PRIVACY POLICY

Last updated April 19, 2026

This Privacy Notice for Ingrain Labs LLC (doing business as Ingrain) describes how and why we might collect, store, use, and share your personal information when you use our services, including when you:

Questions or concerns? Contact us at hello@ingrainapp.com.


SUMMARY OF KEY POINTS


TABLE OF CONTENTS

  1. What Information Do We Collect?
  2. How Do We Process Your Information?
  3. When and With Whom Do We Share Your Personal Information?
  4. Do We Use Cookies and Other Tracking Technologies?
  5. Do We Offer Artificial Intelligence-Based Products?
  6. How Do We Handle Your Social Logins?
  7. How Long Do We Keep Your Information?
  8. How Do We Keep Your Information Safe?
  9. What Are Your Privacy Rights?
  10. Controls for Do-Not-Track Features
  11. Do United States Residents Have Specific Privacy Rights?
  12. Longitudinal Coaching Data
  13. Do We Make Updates to This Notice?
  14. How Can You Contact Us About This Notice?
  15. How Can You Review, Update, or Delete the Data We Collect From You?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide when you register on the Services or otherwise interact with us. This includes:

Sensitive Information: We do not process sensitive information.

Payment Data: All payment data is handled and stored by Stripe, Apple, and Google. Payment information is processed directly by Stripe and is never stored on Ingrain's servers. Ingrain retains only subscription status and plan type. Privacy policies: Stripe | Apple | Google

Social Media Login Data: If you register using Google or Apple, we receive certain profile information from those providers. See Section 6 for details.

Application Data:

Information automatically collected

We automatically collect certain information including IP address, browser and device characteristics, operating system, language preferences, and usage information. We also collect information through cookies. See our Cookie Notice at ingrainapp.com/cookie-policy.

Automatically collected data includes:

Google API

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.


2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for the following reasons:


3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your data with third-party vendors who perform services for us. We have contracts in place with all third parties to safeguard your personal information.

Third parties we share personal information with:

We may also share your information in connection with a business transfer (merger, acquisition, or sale of assets).


4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (web beacons, pixels) to gather information when you interact with our Services. These help maintain security, prevent crashes, fix bugs, save preferences, and assist with basic site functions.

For more detail, see our Cookie Notice: ingrainapp.com/cookie-policy


5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

Yes. We offer products powered by artificial intelligence through Anthropic. Your input, output, and personal information will be shared with and processed by Anthropic to enable your use of our AI features. You must not use the AI Products in any way that violates the terms or policies of Anthropic.

Our AI Products are designed for:

How to Opt Out:

Note: Because AI session generation is core to the Ingrain service, opting out effectively means opting out of the product. Account deletion removes all personal information from the coaching context.


6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

Our Services offer you the ability to register and log in using Google or Apple account details. We will receive certain profile information from the provider: typically name, email address, and profile picture.

We will use this information only for the purposes described in this Privacy Notice. We are not responsible for other uses of your personal information by the third-party provider. We recommend reviewing their privacy notices:


7. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required by law. In general, data is retained for the lifetime of your account.

Upon account deletion, all personal information and coaching history is permanently deleted within 30 days. IP-based geolocation data captured in infrastructure logs is retained for up to 6 months and is not used for personalization or marketing purposes.

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it. If deletion is not immediately possible (e.g., data stored in backup archives), we will securely store and isolate it until deletion is possible.


8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures including:

However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. You should only access the Services within a secure environment.


9. WHAT ARE YOUR PRIVACY RIGHTS?

You may review, change, or terminate your account at any time.

Withdrawing your consent: You can withdraw consent at any time by contacting us at hello@ingrainapp.com. This will not affect the lawfulness of processing before withdrawal.

Opting out of marketing: Unsubscribe by clicking the unsubscribe link in our emails, or by contacting us. You may still receive service-related (non-marketing) messages.

Push notifications: Adjust notification preferences directly in your mobile device settings.

Account Information: To review or change your account:

Upon account termination request, we will deactivate or delete your account and information from our active databases. We may retain some information to prevent fraud, assist with investigations, or comply with legal requirements.

Cookies: Most browsers accept cookies by default. You can choose to remove or reject cookies, though this may affect certain features. See: ingrainapp.com/cookie-policy

For privacy rights questions: hello@ingrainapp.com


10. CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to Do-Not-Track (DNT) browser signals, as no uniform technology standard for recognizing and implementing DNT signals has been finalized. If a standard is adopted that we must follow, we will update this notice.

California law requires us to disclose this: we do not respond to DNT signals at this time.


11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to, correct, copy, or delete your personal information, and to withdraw consent to our processing.

Categories of Personal Information Collected in the Past 12 Months

CategoryExamplesCollected
A. IdentifiersEmail address, IP address, account nameYES
B. California Customer RecordsFinancial informationYES
C. Protected classification characteristicsAge confirmation (13+)YES
D. Commercial informationSubscription plan and statusYES
E. Biometric informationFingerprints, voiceprintsNO
F. Internet or other network activityApp usage events, session behaviorYES
G. Geolocation dataIP-based locationYES
H. Audio, electronic, sensory informationAudio, video recordingsNO
I. Professional or employment-related informationWork history, job titlesNO
J. Education informationStudent recordsNO
K. Inferences drawn from personal informationCoaching profile, learning patternsYES
L. Sensitive personal informationn/aNO

Retention by category:

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding 12 months.

Your Rights include:

How to Exercise Your Rights

Appeals

If we decline your request, you may appeal by emailing hello@ingrainapp.com. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine the Light" Law

California residents may request information about categories of personal information disclosed to third parties for direct marketing purposes. Submit requests using the contact details in Section 14.


12. LONGITUDINAL COACHING DATA

Ingrain's core service relies on accumulating a coaching context across practice sessions to deliver increasingly personalized guidance over time. This coaching context includes your skill level, practice goals, self-reported weaknesses, session reflections, and inferred learning patterns. This data is used exclusively to generate your personalized practice sessions and improve coaching quality over time. It is never used for advertising, sold to third parties, or used for any purpose outside of delivering the Ingrain coaching service. You may request deletion of your coaching data at any time by contacting hello@ingrainapp.com or deleting your account.


13. DO WE MAKE UPDATES TO THIS NOTICE?

Yes. We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top. If we make material changes, we may notify you by posting a prominent notice or by sending you a direct notification. We encourage you to review this notice frequently.


14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Ingrain Labs LLC
Data Protection Officer
8 The Green, Suite B
Dover, DE 19901
United States

Email: hello@ingrainapp.com


15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, correct inaccuracies, or delete your personal information. To do so, submit a data subject access request, or contact us at hello@ingrainapp.com.