Privacy Policy

Introduction

Cien Rios LLC ("we," "our," or "us") operates the Sootheli mobile application and website (collectively, the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

Contact us at: privacy@sootheli.com

1. Information We Collect

1.1 Information You Provide

• Account Information: Name, email address, and password when you create an account
• Payment Information: Billing details processed securely through Stripe (we do not store card numbers)
• Preferences: Sensory preferences and personalization settings you provide during onboarding
• Communications: Messages you send to our support team

1.2 Automatically Collected Information

• Usage Data: Session duration, sounds played, features used (for personalization)
• Device Information: Device type, operating system, unique device identifiers
• Log Data: IP address, access times, app crashes and errors
• Analytics: Anonymized usage patterns (opt-in only)

1.3 Information We Do NOT Collect

• Health or medical data
• Biometric data
• Precise location data
• Microphone or camera recordings

2. How We Use Your Information

• Provide Service: Deliver ASMR content and personalized recommendations
• Process Payments: Manage subscriptions and billing
• Improve Service: Analyze usage to enhance features and fix bugs
• Communications: Send service updates, security alerts, and support messages
• Marketing: Send promotional content (only with your explicit consent)
• Legal Compliance: Comply with applicable laws and regulations

3. How We Share Information

We never sell your personal data.

We may share information with:

• Service Providers: Stripe (payments), Supabase (database), Sentry (error tracking), Firebase (analytics)
• Legal Requirements: When required by law, court order, or government request
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: When you explicitly agree to share

4. Data Retention

• Active Accounts: Data retained while your account is active
• Deleted Accounts: Data permanently deleted within 30 days of account deletion
• Analytics Data: Anonymized after 24 months
• Legal Requirements: Some data may be retained longer if legally required

5. Your Rights (GDPR/CCPA)

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Portability: Export your data in a machine-readable format
• Opt-Out: Unsubscribe from marketing communications
• Restrict Processing: Limit how we use your data
• Non-Discrimination: We will not discriminate against you for exercising these rights

To exercise these rights, contact us at privacy@sootheli.comor use the "Export My Data" and "Delete Account" features in the app settings.

6. Data Security

• TLS 1.3 encryption for all data in transit
• AES-256 encryption for data at rest
• Regular security audits and penetration testing
• Access controls and authentication requirements
• Incident response procedures

7. Children's Privacy

Sootheli is not directed to children under 13 (or the minimum digital consent age in your jurisdiction).

• We do not knowingly collect data from children under 13
• Users ages 13-17 require parental consent
• If we discover we have collected data from a child under 13, we will delete it immediately
• Parents may contact us at privacy@sootheli.com to request deletion of their child's data

8. International Data Transfers

Your data may be processed in the United States, which may have different privacy protections than your country of residence. By using the Service, you consent to this transfer. We use standard contractual clauses and other safeguards to protect data during international transfers.

9. Third-Party Services

10. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes via email or in-app notification at least 30 days before they take effect. Continued use of the Service after changes constitutes acceptance of the updated policy.

11. Contact Us

For privacy inquiries:

• Email: privacy@sootheli.com
• Support: support@sootheli.com
• Company: Cien Rios LLC