Privacy Policy

1. Important Information

1.1 Ayda Is Not a Medical Service

Ayda provides wellness coaching, not medical treatment or therapy. Ayda is an AI-powered assistant that offers general wellness information and evidence-based anxiety management techniques such as breathing exercises, grounding techniques, and cognitive reframing.

Ayda is NOT:

• A licensed mental health professional
• A substitute for professional medical advice, diagnosis, or treatment
• An emergency service

If you are experiencing a mental health crisis or emergency, please contact emergency services (911 in the US) or a crisis hotline such as the 988 Suicide and Crisis Lifeline immediately.

1.2 AI-Powered Service

Ayda uses artificial intelligence (AI) to provide coaching responses. Specifically:

• Your conversations are processed by Claude (developed by Anthropic), hosted on AWS Bedrock
• The AI analyzes your messages to provide personalized coaching suggestions
• The AI maintains a memory of your conversations to provide continuity
• Responses are generated automatically by AI, not written by humans
• Your data is not used to train AI models when processed through AWS Bedrock

We are transparent about our use of AI because we believe you have the right to know how our service works.

2. Information We Collect

2.1 Information You Provide Directly

2.2 Information Collected Automatically

3. How We Use Your Information

3.1 To Provide the Service

• Deliver AI coaching responses to your messages
• Maintain conversation context and memory across sessions
• Send scheduled check-ins at times you prefer
• Process and manage your subscription

3.2 To Improve and Personalize the Service

• Understand which coaching techniques work best for you
• Adapt communication style to your preferences
• Track your progress toward wellness goals
• Improve our AI models and coaching approaches (using aggregated, anonymized data only)

3.3 To Communicate With You

• Send service-related messages (check-ins, reminders)
• Respond to your inquiries or support requests
• Notify you of important changes to the service or this policy

4. Legal Basis for Processing (GDPR)

Under the GDPR, we must have a lawful basis for processing your personal data. We rely on the following bases:

4.1 Consent for Sensitive Data

Because Ayda processes information relating to your mental health and emotional wellbeing, this constitutes "special category data" under GDPR Article 9. We process this data based on your explicit consent, which you provide when you:

1. Initiate a conversation with Ayda on WhatsApp
2. Actively share information about your anxiety and wellness goals
3. Continue using the service after reading this Privacy Policy

You may withdraw consent at any time by contacting us at contact@morpheus.agency or by sending "STOP" to Ayda. Withdrawal of consent will not affect the lawfulness of processing before withdrawal.

5. How We Share Your Information

We do not sell your personal information. We share your information only with the following categories of recipients:

5.1 Service Providers

All service providers are bound by data processing agreements requiring them to protect your data and use it only for the specified purposes.

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5.3 Business Transfers

If Morpheus is involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change.

6. International Data Transfers

Morpheus Agency is based in France (European Union). When you use our service, your data may be transferred to and processed in the United States by our service providers.

For transfers of personal data outside the European Economic Area (EEA), we implement appropriate safeguards including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data Processing Agreements with all processors
• Technical measures including encryption in transit and at rest

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this policy:

When data is no longer needed, it is securely deleted or anonymized.

8. Your Privacy Rights

8.1 Rights Under GDPR (All Users)

As a company based in France, we extend GDPR rights to all users regardless of location:

8.2 Additional Rights for California Residents (CCPA/CPRA)

If you are a California resident, you have the following additional rights:

• Right to Know: Request information about what personal information we collect, use, and disclose
• Right to Delete: Request deletion of your personal information
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: Opt out of the sale or sharing of your personal information (Note: We do not sell or share your personal information)
• Right to Limit Use of Sensitive Personal Information: Limit our use of sensitive personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

We do not sell or share your personal information as defined by the CCPA/CPRA.

8.3 How to Exercise Your Rights

To exercise any of your privacy rights, you may:

• Email: contact@morpheus.agency
• WhatsApp: Send "PRIVACY REQUEST" to Ayda

We will respond to your request within:

• GDPR: 30 days (may be extended by 60 days for complex requests)
• CCPA: 45 days (may be extended by 45 days with notice)

9. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption: Data encrypted in transit (TLS 1.3) and at rest (AES-256)
• Access Controls: Role-based access limited to authorized personnel
• Infrastructure: Hosted on secure, SOC 2 compliant infrastructure
• Monitoring: Continuous security monitoring and logging
• Vendor Security: All service providers meet rigorous security standards

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

10. WhatsApp-Specific Information

10.1 Consent to Messaging

By initiating a conversation with Ayda on WhatsApp, you consent to receive messages from us. This includes:

• Responses to your messages
• Scheduled check-ins (at times you specify)
• Service-related notifications

10.2 Opting Out

You can opt out of receiving messages at any time by:

• Sending "STOP" to Ayda
• Contacting us at contact@morpheus.agency

Opting out will end your access to the coaching service.

11. Children's Privacy

Ayda is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us at contact@morpheus.agency, and we will delete such information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you via WhatsApp or email (if we have your email address)
• For significant changes affecting your rights, request renewed consent if required

We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Morpheus Agency SAS
Email: contact@morpheus.agency

13.1 Data Protection Contact

For GDPR-related inquiries, you may contact our Data Protection contact:
Email: privacy@morpheus.agency

13.2 Supervisory Authority

If you are in the European Union and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with a supervisory authority. For France:

CNIL (Commission Nationale de l'Informatique et des Libertes)
3 Place de Fontenoy, TSA 80715
75334 Paris Cedex 07, France
Website: https://www.cnil.fr

14. Summary of Key Points