Soul - Privacy Policy

Date Last Updated: January 21, 2026

Soul Global, Inc., a Delaware corporation ("Soul," "Company," "we," "us," or "our"), respects your privacy and is committed to safeguarding any information we collect from or about you. This privacy policy, as amended from time to time ("Privacy Policy"), outlines our practices regarding the data we collect when you use our mobile applications, website, and services (collectively, the "Services") for non-professional purposes or services, as intended. The Services include the features and capabilities of our AI-powered companion application, including voice conversations, text conversations, memory extraction, and voice cloning features.

Data that may be relatable, from sources we collect, to an identifiable living natural person is referred to herein as "personal information" or "personal data" or "PI."

Soul seeks to comply with general principles of privacy, many of which have been reduced to laws in various jurisdictions. We comply fully with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and any applicable U.S. state privacy laws. This Privacy Policy is a statement of principles and does not opt Soul into any jurisdiction not otherwise applicable to it; Soul reserves all rights to object to application of any law to it as appropriate, and this Privacy Policy does not create in third parties any rights of enforcement.

Soul seeks to provide secure and confidential Services to its users, some of which might be defined under local law as personal information or personal data. Our goal is to collect and process only sufficient data to perform our Services safely, efficiently and securely, to communicate with persons about our Services, and to retain PI that has not been anonymized or aggregated only as long as required for our business purposes. Data is deleted pursuant to the retention policies set forth herein.

1. Data Controller

For the purposes of the GDPR (General Data Protection Regulation), Soul is a "data controller," meaning we are the party responsible for deciding the purposes and means of processing "personal information," as defined by the GDPR.

2. Personal Data Collected

While using our Services, we may ask you to provide us with certain PI that can be used to contact or identify you. The Company collects only sufficient information to provide its Services and, in some instances, to communicate with a person or to process their PI, as well as to monitor operations and prevent abuse, and to ensure system security and functionality. Personally identifiable information may include information you have provided, information received from your use of the Services, and information received from other sources.

The Services and personal information collected are not intended for use by you for health-related purposes or services. We do not use, process, store, or share any data collected through this technology for the purpose of providing health-related advice, diagnoses, treatments, services, or any other health-related purposes. The Services are not designed or intended to be used to support or replace professional medical care.

The Services and personal information collected are not intended for use by you for legal-related purposes or services. We do not use, process, store, or share any data collected through the Services for the purpose of providing legal advice or services. The Services are not designed or intended to be used to support or replace professional legal advice or services.

The Services and personal information collected are not intended for use by you for financial or real estate-related purposes or services. We do not use, process, store, or share any data collected through the Services for the purpose of providing professional financial or real estate services. The Services are not designed or intended to be used to support or replace professional financial or real estate services.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Data You Provide

Through the use of the Services or the creation of an account, we may collect data and personal information from you directly. This data can include, but is not limited to:

Data Received from Use of the Services

We and our third-party vendors may use cookies, web beacons, and other tracking technologies to collect information about the devices (including mobile devices) you use to access the Services. We may collect and analyze information including but not limited to:

Identifiers:

Log Information:

Audio and Biometric Data:

AI-Generated and Inferred Data:

Internet Activity:

Geolocation Data:

Data Received from Other Sources

We may receive information from our partners, such as:

3. How Personal Data is Used and Shared

We specifically note that the Company does not sell data to third parties to perform marketing or profiling. We may use personal data for the following purposes:

We may also aggregate or de-identify personal data so that it no longer identifies you and use this information for the purposes described above, such as to analyze the way our Services are being used, to improve and add features to them, and to conduct research. We will maintain and use de-identified information in de-identified form and not attempt to reidentify the information, unless required by law.

We seek to limit third-party contractors' use of data provided by us to them in connection with assisting with providing our Services by contractual provisions aimed at solely serving the purposes of the Company and its customers.

As noted above, we may use data and personal information you provide us to improve our Services. For example, the data you provide may be used to train the models that power Soul.

4. Disclosure of Personal Data

The Company will not disclose any of its users' personal information to a third party, except: (a) to the extent that it believes is or may be required to do so pursuant to any applicable laws, rules or regulations; (b) if there is a duty to disclose; (c) if our legitimate business interests require disclosure; (d) in line with our Terms of Service; (e) for safety and security purposes; (f) in connection with business changes (such as merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction); (g) with Service Providers to assist in providing, delivering or improving the Services; or (h) at your request or with your consent or to those described in this Privacy Policy.

