This Policy explains what Elata processes, what stays on your device, when derived information can leave it, and how to exercise your choices. It covers the ecosystem while distinguishing independent app operators and external providers.
1. Scope and controller
This Policy covers information processed by Elata across elata.bio, app.elata.bio, our documentation, accounts, hosted-app platform, checkout, platform APIs and related services we operate. The controller for the Services covered here is Elata Holdings Corporation, registered in Delaware, United States (file number 10694817). Contact: info@elata.bio.
The Policy distinguishes platform processing from independently operated applications and services. A listed developer may separately determine how its app processes information and must provide its own notice where needed. Elata Holdings Corporation controls its own account, platform, consent, commerce and operational processing.
Crystal Sciences Association separately operates DAO and token activities. Where such an activity is available, its notice must identify the entity responsible for that processing and any relationship with the Company. A common brand does not mean all personal information is shared between the entities.
Open-source code can be used outside Elata. Merely installing or running an SDK does not necessarily create an Elata account or send data to us. A separately hosted or modified integration may have different practices; consult its operator's notice.
This Policy is a notice about processing, not a blanket request for consent. Where consent is required, it is requested separately for the relevant purpose. Read our Terms of Service for service and developer obligations.
2. Information we collect
The information depends on the features you use.
| Category | Examples and source |
|---|---|
| Account and authentication | Account identifier, sign-in method, email or provider-supplied profile information where provided, linked wallets, session and login records |
| Profile and community | Display name, profile content, reviews, comments, follows, saved apps and information you choose to publish |
| Application records | App-scoped settings, saves, progress, events and scores submitted through platform interfaces |
| Derived session information | Measurements, inferred states and session summaries when an enabled feature and its applicable permission allow their transmission; see Biosignal data |
| Commerce and credits | Product identifiers, purchase and access periods, payer or recipient addresses, transaction hashes, payment status, credit balances and metered usage |
| Developer information | App listings, releases, uploaded code or assets, team roles, product configuration, payout addresses and submission-policy acceptance |
| Support and communications | Messages, contact details, feedback, incident reports and information you provide to resolve a problem |
| Technical and usage information | IP address, browser and device characteristics, pages and features used, event timing, error and performance information, consent and policy-version records |
| AI requests, where used | Submitted messages, uploaded images, relevant conversation context and any optional derived context sent with a request; see AI features |
Do not provide unnecessary sensitive information, wallet private keys or recovery phrases in app fields, feedback, chat or support. A wallet address or derived metric can be personal information when associated with an account or other identifying information.
3. Biosignal data
Raw inputs and derived results are different. Raw inputs include camera frames, microphone audio where a feature uses it, EEG samples and PPG waveforms. Derived results can include heart rate, HRV, respiration estimates, EEG features, inferred affective states, calm/stress measures, session summaries and scores.
The supported capture and processing SDKs are designed to process raw physiological inputs on your device. Elata's hosted-app submission rules prohibit sending captured raw biosignals, webcam frames or microphone audio off the device. Browser permission to access a sensor is not permission to upload its raw output.
This does not mean that all information stays local. App saves, events, scores, account information and commerce records can be stored by Elata. Separately enabled features can transmit permitted derived information for their disclosed purpose. A derived result is not inherently anonymous; it may be personal or sensitive information when linked to you, your account, wallet or session.
Physiological measurements, inferred health-related information and identification-related biometric information can have different legal classifications. We treat potentially sensitive derived information according to its purpose and applicable law rather than assuming it is non-identifying.
Sharing with the Elata Score is separate from sharing context with an AI service or participating in research. See the respective sections below. External applications and modified SDK integrations are governed by their actual implementation and operator notices, not an assurance that every third-party integration is technically identical.
4. Local and cloud storage
On this device. Processing buffers, local application records and compatible local session recordings can use browser storage such as IndexedDB or OPFS. They may remain specific to the device, browser and profile. They are not automatically backed up or synchronized just because you sign in. Clearing site data, changing browsers or losing a device can remove access.
On Elata's servers. Approved platform interfaces can save app-specific settings, progress, events and scores against your account. The platform enforces app-specific access boundaries; one hosted app does not receive general access to another app's records. Cloud storage is not automatically authorized for raw physiological inputs.
Experimental long-session recording and local-analysis integrations are developer-preview capabilities and are disabled in production unless expressly enabled for the relevant deployment. This description does not promise general availability or encrypted cloud synchronization.
Deleting local recordings and deleting server-held account information are separate operations. A server-side request cannot reliably clear all browser copies, downloads, user exports or third-party records. Conversely, clearing browser storage does not erase cloud saves, purchases or public blockchain transactions.
Do not infer end-to-end encryption or an inability for Elata to access cloud records merely from our local-processing architecture. Such a feature requires a specific implementation and disclosure.
