Effective date: September 15, 2026  ·  Last updated: September 15, 2026

This Privacy Policy explains how HOLOPSY GLOBAL EVENTS ORGANIZING & MANAGING FZCO ("Holopsy", "we", "us", or "our"), a company registered in Dubai, United Arab Emirates, collects, uses, stores, and protects personal information when you use the Whyme mobile application (the "App") and related services (together, the "Services").

We provide an AI-assisted personal development and coaching application. We are committed to protecting your privacy and handling your personal data transparently and lawfully, in accordance with the laws that apply to you, including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL"), the European Union General Data Protection Regulation ("GDPR") for users in the European Economic Area and the United Kingdom, and United States privacy laws including the California Consumer Privacy Act / California Privacy Rights Act ("CCPA/CPRA") and the Children's Online Privacy Protection Act ("COPPA").

Important — not a medical service. Whyme is a personal development, well-being and coaching tool. It does not provide medical, psychological, or therapeutic diagnosis or treatment, and it is not a medical device. If you are experiencing a crisis or require medical advice, please contact a qualified healthcare professional or your local emergency services.

1. Who we are

HOLOPSY GLOBAL EVENTS ORGANIZING & MANAGING FZCO is the data controller responsible for your personal information.

·Registered address: Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates.

·Contact email: kilian.vernois@holopsy.ae (privacy enquiries: admin@holopsy.ae).

2. Information we collect

We collect information in the following categories. We only collect what is reasonably necessary to provide and improve the Services.

2.1 Account information

When you create an account, we collect your email address, an optional name, and a password (stored only in hashed, non-reversible form). We may also support sign-in through third-party authentication providers, in which case we receive the identifiers they share with us.

2.2 Profile and assessment data

To personalise your experience, we collect responses to personality and personal-development questionnaires, including process-communication (PCM), Enneagram, Spiral Dynamics and transactional-analysis based assessments. This produces derived profile data such as your dominant personality types, communication preferences, goals, and summary insights. This data can reveal information about your personality and psychological characteristics and is treated as sensitive personal data (see section 5).

2.3 Coaching content

We store the content you generate while using the App, including messages exchanged with the AI coach, session notes, tasks, and exercise activity.

2.4 Voice data

If you use voice input, audio recordings may be processed and transcribed to text using a third-party speech-to-text service. Transcriptions are stored; audio is used only to produce the transcription and is not retained longer than necessary for that purpose.

2.5 Payment and subscription data

If you purchase a subscription or use paid features, payment is processed directly by the app stores — Google Play Billing (Android) and the Apple App Store (iOS). We receive confirmation of your subscription status and a transaction identifier. We do not collect or store your full payment card details (Google and Apple handle payment). We also maintain an internal record of credit balances and promotional codes applied to your account.

2.6 Usage and device data

We automatically collect limited technical data such as device type, operating system, app version, language, approximate location (derived from IP address), and log data (error and activity logs). We do not collect persistent device identifiers such as IMEI, IMSI, or SIM serial numbers, and we do not link such identifiers to your personal data.

2.7 Files you upload

Any files, images, or audio you choose to upload are stored on our cloud storage (Amazon Web Services S3) so that they are available to you within the App.

3. How we use your information

·Provide and operate the Services — create and manage your account, deliver the coaching experience, store and retrieve your content.

·Personalise your experience — adapt content, recommendations and coaching to your profile and preferences.

·Process payments and subscriptions — manage credits, promotional codes and subscription entitlements.

·Improve our products — analyse aggregated, de-identified usage patterns to fix issues and develop features.

·Communicate with you — respond to support requests and send service-related notifications.

·Comply with legal obligations — meet applicable laws, respond to lawful requests, and protect our rights and users.

4. Legal bases for processing (GDPR)

For users in the EEA and the UK, we rely on the following legal bases under the GDPR:

·Performance of a contract — to provide the Services you request (account, coaching, payments).

·Consent — for processing sensitive profile data and for any optional data processing where you are asked to agree.

