MyPossePrivacy Policy
Effective Date: 1 September 2026
1. Introduction and Scope
1.1 This Privacy Policy explains how MyPosse LTD. ("MyPosse", "we", "us" or "our") collects, uses, discloses and retains personal information in connection with the MyPosse mobile application, our website and all related services (together, the "Service").
1.2 MyPosse is a private social application for small, closed groups of family members and friends, which we call Posses. The design of the Service means that a substantial part of the information you provide is shared with the other members of your Posse rather than kept private to you. Section 11 explains how this works. Please read it carefully.
1.3 This Privacy Policy applies to personal information we process as a controller of that information. It does not apply to the practices of third parties whose services you may access through or alongside the Service, including Apple, Google and any third party you choose to share content with outside the Service.
1.4 Information concerning mood and wellbeing is subject to additional protections and additional disclosures. Those are set out in Section 6 of this Privacy Policy and, in greater detail, in our separate Consumer Health Data Privacy Notice below.
1.5 By using the Service you acknowledge that you have read this Privacy Policy. Where we rely on your consent to process information, we will ask for that consent separately and you may withdraw it as described in this Policy.
2. Who We Are and How to Contact Us
2.1 MyPosse LTD. is the entity responsible for the personal information described in this Privacy Policy. Our registered address is [Company Address].
2.2 You may contact us about privacy matters by email at privacy@myposse.app, or by post at the address in Section 2.1.
2.3 If you have a complaint about how we have handled your personal information, please contact us first so that we may attempt to resolve it. You may also have the right to complain to the attorney general of your state or to another competent regulator.
3. Information You Provide to Us
3.1 Account information. When you register we collect your name, an email address or mobile telephone number, your date of birth and a password. Where you register using a third party sign in provider, we receive the information described in Section 5.
3.2 Profile information. We collect any profile details and profile image you choose to add.
3.3 Posse information. We collect the name and type of any Posse you create, the invitation codes generated, and the record of which Posses you belong to.
3.4 User content. We collect the content you submit through the Service, including answers to Anchor Questions, messages, photographs and other media, Journal entries, quiz and guessing game answers, poll responses and Vibe Check responses.
3.5 Mood entries. We collect the mood state you select when you use the Mood Mosaic feature, together with the date on which it was recorded. See Section 6.
3.6 Support and correspondence. We collect the content of any message you send to us, including support requests, reports about other users, and copyright or privacy complaints.
3.7 Payment related information. Purchases are processed by Apple or Google. We do not receive or store your full payment card details. We receive confirmation of your subscription status and related transaction identifiers.
4. Information Collected Automatically
4.1 Device and technical information. We collect device identifiers, device model, operating system and version, application version, language and time zone settings, and mobile network information.
4.2 Usage information. We collect information about how you use the Service, including features accessed, screens viewed, prompts answered or skipped, streak activity, session duration and dates and times of access.
4.3 Log and diagnostic information. We collect log data, crash reports, performance data and error reports generated when you use the Service.
4.4 Approximate location. We may derive an approximate location, such as a country or region, from your internet protocol address. We do not collect precise geolocation from your device unless we tell you otherwise and obtain any consent required.
4.5 Authentication and session information. We collect session tokens and related authentication data. Where you enable the option to remain signed in, that token persists on your device until you sign out or the session expires.
5. Information From Third Parties
5.1 Sign in providers. If you sign in using Apple or Google, that provider transmits to us the identifiers necessary to authenticate you, which typically include a unique user identifier, your name where you permit it, and an email address. If you use a private email relay service offered by a sign in provider, we receive a relay address rather than your personal email address.
5.2 Platform information. Apple and Google provide us with subscription and transaction status so that we can enable or disable paid features.
5.3 Information from other users. Other users may provide information about you, including by inviting you to a Posse using your contact details, by naming you in an answer or quiz response, or by uploading a photograph in which you appear.
