Legal

Privacy Policy

Last updated: 2026-07-21

The short version

Refrakto is a private coaching tool. This page explains what personal information we collect from you, what we do with it, and the choices you have.

  • Your data is encrypted in transit and at rest.
  • Servers are in the European Union.
  • We never train AI models on your conversations.
  • We never sell your data.
  • You can export or delete everything from Settings in one click.

Refrakto is a coaching tool, not a substitute for licensed mental-health care.

What we collect

We only collect what we need to run the service:

  • Account information — your email address and a password you set. Passwords are stored as secure hashes; we never see them in plain text.
  • Content you share — the messages, notes, and situations you write while using Refrakto.
  • Basic usage information — anonymised events like which features you use and when, so we can improve the product.
  • Payment information — if you subscribe, our payment provider handles your card details. We only store your subscription status.

How we use it

We use your information to provide the service to you: authenticate your account, generate coaching responses, remember your context so future sessions feel continuous, send necessary emails (welcome, receipts, password reset), and understand how the product is used in aggregate.

Who we share it with

We rely on a small number of trusted service providers to operate the service — for example a hosting provider, a database provider, an email sender, an analytics provider, and an AI model provider. Each of them is bound by a data-processing agreement and only processes your data on our instructions. We do not sell your data and we do not share it with advertisers or data brokers.

International transfers

Most of your data stays in the European Union. Where a provider is based outside the EU, we rely on Standard Contractual Clauses (SCCs) to protect your data during the transfer.

How long we keep it

We keep your data for as long as your account exists. When you delete your account, we permanently remove your content. If you have an active subscription, deletion is scheduled for the end of your current billing period so you keep access to what you paid for; you can undo the scheduled deletion any time before it runs.

Aggregate, anonymised usage data may be retained longer for product-improvement purposes.

Your rights

Under EU data-protection law you have the right to access, correct, export, or delete your personal data. You can do all of that from Settings or by contacting us. You can also withdraw your consent at any time and lodge a complaint with the data-protection authority in your country of residence.

To exercise any of these rights, email refrakto.info@gmail.com or use the contact form. We aim to reply within 30 days.

Cookies and similar technologies

Refrakto uses a small number of cookies. Some are strictly necessary to keep you signed in and to keep the site secure — these are always on. Others help us understand how the product is used and are set only if you accept them. We do not use advertising cookies, and we do not track you across other websites.

Children

Refrakto is not intended for children. You must be at least 18 years old to use it, and we do not knowingly collect data from anyone under 18. If you believe a minor has created an account, please contact us and we will delete it.

Changes to this policy

We may update this policy from time to time. When we make material changes, we’ll let you know by email or in the app before they take effect. The “Last updated” date at the top always reflects the current version.

Contact

Questions about this policy? Email refrakto.info@gmail.com or use the contact form.