Privacy Policy

Last updated: 2026-05-23 · Policy version 2026-05-23

1. Information We Collect

1.1 Account Information

• Name and email address
• Password (encrypted)
• Account creation date
• Login activity and session data

1.2 Verification Data (Spark Users Only)

• Phone number for SMS verification
• Identity verification documents (if provided)
• Voice recordings for voice authenticity
• Profile photos
• Background check results (if consented)

1.3 Content You Create

• Pulse: Mood data, daily reflections, voice journals, photos
• Bond: Voice messages, photos, connection information
• Thread: Story content, narrative collections
• Spark: Profile information, match preferences, conversations
• Vault: Archived memories and saved content

1.4 Technical Data

• IP address and device information
• Browser type and version
• Usage analytics (pages visited, features used)
• Error logs and performance data

2. How We Use Your Information

Purpose	Data Used
Provide core services	All account and content data
Verify authenticity (Spark)	Verification data, voice, photos
Improve platform	Usage analytics, technical data
Communicate with you	Email address
Prevent fraud	Verification data, usage patterns
Legal compliance	All data as required by law

3. Data Storage and Security

3.1 Where We Store Data

• Primary database: Google Cloud Firestore, hosted in the nam5 multi-region (data centers in Iowa, Oklahoma, and South Carolina, United States).
• File storage: Google Cloud Storage in the same United States multi-region (used for voice recordings, photos, video, and PDF exports).
• Authentication: Firebase Authentication (Google LLC) for sign-in credentials.
• Email delivery: SendGrid (Twilio Inc.) for transactional email.
• Payments: Stripe, Inc. for card data — we never store full card numbers; EMTRACE only holds tokenized customer identifiers (PCI SAQ A).
• EU-region storage: not yet available. If you are in the EU/EEA and require data residency in an EU region under GDPR Art. 44+, please contact [email protected] before creating an account. Today, every EMTRACE user’s data is processed in the United States under Standard Contractual Clauses where applicable.
• Browser-side caches (localStorage, IndexedDB, Service Worker storage) hold short-lived UI state and offline queues only — not your primary record. Clearing site data does not delete server-side data; use the “Account deletion” flow for that.

3.2 Security Measures

• Password encryption (bcrypt/Argon2)
• HTTPS encryption for all data transmission
• Regular security audits
• Access controls and authentication
• Automated threat detection

4. Data Sharing and Third Parties

4.1 We Share Data With:

• Verification Partners: Twilio (phone), SendGrid (email), Jumio/Onfido (ID), Checkr (background checks)
• Cloud Storage: AWS/Google Cloud/Azure for secure data hosting
• Analytics: Anonymized usage data for platform improvement

4.2 We DO NOT:

• Sell your personal data to advertisers
• Share your content without your permission
• Use your voice recordings for AI training without consent
• Share your location or personal details with matches without your approval

5. Your Rights and Control

5.1 You Can:

• Access: Download all your data at any time
• Edit: Update your profile and account information
• Delete: Request account deletion (processed within 30 days)
• Control: Manage privacy settings for each feature
• Object: Opt-out of non-essential data processing

5.2 Data Retention

• Active accounts: Data retained as long as account is active
• Deleted accounts: Data removed within 30 days (except legal requirements)
• Verification data: Retained for 90 days after account deletion for fraud prevention

6. Children's Privacy

EMTRACE is intended for users 13 years of age and older. We do not knowingly collect personal information from children under 13 in compliance with the U.S. Children's Online Privacy Protection Act (COPPA). If we discover an account belonging to a child under 13, it will be immediately deleted.

For users between 13 and 17, we recommend parental awareness of account creation and platform use. Emtrace is designed with strong safety primitives — every member is voice-verified, every voice is checked for authenticity in real time, there is no algorithmic feed pushing content, and no member data is sold to advertisers.

7. International Users

If you are accessing EMTRACE from outside the United States:

• Your data may be transferred to and processed in the US
• We comply with GDPR for EU users
• We comply with CCPA for California users

8. Cookies and Tracking

8.1 We Use:

• Essential cookies: For authentication and security
• Analytics cookies: To understand platform usage (anonymized)
• Preference cookies: To remember your settings

8.2 You Can:

• Disable non-essential cookies in settings
• Clear cookies from your browser

9. Voiceprints & Biometric Data

9.1 What we collect

When you submit a Truth Glow voice capsule, our server-side verifier (the recordTruthGlowEarning Cloud Function calling _speakerVerify.js) extracts a numeric voice embedding — a mathematical fingerprint of how your voice sounds. The embedding is a 192–512-dimensional vector of floating-point numbers; it is not the audio itself, but it qualifies as a “biometric identifier” under 740 ILCS 14/10 and analogous state statutes.

