1. Who controls your data
The intended data controller is Layers Ventures, trading as EMIL AI. Layers Ventures is a UK limited company that is not yet incorporated. Before this policy comes into force, we will complete:
- Company number: [COMPANY NUMBER]
- Registered office: [REGISTERED ADDRESS]
For privacy questions or rights requests, email contact@askemil.xyz with “Privacy” in the subject line. We will publish the final controller details when the company is incorporated.
2. Data we collect
We collect only what we need for the purposes below.
| Category | Examples | How we receive it |
|---|---|---|
| Waitlist data | Email address, optional first name, role level, leadership challenge, referring page or source, and join date | From you when you join the January waitlist |
| Teams enquiry data | Work email, optional name, company, role or job title, approximate team size, intended start timing, message, source and campaign attribution, and enquiry date | From you when you submit a Teams business enquiry |
| Account data | Name, email address, login and account settings | From you when you create or manage an account |
| Coaching data | Conversation messages, goals, reflections, preferences, and progress | From you when you use coaching features |
| Uploaded context | Documents or text you choose to upload | From you |
| Usage and technical data | Device, browser, IP address, logs, feature use, and error details | Automatically when you use the website or app |
| Payment data | Plan, transaction, billing country, and tax information | From Paddle and from you at checkout |
| Support data | Messages, attachments, and records of requests | From you when you contact us |
We do not ask you to provide special-category data. If you choose to include sensitive information in a coaching conversation or document, we process it only to provide the feature you requested and ask you to keep it to the minimum necessary.
3. Why we use it and lawful bases
| Purpose | Lawful basis |
|---|---|
| Run the January waitlist, send launch updates, and keep a record of your unsubscribe choice | Your consent to receive launch updates; you can unsubscribe at any time using the link in every email or by contacting us |
| Respond to a Teams business enquiry and follow up about whether the planned Teams service may fit your organisation | Our legitimate interests in responding to business enquiries and developing business relationships, balanced against your rights; a Teams enquiry does not join the individual waitlist |
| Create your account, provide coaching, save goals and context, and operate the app | Performance of a contract with you |
| Process subscriptions, payments, tax, refunds, and fraud checks | Performance of a contract and legal obligations |
| Send service notices, receipts, security messages, and support replies | Performance of a contract and our legitimate interests |
| Keep the service secure, prevent abuse, rate-limit requests, and troubleshoot errors | Our legitimate interests in running a safe service |
| Improve product reliability and understand feature use using aggregated or minimised information | Our legitimate interests, balanced against your rights |
| Send optional marketing messages | Your consent, which you can withdraw at any time |
| Meet accounting, tax, legal, and regulatory requirements | Legal obligation |
Where we rely on legitimate interests, those interests are providing, securing, and improving EMIL AI. We do not use coaching content to train external AI models.
We retain waitlist details until you unsubscribe or until they are no longer needed for the January launch and related updates. We may keep a minimal suppression record to make sure we honour an unsubscribe request.
Teams enquiry records are kept separately from the waitlist. We normally retain them for up to 24 months after the last contact so we can manage the business enquiry and its follow-up, unless you ask us to delete them earlier or we need to keep them for a legal reason.
4. Information about other people
This information is used solely to coach the account holder. It is never shared with those individuals or with anyone else. It is not used to train external AI models. You can view and delete it from your account.
Please keep information about other people minimal. Use first names, initials, or role descriptions instead of full names where possible. Do not add information that is not needed for your coaching, and do not upload special-category or confidential information about another person unless you have a lawful basis and appropriate permission.
You are responsible for making sure that your use of another person’s information is fair and lawful. EMIL AI does not contact, profile, score, monitor, or notify those people.
5. Service providers and sub-processors
We use carefully selected providers to operate EMIL AI. They process data only under our instructions where they act as processors, and under their own terms where the law makes them an independent controller.
| Provider | Role |
|---|---|
| Supabase | Database, authentication, and hosting user data |
| OpenAI | AI model provider for selected coaching requests |
| Anthropic | AI model provider for selected coaching requests |
| Resend | Transactional email delivery |
| Paddle | Payments, merchant-of-record services, tax, and billing support |
| Upstash | Rate limiting and abuse prevention |
We may add or replace providers when needed to run the service. We will update this list or notify users where required.
6. Retention by plan
We keep information for as long as needed to provide the plan, comply with law, resolve disputes, and enforce agreements. The planned coaching-memory retention periods are:
| Plan | Coaching conversations and memory | After account closure |
|---|---|---|
| Free tier | 30 days after last activity | Deleted within 30 days, except required records |
| 7-day paid trial | Same retention as the paid plan selected | Deleted within 30 days if the trial does not convert |
| Ascent | 12 months after last activity | Deleted within 30 days, except required records |
| Executive Track | 24 months after last activity | Deleted within 30 days, except required records |
| Teams | 12 months after last activity | Deleted within 30 days, except required records |
Account and billing records may be retained for up to seven years where needed for tax, accounting, fraud prevention, or legal obligations. Support records are normally kept for up to 24 months after the request is closed. You may delete individual memories or request earlier deletion by contacting us.
7. International transfers
Some providers may process data outside the UK or European Economic Area. When we transfer personal data internationally, we use an adequacy decision where available or appropriate safeguards such as the UK International Data Transfer Agreement, UK Addendum, or EU Standard Contractual Clauses. You can contact us for more information about the safeguards relevant to a particular transfer.
8. Security
We use access controls, encryption in transit, provider security controls, authentication safeguards, rate limiting, and monitoring designed to protect personal data. Access to coaching data is limited to the account holder and authorised service operations.
No online service is completely secure. If you believe your account or data is at risk, contact us promptly at contact@askemil.xyz.
9. Your rights
Under UK GDPR, you may have the right to access your personal data, correct inaccurate data, request erasure, restrict processing, receive portable data, and object to processing based on legitimate interests or direct marketing. You can also withdraw consent where processing relies on consent. These rights are subject to legal exceptions.
To make a request, email contact@askemil.xyz. We may need to verify your identity and will normally respond within one month. You also have the right to complain to the UK Information Commissioner’s Office at ico.org.uk/make-a-complaint.
10. Children and changes
EMIL AI is intended for adults and is not directed to children under 18. We do not knowingly collect children’s data.
We may update this policy when the service, providers, or law changes. We will publish the new version and date at the top of this page. Material changes will be communicated through the service or by email where appropriate.