1. Introduction

ANXI LLC ("Company," "we," "us," or "our") operates the ANXI Academy wellness application (the "Service"). This Privacy Policy explains how we collect, use, store, protect, and share your personal information when you use our Service.

Service Context: ANXI Academy is a non-clinical wellness application designed to support users in managing everyday anxiety through educational content and self-guided exercises. The Service is not intended for use in medical emergencies, crisis situations, or as a substitute for professional mental health treatment.

2. Information We Collect

2.1 Information You Provide

• Registration Information: Name, email address, country of residence
• Onboarding Responses: Anxiety level, personal goals, commitment preferences
• Program Usage Data: Lesson completion status, progress tracking, chat messages with ANXI AI
• Payment Information: Processed by Stripe (we do not store payment card details)

2.2 Information Collected Automatically

• Usage Data: Pages visited, time spent, interactions with features
• Device Information: Browser type, operating system, IP address
• Analytics Data: Anonymized usage patterns via Umami Analytics

3. How We Use Your Information

We use your personal information for the following purposes:

• Service Delivery: Provide access to the 21-day program, track progress, deliver personalized content
• Communication: Send program updates, reminders, and support messages
• Improvement: Analyze usage patterns to enhance the Service
• Payment Processing: Process transactions via Stripe
• Legal Compliance: Comply with applicable laws and regulations

4. Legal Basis for Processing (GDPR)

Under the GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide the Service you purchased
• Consent: You have given explicit consent for specific processing activities (e.g., marketing emails)
• Legitimate Interests: Processing necessary for our legitimate business interests (e.g., fraud prevention, service improvement)
• Legal Obligation: Processing required to comply with legal requirements

5. Data Sharing and Disclosure

We share your personal information with the following third parties:

• AWS (Amazon Web Services): Cloud hosting and database storage
• Stripe: Payment processing
• OpenAI: AI-powered chat support (messages processed for service delivery only, not used for model training)
• Manus OAuth: User authentication
• Umami Analytics: Anonymized usage analytics

We do not sell or share your personal data with third parties for marketing purposes.

6. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), United Kingdom, and Switzerland, including the United States. We ensure such transfers comply with GDPR requirements by implementing Standard Contractual Clauses and other appropriate safeguards.

For more information, see our Cross-Border Data Transfer Statement.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption: Data encrypted in transit (TLS 1.2+) and at rest
• Access Controls: Role-based access restrictions
• Authentication: Secure session management with JWT tokens
• Monitoring: Regular security audits and breach detection

8. Data Retention

We retain your personal data for the following periods:

• Account Information: Duration of account + 3 years after deletion
• Program Usage Data: Duration of account + 1 year after deletion
• AI Chat History: Duration of account + 1 year after deletion
• Payment Records: 7 years (legal requirement)
• Analytics Data: 12 months (anonymized)

9. Your Rights (GDPR)

You have the following rights regarding your personal data:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Restriction: Limit how we process your data
• Right to Data Portability: Receive your data in a machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time
• Right to Lodge a Complaint: File a complaint with a supervisory authority

To exercise your rights, contact us at [email protected].

10. AI and Automated Decision-Making

AI Chat Support: ANXI Academy uses OpenAI's language models to power the ANXI Chat feature. Your chat conversations are processed solely for service delivery and are not used to train or improve third-party AI models.

No Automated Decision-Making: ANXI Academy does not engage in automated decision-making or profiling that produces legal or similarly significant effects on users. All program recommendations are based on your explicit choices, not automated profiling.

11. Children's Privacy

The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last Reviewed" date. Your continued use of the Service after changes become effective constitutes acceptance of the updated policy.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us: