Adero Privacy Policy

1. Who Operates Adero#

Adero is operated by:

MntraAI LLC

6200 Stoneridge Mall Rd, Suite 300

Pleasanton, CA 94588

United States

Privacy inquiries: privacy@mntraai.com

2. Information We Collect#

2.1 Account Information

When you create or use an Adero account, we may process information such as:

your email address or information necessary to authenticate through Apple;

an internal account identifier;

the name, nickname, initials, or other chosen name you tell Adero to use;

authentication and account status information;

a device push token, if you enable notifications;

subscription status; and

account settings and preferences.

Adero does not require you to provide your legal name merely to choose what your companions should call you.

We do not require your birth date to use Adero.

2.2 Conversations

We process the messages and other content you submit during conversations with Adero companions.

Your conversations may contain information that you voluntarily disclose about yourself, your experiences, relationships, interests, preferences, work, family, emotions, health, or other aspects of your life.

Because conversation is open-ended, you control much of the information you provide to Adero. Please do not provide information you do not want processed as part of the service.

2.3 Memories, Personalization and Information Adero Derives

Adero is designed to maintain continuity across conversations.

To provide that experience, our systems may analyze conversations and generate or maintain structured information derived from what you tell Adero. Depending on your interactions, this may include:

facts or events you have shared;

preferences and interests;

goals;

people or relationships you mention;

life context;

information associated with previous conversations;

relationship or conversation context used to maintain continuity;

companion interaction state; and

other information or inferences used to personalize future conversations.

These derived records may not reproduce your original words. They are generated by automated systems and may sometimes be incomplete, inaccurate, or mistaken.

Adero may also create mathematical representations, commonly called embeddings, that help retrieve information relevant to a conversation.

2.4 Information About Other People

You may choose to talk with Adero about friends, relatives, coworkers, partners, or other people.

When you do, information about those people may appear in your conversations or in memories and other personalization information derived from your conversations.

Adero does not independently establish an account or relationship with a person merely because you mention them in a conversation.

2.5 Safety and Conversation Classification

Adero uses automated systems to evaluate conversations and generated responses for safety and other operational purposes.

For example, systems may classify messages or interactions for indicators of crisis, self-harm risk, unsafe responses, or other conditions relevant to Adero's safety systems.

These systems may generate and store classifications or safety-related events associated with an interaction.

Automated safety systems are not perfect. A classification may be incorrect, may fail to identify a risk, or may identify a risk where none exists. Adero should therefore not be relied upon as an emergency monitoring service or as a substitute for professional assistance.

2.6 Activity and Presence Information

Adero may process limited information about your interaction with a conversation, such as whether a conversation is in focus, whether you are actively typing, whether a message has been seen, and timestamps associated with those activities.

These signals help support conversation state and product functionality.

A typing indicator does not require Adero to store the text of an unfinished draft merely to report that you are typing.

2.7 Voice Dictation

Where voice dictation is available, speech recognition may be performed using Apple speech-recognition capabilities.

Adero does not operate its own service for storing raw voice recordings from dictation.

When supported by the device, speech recognition may occur on-device. In circumstances where on-device recognition is unavailable, Apple may process audio as necessary to provide speech recognition.

The resulting text can then be processed by Adero in the same manner as a message you type.

2.8 Subscription and Transaction Information

If you purchase an Adero subscription, we process information necessary to determine subscription status, entitlement, renewal, restoration, and related account access.

Purchases through Apple are processed through Apple's payment systems.

Adero also uses RevenueCat to help manage subscription entitlements.

We do not receive your complete payment-card number from Apple.

Certain transaction and financial records may need to be retained separately from conversational data for accounting, fraud prevention, dispute resolution, tax, legal, or regulatory purposes.

2.9 Operational and Technical Information

We process limited technical and operational information needed to operate, secure, troubleshoot and measure the service.

This may include information such as:

internal account or relationship identifiers;

request and response timing;

message lengths;

token or model usage;

provider usage and cost information;

internet protocol (IP) address information processed by our service providers, from which an approximate country may be derived;

error and status information; and

timestamps.

Operational logs may therefore be associated with an account even when they do not contain the content of a conversation.

Adero does not intentionally place conversation content into ordinary operational logs.

3. How We Use Information#

We use information described in this Policy to:

provide conversations with Adero companions;

authenticate users and maintain accounts;

remember information you have shared;

personalize future conversations;

retrieve relevant memories and context;

maintain continuity across conversations;

generate AI responses;

operate safety systems;

classify interactions for safety and quality purposes;

provide and restore subscription access;

maintain conversation and relationship state;

operate, troubleshoot and secure Adero;

measure technical usage and provider costs;

investigate abuse, fraud, security incidents or violations of our Terms;

comply with legal obligations; and

enforce or defend our legal rights.

We do not use your conversations to serve third-party advertising.

4. Artificial Intelligence Processing#

AI processing is fundamental to Adero.

Information you provide may be sent to third-party AI infrastructure providers when necessary to generate responses, retrieve relevant memories, create embeddings, perform classification, or provide other Adero functionality.

Anthropic

Adero uses Anthropic technology for AI functionality, including conversational responses and other automated processing.

Depending on the feature being performed, information sent for processing may include conversation content, relevant context, memories, or other information necessary to produce the requested Adero functionality.

Adero does not intentionally send your Adero account identifier or email address to Anthropic as an end-user identifier.

OpenAI

Adero uses OpenAI technology for embeddings and retrieval-related processing.

This can include processing text from a message you send in order to identify memories relevant to that message, as well as processing derived memory information used for retrieval.

Adero does not intentionally send your Adero account identifier or email address to OpenAI as an end-user identifier.

Information Contained in Your Words

Even when Adero does not send an account identifier to an AI provider, the text itself may contain identifying or sensitive information if you choose to include it.

For example, if you type your legal name, address, medical information, employer, or another identifying fact into a conversation, that information may be present in text processed to provide the service.

We therefore do not represent conversational text as anonymous merely because an internal account identifier has been removed.

5. Other Service Providers#

We use companies that perform services necessary to operate Adero, including:

Supabase - authentication, database and backend infrastructure;

Anthropic - artificial intelligence processing;

OpenAI - embeddings and retrieval-related AI processing;

RevenueCat - subscription and entitlement management;

Expo - push notification delivery; and

Apple - authentication, App Store purchases, device/platform services, and speech-recognition functionality where applicable.

Service providers may process information as necessary to provide services to us, subject to their agreements with us and applicable law.

We may change service providers as Adero evolves. Material changes to our privacy practices will be reflected in this Policy as appropriate.

6. What We Do Not Do#

We do not sell your personal information.

We do not sell your conversations.

We do not share your personal information for cross-context behavioral advertising.

We do not use an advertising SDK in Adero.

We do not use an analytics SDK in Adero.

We do not use IDFA for advertising tracking.

We do not store raw voice recordings from Adero's dictation feature.

We do not intentionally send your Adero account identifier or email address to Anthropic or OpenAI as an end-user identifier.

If these practices materially change, this Privacy Policy and any legally required notices or choices will be updated before or when the new practice applies.

7. Sensitive Information#

Conversations with an AI companion can become personal.

You may voluntarily disclose information concerning health, relationships, finances, family matters, emotional experiences, sexuality, beliefs, employment, or other sensitive subjects.

Adero does not need every detail of your life in order to function. You decide what you want to share.

Where applicable law treats certain information as sensitive personal information, we process such information for purposes reasonably necessary to provide and operate the service, maintain safety and security, comply with law, and perform other purposes described in this Policy.

8. How Long We Keep Information#

A user's ordinary Adero data may be retained for up to 12 months after paid or otherwise authorized access to Adero ends, unless the user deletes the account sooner or a longer retention period is reasonably necessary or legally required.

Cancellation does not necessarily mean access ends immediately. For example, if you cancel a paid subscription but remain entitled to use Adero through the end of the paid subscription period, the post-access retention period begins after that access ends.

If access is later restored before ordinary data is deleted, information that remains associated with the account may continue to be used to provide the service.

Certain categories of information may be retained for different periods when reasonably necessary for:

financial, tax and accounting obligations;

transaction records;

fraud prevention;

security;

dispute resolution;

enforcing our agreements;

establishing, exercising or defending legal claims; or

complying with applicable law.

Operational logs and security records may also follow retention periods appropriate to their purpose and the systems that generate them.

Backups

Deletion from active systems may not immediately remove information from encrypted backups or disaster-recovery copies.

Backup copies may remain until overwritten or expired through ordinary backup-retention processes, unless a longer period is required by law.

Information retained in backups is not intended to be restored to active use except as necessary for legitimate backup, disaster-recovery, security, or legal purposes.

9. Account Deletion#

You can request deletion of your Adero account through the app.

Account deletion is different from merely cancelling a subscription or allowing access to expire.

When an account-deletion request is completed, Adero deletes or de-identifies ordinary account information and associated user data from active systems, subject to limited exceptions described in this Policy.