5.4 Service providers. Our infrastructure, analytics and messaging providers generate technical information about the operation of the Service, which we receive in the course of operating it.
6. Mood, Vibe Check and Wellbeing Information
6.1 The Mood Mosaic feature records a mood state that you select. If you record a mood, that mood is displayed to the other members of your Posse and is attributed to you by name. Recording a mood is optional and may be skipped.
6.2 Mood entries and Vibe Check responses are self reported expressions shared for social connection. They are not a clinical assessment, a diagnosis, or a record of any medical or psychological condition, and we do not treat them as such.
6.3 We nevertheless recognise that information reflecting a person's emotional state may be treated as sensitive under the laws of some states, including as consumer health data under the laws of Washington and Nevada. We therefore apply additional protections to this information.
6.4 We use mood information only to operate the mood features of the Service, which means displaying your mood to the members of your Posse, showing you your own record, and providing related in application functionality.
6.5 We do not sell mood information. We do not use mood information for advertising or for cross context behavioural advertising. We do not use mood information to build inferences about your health, and we do not disclose mood information to any third party for that third party's own purposes.
6.6 You may delete your mood entries and withdraw any consent you have given in relation to mood information as described in Section 20 and in the Consumer Health Data Privacy Notice below.
7. Contacts and Invitations
7.1 The Service allows you to invite others to a Posse by sharing an invitation code or invitation link. Where you share an invitation using your device's sharing tools, the sharing takes place through the application you select and is subject to that application's own terms.
7.2 If we ask for permission to access your device contacts, we will explain the purpose at the time and you may decline. Declining does not prevent you from using the Service. You may withdraw the permission at any time in your device settings.
7.3 Where we receive contact information relating to a person who is not a user of the Service, we use it only for the purpose of the invitation for which it was provided, and we do not use it to build a profile of that person or for marketing.
7.4 If you provide us with another person's contact information, you confirm that you are entitled to do so.
8. Media and Device Permissions
8.1 The Service may request permission to access your camera or photo library so that you can upload a profile image or share media within a Posse. We access only the content you select.
8.2 The Service may request permission to send push notifications. Push notification tokens are used to deliver notifications to your device and are handled by our notification provider.
8.3 You may grant, refuse or withdraw any device permission at any time in your device settings. Withdrawing a permission may limit the availability of the related feature.
9. How We Use Personal Information
9.1 We use personal information to: (a) create and administer your account; (b) authenticate you and secure your account; (c) create, operate and administer Posses and deliver content to their members; (d) present Anchor Questions, quizzes, polls, Vibe Checks and the Mood Mosaic; (e) maintain the Journal and other archives within a Posse; (f) operate streaks, leaderboards and virtual items; (g) provide and administer MyPosse Premium; (h) send transactional, security and service communications; (i) send engagement notifications in accordance with your notification preferences; (j) provide customer support and respond to your requests; (k) monitor, investigate and enforce our Terms of Use, Community Guidelines and Acceptable Use Policy; (l) protect the safety of users, in particular minors, and the security and integrity of the Service; (m) analyse usage in order to maintain, troubleshoot and improve the Service; and (n) comply with Applicable Law and respond to lawful requests.
9.2 We do not use the content of your Anchor Question answers, messages or mood entries to target advertising to you.
9.3 Where we use information for analytics, we use aggregated or de identified information wherever it is practicable to do so. Where we hold de identified information, we maintain it in de identified form and do not attempt to re identify it, except as permitted by Applicable Law to test the effectiveness of our de identification.
10. Legal Bases and Consent
10.1 Where Applicable Law requires a legal basis for processing, we rely on the following: performance of our contract with you, in order to provide the Service you have requested; our legitimate interests in securing the Service, preventing abuse, and improving our product, where those interests are not overridden by your rights; compliance with legal obligations; and your consent, where consent is required.
