Last updated: 1 October 2026
This explains what Soulwise processes and why. It asks you for nothing — the places where your consent is needed are asked separately, one at a time. See our AI Processing Consent.
Related documents: Safety and crisis protocol · Consumer Health Data Privacy Policy
Soulwise is operated by LUMİNA YAZILIM İNOVASYON TEKNOLOJİ TİCARET LİMİTED ŞİRKETİ, a limited company registered in Türkiye. It is the controller of the personal data described in this policy.
Address: Esentepe Mah. Tevfik Erdönmez Paşa Sk. 6 Blok No: 5 İç Kapı No: 8, Şişli / İstanbul, Türkiye
Contact: soulwise@luminateknoloji.net
Soulwise is an AI conversation companion. It does not provide health care, does not diagnose and does not treat, and it is not a substitute for a licensed professional. Every response is generated by artificial intelligence.
Your personal data is collected electronically, through the mobile app and the website, by automated means.
You give us:
Your conversation messages and mood check-ins are stored only after you have given the AI processing consent.
Created as you use the app:
Your conversation content, mood check-ins, session summaries and the profile the AI keeps about you are health data about your mental wellbeing (special category data under the GDPR and UK GDPR, Art. 9), and we treat them as the most sensitive category we hold. We process them only with your explicit consent. They are never used for advertising, for marketing, or for any other use-based data mining.
| What for | Legal basis (GDPR / UK GDPR) |
|---|---|
| Creating your account, verifying your sign-in, checking the 18+ requirement | Performance of a contract (Art. 6(1)(b)) |
| Running your account and subscription, providing the features you bought | Performance of a contract (Art. 6(1)(b)) |
| Resolving billing disputes, keeping financial records | Legal obligation (Art. 6(1)(c)) |
| Optional profile fields (gender, occupation, country, city, goals) — you choose to give them | Performance of a contract (Art. 6(1)(b)) |
| Sending notifications — only if you allow them in your device settings | Performance of a contract (Art. 6(1)(b)) |
| Error reports — keeping the app working. | Legitimate interests (Art. 6(1)(f)) |
| Product analytics (mobile app) — understanding which features are used; carries no conversation content and is not linked to your account ID. Off until you turn it on, in every country; switch it on or off at any time in Settings → Privacy → Usage analytics. | Consent (Art. 6(1)(a); ePrivacy Directive art. 5(3) / PECR reg. 6) |
| Reminder emails when you have not used Soulwise for a while (see below) | Legitimate interests (Art. 6(1)(f)) |
| Preventing abuse, keeping security records, applying usage limits | Legitimate interests (Art. 6(1)(f)) |
| The security record of an account deletion | Legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)) |
| Processing your conversation to generate replies, storing your conversations, producing session summaries and the profile the AI keeps, keeping mood check-ins, writing weekly letters | Explicit consent (Art. 9(2)(a) and Art. 6(1)(a)) |
| Sending this data to our AI provider outside your country | Explicit consent (Art. 49(1)(a)) |
| Using your conversations to improve Soulwise | Separate, optional explicit consent (Art. 9(2)(a)) — off by default |
Reminder emails. If you stop using Soulwise, we may send you up to two short reminder emails, about 3 and 7 days after your last visit. They contain no conversation content — only counts such as your active days or your streak. They are on by default. Every one of them has a one-tap unsubscribe link, and you can switch them off under Settings in the app or on the website.
If you live in Türkiye, the Turkish version of this policy lists the corresponding bases under the KVKK.
If you do not give the AI consent, chat does not work; your account, your settings and your right to delete your data keep working. Declining the improvement consent restricts nothing.
We do not sell your data. We do not share it with advertising networks or data brokers, and we do not track you across other companies' apps or websites.
Our agreements require these providers to protect your data with the same or equivalent protection described here.
Limits worth knowing:
Some of our providers are outside your country; our AI provider is based in the United States, where data protection law may differ from your own. This transfer rests on your consent, and you can withdraw it at any time.
If you sign up but never verify your email address and never use the service, the account and its sign-up details are deleted 30 days after sign-up.
Delete your account under Settings → Delete Account, or — without signing in — through our data deletion page.
A few small records survive erasure, and none of them carries your name, your email or your conversation content:
Your sign-in sessions are ended on every device at the moment of deletion.
Deleting your account does not cancel an app store subscription. To stop being charged, cancel it separately in your App Store or Google Play account settings.
Every consent you give can be withdrawn under Settings → Privacy. Withdrawal takes effect going forward: it does not undo processing that was lawful before.
Depending on where you live, you have the right to:
Download your data: under Settings you can download a copy of your data at any time as a machine-readable JSON file — your profile, conversations, session summaries, mood check-ins and weekly letters.
How to ask: write to soulwise@luminateknoloji.net from the email address on your account, or by post to the address in section 1. We answer within 30 days and do not charge for it.
Appeal: if we refuse your request, in whole or in part, reply to our answer and say that you are appealing. We respond to an appeal within 45 days and explain our decision. If the appeal is refused, you may contact your state attorney general or data protection authority.
Third parties: on request, we give you the names of every third party and affiliate we have shared your consumer health data with. See our Consumer Health Data Privacy Policy.
We make no automated decisions that have legal or similarly significant effects on you. Session summaries are used only to give you context in your later conversations.
Passwords are stored irreversibly, all traffic between the app and our servers is encrypted, and conversation content is masked in our own logs. Soulwise is for people aged 18 and older; we close accounts we learn belong to someone under 18.
We do no cross-site or cross-app tracking and show no targeted advertising, so there is nothing for a Do Not Track or Global Privacy Control signal to switch off.
If we update this policy we publish the new version here. We announce material changes in the app before they take effect, and where a change affects what your consent covers, we ask for your consent again.
soulwise@luminateknoloji.net
If you are in crisis, do not wait for Soulwise. In the US and Canada call or text 988; in Türkiye and the European Union call 112; in the UK call Samaritans on 116 123, or 999 in an emergency. Lines for other countries: Support.