Some records may be retained when necessary for legal, financial, security, fraud-prevention, transaction, or compliance purposes. Where appropriate, retained records may be separated from the deleted account or have direct user identifiers removed.

Deletion from active systems may not immediately remove information from backups, as described above.

10. Security#

We use administrative, technical and organizational measures designed to protect information processed by Adero.

These measures may include authentication controls, access restrictions, database security policies, encrypted network connections, infrastructure security controls, and limitations on what information is sent to service providers.

However, no system can guarantee absolute security. We cannot promise that unauthorized access, loss, misuse, or other security incidents will never occur.

You are responsible for protecting the credentials used to access your account.

11. Your Privacy Choices#

Depending on your account and applicable law, you may be able to:

review or change the name Adero uses for you;

access certain information through the service;

manage account settings;

delete your account;

end your subscription;

request information concerning our privacy practices; or

exercise privacy rights provided by applicable law.

For privacy requests that cannot be completed directly in the app, contact privacy@mntraai.com.

We may need to verify your identity before completing certain requests.

12. California Privacy Rights#

If you are a California resident, California law may provide rights concerning your personal information, subject to applicable exceptions.

Depending on the circumstances, these may include the right to:

know the categories and specific pieces of personal information we have collected;

know the categories of sources from which personal information is collected;

know the purposes for collecting, using or disclosing personal information;

know the categories of third parties to whom information is disclosed;

request correction of inaccurate personal information;

request deletion of personal information;

receive certain information in a portable format; and

not receive discriminatory treatment for exercising applicable privacy rights.

Sale and Sharing

MntraAI does not sell personal information and does not share personal information for cross-context behavioral advertising as those terms are defined by California privacy law.

Accordingly, Adero does not currently provide a "Do Not Sell or Share My Personal Information" mechanism because we do not engage in those practices.

Sensitive Personal Information

Users may voluntarily include sensitive information in conversations. Where California law applies, we use sensitive personal information for purposes reasonably necessary to provide, secure and operate Adero and for other legally permitted purposes described in this Policy.

To submit a California privacy request, contact privacy@mntraai.com.

Where required by law, an authorized agent may submit a request on your behalf. We may require appropriate verification of the request and the agent's authority.

13. Children and Age Restrictions#

Adero is intended only for adults 18 years of age or older.

We do not knowingly offer Adero to children under 18.

Adero does not require users to submit a birth date or government identification to establish age. The absence of an age-verification mechanism does not change the 18+ restriction in our Terms of Use.

If we learn that an individual under 18 has provided personal information through Adero in violation of this restriction, we may take appropriate steps concerning the account and associated information.

If you believe a person under 18 is using Adero, contact privacy@mntraai.com.

14. AI Safety and Emergencies#

Adero includes automated safety mechanisms intended to identify certain potentially dangerous or crisis-related interactions and to influence how the system responds.

These systems are automated and may fail.

Adero does not continuously monitor users, guarantee detection of emergencies, guarantee intervention, or provide emergency-response services.

If you believe you or another person is in immediate danger, contact appropriate local emergency services or another qualified source of immediate assistance rather than relying on Adero.

Additional limitations concerning AI companions and professional advice are described in the Terms of Use and AI Disclosure.

15. Data Processing Locations#

MntraAI LLC is based in the United States, and Adero is currently offered in the United States.

We and our service providers may process, store, or access information in the United States or in other jurisdictions where they operate.

Privacy and data-protection laws may differ between jurisdictions. Where required by applicable law, we use appropriate measures for the processing and transfer of personal information.

16. Legal Disclosures and Business Transfers#

We may disclose information when we reasonably believe disclosure is necessary to:

comply with applicable law, regulation, legal process, or valid governmental request;

protect the rights, property, security, or safety of MntraAI, Adero, our users, or others;

investigate fraud, abuse, security incidents, or violations of our Terms; or

establish, exercise, or defend legal claims.

If MntraAI or Adero is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, information may be transferred as part of that transaction, subject to applicable law.

17. Changes to This Privacy Policy#

We may update this Privacy Policy as Adero, our technology, or applicable legal requirements change.

When we make changes, we will update the Last Updated date above.

If a change materially affects how we handle personal information, we may provide additional notice when appropriate or required by law.

18. Contact Us#

For questions, requests, or concerns about privacy or this Privacy Policy:

MntraAI LLC

6200 Stoneridge Mall Rd, Suite 300

Pleasanton, CA 94588

United States

privacy@mntraai.com