10.2 We rely on your consent for the collection and sharing of mood information where such consent is required, for access to device permissions, and for optional communications. You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
10.3 We do not make any statement in this Privacy Policy that we comply with any particular legal framework or certification unless we say so expressly. Where a specific statutory right applies to you, it is described in Section 19.
11. How Information Is Shared Within a Posse
11.1 Content you share within a Posse is visible to every member of that Posse. This includes your name, your profile image, your answers to Anchor Questions, your messages, media you upload, your quiz and poll responses, your Vibe Check responses, your mood entries and your streak activity.
11.2 Answers to Anchor Questions operate reciprocally. Other members' answers are hidden from you until you submit your own. Once you submit an answer, it becomes visible to the members of the Posse.
11.3 Content retained in the Journal may be visible to members who join the Posse after the content was created. Anyone with a valid invitation code or link may be able to join a Posse and view retained content.
11.4 Members may be able to save, screenshot or copy content shared within a Posse. We cannot control what a member does with content after they have seen it, and we are not responsible for any copy retained outside the Service.
11.5 The Service does not provide end to end encrypted messaging. Content is protected in transit and at rest by the measures described in Section 17, but it is technically accessible to us in the course of operating the Service.
12. Disclosure to Service Providers and Others
12.1 We disclose personal information to service providers who process it on our behalf and under contract, restricted to the purposes we specify. The categories of provider we use include: cloud hosting and storage; authentication; database and backend infrastructure; push notification delivery; transactional email and messaging; product analytics and crash reporting; customer support tooling; and, in respect of subscriptions, the app store operators.
12.2 We require our service providers to protect personal information, to process it only on our instructions, and not to use it for their own purposes.
12.3 We may disclose personal information where we believe in good faith that disclosure is necessary to: comply with Applicable Law or a lawful request from a public authority; enforce our Terms of Use and related policies; detect, prevent or address fraud, security or technical issues; or protect the rights, property or safety of MyPosse, our users or the public, in particular where the safety of a minor is engaged.
12.4 We may disclose personal information in connection with a merger, acquisition, financing, reorganisation or sale of assets, or in the course of due diligence for such a transaction, subject to appropriate confidentiality protections. Where personal information becomes subject to a different privacy policy as a result, we will notify you.
12.5 We may disclose aggregated or de identified information that cannot reasonably be used to identify you.
13. No Sale and No Cross Context Behavioural Advertising
13.1 We do not sell personal information for money, and we do not share personal information for cross context behavioural advertising, as those terms are defined under the California Consumer Privacy Act as amended by the California Privacy Rights Act.
13.2 We do not sell or share the personal information of any user we know to be under 16 years of age.
13.3 We do not sell consumer health data, including mood information, and we do not disclose it in exchange for anything of value.
13.4 If we ever intend to change any of these positions, we will update this Privacy Policy, give notice before the change takes effect, and obtain any consent required by Applicable Law.
14. Cookies and Similar Technologies
14.1 The mobile application does not use browser cookies. It uses local storage on your device, software development kits and device identifiers in order to operate, to keep you signed in and to understand how the application is performing.
14.2 Where we operate a website, that website may use cookies and similar technologies. The categories of cookie used, their purposes, and the choices available to you are described in our Cookie Policy below.
14.3 You can manage device level identifiers through the privacy settings on your device, including any setting which limits advertising tracking.
15. Notifications and Communications
15.1 We send service communications that are necessary to operate your account, including verification codes, security alerts, billing notices and notices of changes to our terms. You cannot opt out of these while you hold an account.
15.2 We send engagement notifications, such as reminders relating to Anchor Questions, streaks and Posse activity. You may manage these in the notification preferences within the Service and in your device settings.
15.3 Where we send marketing communications, we do so only where permitted by Applicable Law, and every such communication contains an unsubscribe mechanism.
15.4 Where we send messages to a mobile telephone number, we do so in accordance with Applicable Law and any consent requirements that apply. Message and data rates may apply.
