Privacy Policy

This Privacy Policy explains how Balans IQ processes personal data when you use the individual Life OS application, including Daily Check-in, Command Chat, Pattern Lab, Life Plan, Life Circles, Weekly Review, monthly review, badges, billing, and support channels.

It applies to: account registration data, check-in entries, chat messages, AI-generated responses and plans, mood inputs, behavioral analysis, Life Plan outputs, subscription and billing records, device metadata, consent records, and all information you voluntarily submit through the service.

This policy is written for global use and is designed to comply with the UK GDPR, EU GDPR (Regulation 2016/679), the Serbian Law on Personal Data Protection (Zakon o zaštiti podataka o ličnosti, Sl. glasnik RS br. 87/2018 — ZPDP), the California Consumer Privacy Act (CCPA) as amended by the CPRA, and similar privacy frameworks applicable in your jurisdiction. Where mandatory local consumer law provides stronger protections, those protections apply.

Regional annexes at the end of this policy provide jurisdiction-specific information for EU/EEA users (Annex A), Serbian users (Annex B), and US-based users (Annex C). If you are located in one of those regions, the relevant annex applies in addition to the global sections above.

Data controller: TRIAXIS LTD, Company Number 16978369, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

ICO Registration Number: C1949442. TRIAXIS LTD is registered with the Information Commissioner's Office (ICO) as a data controller under the UK GDPR.

Privacy contact and data subject rights requests: office@balanscare.com. TRIAXIS LTD does not currently designate a separate Data Protection Officer; all DPO-equivalent communications are handled by our privacy team at the address above.

If your account is sponsored or provisioned by an employer through the HR platform, your employer may also act as an independent data controller for employment-related decisions. In that case, both this policy and your employer's privacy practices will apply to the relevant data.

EU/EEA representative: EU/EEA data subjects may direct inquiries to the UK establishment address above and may also contact the supervisory authority in their country of residence. Where an EU representative is required, that appointment will be communicated via this policy.

Identity and account data: full name, email address, bcrypt-hashed password, preferred language, timezone, avatar, and system-generated account identifiers (UUIDs).

Life OS content: all check-in entries, chat messages you send and AI responses you receive, mood inputs, Life Plan outputs, task completion status, daily behavioral patterns, and feature interaction logs.

AI interaction data: text content submitted to AI models for processing (Daily Check-in, reflection, Command Chat, Weekly Review, monthly review, Life Plan analysis, Pattern Lab sessions), language detected from your text, raw and structured AI outputs stored server-side.

Technical and security data: IP address at login and key actions, session tokens (HttpOnly JWT cookies), browser type and version, device type, consent records (legal acceptance timestamps and version hashes), and fraud-prevention signals.

Billing and commercial data: subscription tier, subscription start and end dates, Airwallex payment intent identifiers and consent identifiers, billed currency, IQ credit balance and transaction log, and support history.

Life Circles data: if you join or create a Life Circle, your messages, circle membership, and participation history are stored in association with the circle identifier.

Balans IQ offers an optional encrypted mode for sensitive content. When enabled, your device derives a 256-bit master key locally using PBKDF2-SHA256 with 100,000 iterations and a user-specific salt before encrypting protected payloads.

Protected content is encrypted on the client with AES-256-GCM before upload. The server receives ciphertext, IV, authentication tag, and wrapped key material needed for your own future unlock flow.

When encrypted mode is active: TRIAXIS LTD has no technical ability to access, read, or process the content of your encrypted data. Only metadata necessary for service operation (email address, account creation date, usage statistics, and subscription information) is accessible to us as data operator.

Your master key is wrapped twice on the client: once with your unlock secret and once with your recovery key. We store only the wrapped versions on the server. We do not store your plaintext unlock secret or plaintext master key.

Recovery key design: if you lose both your unlock secret and your recovery key, the encrypted data cannot be recovered by TRIAXIS LTD. This is a deliberate security property, not a support limitation.

Encrypted mode is currently used for encrypted content flows supported by the app. Other account and billing records described in this policy remain protected by transport encryption, access controls, and standard server-side safeguards.

The Android app is a Trusted Web Activity (TWA) wrapper for https://app.balanscare.com and follows the same privacy rules as this policy.

INTERNET permission is required to securely load the app experience and communicate with our API over HTTPS.

POST_NOTIFICATIONS permission is optional and used only if you enable notifications. You can deny or revoke this permission at any time in Android system settings without losing core app functionality.

We do not request location, contacts, microphone, camera, SMS, call logs, or background location permissions for the core Android app experience.

Core AI features — including Daily Check-in analysis, Command Chat responses, Weekly Review generation, monthly review generation, Life Plan creation, and Pattern Lab sessions — require sending relevant portions of your check-in entries and chat history to third-party AI model providers through OpenRouter or equivalent routing infrastructure. No personally revealing metadata beyond your written text is transmitted in those requests.