5. Score and insights
Where available, the Elata Score combines permitted derived session summaries across participating apps. The current consent purpose is contributing to your cross-app Score, not general permission to reuse your data for anything.
Contributions are off until you grant the separate consent. The consent applies across participating Elata apps as stated in the prompt. A new participating app does not automatically obtain access to all other apps' data. An app also needs the appropriate platform capability; capability and user consent are separate requirements.
We record the consent purpose, version and grant or withdrawal information. Contributions must satisfy the applicable active-consent checks. Material changes to the purpose or consent terms require renewed consent rather than treating an old grant as permission for a new purpose.
Use the available consent controls to stop future contributions. Withdrawing consent and requesting deletion of contributed information are distinct actions; use the provided deletion control or contact info@elata.bio. Stopping contributions does not itself delete purchases, ordinary app saves or information processed on another applicable legal basis.
Scores and insights are automated estimates, not diagnoses or definitive assessments of your emotional state. They may be inaccurate. Profile, leaderboard or sharing visibility should be assessed separately from consent to contribute; contribution consent is not blanket permission to publish sensitive information.
6. Research and model training
We do not treat account registration, acceptance of the Terms, sensor permission, ordinary app use or Score consent as consent to research or model-training reuse of biosignal information.
Any such reuse requires a separate, specific opt-in describing the purpose, information involved, responsible organizations, recipients, retention, withdrawal choices and any additional legally required details. A study also needs its own participant information and consent process where required. Declining optional research or training does not prevent ordinary use of unrelated Services.
Federated learning and other model-improvement approaches may be explored in the future. They are not enabled by this Policy alone. Even if raw inputs stay on a device, transmitted model updates or aggregates can have privacy risks; the relevant notice must describe the actual implementation and safeguards before participation.
Withdrawal stops further processing based on that consent, subject to applicable law. A project must explain how withdrawal and deletion affect contributed records and prior analyses or trained models; we do not promise that every prior result can automatically be reversed. These explanations cannot waive statutory rights.
We do not use biosignal information, including derived physiological or affective measurements, for advertising or advertising audience targeting. We do not authorize hosted developers to do so through the platform.
7. AI features
Some Elata features, including Neural Chat where enabled, use external model providers. A cloud AI request can send the submitted conversation, uploaded images, relevant prior messages, prompts and any optional derived context to Elata's server and the configured provider. Keeping conversation history locally does not make inference local.
The current server integration supports OpenRouter and its selected model provider, or OpenAI as a configured alternative. The active provider and feature configuration determine the recipients. A feature should identify the relevant provider and obtain any required permission before transmitting sensitive context. Permission to contribute to the Elata Score is not permission to send that information to an AI provider.
The Neural Chat implementation keeps conversation history in the browser and handles chat requests without storing a server-side conversation archive in that endpoint. The server can still process request content and retain trial counters, metering, credit transactions, errors or necessary operational records. Provider handling is separate from local history.
User-selected image uploads or text can themselves contain personal information. This is distinct from secretly exporting raw sensor capture; the raw-signal restrictions still apply. Avoid unnecessary sensitive uploads.
We do not claim that every external provider has zero retention or never uses inputs for training. The actual provider configuration and contractual protections must be disclosed for the relevant feature. Our requirement for separate consent to biosignal research or model-training reuse also applies when arranging processing through a provider.
AI outputs can be inaccurate. They are not medical advice, an emergency service or a substitute for professional care.
8. Purposes and legal bases
We process information to deliver requested features, maintain accounts and entitlements, provide support, secure the platform, administer developer distribution and commerce, and meet legal obligations. Optional uses depend on the relevant choice.
Where the GDPR applies, the applicable Article 6 basis depends on the specific processing:
| Purpose | Basis where applicable |
|---|---|
| Accounts, requested app storage, checkout, access and metered services | Performance of a contract or steps requested before entering one, to the extent necessary |
| Optional Score contributions, research or biosignal model-training reuse | Consent for the particular purpose |
| Security, abuse prevention, necessary service diagnostics and support | Legitimate interests where appropriate and after assessing impacts, contract where necessary, or a legal obligation |
| Accounting, lawful disclosures and other mandatory records | Legal obligation where applicable |
| Non-essential cookies or similar tracking, and optional marketing | Consent where required; another lawful basis only where permitted |
Where information qualifies as special-category or otherwise sensitive data, a general Article 6 basis is not sufficient by itself. We must also meet the applicable additional condition, such as explicit consent where required. A contract or generic analytics interest does not authorize unrestricted use of health-related information. Swiss and other applicable laws may impose their own conditions.
Automated scores, app recommendations, usage analysis and fraud controls can involve evaluation of activity. We do not characterize those activities as universally anonymous or as the absence of profiling. If a feature involves a decision producing legal or similarly significant effects, its specific safeguards and required notices must be addressed before use.