16. Data Retention
16.1 We retain personal information for as long as necessary for the purposes described in this Privacy Policy, and thereafter only where retention is required by Applicable Law or is necessary for the establishment, exercise or defence of legal claims.
16.2 Account information is retained while your account is active. Following deletion of your account, we delete or de identify account information within a reasonable period, subject to Section 16.5.
16.3 Content shared within a Posse, including Anchor Question answers and Journal entries, is retained while the Posse exists, and may remain visible to the members of that Posse after you leave the Posse or delete your account, because it forms part of a shared record contributed to by several people. Section 20 explains how to request removal of such content.
16.4 Mood entries are retained in accordance with the Consumer Health Data Privacy Notice and are deleted when you delete them or when your account is deleted.
16.5 Log, security and transaction records may be retained for a longer period where necessary for security, fraud prevention, accounting or legal compliance purposes.
16.6 Backups are overwritten in the ordinary course of business. Information deleted from the live Service may persist in backup media for a limited period before being overwritten.
17. Information Security
17.1 We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorised access, disclosure, alteration and destruction. These include encryption of data in transit, access controls, authentication requirements, logging and monitoring, and restriction of access to personnel who require it.
17.2 No method of transmission or storage is completely secure. We cannot guarantee absolute security, and you provide information at your own risk.
17.3 You are responsible for keeping your account credentials confidential and for the security of the devices on which you remain signed in.
17.4 Where we are required by Applicable Law to notify you of a security incident affecting your personal information, we will do so without undue delay and in accordance with the applicable requirements.
18. Children's Privacy
18.1 The Service is not directed to children under 13 and we do not knowingly collect personal information from children under 13.
18.2 We collect a date of birth at registration in order to apply our minimum age requirement.
18.3 If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information and terminate the associated account promptly.
18.4 A parent or legal guardian who believes that a child under 13 has provided personal information to us may contact us using the details in Section 2 to request review and deletion of that information and to refuse further collection.
18.5 A Posse designated as a "Family" Posse is subject to the same minimum age requirement. Members are responsible for not inviting any person under 13 to a Posse.
19. Your Privacy Rights
19.1 Depending on where you live, you may have some or all of the following rights in respect of your personal information: the right to know what personal information we have collected, the sources from which it was collected, the purposes for which it is used, and the categories of recipient to whom it is disclosed; the right to access and to obtain a copy of your personal information in a portable format; the right to correct inaccurate personal information; the right to request deletion of your personal information; the right to opt out of the sale of personal information, of sharing for cross context behavioural advertising, and of certain profiling; the right to limit the use and disclosure of sensitive personal information; and the right not to receive discriminatory treatment for exercising a privacy right.
19.2 Residents of California have these rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act. Residents of other states which have enacted comprehensive consumer privacy legislation, including Virginia, Colorado, Connecticut, Utah and Texas, have rights under the legislation of their state. The precise scope of each right, and the exceptions to it, are determined by the law of your state.
19.3 We do not sell or share personal information as described in Section 13, so no opt out of sale or sharing is required for our current practices. We nevertheless honour opt out preference signals transmitted by your browser or device to the extent required by Applicable Law.
19.4 Where we hold information which qualifies as sensitive personal information, we use it only for the purposes permitted without a right of limitation, namely to provide the Service you have requested, to secure it and to comply with law.
19.5 Rights in respect of consumer health data, including the right to withdraw consent and the right to have such data deleted, are described in the Consumer Health Data Privacy Notice below.
19.6 Some rights are subject to exceptions. For example, we may be unable to delete information which we are required to retain by law, or which is necessary to complete a transaction, to detect security incidents, or to defend legal claims. Where we decline a request in whole or in part, we will tell you why.
20. How to Exercise Your Rights
20.1 You may exercise your rights by using the account settings within the Service, or by contacting us using the details in Section 2. Your request should identify the right you wish to exercise and the account to which it relates.