Language detection: we analyze the textual content of your messages to detect the language and instruct the AI to respond in the same language. This analysis happens server-side and does not result in permanent storage of language labels beyond your session context.

AI-generated outputs (reviews, plans, responses) are stored in our database associated with your account to provide continuity, allow you to review past outputs, and allow the AI to maintain context across conversations.

We do not train any AI model on your private content without explicit separate consent. Your Life OS data is used solely to serve the features you activate — not to improve third-party model weights.

International transfer to AI providers: text content submitted to AI features may be transmitted to OpenRouter and downstream AI model providers. This transfer is necessary to deliver core functionality you request. Depending on the model route selected by our infrastructure, relevant text may be processed on servers located outside the EU/EEA/UK, including providers operating infrastructure in the United States or other non-EU jurisdictions. Some model providers available through these routes may be headquartered or operated from China. TRIAXIS LTD relies on applicable provider data processing terms and Standard Contractual Clauses where required by UK/EU GDPR. Provider API policies may prohibit using API-submitted content to train their models, depending on the selected provider.

When you request a Weekly Review, monthly review, Life Plan, or Pattern Lab session, the AI reads recent check-in entries and chat exchanges to produce a coherent, personalised output. You may delete your content at any time, which will affect the quality of future AI outputs.

Mood, emotional signals, and behavioral pattern data derived from check-in entries are processed server-side to generate risk indicators and personal analytics. These outputs are for your personal reflection only. We do not share individual-level behavioral signals with third parties outside this service or your employer (if applicable) beyond the contracted deployment scope.

Balans IQ operates a credit system called IQ Credits. Each AI action (chat message, review generation, Pattern Lab session, Life Plan generation) deducts a defined number of credits from your account balance. Daily Check-in entries and manual task tracking are free.

Free tier accounts receive 30 IQ credits. Paid subscription tiers receive a higher monthly credit allocation that is reset (not accumulated) upon each successful subscription payment or renewal.

Credit balances, transaction history (refills, deductions, action types), and billing references are stored in our database and used to enforce usage quotas, display your balance, and prevent fraud.

Payments are processed by Airwallex. Airwallex stores your payment method details and a payment consent identifier. We store only the non-sensitive reference identifiers returned by Airwallex — we do not store raw card numbers.

Subscriptions auto-renew monthly unless cancelled before the renewal date. We record payment consent identifiers provided by Airwallex to execute authorized renewals on your behalf. Auto-renewal activity is logged in the billing transaction history.

To provide and personalize the service: authenticate your account, serve AI responses, generate reviews and Life Plans, maintain check-in and chat history, manage credits, and display billing status.

To operate billing: process subscription payments, execute authorized auto-renewals via stored payment consent, calculate correct credit allocations, and send subscription confirmation and renewal emails.

To maintain security: detect unauthorized access, block abuse, enforce rate limits, investigate incidents, and maintain audit logs for fraud and legal compliance.

To improve the service: using aggregated and de-identified operational analytics (error rates, feature usage patterns, response latencies). We do not use your private check-in content for product analytics.

To meet legal obligations: tax records, accounting, lawful regulatory requests from public authorities, and compliance with applicable data protection law.

Contract (Article 6(1)(b) UK/EU GDPR; Article 12(1)(b) ZPDP): account creation and management, delivering Command Chat, reviews, Life Plan, Pattern Lab sessions, check-in storage, and subscription billing you request.

Legitimate interests (Article 6(1)(f) UK/EU GDPR; Article 12(1)(f) ZPDP): fraud detection, security monitoring, abuse prevention, service diagnostics, product improvement using aggregated data, and business continuity planning — where these interests are not overridden by your rights.

Consent (Article 6(1)(a) UK/EU GDPR; Article 12(1)(a) ZPDP): legal acceptance records at account creation, optional marketing communications where applicable, and any additional uses specifically flagged at the point of collection. You may withdraw consent at any time by contacting office@balanscare.com; withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Explicit consent for special category (health) data (Article 9(2)(a) UK/EU GDPR): Balans IQ processes psychological and emotional wellbeing data — including mood entries, check-in responses, emotional patterns, and behavioral analytics — which constitutes special category data under UK GDPR Article 9. Processing this data requires your explicit, separate consent provided at registration via a dedicated opt-in. You may withdraw this consent at any time by contacting office@balanscare.com; withdrawal will prevent the AI-driven wellness features from functioning as intended but will not affect the lawfulness of prior processing.