Your personal data may be disclosed in the following circumstances:

Vendors and Service Providers

To assist us in meeting business operations needs and to perform certain services and functions, we may disclose personal data to vendors and service providers, including:

Pursuant to our instructions, these parties will access, process, or store personal data only in the course of performing their duties to us.

Business Transfers

If we are involved in any business transaction such as reorganization, bankruptcy, merger, acquisition, or other sale of Company assets (collectively, a "Transaction"), your personal data may be disclosed in the diligence and negotiation process with counterparties and transferred to a successor or affiliate as part of that Transaction.

Government Authorities or Other Third Parties

We may share your personal data, including information about your interaction with our Services, with government authorities or other parties as necessary in compliance with the law: (i) if required to do so, or in good faith belief that action is necessary, to comply with a legal obligation; (ii) to protect and defend our rights or property; (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, users, or the public; or (vi) to protect against legal liability.

Transfers Directed or Permitted by You

We may disclose personal data about you to certain other third parties at your direction or with your consent or permission.

Non-Identifiable Data

In addition, where allowed by applicable law, we may use and disclose information that is not in a personally identifiable form for any purpose. If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

5. AI and Automated Processing

Soul is an AI-powered companion application. To provide our Services, we use artificial intelligence and machine learning technologies to process your data in the following ways:

Conversation Processing

When you interact with our AI assistant, your messages (whether typed or spoken) are processed by third-party AI services. These services generate responses to your messages, analyze the context of your conversation, and maintain continuity across conversation sessions.

Memory Extraction and Storage

Our AI system automatically extracts and stores "memories" from your conversations. These memories include personal details you share (preferences, experiences, relationships), topics you frequently discuss, and inferred information about your interests and circumstances. These memories are stored in our database and used to personalize future conversations, provide continuity across sessions, and enable the AI to recall previous discussions.

Speech Processing

When you use voice features, your speech is transcribed to text using third-party speech recognition services. The transcribed text is then processed by our AI, and transcripts are stored as part of your conversation history.

Voice Synthesis

If you use voice cloning features, your voice samples are processed by third-party voice synthesis services. A synthetic voice model is created based on your voice characteristics, and this model is used to generate speech that sounds like you.

Emotion Recognition

The Service may analyze your voice to detect emotional states and adjust responses accordingly. This analysis is performed in real-time and may be stored as part of your conversation history.

Limitations

6. Audio Data and Call Recording

Voice Call Recording

When you have voice conversations with our AI assistant, these conversations may be recorded. Specifically:

Speech-to-Text Transcription

Your voice conversations are transcribed to text in real-time using third-party speech recognition services. Your spoken words are sent to third-party servers for processing, the resulting text transcript is returned to our systems, and transcripts are stored as part of your conversation history.

7. Voice Cloning

Soul offers an optional voice cloning feature that allows the AI assistant to speak in a voice that sounds like you or another voice you provide.

How Voice Cloning Works

You record or upload voice samples, which are processed by our voice synthesis providers to create a voice model. This model captures the characteristics of the provided voice and is used to generate speech when the AI responds.

Data Collection and Storage

Third-Party Processing

Voice samples are processed by third-party voice synthesis services. These services receive your voice audio samples, process them to create a voice model, and store the resulting model to enable voice synthesis. These services are subject to their own privacy policies.

Your Control

Important Considerations

8. Device Permissions

Our mobile application requests the following device permissions:

Microphone

Camera

Photo Library

Push Notifications

Background Audio

You can manage these permissions at any time through your device settings.

9. Retention

We will retain personal data we process on behalf of our users for as long as needed to provide the Services to our customers, subject to our compliance with this Privacy Policy and any relevant customer agreements. When we consider that personal information is no longer necessary for the purpose for which it was collected, we will delete such information or remove any details that will identify you, or we will securely destroy the records.

