Privacy Policy

Effective Date: March 23, 2026  |  Last Updated: March 23, 2026

This Privacy Policy explains how GoShapers L.L.C-FZ ("we," "us," or "our") collect, use, disclose, and protect your personal information when you use the Auralyo application and related services (the "Service"). It describes your rights under the EU General Data Protection Regulation ("GDPR"), UK GDPR, and the California Consumer Privacy Act ("CCPA").

I. Data Controller

GoShapers L.L.C-FZ is the sole data controller for all users of the Service worldwide.

Entity Role Users served
GoShapers L.L.C-FZ Primary data controller. IP holder. Contracts with all non-US users. EU, UK, UAE, GCC, international users. All product data.
Privacy contact: privacy@auralyo.com
Registered address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.

II. What Data We Collect And Why

GoShapers L.L.C-FZ is the sole data controller for all users of the Service worldwide.

Purpose Data collected Legal basis (GDPR Art. 6) Retention
Account creation and authentication Name, email address, password (hashed), account ID Art. 6(1)(b) — contract performance Duration of account + 30 days after deletion
Subscription and payment processing Email, billing address, payment method type, last 4 digits, transaction ID, amount, currency (full card data never stored by us) Art. 6(1)(b) — contract performance 7 years (tax/legal obligation)
Providing personalised audio sessions Quiz responses (work type, stimulation preference, session length, focus goals), audio session history, work mode selections Art. 6(1)(b) — contract performance Duration of subscription + 6 months
Performance tracking and progress metrics Focus session logs (duration, completion rate, task-start speed), weekly performance data Art. 6(1)(b) — contract; Art. 6(1)(f) — legitimate interest Duration of subscription + 6 months
Marketing communications Email address, communication preferences, engagement data Art. 6(1)(a) — consent (opt-in). Withdraw at any time. Until consent withdrawn or 2 years inactivity
Analytics and service improvement IP address, device type, OS, app version, session events (pseudonymised) Art. 6(1)(f) — legitimate interest 13 months (rolling)
Advertising and retargeting (web funnel) Cookie IDs, pixel data, referring URL, ad click data Art. 6(1)(a) — consent (via cookie banner) Per Cookie Policy; typically 90 days
Security, fraud prevention, legal compliance IP address, device identifiers, login timestamps, chargeback data Art. 6(1)(c) — legal obligation; Art. 6(1)(f) — legitimate interest 1 year after incident or legal matter closes
Customer support Name, email, support ticket content, correspondence Art. 6(1)(b) — contract; Art. 6(1)(f) — legitimate interest 3 years from last contact

III. How We Collect Data

3.1 Directly from you

We collect data you provide when you: (a) register an account; (b) complete the focus quiz; (c) make a purchase; (d) contact our support team; or (e) subscribe to marketing communications.

3.2 Automatically

When you use the Service, we automatically collect: IP address, device and browser information, operating system, app version, session events, and in-app behaviour via analytics tools.

3.3 From third parties

We may receive information from payment processors (transaction confirmation), advertising platforms (ad attribution), and app stores (purchase validation).

IV. Data Processors And Third-Party Sharing

We share your data only with trusted service providers who process it on our behalf under written data processing agreements compliant with GDPR Article 28. We do not sell your personal information. Our current processors include:

Processor Purpose Location / transfer basis
Stripe, Inc. Web payment processing USA — EU-US DPF certified
Paddle.com Market Ltd. Web payment processing (merchant of record) UK — UK IDTA / EU SCCs
PayPal (Europe) S.àr.l. Web payment processing (PayPal checkout) Luxembourg — EU-US DPF certified
RevenueCat, Inc. Subscription management & entitlements USA — SCCs
PostHog Product analytics (pseudonymised) USA / EU hosting available — SCCs
Resend Transactional email delivery USA — SCCs
Klaviyo, Inc. Marketing email & SMS automation USA — EU-US DPF certified
Vercel, Inc. Web hosting and CDN USA — EU-US DPF certified
Sentry Error monitoring and crash reporting USA — EU-US DPF certified
Meta Platforms Advertising pixels and retargeting USA — EU-US DPF certified
Apple Inc. iOS in-app purchase billing USA — SCCs
Google LLC Android billing; Firebase analytics USA — EU-US DPF certified

We may also disclose your data: (a) to comply with a legal obligation or court order; (b) to protect the rights, property, or safety of Auralyo, our users, or the public; or (c) in connection with a merger, acquisition, or sale of assets.