Legal obligation (Article 6(1)(c) UK/EU GDPR; Article 12(1)(c) ZPDP): financial recordkeeping, tax compliance, auditing, sanctions screening, and responding to lawful requests from regulators, courts, or law enforcement.

Automated decision-making: some features (Weekly Review, load-risk indicators, nudges, and Life Plan suggestions) involve automated processing of your behavioral data to generate personalized outputs. These outputs are for personal reflection and planning and do not produce legal or similarly significant effects directly. You may contact office@balanscare.com to request human review of any automated output or to object to this processing.

If your Balans IQ account is linked to an employer-sponsored HR platform deployment, authorized administrators within your employer's account may receive aggregated analytics, risk indicators, or performance-related outputs generated within that deployment.

Individual check-in entries and personal chat messages are NOT disclosed to your employer unless you explicitly share them. The scope of employer visibility is defined in the employer's contract with TRIAXIS LTD and disclosed during onboarding.

Do not use an employer-sponsored account for content you strictly wish to keep confidential from your employer. TRIAXIS LTD is not responsible for how your employer uses data once lawfully disclosed to them under the applicable contract.

Primary production hosting is provided on Hetzner infrastructure located in the European Union (EU).

Data may be processed in the United Kingdom, European Economic Area, United States, and other jurisdictions where our infrastructure providers (cloud hosting, AI model APIs, payment processing) operate.

Known international transfers: (1) AI processing — OpenRouter and downstream AI model providers, covered by applicable provider terms and SCCs where required. Depending on the selected route, this may include processing on servers outside the EU/EEA/UK, including the United States and other non-EU jurisdictions, and may include model providers headquartered or operated from China; (2) Payment processing — Airwallex, transfers in accordance with Airwallex's privacy policy and applicable contractual safeguards.

For transfers from the UK or EEA to non-adequate countries, we rely on Standard Contractual Clauses (Commission Decision 2021/914 or UK ICO International Data Transfer Agreement) or another legally valid safeguard. You may request a copy of applicable safeguard documentation by contacting office@balanscare.com.

Serbia — transfers outside Serbia: made in compliance with Chapter V ZPDP. Transfer to the UK proceeds under the adequacy findings. Transfer to the US and other non-adequate jurisdictions (AI model providers, Airwallex) proceeds under Standard Contractual Clauses or equivalent mechanisms approved under ZPDP.

We retain account data and Life OS content for as long as your account is active and for up to 2 years after last activity or account closure to support dispute resolution, auditing, and legal obligations. You may request deletion at any time — see Your Rights below.

Billing records and transaction logs are retained for a minimum of seven years to satisfy tax and accounting obligations, even after account deletion.

AI token usage logs are retained for up to 2 years for security, abuse-prevention, and billing validation purposes, then deleted or anonymized.

Depending on your jurisdiction, you may have the right to: access your personal data, correct inaccurate data, request deletion of your account and content, restrict or object to specific processing, receive a portable copy of your data, withdraw consent where processing is based on consent, and not be subject to solely automated decisions with legal or significant effects.

Account deletion is available directly in the app: Profile → Danger Zone → Delete Account & Data. You can also request deletion by contacting office@balanscare.com from your account email address.

To exercise any of these rights, contact office@balanscare.com from the email address associated with your account. We will respond within the timeframe required by applicable law (30 days for UK/EU GDPR and Serbian ZPDP requests; 45 days for US state privacy requests with one 45-day extension where permitted).

UK supervisory authority: Information Commissioner's Office — ico.org.uk.

EU supervisory authority: the data protection authority (DPA) in the EU member state where you reside, work, or where the alleged infringement occurred. Directory of EU DPAs: edpb.europa.eu.

Serbia supervisory authority: Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti — poverenik.rs.

US state rights: California (CCPA/CPRA), Colorado (CPA), Virginia (VCDPA), Texas (TDPSA), and other state privacy laws may provide rights to know, delete, correct, or opt-out. We do not sell personal information for money or share it for cross-context behavioral advertising. Contact office@balanscare.com. We will not discriminate against you for exercising privacy rights.

Passwords are stored as bcrypt hashes — never in plain text. Sessions use HttpOnly JWT cookies with short expiry periods. API endpoints require valid session tokens for all authenticated actions.

All connections to the Balans IQ platform use HTTPS/TLS. Communication between backend services and AI model APIs is encrypted in transit.

Where you enable the optional encrypted mode, protected content is encrypted on your device before upload using AES-256-GCM. Stored server-side wrappers allow only you to unlock that content with your unlock secret or recovery key.

Access to production databases is restricted to authorized personnel. We implement rate limiting, input validation, and SQL injection protections across all API endpoints.

Despite these measures, no system is perfectly secure. You are responsible for keeping your login credentials confidential and notifying us immediately at office@balanscare.com if you suspect unauthorized access.

