Privacy Policy Lighten Journey™

Last updated: August 17, 2026

1. Who we are

Lighten Journey is developed and operated by Mayanfa, a French société par actions simplifiée with a sole shareholder (SASU), registered with the Paris Trade and Companies Register under number 103 704 961 R.C.S. Paris (EUID: FR7501.103704961), with its registered office at 30 rue des Cordelières, 75013 Paris, France (“Mayanfa,” “we,” “us,” or “our”).

For the purposes of applicable data-protection laws, including the EU General Data Protection Regulation (“GDPR”) and the UK GDPR, Mayanfa is the controller of the personal data described in this Privacy Policy.

Privacy contact: support@mayanfa.com

2. Scope

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you use the Lighten Journey mobile application, contact support, or otherwise interact with the Lighten Journey service.

3. Personal data we process

Depending on how you use Lighten Journey and on the technical services enabled in the app, we may process the following categories of data:

  • Account information: Your email address, internal account identifier, authentication information, account status, and account creation or deletion dates.

  • Private journal content: Titles assigned to memories and any personal notes you choose to enter in the app. This content may reveal sensitive information about your emotional life or health.

Option A: This content is stored only on your device and is never transmitted to Mayanfa or its service providers.

Option B: This content is stored on Mayanfa’s servers so that it can be saved and/or synchronized. It is processed only to provide the private journal functionality. It is not used for advertising, profiling, analytics, or product training, and is not routinely accessed by our team.

Option C: This content is end-to-end encrypted. Explain where it is stored, who holds the encryption keys, and whether recovery is possible.

  • Usage and technical data: This may include app version, device type, operating system, language, general or approximate country, IP address, timestamps, session-start and session-completion events, subscription-access events, diagnostic logs, and crash reports. Delete every item that is not actually collected and add any data that is collected but not listed here.

  • Subscription and transaction data: Subscription product selected, subscription status, purchase or transaction identifier, renewal or expiration information, and the storefront used. Apple or Google processes the payment. We do not receive your full payment-card or banking details.

  • Support communications: Your email address and the information you include when contacting us, including any attachments or technical details needed to investigate a request.

4. How we collect data

We collect personal data:

  • directly from you when you create an account, enter content, or contact support;

  • automatically from the app and device when you use Lighten Journey;

  • from Apple or Google when they confirm a subscription transaction or entitlement; and

  • from the service providers identified below, where applicable.

5. Why we process personal data and our legal bases

Where the GDPR or UK GDPR applies, we rely on the following legal bases:

  • Performance of a contract: to create and manage your account, provide access to the app and audio sessions, save or synchronize content where applicable, verify subscription status, and provide support.

  • Legitimate interests: to protect the app and users, prevent fraud and abuse, diagnose failures, and improve reliability using proportionate technical information. We do not rely on this basis where your rights and interests override ours.

  • Consent: where required for optional analytics, notifications, or the processing of sensitive personal data. You may withdraw consent at any time without affecting processing that occurred before withdrawal.

  • Legal obligations: to comply with applicable accounting, tax, consumer-protection, security, and lawful-request obligations.

  • Sensitive data warning: Journal entries and the context of guided emotional sessions may reveal health-related or other sensitive information. If this information is transmitted to Mayanfa’s servers, Mayanfa must identify and implement a valid condition for processing it under Article 9 GDPR/UK GDPR, which may require a clear explicit-consent step.

6. How we use personal data

We use personal data to:

  • create, authenticate, and maintain your account;

  • deliver audio sessions and the private journal functionality;

  • verify and manage subscription access;

  • synchronize data across devices, if this feature exists;

  • respond to support and privacy requests;

  • maintain security, prevent fraud, and troubleshoot technical problems;

  • understand high-level use of the app and improve its reliability, where permitted; and

  • comply with legal obligations.

We do not sell personal data. We do not use private journal content for advertising, ad targeting, profiling, data brokerage, or the training of artificial-intelligence models. We do not share personal data for cross-context behavioural advertising.

7. Service providers and disclosures

We disclose personal data only as necessary to providers acting on our behalf, to Apple or Google in connection with subscriptions, during a lawful business transaction, or where required by law.