V. International Data Transfers

GoShapers L.L.C-FZ is based in Dubai, UAE. Your data may be transferred to and processed in countries outside your home jurisdiction. We rely on the following safeguards:

• EU-US Data Privacy Framework (DPF): Processors certified under the EU-US DPF (approved by the European Commission in July 2023) provide adequate protection under GDPR.
• Standard Contractual Clauses (SCCs): Where DPF certification is unavailable, we use EU Commission-approved SCCs (2021 edition).
• UK IDTA: For transfers from the UK, we use the UK International Data Transfer Agreement or UK Addendum to SCCs.
• UAE transfers: Transfers to or from the UAE are governed by the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection. GoShapers L.L.C-FZ complies with all applicable requirements of this law.

You may request a copy of the relevant safeguards by contacting privacy@auralyo.com.

VI. Your Privacy Rights

6.1 EEA / UK Users — GDPR Rights

If you are located in the EEA or UK, you have the following rights:

• Right of access — to obtain a copy of the personal data we hold about you
• Right to rectification — to correct inaccurate or incomplete data
• Right to erasure — to request deletion of your data, subject to legal retention obligations
• Right to restriction — to limit how we process your data in certain circumstances
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent — where processing is based on consent, withdraw at any time
• Right to lodge a complaint — with your local supervisory authority (e.g., ICO in the UK)

To exercise these rights, email privacy@auralyo.com. We will respond within 30 days.

6.2 California Residents — CCPA / CPRA Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to know — categories and specific pieces of personal information collected in the prior 12 months
• Right to delete — request deletion of personal information, subject to certain exceptions
• Right to correct — request correction of inaccurate personal information
• Right to opt-out of sale or sharing — Auralyo does not sell personal information. Pseudonymised advertising data sharing may be opted out via Cookie Policy settings
• Right to limit use of sensitive personal information
• Right to non-discrimination — we will not discriminate against you for exercising CCPA rights

To exercise CCPA rights, email privacy@auralyo.com with "California Privacy Rights Request" in the subject line. We will respond within 45 days. You may designate an authorised agent by providing written authorisation.

6.3 All Users

Regardless of location, you may contact us to: (a) access your data; (b) correct inaccurate data; (c) delete your account; or (d) opt out of marketing communications at any time.

VII. Data Retention

We retain personal data for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required by law. Specific retention periods are set out in the GDPR Article 6 table in Section II. When data is no longer needed, it is securely deleted or anonymised.

VIII. Cookies

We use cookies and similar tracking technologies on our website and web quiz funnel. For full details, please see our Cookie Policy at auralyo.com/cookie-policy. We use a Consent Management Platform (CMP) that requires your explicit consent before placing non-essential cookies. You can update your cookie preferences at any time via "Cookie Settings" in the footer.

IX. Children's Privacy

The Service is intended for users aged 18 and older. We do not knowingly collect personal data from individuals under 18. If you believe a minor has submitted personal data to us, please contact privacy@auralyo.com immediately and we will promptly delete it.

X. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure, including encryption in transit (TLS), encrypted storage, and access controls. No transmission over the internet is 100% secure.

XI. Data Breach Notification

In the event of a security breach reasonably likely to result in harm to users, we will notify affected users and relevant supervisory authorities as required by applicable law. Under GDPR, we will notify the relevant supervisory authority within 72 hours of becoming aware of a qualifying breach. We will notify affected users without undue delay via email and/or prominent in-app notice.

XII. Automated Decision-Making

Auralyo does not make decisions that produce significant legal effects concerning you based solely on automated processing, including profiling, within the meaning of GDPR Article 22.

XIII. Changes To This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or in-app notice at least 30 days before taking effect. Continued use of the Service after changes take effect constitutes acceptance.

XIV. Contact Us

• Email: privacy@auralyo.com
• Response time: 30 days (EEA/UK users); 45 days (California users)
• For UAE data protection enquiries: GoShapers L.L.C-FZ, Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.