Balans IQ is not an emergency service, not a medical device, and is not a substitute for medical care, psychotherapy, legal advice, or crisis intervention. If you or someone else is in immediate danger, contact local emergency services immediately.

AI outputs are probabilistic, may contain errors, and must not be relied upon for decisions with significant health, financial, legal, or safety consequences without independent verification.

Do not submit to the service: information that is legally privileged, classified, export-controlled, or that you are not authorized to process under applicable law. We may suspend access to protect the platform or comply with legal obligations.

Your private check-in and chat content is your own. We do not sell, rent, or monetize your personal Life OS content to third parties.

This annex supplements the global policy for users in EU/EEA member states and provides information required by Articles 13 and 14 of EU GDPR (Regulation 2016/679).

Data controller for EU/EEA purposes: TRIAXIS LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. Privacy contact: office@balanscare.com.

Recipients and categories of recipients: cloud hosting providers (EU/UK); OpenRouter and downstream AI model providers (AI processing, covered by SCCs where required); Airwallex (payment processing, covered by their DPA and applicable safeguards); professional advisors under confidentiality obligations; law enforcement or regulators where legally required.

Transfer mechanisms: transfers to the UK rely on the EU adequacy decision for the UK (adopted June 2021). Transfers to the US and other non-adequate jurisdictions (AI model providers, Airwallex) rely on Standard Contractual Clauses (SCCs, Commission Decision 2021/914) or equivalent safeguards. You may request a copy of applicable SCCs by contacting office@balanscare.com.

Where processing is based on legitimate interests, you have the right to object at any time by contacting office@balanscare.com. We will assess your objection and cease processing unless we can demonstrate compelling legitimate grounds that override your rights.

Retention: account and Life OS data up to 2 years after account closure; billing records minimum 7 years for EU accounting compliance. After retention periods, data is deleted or anonymized.

Right to lodge complaint: supervisory authority in your EU member state of habitual residence, place of work, or place of alleged infringement. See edpb.europa.eu/about-edpb/board/members for the full directory of EU national DPAs.

This annex applies to users located in the Republic of Serbia, in accordance with the Law on Personal Data Protection (Official Gazette of the RS, No. 87/2018 — ZPDP).

Controller: TRIAXIS LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. Contact: office@balanscare.com.

Your rights under ZPDP include: right of access (Art. 26), rectification and completion (Art. 29), erasure (Art. 30), restriction of processing (Art. 31), data portability (Art. 36), objection (Art. 37), not being subject to solely automated decision-making (Art. 38), and withdrawal of consent (Art. 15(3)). Send requests to office@balanscare.com.

Cross-border transfers outside Serbia: transfers to the United Kingdom are based on an adequacy decision. Transfers to the US and other non-adequate jurisdictions (AI model providers, Airwallex) are performed under Standard Contractual Clauses or another legal basis recognized under ZPDP.

Complaint to the Commissioner: if you believe your personal data is processed contrary to ZPDP, you may file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection. Address: Bulevar kralja Aleksandra 15, 11000 Belgrade. Web: poverenik.rs.

This annex supplements the global policy for residents of US states with applicable privacy laws, including California, Colorado, Virginia, Texas, and other states with comprehensive consumer privacy legislation.

Categories of personal information collected in the past 12 months: identifiers (name, email, UUID); commercial information (subscription tier, billing references); internet or other electronic network activity information (logs, session tokens, device type); inferences drawn to create a profile about behavioral patterns (mood trends, load indicators, Life Plan outputs); and sensitive personal information (mood data and check-in entries processed for AI features).

Purposes for collection: as described in the Why We Use Your Data section. Personal information is collected and used for disclosed business purposes only.

Sale and sharing: TRIAXIS LTD does not sell personal information for monetary consideration. We do not share personal information for cross-context behavioral advertising. We do not knowingly sell or share personal information of users under the age of 16.

Sensitive personal information: Life OS check-in content and mood data may qualify as sensitive personal information under CPRA and similar state laws. We use this data only to deliver the services you request and do not use it for inferring unrelated characteristics.

Your California rights (CCPA/CPRA): right to know what personal information is collected, used, disclosed, or sold; right to delete; right to correct inaccurate personal information; right to opt-out of sale/sharing (not applicable — we do not sell); right to limit use and disclosure of sensitive personal information; right to non-discrimination for exercising CCPA rights. Submit requests to office@balanscare.com.

Other US state rights (Colorado CPA, Virginia VCDPA, Texas TDPSA, and similar): access, correct, delete, data portability, opt-out of targeted advertising (not applicable), opt-out of sale (not applicable), opt-out of profiling for decisions with significant effects. Contact office@balanscare.com. Response within 45 days, with one 45-day extension where necessary.