9.2 Why we collect it

• Anti-impersonation: verifying that the voice belongs to the account holder — not a deepfake, a clone, or another user farming Truth Glow earnings.
• Earnings integrity: Truth Glow payouts are gated on a real-human speaker match.
• We do NOT use voiceprints for advertising, behavioral targeting, AI-model training, sale, or sharing with brokers.

9.3 Where it lives

• Per-user: /users/{uid}/voicePrints/{id} — readable only by the account owner; server-only writes.
• Cross-user farming index: /speaker_print_index/{id} — server-only read/write; never exposed to client code.
• Underlying audio bytes (the WebM source) live under vault/{uid}/… in Cloud Storage; the same retention & destruction rules below apply.

9.4 Retention & destruction schedule (BIPA §15(a))

• Active account: voiceprints and their underlying audio are retained for as long as your account is active. There is no separate “ad analytics” copy; the embedding exists only in the locations listed in § 9.3.
• Account closure: when you invoke Account Deletion, the requestAccountDeletion Cloud Function permanently deletes (a) every document under /users/{uid}/voicePrints, (b) every speaker_print_index document where userId == your-uid, and (c) every audio object under your user-keyed Cloud Storage prefixes. The destruction must complete within 30 days of account closure, and the completion event is logged to the immutable account_deletions collection for audit.
• Idle accounts: accounts inactive for more than 3 years are flagged for retention review; biometric data is purged after the review period regardless of account status, in addition to the deletion-on-closure rule above.
• Legal hold exception: if a court order, subpoena, or active fraud investigation specifically names your account, biometric data may be retained beyond the 30-day window solely to comply with that order; the rest of your data is still deleted, and the retention is logged.

9.5 Your rights

• Revoke consent at any time by closing your account from Settings → Privacy (the Settings surface is shipping under Layer 1, item L1-6; until then, write to [email protected] and we will action the deletion within 30 days).
• Inspect the metadata of your voiceprint (provider, enrolled-at timestamp, dimensionality) via the “Data Export” flow (the underlying requestDataExport Cloud Function is live; the user-facing button ships with the Settings surface).
• Send any voiceprint-specific request to [email protected] with subject line “Biometric Data Request”.

9.6 Other voice data (non-biometric)

• Your audio recordings remain your content. We do NOT use your voice for AI-model training without separate, explicit consent.
• Where possible, voice authenticity analysis is performed on-device. The server-side embedding above is the exception, and only created on Truth Glow verification.
• You can delete voice recordings at any time from the surface they were created in (Vault, Bond, Spark voice intro, etc.).

10. Content moderation and reports

EMTRACE provides a platform-wide reporting flow so anyone using the service can flag content that may violate our Community Standards or the law. This section describes how that flow works, what we retain when a report is submitted, and how we comply with the European Union Digital Services Act (Regulation (EU) 2022/2065) and the United Kingdom Online Safety Act 2023.

10.1 What you can report and how

• Every Trace that shows user-generated content (Bond, Spark, Vault, Pulse, and Thread) surfaces a “Report” affordance. In Bond the affordance lives in the long-press / right-click action menu on each letter; in Spark it lives on each connection card; in Vault it lives on the Vault wall; and in Pulse and Thread it lives in the page footer.
• You can also block any user. A block is platform-wide: a blocked user can no longer see your content, and you can no longer see theirs, across every EMTRACE surface. Blocks are reflected in your Settings page (“Reports & Blocks”).
• When you submit a report we ask for a category (harassment, hate speech, sexual content involving a minor, terrorism, self-harm content, spam, fraud, impersonation, other illegal content, or “something else”), an optional free-form note (up to 1,000 characters), and we capture an immutable snapshot of the content as it appeared to you at the moment of the report.

10.2 Your reference number and acknowledgement

• Every submitted report is assigned a human-readable reference number of the form ETR-YYYY-MM-DD-XXXXXX. The reference number is displayed in the confirmation dialog after submission and can be copied to the clipboard with a single tap.
• Within 24 hours of submission you will receive an acknowledgement email from [email protected] at the address tied to your EMTRACE account, repeating the reference number. This satisfies the receipt-acknowledgement requirement of EU DSA Article 16(4) and the UK Online Safety Act’s “easy to access and use” reporting test.
• You can view every report you have ever submitted, along with its current status, in Settings → Reports & Blocks.

10.3 Priority categories and escalation

Reports filed under one of the “priority categories” below are auto-routed to an internal alert queue and are reviewed on a fast-path basis:

• Sexual content involving a minor (CSAM). EMTRACE has zero tolerance for child sexual abuse material. Reports in this category are escalated immediately and may be referred to the National Center for Missing & Exploited Children (NCMEC), the Internet Watch Foundation (IWF), and/or competent law enforcement, in compliance with 18 U.S.C. § 2258A, the EU CSAM Regulation, and the UK Online Safety Act § 121.
• Terrorism or violent extremism. Reports in this category are escalated for immediate review and may be referred to authorities (including the EU Internet Referral Unit and the UK Counter Terrorism Internet Referral Unit) where required by Regulation (EU) 2021/784 and the UK Counter-Terrorism and Border Security Act 2019.
• Self-harm and suicide-promotion content. Reports in this category are escalated immediately. Where appropriate, the reporter is offered a link to local crisis-line resources.

10.4 What we retain and for how long

• Each report is stored as an audit-grade record in our contentReports collection. The record contains: your account UID and email, the UID of the account whose content was reported, the category, the optional note, the snapshot of the reported content, the reference number, the truncated IP prefix (/24 for IPv4, /48 for IPv6) and User-Agent of the device that submitted the report, the resolution outcome, and timestamps for every status change.
• The snapshot survives even if the underlying content is later deleted — this is required so that we can defend moderation decisions to regulators and to users challenging a decision.
• Reports are retained indefinitely for legal-compliance, transparency-reporting, and pattern-detection purposes. Subject to the EU DSA Article 15 transparency-reporting cycle and the UK OSA § 23 record-keeping obligations, we cannot delete a report at the requester’s instruction even when the requester is the reporter. (You may, however, request deletion of personal identifiers tied to the report through [email protected]; we will redact rather than purge.)

10.5 Outcomes and your right to appeal

After review, a report may close with one of: no action, content removed, user warned, user suspended, user banned, or escalated to authorities. Where we restrict content or an account on the basis of a report, we will provide the affected party with a Statement of Reasons (EU DSA Article 17) and an internal-appeal route (EU DSA Article 20). Reporters may also request reconsideration by emailing the reference number to [email protected].

10.6 Transparency reporting

EMTRACE is committed to publishing an annual Transparency Report covering: total report volume, breakdown by category, median time-to-acknowledgement and time-to-resolution, accuracy metrics for any automated detection deployed, and a breakdown of outcomes and appeal results, in accordance with EU DSA Articles 15 and 24 and the UK OSA § 23. The first report is forthcoming and will be linked here when published.

10.7 Anti-abuse

The reporting flow is intended for good-faith use. Repeatedly submitting bad-faith or vexatious reports may itself lead to enforcement action against the reporting account, in line with EU DSA Article 23 (suspension of frequent submitters of unfounded notices) and our Terms of Service.

10.8 Contact

For escalations, press inquiries, or trusted-flagger applications, contact [email protected]. We accept Notice and Action submissions in any official EU language and in English (UK).

11. Changes to Privacy Policy

We may update this policy periodically. Changes will be:

• Posted on this page with updated "Last Updated" date
• Notified via email for material changes
• Effective 30 days after posting

12. Contact Us

For privacy questions or to exercise your rights, contact us at:

Privacy email: [email protected]
Data Protection Officer: [email protected]
Biometric requests (BIPA §15): [email protected] — subject line “Biometric Data Request”
CCPA / CPRA requests: [email protected] — subject line “CCPA Request”
Mailing address: EMTRACE Privacy Department, c/o the EMTRACE legal team. Postal mail handling is forthcoming; until the permanent mailing address is published below, use the email channels above — we will respond within 48 hours and forward to legal counsel where appropriate.

12A. CCPA / CPRA Rights (California Residents)

If you are a California resident, the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq., as amended by the CPRA) gives you specific rights regarding your personal information:

• Right to know what categories of personal information we collect, how we use it, and whether we disclose it.
• Right to delete personal information we hold about you (subject to legal exceptions).
• Right to correct inaccurate personal information.
• Right to opt out of the sale or sharing of personal information.
• Right to limit the use and disclosure of sensitive personal information (including voice recordings and geolocation data).
• Right to non-discrimination for exercising any of the above.

EMTRACE does not sell personal information for money, and we do not knowingly disclose personal information to third parties for cross-context behavioral advertising. The links below are provided as required by Cal. Civ. Code § 1798.135 even where no such sale or sharing is currently happening:

· Do Not Sell or Share My Personal Information
· Limit the Use of My Sensitive Personal Information
· Request a copy of the personal information we hold
· Request deletion of my account and personal information

We verify CCPA requests by confirming control of the account’s email address. We will respond within 45 days as required by Cal. Civ. Code § 1798.130, and may extend by an additional 45 days when reasonably necessary, with notice.

13. Legal Basis (GDPR)

We process your data under the following legal bases:

• Contract: To provide EMTRACE services
• Consent: For optional features like background checks
• Legitimate Interest: Platform improvement and fraud prevention
• Legal Obligation: Compliance with laws