·Legitimate interests — to secure the Services, prevent fraud, and improve our products, balanced against your rights.

·Legal obligation — where we must retain or disclose data to comply with the law.

5. Sensitive personal data

Assessment results and coaching content can reveal information about your personality and psychological characteristics, which the GDPR classifies as a special category of personal data. We process this data only:

·with your explicit consent (you may withdraw it at any time, without affecting the lawfulness of prior processing);

·because it is necessary to provide the coaching service you have requested.

We do not use your sensitive data for advertising, and we do not sell your personal data to third parties.

6. How we share and disclose information

We do not sell your personal information. We disclose it only to the following categories of recipients, and only to the extent necessary:

·Service providers — hosting and database providers, cloud storage (Amazon Web Services S3), speech-to-text transcription providers, and AI model providers, acting on our instructions under contract.

·App store providers — Google Play Billing and the Apple App Store process subscription payments directly and receive only the information necessary to complete the transaction.

·Professional advisers and authorities — where required by law, regulation, or legal process, or to protect our rights, property, and the safety of our users.

·Business transfers — in connection with a merger, acquisition, or sale of assets, subject to appropriate confidentiality obligations.

All third-party service providers, SDKs, and AI integrations we use are contractually required to handle your data in compliance with this policy and applicable law, and are prohibited from selling your personal or sensitive data.

7. International data transfers

Our services are hosted and operated globally. Your data may be processed in the United Arab Emirates, the European Economic Area, the United States, and other jurisdictions where our service providers operate. Where we transfer personal data across borders, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses (for GDPR-governed transfers) and equivalent mechanisms required under the UAE PDPL.

8. Data retention

We retain personal data only for as long as necessary to fulfil the purposes described in this policy:

·Account and coaching data — for as long as your account is active, plus a reasonable period thereafter to comply with legal obligations and resolve disputes.

·Payment records — for the period required by applicable tax and accounting laws.

·Audio recordings — only as long as needed to produce the transcription, after which they are deleted.

To permanently delete your account and all associated data, see our Account Deletion page (holopsy.ae/delete-account), or see section 11 below for your privacy rights.

9. Data security

We implement appropriate technical and organisational measures to protect your data, including encryption in transit (TLS), hashed passwords, access controls, and secure hosting. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Children's privacy

11. Your privacy rights

11.1 Rights for EEA and UK users (GDPR)

·Access — request a copy of your personal data.

·Rectification — correct inaccurate or incomplete data.

·Erasure ("right to be forgotten") — request deletion of your data.

·Restriction — limit how we process your data.

·Portability — receive your data in a structured, machine-readable format.

·Objection — object to processing based on legitimate interests.

·Withdraw consent — at any time, for consent-based processing.

·Automated decision-making — request human review of decisions made solely by automated means with legal or similar effect.

You also have the right to lodge a complaint with your local supervisory authority (a Data Protection Authority in the EEA, or the Information Commissioner's Office in the UK).

11.2 Rights for California residents (CCPA/CPRA)

·Know — request the categories and specific pieces of personal information we collect.

·Delete — request deletion of your personal information.

·Correct — request correction of inaccurate personal information.

·Opt out of sale and sharing — we do not sell or "share" your personal information for cross-context behavioural advertising.

·Non-discrimination — you will not be discriminated against for exercising these rights.

To exercise these rights, contact us at admin@holopsy.ae. We will verify your identity before fulfilling requests.

11.3 Rights under the UAE PDPL

In accordance with the UAE Federal Decree-Law No. 45 of 2021, you have the right to request access to your personal data, request correction of inaccurate data, request deletion, and withdraw consent where processing is consent-based. You may also contact the UAE Data Office regarding concerns about how we handle your personal data.

To exercise any of these rights, contact us at admin@holopsy.ae. We will respond within the timeframe required by applicable law (typically within 30 days under GDPR).

12. Cookies and analytics

The mobile App itself does not rely on browser cookies for core functionality. Our website (holopsy.ae) may use cookies and similar technologies for essential functionality and, where applicable, aggregated analytics. We do not use third-party advertising trackers that build profiles of you across apps or websites.