Specific Retention Periods

Data Type Retention Period Notes
Account Information Duration of account + 30 days after deletion Name, email, phone, age, gender, pronouns
Voice Call Recordings 90 days Audio recordings stored in secure cloud storage
Voice Samples (for cloning) Duration of account Deleted when user removes sample or deletes account
Conversation Transcripts Duration of account Stored to power AI memory and personalization
AI-Extracted Memories Duration of account Deleted upon account deletion or user request
Conversation Data Duration of account Deleted with account
Analytics Data 12 months Aggregated data may be retained longer
Session Replay Data 90 days Screen recordings of app interactions
Push Notification Tokens Until revoked or app uninstalled Automatically cleaned when invalid

However, we may need to maintain records for a significant period of time after you cease being our user. We may further retain and use this personal data as necessary, including but not limited to:

Data Deletion

10. Your Rights

Depending on where you live, you may have certain statutory rights in relation to your personal data. For example, depending on your jurisdiction you may have the right to:

You can exercise some of these rights through your Soul account settings. If you are unable to exercise your rights through your account, please submit your request to support@soul.download.

A note about accuracy: Services like ours generate responses by reading a user's request and, in response, predicting the words most likely to appear next. In some cases, the words most likely to appear next may not be the most factually accurate. For this reason, you should not rely on the factual accuracy of output from our models. Similarly, AI-extracted memories may contain inaccuracies.

11. Protections for Children

Soul does not expect nor does it knowingly permit the use of Company services by children under 13. We do not, by our Terms of Service, permit anyone under 13 to use the Services, and we do not knowingly collect personal data from children under 13.

Age Verification

During account registration, we collect your age. If you indicate that you are under 13 years of age, you will not be permitted to create an account or use our Services.

Users Under 18

While users between 13 and 18 years of age may use our Services with parental consent, parents and guardians should be aware that:

We encourage parents and guardians to monitor their children's use of our Services.

Parental Rights

If you have reason to believe that a child under 13 has provided personal data to Soul through the Services, please email us at support@soul.download. If you are a parent or guardian and become aware that a minor has accessed our services, please contact us directly. We will investigate any notification and, if appropriate, delete the personal data from our systems and close the account.

12. Security

Our platform uses cloud services that might process and retain data and your personal information in different jurisdictions other than your primary location, including in the United States of America and elsewhere in the world. By using our Services, you are deemed to agree that your personal information may be transferred to, stored, and handled as described in this Policy.

We seek to take reasonable measures to protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. These measures include:

However, it is not possible to guarantee 100% security or confidentiality of information you provide to us. If you have reason to believe that your interactions with us are no longer secure, please contact support@soul.download immediately.

13. Breach Notification Protocols

In case of a data breach involving personal information:

Under GDPR

We will notify supervisory authorities within 72 hours after discovery and the affected individuals promptly if their rights are impacted.

Under U.S. State Laws

We will notify affected individuals within the timeframes required by applicable state law. Breaches involving large numbers of individuals will also be reported promptly to authorities as required by law.

14. Regional Privacy Disclosures and Rights

Some regions, both within the United States and the EEA/Switzerland/UK regions, require additional or specific disclosures and afford users with additional or different rights.

Your State Privacy Rights

Depending on where you live and subject to applicable exceptions, you may have the following privacy rights in relation to your personal data:

We do not "sell" personal data or "share" personal data for cross-contextual behavioral advertising, and we do not process personal data for "targeted advertising" purposes (as those terms are defined under state privacy laws). We also do not process sensitive personal data for the purpose of inferring characteristics about a consumer.

Additional GDPR Rights

For those users that live in the European Economic Area (EEA), Switzerland, or the UK, you have the following additional rights:

The GDPR also requires data controllers to tell you about the legal basis they rely on for using, sharing, or disclosing personal data. Our legal grounds for processing your data are detailed in Section 15 below.

15. Lawful Basis for Processing

As required by the GDPR, we legally process data when you have given us clear consent to process your personal information. Other processing of data is lawful due to the following bases:

Purpose of Processing Type of Personal Data Legal Basis
To provide, analyze, improve and maintain our Services Account Information, User Content, Voice Data, AI-Generated Data, Log Data, Device Information Where necessary to perform a contract with you. Where necessary for our legitimate interests, including developing and improving our Services.
To communicate with you Account Information, Contact Information, Device Information Where necessary to perform a contract with you. Your consent when we ask for it, such as for marketing communications.
To enable voice cloning features Voice Samples, Biometric Data Your explicit consent when you choose to use voice cloning features.
To extract and store memories Conversation Content, AI-Generated Data Where necessary to perform a contract with you (providing personalized AI interactions). Where necessary for our legitimate interests in improving our Services.
To prevent fraud and protect security Account Information, Log Data, Device Information, Usage Data Where necessary to comply with a legal obligation. Where necessary for our legitimate interests in protecting our Services from abuse, fraud, or security risks.
To comply with legal obligations All categories as necessary Where necessary to comply with a legal obligation, such as retaining records for regulatory requirements.

