context and memory across all your interactions. This is a core feature that enables your AI thinking partner to provide relevant, contextual insights.

HOW IT WORKS:
• Each conversation builds upon previous conversations
• The AI maintains awareness of your patterns, preferences, and history
• This creates a continuous thread of thought, like an ongoing dialogue

IMPORTANT UNDERSTANDING:
• Individual messages cannot be selectively deleted
• Deleting one message would break contextual continuity
• This is an intentional design feature, not a technical limitation

YOUR OPTIONS:
• Edit or redact message content in place
• Export your complete conversation history anytime
• Delete your entire account and all associated data
• Request anonymization of specific sensitive information

If you require the ability to selectively delete individual messages, Reflect may not be suitable for your needs. By creating an account, you acknowledge and accept this continuous conversation design.

6. YOUR PRIVACY RIGHTS

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

ACCESS:
• Request a copy of your personal data
• Obtain information about how we process your data

PORTABILITY:
• Export your conversation history in machine-readable format (JSON)
• Available directly in the Reflect app
• Or request via email: privacy@reflect.chat

CORRECTION:
• Update your account information directly in the app
• Request correction of inaccurate data

DELETION:
• Delete your entire account and all associated data
• Available directly in the Reflect app
• Or request via email: privacy@reflect.chat
• Note: Individual messages cannot be deleted (see Section 5)

RESTRICTION:
• Request that we limit processing of your data in certain circumstances

OBJECTION:
• Object to processing based on legitimate interests
• Opt out of marketing communications

WITHDRAWAL OF CONSENT:
• Withdraw consent for processing where we relied on consent
• This does not affect the lawfulness of processing before withdrawal

U.S. STATE PRIVACY RIGHTS (California, Colorado, Virginia, etc.):

If you are a U.S. resident, you have specific rights under state privacy laws:

• Right to Know: What personal information we collect, use, and share
• Right to Delete: Request deletion of your personal information
• Right to Correct: Request correction of inaccurate information
• Right to Opt-Out: We do NOT sell your data or share it for advertising
• Right to Non-Discrimination: We will not discriminate for exercising your rights

Categories of Personal Information We Collect:
• Identifiers (name, email, IP address)
• Commercial information (subscription records)
• Internet activity (app usage, features used)
• Geolocation data (general location from IP, not precise GPS)
• Audio data (voice input converted to text, audio not stored)
• Inferences (patterns derived from your usage, not shared with third parties)

We do NOT:
• Sell your personal information
• Share your data for cross-context behavioral advertising
• Use sensitive personal information for purposes other than providing Reflect

EUROPEAN ECONOMIC AREA (EEA), UK, AND SWITZERLAND RIGHTS:

If you are located in the EEA, UK, or Switzerland, you have additional rights under GDPR:

• Data Protection Officer: Contact privacy@reflect.chat
• Supervisory Authority: Right to lodge a complaint with your local data protection authority
• Legal Basis for Processing:

• Performance of contract (to provide Reflect services)

• Legitimate interests (to improve services, ensure security)

• Consent (for marketing communications)

• Legal obligations (to comply with laws)

EXERCISING YOUR RIGHTS:

To exercise any privacy rights:

1. Email: privacy@reflect.chat

2. In-App: Use account settings for direct actions

3. Verification: We may verify your identity before fulfilling requests

4. Response Time: We will respond within 30-45 days (as required by law)

5. Appeals: If we deny your request, you may appeal the decision

We may decline requests that are:
• Manifestly unfounded or excessive
• Not verifiable
• Not permitted by law
• Subject to legal obligations or litigation holds

AI OUTPUT ACCURACY:

Reflect's AI may occasionally produce inaccurate information. If you notice that AI output contains factually incorrect information about you and you would like it corrected or removed, you may submit a request to privacy@reflect.chat. We will consider your request based on technical feasibility and applicable law.

7. SECURITY

We implement industry-standard security measures to protect your data:

TECHNICAL SAFEGUARDS:
• TLS 1.2+ encryption for all data in transit
• AES-256 encryption for data at rest
• Encrypted authentication credentials
• Secure cloud infrastructure (Google Firebase)
• Regular security assessments and updates
• Access controls limiting who can access your data

ORGANIZATIONAL SAFEGUARDS:
• Employee access limited to those who need it
• Confidentiality obligations for all personnel
• Regular security training
• Incident response procedures

THIRD-PARTY SECURITY:
• OpenAI and Apple process data over encrypted connections
• Firebase provides enterprise-grade security infrastructure
• All providers undergo regular security audits

LIMITATIONS:

No security system is 100% secure. While we implement robust protections, we cannot guarantee absolute security.