9. Cookies, analytics and session replay
We use cookies, local storage and related technologies for login sessions, wallet restoration, preferences, consent records, diagnostics and, where enabled, analytics or experimentation.
The main website integrates Vercel Analytics and Vercel Speed Insights in production. The appstore integrates PostHog for usage events, performance and error information, user identification after sign-in, feature analysis and potentially session replay. Its analytics forwarding route can send information to PostHog's US-hosted infrastructure; forwarding through an Elata URL does not make it self-hosted.
Website session replay means a reconstruction of interactions such as clicks, scrolling and displayed interface content. It is not the same as a locally recorded physiological session. The appstore's replay configuration masks input fields and designated sensitive text. That configuration is not a guarantee that every other visible page element is masked, and biosignal or sensitive content must not be deliberately added to replay or analytics payloads.
Required storage and optional tracking serve different purposes. Non-essential tracking must be subject to the choices required by applicable law. Browser settings can also restrict cookies and storage, but doing so may affect sign-in or other functionality. Contact info@elata.bio for assistance with privacy choices.
We do not use biosignal information for advertising targeting. Do not interpret that commitment as a claim that no service-provider requests occur or that every operational event is anonymous.
10. Sharing and service providers
We disclose information only for the relevant disclosed service or other applicable lawful purpose, including:
| Recipient or category | Purpose and information involved |
|---|---|
| Hosting and infrastructure providers, including Vercel where used | Serving websites and APIs, processing requests, hosting and performance information |
| PostHog where enabled | The usage, identification, diagnostic and replay information described above |
| Authentication and wallet providers, including Google and thirdweb where used | Sign-in, identity verification, embedded-wallet creation or recovery, wallet connection and authorization |
| Email and communications providers, including Resend where used | Requested authentication or service messages and delivery information |
| Configured AI providers | The request content and context described in AI features |
| A hosted application's authorized operators | App-scoped records and appropriate dashboard information, including permitted commerce reporting |
| Payment infrastructure and public blockchain networks | Transaction submission, verification, payment routing and public transaction records |
| Crystal Sciences Association, where a separately identified DAO or token activity requires it | Only information necessary for that disclosed activity under an applicable lawful basis; this Policy does not authorize unrestricted sharing between the entities |
These are integrations supported by the ecosystem, not a representation that every provider is used for every visit. A provider may process data on our instructions or separately under its own responsibilities, depending on the service. A provider's own account, wallet or external website has its own notice.
Usage dashboards can show aggregates with suppression of small groups. Commerce dashboards can show shortened buyer wallet addresses, product or subscription information and transaction links to authorized app managers. These commerce records are not anonymous.
We may disclose information when required by law or reasonably necessary to protect rights and security, subject to applicable safeguards. A business transfer may involve relevant records; applicable notice and protection obligations still apply. Other disclosures require the relevant authorization or lawful basis.
We do not sell personal information or use biosignal information for advertising audience targeting. Rights concerning "sale" or "sharing" can have specific statutory definitions; contact us to exercise applicable rights. This Policy does not grant an unrestricted right to share sensitive information with developers or providers.
11. Public information and blockchains
Information you publish in a profile, review, comment or other public surface may be visible to others. Check the relevant visibility controls before posting. Optional consent to a biosignal feature is not consent to publish all underlying information.
Public blockchain transactions may expose payer and recipient addresses, amounts, transaction hashes and other transaction data. Historic protocol activity may also remain visible. A wallet address is pseudonymous, not necessarily anonymous; account links or public activity can connect it to a person.
We cannot remove or rewrite the underlying public blockchain. We can still assess rights requests concerning our own off-chain copies, account links and associated information. Public availability does not mean that all subsequent use of personal information is unrestricted.
A private profile does not make a public-chain payment private. Do not include raw physiological data or other sensitive information in public-chain transaction data.
12. Retention and deletion
We keep information only as long as needed for its disclosed purpose and applicable legal, accounting, security or dispute requirements. Retention differs by record type:
| Information | Retention approach |
|---|---|
| Account, app saves and settings | While needed to provide the account or app feature; reviewed on deletion or closure requests, subject to necessary legal exceptions |
| Optional Score contributions and consent records | According to the active purpose and deletion choices; limited consent evidence may need to remain for accountability |
| Research or training contributions, if separately enabled | The specific project notice must state its retention and withdrawal arrangements |
| Analytics and usage data | The published maximum is up to 24 months from collection, unless a shorter feature-specific period applies |
| Website session replay | The published maximum is up to 12 months from recording, subject to consent and deletion rights |
| Support communications | Up to 36 months from the last communication, unless a longer period is necessary for a legal obligation or active dispute |
| Mailing-list contact information | Until unsubscribe or deletion, with a wind-down period not exceeding 30 days; a minimal suppression record may be retained to respect the opt-out |
| Purchase, subscription, credit and accounting records | As needed for entitlements, reconciliation, applicable statutory retention and disputes; not automatically erased by disconnecting a wallet |
| Local recordings and local chat history | Controlled by browser or device storage and available local deletion tools; not a promised cloud backup |
| Public blockchain information | Remains on the public network; Elata cannot delete the underlying chain record |
When a record is no longer needed, it should be deleted or appropriately anonymized. Pseudonymization is not anonymization. Backup copies can take additional time to expire and should not be restored into active use except for a legitimate recovery need consistent with the deletion request.
