This Privacy Policy is product-scoped and covers both DailyBeBetter products under one and the same data controller:
Where a data flow belongs to only one product it is marked (Coach) or (Soul Blueprint). Where unmarked, it applies to both. The two products share a single controller; their data flows are otherwise separate.
The data controller for both products is Daily Be Better - F.Z.C, a UAE Ajman Free Zone company (License No. 55075), Ajman Free Zone C1 Building, B.C. 1308557, Ajman Free Zone, Ajman, United Arab Emirates.
EU / UK representatives and Data Protection Officer details will be added once appointed. This policy remains a draft pending counsel review.
DailyBeBetter is operated by the entity identified above (UAE — Ajman Free Zone). We are the data controller for both products. For privacy questions, to exercise your rights, or to reach our Data Protection Officer, contact office@dailybebetter.com. If you are in the EU or the UK, you may also contact our representative once it is appointed.
DailyBeBetter is a wellness and personal-development coaching service. It is not a medical service, and it does not diagnose, treat, or prescribe. Some data we process is, for the limited purpose of choosing the correct legal basis, classified as “special-category” or “consumer health data” under data-protection law (see sections 2–3) — that legal classification does not change the wellness / coaching nature of the service.
The categories flagged special-category below are treated, for the lawful-basis classification only, as GDPR Article 9 data concerning health or as Washington consumer health data (see section 3). Mental-wellbeing status is treated as health data even outside any clinical setting.
Coach
Soul Blueprint
For the special-category data identified above, our Article 9 lawful basis is your explicit consent (GDPR Art 9(2)(a)). For Coach, that consent is captured in-app at the consent gate as three separate, unbundled, default-unchecked tick-boxes:
None of these is pre-ticked, and none is bundled with another — each is a freely-given, specific, informed opt-in. Deleting your account withdraws this consent (see section 9).
Our AI inference of your emotional and wellbeing state — the persistent Client Graph that lets the coach surface patterns across sessions — is intentional special-category processing regardless of confidence level, and is covered by the same explicit consent.
Voice and biometrics. Your live voice is processed to deliver the conversation; it is not processed to uniquely identify you as a person. On that basis it is not biometric special-category data under the Article 9 biometric limb. The voice content can carry wellbeing information, which we capture as a text transcript, not as an audio recording (see section 8).
(Coach) When you use Coach, you are interacting with an AI coach (presented as a named persona, Arabella or James) — not a human. You receive a clear in-product disclosure of this, spoken and on-screen, at the start of your first session and on a recurring cadence thereafter. Your voice and text are processed by:
AI-generated session recaps are marked “AI-generated” in-app.
(Soul Blueprint) Your birth details are processed by AI (Anthropic Claude, via Anthropic’s direct API) to generate personalized interpretations of your numerological, astrological, and Soul Diamond profiles. Anthropic does not use API inputs for training. Generated reports are stored temporarily to enable delivery and re-download (see section 8).
We do not sell your personal data, and we do not use your coaching content for advertising.
We share data only with the recipients below, scoped per product. Each link is to that recipient’s own privacy policy.
Coach recipients (the live coaching-data set)
Soul Blueprint recipients
Forthcoming (planned, not yet live): RevenueCat (subscription-entitlement management) and Sentry (crash reporting with transcript / PII scrubbed) are planned recipients. They are disclosed here as planned; they do not process your data today. This policy will be updated before either goes live.
All coaching data at rest resides in the EU — AWS eu-west-3 (Paris). The data controller is established in the UAE, and engineering and maintenance access to the EU-hosted data is performed from the UAE. That remote access is itself an EU → UAE third-country transfer (remote access to data is a transfer even when no copy is made).
Because we collect personal data directly from EU users while established outside the EU, our processing of EU users’ data is also governed by GDPR by virtue of Article 3(2).
The UAE has no EU adequacy decision, so an Article 46 transfer safeguard applies to the EU → UAE leg. The exact Article 46 instrument is a counsel decision tracked in our vendor-DPA checklist. In the interim we operate on a GDPR-aligned contractual posture (data processing agreements binding each recipient to equivalent protection).
We state our actual retention behavior:
Two deletion paths (Coach)
An important caveat (we will not overstate this): two records may survive the cascade, both keyed outside your account partition: (1) an account-deletion-request audit record (keyed to your email) — a record that a deletion was requested, for which a retention policy is under review; and (2) content-report evidence — if you (or another user) reported AI content, a pseudonymized copy of the report and the reported conversation is kept for up to 12 months for safety and legal review, then auto-deleted (section 8). It contains no name, email, or account identifier, and its lawful basis is the establishment, exercise or defence of legal claims plus our platform-safety legitimate interest. We therefore do not claim “everything is removed” — these two records can remain (the second only ever pseudonymized and time-bound). Your right to delete is never blocked, delayed, or conditioned on an open report — we preserve the evidence, not the account, and your in-app deletion always runs immediately and in full. On production, the ElevenLabs processor holds no copy of your data to delete (Zero Retention Mode).
Your GDPR / UK rights. You have the right to: access, rectification, erasure, data portability, restriction of processing, objection, and to withdraw consent. Because your special-category processing rests on explicit consent (section 3), deleting your account withdraws that Article 9 consent and stops the associated processing.
US state rights. If you are a Washington resident, your consumer-health-data rights (My Health My Data Act) — including the right to withdraw your collection or sharing consent and to have consumer health data deleted — are described in our separate Consumer Health Data Privacy Policy, where California residents’ rights are also cross-referenced. To exercise any right, contact office@dailybebetter.com.
Both products are for adults 18 and over only. Coach enforces a self-declared 18+ age gate at signup. We do not direct either product to, or knowingly collect personal data from, anyone under 18. If you believe a minor has provided us data, contact us and we will delete it.
We may update this policy; we will post the new version with an updated Last updated date and, for material changes, notify you (e.g. by email or in-app notice).
Questions, requests, or complaints: office@dailybebetter.com. EU and UK users have the right to lodge a complaint with their local supervisory authority.
Last updated: June 2026 (draft — pending counsel review and entity incorporation).