You are responsible for:
• Protecting your account credentials
• Using a strong, unique password
• Enabling device security (passcode, biometrics)
• Not sharing your account with others
• Reporting suspected security issues to security@reflect.chat

We are NOT responsible for:
• Security breaches caused by your actions (e.g., sharing passwords)
• Vulnerabilities in third-party platforms outside our control
• Unauthorized access due to device compromise (malware, jailbreaking)

SECURITY RESEARCH:

We welcome good-faith security researchers. If you discover a vulnerability:
• Report it to security@reflect.chat
• Provide reasonable time to address the issue
• Do not violate user privacy or disrupt services
• We will not pursue legal action under CFAA or similar laws for good-faith research

DATA BREACH NOTIFICATION:

If a data breach affects your personal information, we will:
• Notify you as required by applicable law
• Notify relevant regulatory authorities
• Provide information about what data was affected
• Explain steps we are taking to address the breach

8. INTERNATIONAL DATA TRANSFERS

Reflect is operated by Solo Eleven LLC, a company based in the United States. Your data is primarily stored and processed in the United States.

WHERE YOUR DATA LIVES:
• Primary storage: Google Firebase (us-central region, United States)
• AI processing: OpenAI servers (United States)
• Speech services: Apple servers (United States)

INTERNATIONAL USERS:

If you use Reflect from outside the United States, your data will be transferred to and processed in the United States. The United States may have data protection laws that differ from your country.

We protect your data regardless of where it is processed using:
• This Privacy Policy
• Contractual protections with service providers
• Industry-standard security measures
• Compliance with applicable data transfer mechanisms

EUROPEAN ECONOMIC AREA, UK, AND SWITZERLAND:

For users in the EEA, UK, or Switzerland, we rely on the following mechanisms for data transfers:

• Standard Contractual Clauses (SCCs): Approved by the European Commission for transfers to countries without adequacy decisions
• Data Processing Agreements: With all service providers handling EEA/UK/Swiss data
• Adequacy Decisions: Where available for specific countries
• Your Consent: For transfers where you have explicitly agreed

You may request a copy of the SCCs we use by emailing privacy@reflect.chat.

GLOBAL EXPANSION:

As we expand internationally, we may:
• Store data in additional geographic regions
• Establish local entities in certain jurisdictions
• Update data transfer mechanisms as required
• Provide region-specific privacy notices

We will notify you of material changes to where your data is stored or processed.

9. CHILDREN'S PRIVACY

Reflect is only available to users who are 18 years of age or older.

We do not knowingly collect personal information from anyone under 18.

If we discover that someone under 18 has created an account:
• We will immediately terminate the account
• We will delete all associated data within 30 days
• We may pursue legal remedies if age was misrepresented

If you believe a child under 18 has provided information to Reflect, please contact us immediately at privacy@reflect.chat.

PARENTAL NOTE: If your child has used Reflect, please contact us to request account termination and data deletion.

10. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect:
• Changes in our practices or services
• New legal requirements
• Technological developments
• User feedback and improvements

NOTICE OF CHANGES:

• Material Changes: We will notify you at least 30 days in advance via email or in-app notification
• Non-Material Changes: We will post the updated policy and update the "Effective Date"
• Your Continued Use: Constitutes acceptance of the updated policy
• If You Disagree: You should discontinue use and delete your account

You can view previous versions of this Privacy Policy by contacting privacy@reflect.chat.

11. CONTACT US

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

Solo Eleven LLC (d/b/a Reflect)
5900 Balcones Drive, Suite 100
Austin, TX 78731
United States

Email:
• General privacy inquiries: privacy@reflect.chat
• Data subject requests (access, deletion, etc.): privacy@reflect.chat
• Security issues: security@reflect.chat
• General support: care@reflect.chat

Data Protection Officer: privacy@reflect.chat

For EEA/UK/Swiss users:
If you are not satisfied with our response, you have the right to lodge a complaint with your local supervisory authority.

Website: https://reflect.chat

ADDITIONAL INFORMATION FOR SPECIFIC JURISDICTIONS

CALIFORNIA RESIDENTS (CCPA/CPRA):

Categories of Personal Information Sold or Shared: NONE
We do not sell personal information or share it for cross-context behavioral advertising.

Sensitive Personal Information:
We collect and use conversation content (which may include sensitive topics) only to provide Reflect's thinking partner services. We do not use it for advertising or other purposes.

Right to Limit Use: You may request that we limit use of sensitive personal information by contacting privacy@reflect.chat.

Retention Period: See Section 5 for details on how long we retain information.

Shine the Light: We do not share personal information with third parties for their direct marketing purposes.

Financial Incentives: We do not offer financial incentives for personal information.

NEVADA RESIDENTS:

We do not sell your covered information as defined by Nevada law. If you would like to submit a verified request related to this, please contact privacy@reflect.chat.

COLORADO, CONNECTICUT, UTAH, VIRGINIA RESIDENTS:

You have the rights described in Section 6. We do not process data for targeted advertising or sell personal data. To exercise your rights or appeal a decision, contact privacy@reflect.chat.

INTERNATIONAL CRISIS RESOURCES:

If you are in crisis, please contact local emergency services:

• United States: 911 (Emergency) / 988 (Suicide & Crisis Lifeline)
• United Kingdom: 999 (Emergency) / 116 123 (Samaritans)
• European Union: 112 (Emergency) / 116 123 (EU helpline)
• Canada: 911 (Emergency) / 1-833-456-4566 (Talk Suicide Canada)
• Australia: 000 (Emergency) / 13 11 14 (Lifeline)

For additional international resources, visit: https://findahelpline.com

© 2025 Solo Eleven LLC. All rights reserved.