PRIVACY POLICY

1. Introduction

BeBOLD ("we," "us," "our," or "the App") is a social confidence-building application operated by Cooper James Blackburn, a sole trader registered in Queensland, Australia (ABN 75 772 778 194). This Privacy Policy explains:

• What personal information we collect
• How we use, store, and protect your information
• Your rights regarding your data
• How to contact us with privacy concerns

By using BeBOLD, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

Jurisdiction: This policy is governed by Australian privacy law, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). As we serve users globally, we also comply with the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA) and the California Consumer Privacy Act (CCPA) where applicable.

Age Restriction: BeBOLD is intended for users aged 17 and older. We do not knowingly collect information from individuals under 17.

2. Information We Collect

2.1 Account and Authentication Information

When you create a BeBOLD account, we collect:

Storage: Managed by Supabase (our authentication provider). See Section 4.2 for details.

2.2 Profile and Personalization Data

You provide the following information to customize your experience:

Purpose: This data is used to generate personalized AI conversation approaches and feedback tailored to your goals and boundaries.

2.3 Behavioral and Progress Data

We automatically collect and calculate data about your app usage:

Storage: All behavioral data is stored in our PostgreSQL database hosted by Supabase and retained for the lifetime of your account.

2.4 Technical and Operational Data

Note: Idempotency data is automatically purged after 24 hours and also deleted immediately if you delete your account.

3. Information We Do NOT Collect

BeBOLD explicitly does not collect the following:

• ❌ Location data (GPS coordinates, precise location, or city-level location)
• ❌ Contacts from your device
• ❌ Photos, videos, or camera access
• ❌ Microphone or audio recordings (we do not record your voice)
• ❌ Health or fitness data
• ❌ Payment information (handled entirely by Apple for subscriptions)
• ❌ Device identifiers for advertising (IDFA, Android Advertising ID)
• ❌ Cross-app tracking data
• ❌ Browsing history
• ❌ Biometric data (Face ID/Touch ID used only for local device authentication)

Future Changes: If we add location data collection in a future update, we will update this policy and request your explicit permission before collecting such data.

4. How We Use Your Information

4.1 Primary Uses

We use your information for the following purposes:

4.2 Confidence Score Calculation (Algorithmic Decision-Making)

Your confidence score is a core feature of BeBOLD. It is calculated automatically using a rules-based algorithm with limited AI input. Here's exactly how it works:

Base Score Changes (Rules-Based)

AI Sentiment Adjustment (Applied After Base Change)

Our AI analyzes your self-review text and may add a small adjustment:

Score Bounds and Limits

• Range: 0-100 (hard minimum and maximum enforced)
• Maximum change per attempt: +4 (positive outcome + exceptional courage) or -3 (negative outcome + harsh self-judgment)
• Time decay: None. Your score never decreases due to inactivity.

What Your Score Unlocks

AI Approach Calibration:

Your confidence score also influences the style of AI-generated approaches:

• Lower scores (0-30): Safer, less direct, low-pressure approaches
• Mid scores (31-70): Balanced approaches with moderate directness
• Higher scores (71-100): Bolder, more direct, confident approaches

Your Rights: Under GDPR Article 22, you have the right to object to automated decision-making. However, the confidence score is a core feature of the app and opting out would prevent the app from functioning. If you wish to disable confidence tracking, please contact us at beboldapps@gmail.com.

5. Third-Party Service Providers

We share your data with the following third-party services to operate BeBOLD:

6. Data Storage, Security, and International Transfers

6.1 Where Your Data Is Stored

International Data Transfers: If you are located in the European Economic Area (EEA), United Kingdom, or Australia, your data may be transferred to and processed in the United States where Supabase and OpenAI operate servers.

• Standard Contractual Clauses (SCCs): Supabase and OpenAI use EU-approved Standard Contractual Clauses to protect data transferred outside the EEA.
• Adequacy Decisions: We rely on the EU-US Data Privacy Framework where applicable.

6.2 Security Measures

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

No Absolute Security: While we take reasonable steps to protect your data, no internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security.

6.3 Data Breaches

In the event of a data breach that compromises your personal information, we will:

• Notify you via email within 72 hours of discovering the breach (as required by GDPR)
• Notify relevant authorities (Australian Information Commissioner, EU Data Protection Authorities)
• Provide details about what data was affected and steps you can take to protect yourself

7. Data Retention and Deletion

7.1 How Long We Keep Your Data

No Automatic Purging: We do not automatically delete your data after a period of inactivity. Your account and data remain until you delete your account.

7.2 Account Deletion (Your Right to Erasure)

You can delete your account and all associated data at any time directly within the app.

Irreversibility: Account deletion cannot be undone. You cannot recover your data after deletion.

8. Your Privacy Rights

Depending on your location, you have the following rights:

8.1 Rights Under GDPR (EEA/UK Users)

Data Portability: We currently do not offer an automated data export feature. To request a copy of your data, email beboldapps@gmail.com and we will provide a JSON file within 30 days.

Objection to Automated Decision-Making: You can object to the confidence score algorithm, but this would prevent core app functionality. Contact us to discuss alternatives.

8.2 Rights Under Australian Privacy Act

Australian users have rights under the Australian Privacy Principles (APPs):

• Right to access your personal information
• Right to correct inaccurate information
• Right to complain to the Office of the Australian Information Commissioner (OAIC)

Contact: Office of the Australian Information Commissioner - https://www.oaic.gov.au/

8.3 Rights Under CCPA (California Users)

California residents have the following rights:

• Right to Know: What personal information we collect and how we use it
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt out of the "sale" of personal information (Note: We do NOT sell your data)
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

How to Exercise Rights: Contact beboldapps@gmail.com or use the in-app account deletion feature.

Response Time: We will respond to requests within 45 days.

9. Children's Privacy

BeBOLD is not intended for use by individuals under 17 years of age. We do not knowingly collect personal information from anyone under 17. The App Store age rating is set to 17+. If you are a parent or guardian and believe your child under 17 has provided us with personal information, please contact us immediately at beboldapps@gmail.com. We will delete such information promptly.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, new features, or legal requirements.

How We Notify You:

• Material changes: We will notify you via email and/or a prominent notice in the app at least 30 days before changes take effect
• Minor changes: Updated "Last Updated" date at the top of this policy

Your Continued Use: By continuing to use BeBOLD after changes take effect, you accept the updated Privacy Policy.

Version History: You can request previous versions of this policy by contacting beboldapps@gmail.com.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

Response Time: We aim to respond to privacy inquiries within 7 business days.

For GDPR Requests: If you are in the EEA/UK, you also have the right to lodge a complaint with your local Data Protection Authority.

For Australian Privacy Complaints: You may also contact the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/

12. Additional Information

12.1 Cookies and Tracking Technologies

BeBOLD does not use cookies or tracking technologies. We do not track your activity across other apps or websites.

12.2 Do Not Track Signals

We do not respond to "Do Not Track" browser signals because we do not track users across websites or apps.

12.3 Third-Party Links

BeBOLD may contain links to third-party websites or services (e.g., links in educational content). We are not responsible for the privacy practices of these third parties. Please review their privacy policies before providing them with your information.

12.4 User-Generated Content Ownership

You retain all ownership rights to the content you create in BeBOLD (insights, reviews, boundaries). However, by using the app, you grant us a limited, worldwide, royalty-free license to:

• Store your content on our servers
• Process your content through AI services (OpenAI) to generate personalized approaches and feedback
• Use aggregated, anonymized data derived from your content to improve our services

This license terminates when you delete your account. Upon account deletion, we will delete your content as described in Section 7.2.