Before publication, list every provider that receives personal data and explain its role:

  • Hosting/database/authentication: [PROVIDER, COUNTRY, PURPOSE, DATA RECEIVED]

  • Analytics: [PROVIDER OR “None”]

  • Crash reporting: [PROVIDER OR “None”]

  • Email/support: [PROVIDER, COUNTRY, PURPOSE]

  • Push notifications: [PROVIDER OR “None”]

  • Subscription management/receipt validation: Apple, Google

  • Other SDKs or processors: [TO COMPLETE]

Our providers may process information only for the services they provide to us and under contractual confidentiality and data-protection obligations.

8. International transfers

Mayanfa and its providers may process data outside your country, including outside the European Economic Area or the United Kingdom. Where required, we use an adequacy decision, approved standard contractual clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism. Information about relevant safeguards may be requested at support@mayanfa.com.

9. Data retention

We retain personal data only for as long as necessary for the purposes described above and as required by law.

  • Account information: [EXACT PERIOD OR RULE]

  • Private journal content: [EXACT PERIOD; EXPLAIN WHAT HAPPENS AFTER ACCOUNT DELETION AND BACKUP EXPIRY]

  • Usage analytics: [EXACT PERIOD]

  • Crash and diagnostic logs: [EXACT PERIOD]

  • Subscription and transaction records: [EXACT PERIOD REQUIRED FOR ACCOUNTING/TAX]

  • Support communications: [EXACT PERIOD]

  • Backups: [EXACT MAXIMUM BACKUP-REMOVAL PERIOD]

10. Account deletion

You can request deletion [DESCRIBE THE ACTUAL IN-APP PATH, FOR EXAMPLE: Settings → Account → Delete Account] or contact support@mayanfa.com. We may need to verify your identity before completing a request.

When an account is deleted, personal data associated with that account is deleted or irreversibly anonymized, except for information that we must retain to comply with law, resolve disputes, prevent fraud, or enforce our agreements. Deletion from encrypted backups may occur at the end of the applicable backup cycle stated above.

Deleting your Lighten Journey account does not automatically cancel an Apple App Store or Google Play subscription. Subscriptions must be cancelled separately in the relevant store account settings.

11. Your privacy rights

Depending on where you live, you may have the right to:

  • request access to personal data we hold about you;

  • request correction of inaccurate data;

  • request deletion of personal data;

  • restrict or object to certain processing;

  • receive certain data in a portable format;

  • withdraw consent where processing is based on consent;

  • opt out of the sale or sharing of personal information or targeted advertising, where applicable; and

  • appeal a refusal of a privacy request, where applicable law provides that right.

We will not discriminate against you for exercising a privacy right. To submit a request, contact support@mayanfa.com and state the right you wish to exercise. We may request information reasonably necessary to verify your identity. You may also use an authorized agent where applicable law permits it.

If you are in the EEA, you may complain to the data-protection authority in your country. If you are in the United Kingdom, you may complain to the Information Commissioner’s Office. We encourage you to contact us first so that we can try to resolve your concern.

12. California and other US state notices

Where US state privacy laws apply to Mayanfa, residents may have rights to know, access, correct, delete, or obtain a copy of personal information, and to opt out of its sale, sharing, or use for targeted advertising. Mayanfa does not sell personal information and does not share it for cross-context behavioural advertising.

[CONFIRM WITH COUNSEL WHETHER MAYANFA MEETS THE APPLICABILITY THRESHOLDS OF THE CCPA/CPRA OR OTHER US STATE PRIVACY LAWS. IF IT DOES, ADD THE REQUIRED 12-MONTH CATEGORY DISCLOSURES, REQUEST METRICS IF APPLICABLE, AND A “DO NOT SELL OR SHARE” METHOD IF PRACTICES CHANGE.]

13. Children

Lighten Journey is intended only for people aged 18 or older and is not directed to children under 13. We do not knowingly collect personal data from children under 13. If you believe a child has provided personal data, contact support@mayanfa.com so that we can investigate and delete it where required.

14. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal data. [CONFIRM MEASURES BEFORE ADDING SPECIFICS: encryption in transit, encryption at rest, access controls, logging, backups, and incident response.] No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

15. Automated decision-making

We do not use personal data to make decisions that produce legal or similarly significant effects through solely automated processing.

16. Changes to this policy

We may update this Privacy Policy to reflect changes to Lighten Journey, our providers, or applicable law. We will update the “Last updated” date and provide additional notice where required. Material changes will apply prospectively unless the law permits otherwise.

17. Contact

Mayanfa — SASU

103 704 961 R.C.S. Paris — EUID FR7501.103704961

30 rue des Cordelières, 75013 Paris, France

Email: support@mayanfa.com

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