Privacy Policy
Last updated: March 19, 2026
This Privacy Policy explains what personal data is collected when you use the Haply mobile application ("App"), our website located at https://makehaply.com (the "Website") and related services (together with the App and the Website, the "Services"), how such personal data will be used, shared or otherwise processed.
1. Categories of Personal Data We Collect
We collect data you give us voluntarily (for example, when you enter your coaching preferences, name, or email). We also may receive data about you from third parties (for example, when you sign in via Google or Apple). We also collect data automatically (for example, your IP address, activity logs) and use third-party service providers for such collection.
Data you provide directly:
- Name, email address, and profile information
- Coaching preferences, goals, and onboarding quiz answers
- Messages and conversations with your AI coach
- Feedback, survey responses, and support inquiries
- Payment information (processed securely by third-party payment processors)
Data collected automatically:
- Device information (device type, operating system, unique device identifiers)
- Log data (IP address, access times, pages viewed, app activity)
- Usage data (features used, session duration, coaching interactions, habit tracking data)
- Location data (approximate location based on IP address)
2. For What Purposes We Process Your Personal Data
We process your personal data for the following purposes:
- To provide the Services: delivering personalized AI coaching sessions (including sending your messages to our AI provider to generate responses), managing your account, processing subscriptions
- To improve the Services: analyzing usage patterns, conducting research, developing new features
- To personalize your experience: customizing coaching content based on your goals and preferences
- To communicate with you: sending service-related notifications, responding to support inquiries, sharing updates
- To ensure security: detecting and preventing fraud, abuse, and other harmful activities
- To comply with legal obligations: fulfilling regulatory requirements and responding to legal requests
3. Legal Bases for Processing (EEA Users)
If you are located in the European Economic Area (EEA), we process your personal data based on the following legal grounds:
- Contractual necessity: processing necessary to fulfill our contractual obligations to you
- Legitimate interests: processing necessary for our legitimate business interests, such as improving and securing our Services
- Consent: processing based on your explicit consent, which you can withdraw at any time
- Legal obligation: processing necessary to comply with applicable laws
4. Third-Party AI Service — Use of OpenAI
Important: Haply uses OpenAI's API to power its AI coaching features.
When you interact with your AI coach in the App, the following data may be sent to OpenAI, L.L.C. ("OpenAI"), a third-party artificial intelligence service provider, in order to generate personalized coaching responses:
- Messages you send to your AI coach during coaching sessions
- Coaching context such as your selected goals, preferences, and progress data necessary to personalize responses
- Session metadata such as conversation history within a session to maintain context
What is NOT sent to OpenAI:
- Your name, email address, or account credentials
- Your payment or billing information
- Your precise location data
- Your device identifiers or IP address
How OpenAI handles your data:
- Haply uses OpenAI's API with the zero data retention (ZDR) policy where available, meaning OpenAI does not store your inputs or outputs for training purposes.
- Data sent to OpenAI is encrypted in transit using TLS.
- OpenAI processes the data solely to generate a response and does not use your data to train or improve its models.
- OpenAI's data handling practices are governed by their API Data Usage Policy.
Your consent: Before your first AI coaching interaction, the App will ask for your explicit consent to share data with OpenAI. You may withdraw this consent at any time through the App settings, though this will limit your ability to use AI coaching features.
5. With Whom We Share Your Personal Data
We may share your personal data with the following categories of recipients:
- AI service provider (OpenAI): coaching messages and context data are sent to OpenAI, L.L.C. to generate AI coaching responses, as described in detail in Section 4 above
- Service providers: third-party companies that help us operate, maintain, and improve the Services (e.g., cloud hosting, analytics, payment processing)
- Business partners: trusted partners who assist in delivering features or promotional offers
- Legal authorities: when required by law, regulation, or legal process
- Corporate transactions: in connection with a merger, acquisition, or sale of assets
We do not sell your personal data to third parties. All third-party service providers, including OpenAI, are contractually obligated to protect your data and use it only for the purposes specified.
6. How You Can Exercise Your Privacy Rights
Depending on your location, you may have certain rights regarding your personal data, including:
- The right to access your personal data
- The right to rectify inaccurate data
- The right to delete your data
- The right to restrict processing
- The right to data portability
- The right to object to processing
- The right to withdraw consent
To exercise any of these rights, please contact us at info@makehaply.com.
7. Age Limitation
We do not knowingly collect or solicit personal data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any personal data about yourself to us. If we learn that we have collected personal data from a child under age 16, we will delete that data as quickly as possible.
8. International Data Transfers
Your personal data may be transferred to, and maintained on, servers located outside of your state, province, country or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction. We ensure that appropriate safeguards are in place to protect your personal data during such transfers.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last updated" date. We encourage you to review this Privacy Policy periodically. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.
10. Data Retention
We retain your personal data for as long as your account is active or as needed to provide you with the Services. We may also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When your data is no longer needed, we will securely delete or anonymize it.
11. Account Deletion
You can delete your account at any time through the app settings or by contacting us at info@makehaply.com. Upon account deletion, we will delete your personal data within 30 days, except where we are required to retain certain data by law.
12. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at: