Adaptive Soul

Legal

Privacy Notice

Last updated: 3 May 2026

1. Who We Are

My Consigliere ("we", "us", "our"), based in Hong Kong, operates Adaptive Soul ("the Service"). We act as the data controller for personal data we collect through the Service. You can reach us at info@myconsigliere.com.

2. Personal Data We Collect

  • Account data: name, email address, login credentials.
  • Reflection responses: answers you submit during the reflection, and any focus or notes you record.
  • Support communications: messages you send us when contacting support.
  • Usage and device data: pages viewed, features used, browser/device type, approximate location, and IP address (used for security, analytics, and fraud prevention).

3. How We Use Your Data and Our Legal Bases

  • Provide the Service (contract performance): create your account, generate reflections, deliver resources.
  • Improve the Service (legitimate interests): understand how features are used and fix problems.
  • Security and fraud prevention (legitimate interests / legal obligation): detect abuse, protect users and our systems.
  • Customer support (legitimate interests / contract performance): respond to your messages.
  • Communications (consent / legitimate interests): send service-related emails. Marketing emails only if you opt in.
  • Comply with legal obligations: respond to lawful requests and meet tax / accounting requirements.

4. AI Processing

Reflections are generated using AI models. Your reflection responses are sent to AI providers solely to generate the response shown back to you. We do not sell your responses or use them for advertising.

5. Who We Share Data With

  • Hosting and backend infrastructure — to store and serve your account and responses.
  • AI providers — to generate reflection content from your inputs.
  • Email delivery providers — to send transactional emails.
  • Professional advisers (legal, accounting) where necessary.
  • Authorities where we are legally required to do so.

We do not sell your personal data.

6. International Transfers

Some of our service providers are located outside Hong Kong. Where personal data is transferred internationally, we rely on appropriate safeguards (such as the providers' standard contractual clauses) to protect it.

7. Data Retention

We keep your account and reflection data for as long as your account is active. If you delete your account or ask us to delete your data, we will remove or anonymise it within a reasonable period, except where we need to retain certain records to comply with legal, tax, or accounting obligations.

8. Your Rights

Subject to applicable law, you may have the right to:

  • access the personal data we hold about you;
  • request correction of inaccurate data;
  • request deletion of your data;
  • object to or restrict certain processing;
  • withdraw consent where processing is based on consent;
  • lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (or your local data protection authority).

To exercise any of these rights, email info@myconsigliere.com. We aim to respond within 30 days.

9. Security

We use appropriate technical and organisational measures — including encryption in transit, access controls, and managed cloud infrastructure — to protect your data. No system is perfectly secure, so we encourage you to use a strong, unique password.

10. Cookies

We use a small number of essential cookies and similar technologies to keep you logged in and to remember basic preferences. We do not use third-party advertising cookies.

11. Changes to This Notice

We may update this Privacy Notice from time to time. Material changes will be reflected by updating the "Last updated" date.

12. Contact

Questions or requests? Email info@myconsigliere.com.

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