20.2 You may delete your account through the Service or by contacting us. Deleting the application from your device does not delete your account.
20.3 We will verify your identity before acting on a request. Verification will usually involve confirming control of the email address or telephone number associated with your account, and we may ask for additional information where a request concerns sensitive information. We use information provided for verification only for that purpose.
20.4 We will respond to a request within the period required by Applicable Law, which is generally forty five days from receipt, extendable where permitted where the request is complex. We will inform you if an extension is required.
20.5 Where content you contributed remains visible within a Posse after you leave or delete your account, you may contact us to request its removal. We will consider such a request having regard to the rights of the other members who contributed to and rely on the same shared record, and to our obligations under Applicable Law.
20.6 An authorised agent may submit a request on your behalf where permitted by Applicable Law. We will require written proof of the agent's authority and may require you to verify your own identity directly.
21. Appeals
21.1 If we decline a request to exercise a privacy right, you may appeal that decision by contacting us using the details in Section 2 and stating that you wish to appeal.
21.2 We will review the appeal and inform you in writing of the outcome, together with the reasons, within the period required by the law of your state.
21.3 If your appeal is unsuccessful, you may be entitled to submit a complaint to the attorney general of your state or to another competent authority. We will provide information about how to do so when we notify you of the outcome of an appeal.
22. Categories of Information and Purposes at Collection
22.1 The categories of personal information we collect are: identifiers, including name, email address, telephone number, account identifier and device identifier; personal information categories described in state customer records legislation, including name and contact details; commercial information, being records of subscriptions and transactions; internet and network activity, including usage and diagnostic information; approximate location derived from internet protocol address; audio, electronic and visual information, being photographs and other media you upload; inferences drawn for the operation of the Service; and sensitive information, being information which reveals emotional state where it is treated as sensitive or as consumer health data under Applicable Law.
22.2 The sources of this information are: you, your device, other users of the Service, our service providers, and the app store operators.
22.3 The business purposes for which each category is used are set out in Section 9, and the categories of recipient are set out in Section 12.
22.4 The retention periods applicable to each category are described in Section 16.
23. Users Outside the United States
23.1 MyPosse is established in the United States and the Service is operated from the United States. If you access the Service from outside the United States, your personal information will be transferred to and processed in the United States, where data protection laws may differ from those of your country.
23.2 Where you are located in a jurisdiction which restricts international transfers of personal information, you should consider that restriction before using the Service, and we will implement such transfer safeguards as Applicable Law requires of us.
23.3 We do not make any representation in this Privacy Policy that our processing satisfies the requirements of any particular non United States data protection regime. Where obligations under such a regime apply to us, we will comply with them.
24. Automated Processing and Artificial Intelligence
24.1 We do not carry out automated decision making that produces legal effects concerning you or that similarly significantly affects you.
24.2 We may use automated tools, which may include machine learning systems, to generate, select, rotate or personalise prompts and quiz content, to assist with the detection of abusive content and safety risks, and to support customer service.
24.3 Where an automated tool is used in connection with enforcement action against your account or your content, a human review is available on request as described in the Terms of Use.
24.4 We do not use the content of your messages, Anchor Question answers or mood entries to train generally available artificial intelligence models operated by third parties. If we ever propose to change this position, we will give notice in advance and obtain any consent required by Applicable Law.
25. Changes to This Privacy Policy and Contact
25.1 We may update this Privacy Policy from time to time. Where a change is material, we will notify you through the Service, by email, or by another reasonable means before the change takes effect, and we will update the Effective Date at the head of this document.
25.2 Where a change would involve a new or materially different use of information already collected, and Applicable Law requires your consent for that use, we will obtain your consent before making the change.
25.3 We encourage you to review this Privacy Policy periodically. Previous versions are available from us on request.
25.4 You may contact us about this Privacy Policy by email at privacy@myposse.app, or by post at MyPosse LTD., [Company Address]. Our website is at [Website URL].