16. Cookies and Similar Technologies

When you use our products and Services, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (collectively, "Cookies") on your computer or other devices used when engaging with us.

We use Cookies to help us recognize you as a customer, collect information about your use of our products and Services, to better customize our Services and content for you, and to collect information about your computer or other access devices to ensure our compliance with our legal obligations.

Analytics and Session Replay

We use third-party analytics services for product analytics and session replay functionality. These services collect information about your use of our Services, including:

Important Notice About Session Replay: Session replay may capture text you enter into the app. While we take measures to protect sensitive information, you should be aware that your interactions with the app may be recorded for quality and improvement purposes.

Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services.

17. Exercising Your Rights

You may request to exercise your applicable access, rectification, cancellation, and/or objection rights by submitting a request to support@soul.download.

Please note that certain information may be exempt from requests under applicable law. For example, we may retain certain information for legal compliance and to secure our Services. We may need certain information in order to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services.

We hope to address any questions or concerns you may have. Certain people may have the right to complain to their local Data Protection Authority.

18. Verification

In order to protect your personal data from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete personal data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional personal data for verification. If we cannot verify your identity, we will not be able to honor your request.

19. Authorized Agents

You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us. Authorized agent requests can be submitted to support@soul.download.

20. Appeals

Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights. To appeal a decision, please send your request to support@soul.download.

21. Data Transfers

Soul currently processes data in the United States of America. By use of our Services, you are deemed to consent to such usage; if you do not consent to such usage, do not use our Services.

While data protection law varies by country and these countries may not offer the same level of data protection as your home country, we apply the protections described in this Privacy Policy to your personal data regardless of where it is processed. To the extent that we transfer your personal information outside of the EEA and UK, we will use reasonable efforts to ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the European Union (EU) General Data Protection Regulation and the UK Data Protection Act 2018.

By using the Services, you consent to the collection, processing, maintenance, and transfer of your personal information in and to the United States where the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.

22. Links to Third-Party Sites

If you reach our platform(s) via a third-party platform, please see the privacy policy of the third party because Soul does not manage or control independent businesses, nor their customers or service providers. Prior to accessing our Services and once you leave our site, you are governed by the other site's own privacy policy.

The Services may also contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information by third parties will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties before providing information to them.

23. Accessibility

If you have a problem reading or accessing information or materials on the Website or regarding our Services, please inform us at support@soul.download.

24. Changes to Privacy Policy

Our Privacy Policy is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices, are taken into consideration, as well as that it remains abreast of the changing regulatory environment. Any personal information we hold will be governed by our most recent Privacy Policy.

If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate. You consent to these changes by continuing to use our Services.

25. Severability

In the event if any one or more of the provisions of this Privacy Policy should be invalid, illegal, or unenforceable in any respect, the validity, legality, and enforceability of the remaining provisions contained herein shall not in any way be affected or invalidated.

26. Contact

Please contact us at support@soul.download if you have any questions or concerns not already addressed in this Privacy Policy or wish to exercise any privacy rights outlined above.

Soul Global, Inc.
Email: support@soul.download
General Inquiries: info@soul.download

Addendum: Data Protection Authorities

If you are not satisfied with our response to your complaint, you have the right to submit a complaint to the regulator in your country. Here are the contact details of some of the regulators:

For residents of Australia:

Office of the Australian Information Commissioner
GPO Box 5288
Sydney NSW 2001

For residents of Canada:

Contact: https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/

For residents of the United Kingdom:

The Information Commissioner's Office
Wycliffe House, Water Ln
Wilmslow SK9 5AF, UK
Contact: https://ico.org.uk/global/contact-us/

For EEA citizens (European Economic Area):

This will be the supervisory authority in the member state where you work, normally live, or where the alleged infringement of data protection laws has occurred. A list of EEA supervisory authorities is available at:
https://edpb.europa.eu/about-edpb/about-edpb/members_en

For residents of California:

California Attorney General
300 South Spring Street
Los Angeles, CA 90013
Contact: https://oag.ca.gov/contact/consumer-complaint-against-business-or-company

For residents of other U.S. states:

Please contact your state's Attorney General office.

If your own jurisdiction is not listed here, please see your local governmental guidance.

End of Privacy Policy