These limits are not permission to keep all information for the maximum period regardless of need. Contact us for the retention applicable to a particular feature or record and to request deletion.
13. Your rights and choices
Depending on applicable law, you may request access, correction, deletion, restriction, portability, information about recipients or processing, and an opportunity to object. Where processing is based on consent, you may withdraw that consent without affecting the lawfulness of prior processing.
Use the available account, consent or local-data controls, or contact info@elata.bio. We may ask for proportionate identity verification. We aim to respond within 30 days and will comply with the legally applicable deadline and permitted extensions.
A deletion request is assessed across the information we control. Some commerce, security, consent-evidence or legal records may need to remain for a limited lawful purpose. We cannot erase an underlying public blockchain, another operator's independent records or every local copy on your devices. We will explain applicable limitations rather than treating them as a blanket refusal of your rights.
Where relevant, residents of California or other jurisdictions may have rights concerning sale or sharing, sensitive-information use, appeals and non-discrimination for exercising privacy rights. Contact us to exercise rights applicable to you.
You may complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC) or another competent supervisory authority, including your local authority where applicable.
14. Children and eligibility
Elata does not specify one numerical minimum age for every Service in these ecosystem policies. Lawful access still depends on the applicable law, legal capacity, permissions, the particular app or study, and any wallet or payment provider requirements. See Eligibility and authority.
We must not collect or use a child's information where legally required parental authorization, direct notice or other safeguards have not been satisfied. Acceptance of the Terms by a guardian is not, by itself, a completed verifiable-parental-consent process. Nor does choosing not to ask every visitor's age remove obligations that otherwise apply.
A feature requiring a verified parental-consent process must not be offered to the affected child until that process and the relevant safeguards are supported. Developers must not market or operate a child-directed hosted application without the required assessment and safeguards.
If you believe a child has provided information without required authorization, contact info@elata.bio. We will investigate, stop or restrict the affected processing and delete information where required. Parents and guardians may contact us to exercise applicable rights for the child. This section does not claim that a general child-account or guardian-verification feature is already available.
15. Security and incidents
We use technical and organizational measures appropriate to the processing, including supported access controls, transport protection, app isolation and consent checks. No system is completely secure, and sandboxing does not guarantee that all apps are harmless.
Do not disclose wallet keys, recovery phrases or unnecessary sensitive records. Report a suspected incident privately to info@elata.bio. We assess incidents, investigate and provide affected people and authorities with notices where required by applicable law.
We do not claim that all platform data is end-to-end encrypted, inaccessible to Elata, or protected by a particular certification. The local SDK architecture and hosted-service security are distinct.
16. International processing and transfers
Elata Holdings Corporation is registered in Delaware, United States. Hosting, analytics, authentication, payment and AI integrations can involve processing in the United States and other countries, depending on the configured provider.
Where applicable law requires a transfer mechanism or additional safeguards, these must be established for the actual recipient and transfer before processing. Mechanisms can include an applicable adequacy arrangement or approved contractual safeguards, where appropriate.
We do not claim that listing these possible mechanisms establishes that every provider or transfer is automatically covered. Contact info@elata.bio for information about recipients, locations and the safeguards applicable to your information.
17. Changes to this Policy
We may update this Policy when practices or legal requirements change. The revision date appears above. Material changes will receive appropriate notice, and any new processing requiring consent will require the relevant new consent before it begins.
Continued use or acknowledgement of an updated notice does not itself constitute consent to optional research, model training or other newly introduced sensitive-data purposes. A planned capability is not authorization to process information before it is enabled and properly disclosed.
18. Contact
For privacy requests, processing questions, parental inquiries or security reports, contact:
Elata Holdings Corporation, registered in Delaware, United States (file number 10694817)
Email: info@elata.bio
Legal notices requiring service on the Company may be directed through its registered agent: Legalinc Corporate Services Inc., 131 Continental Drive, Suite 305, Newark, DE 19713, United States. This is the registered agent's address, not a representation that Elata operates from that location. Ordinary support and privacy requests should use info@elata.bio.
For purchases, refunds, developers and submission rules, see our Terms of Service. For product guidance, see Elata documentation.