13. AI and automated processing

The App uses artificial intelligence to generate coaching content, insights, and recommendations. AI-generated content is provided for personal development purposes only. Where we make decisions based solely on automated processing that produce legal or similarly significant effects, you may request human review (see section 11).

14. Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the App or by other appropriate means and update the "Effective date" above. Continued use of the Services after changes take effect constitutes acceptance of the revised policy.

15. Contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

HOLOPSY GLOBAL EVENTS ORGANIZING & MANAGING FZCO

Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates

Email: admin@holopsy.ae

Phone: +971 55 308 8814

© 2026 HOLOPSY GLOBAL EVENTS ORGANIZING & MANAGING FZCO. All rights reserved. Whyme is a product of Holopsy.

Effective date: September 25, 2026 · Last updated: September 25, 2026

These Terms of Use (the "Terms", also referred to as the "EULA" — End User Licence Agreement) form a legal agreement between you ("you", the "user") and HOLOPSY GLOBAL EVENTS ORGANIZING & MANAGING FZCO ("Holopsy", "we", "us", or "our"), a company registered in Dubai, United Arab Emirates.

They govern your access to and use of the Whyme mobile application (the "App") and all related services, content and features (together with the App, the "Services").

Please read these Terms carefully before using the Services. By downloading, installing, accessing, or using the App, or by creating an account, you confirm that you have read, understood, and agreed to be bound by these Terms. If you do not agree, do not use the Services.

Important — Whyme is not a medical service. See section 4 below.

1. Who we are

HOLOPSY GLOBAL EVENTS ORGANIZING & MANAGING FZCO

• Registered address: Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates
• Contact email: admin@holopsy.ae
• Phone: +971 55 308 8814

Our Privacy Policy explains how we collect and use your personal information. It forms part of these Terms and is available at www.holopsy.ae. By accepting these Terms, you also acknowledge that you have read the Privacy Policy.

2. Eligibility

3. What the Services are

Whyme is an AI-assisted personal development and mentoring application. It offers guided programmes, self-assessment questionnaires, reflective exercises, and conversations with an AI mentor intended to support personal growth, self-understanding, motivation and everyday wellbeing.

What the Services are not:

• They are not a healthcare, medical, psychological, psychiatric, or therapeutic service.
• They are not a medical device and have not been cleared or approved by any health authority.
• They are not a crisis, emergency, or suicide-prevention service.
• They do not replace the judgement, diagnosis, or treatment of a qualified professional.

4. No medical advice — important safety notice

Whyme does not provide medical, psychological, or therapeutic diagnosis, advice, or treatment.

The content, questionnaires, insights, and AI-generated messages you receive through the Services are provided for general personal development and informational purposes only. They are generated by software, may be incomplete or inaccurate, and must never be relied upon as professional advice.

You are solely responsible for your decisions. Do not disregard or delay seeking professional advice because of something you read or received in the App.

If you are in crisis, experiencing thoughts of self-harm, or believe you or someone else is in danger, do not use the App for help — contact your local emergency services or a qualified professional immediately. The App is not designed to handle emergency situations.

If you are receiving care from a healthcare professional, do not change or stop your treatment based on anything in the App.

5. Your account

5.1 To use most features, you must create an account with a valid email address and a password, and you may optionally provide a name.

5.2 You agree to provide accurate information and to keep it up to date.

5.3 Your account is personal. You must not share your credentials, sell, rent, or transfer your account, or let anyone else use it.

5.4 You are responsible for all activity that occurs through your account. Keep your password confidential and notify us immediately at admin@holopsy.ae if you suspect unauthorised access.

5.5 We may suspend or close an account that breaches these Terms, that we reasonably believe is being used fraudulently or unlawfully, or where we are required to do so by law.

5.6Deleting your account. You can delete your account and associated personal data at any time, from the App's settings or by emailing admin@holopsy.ae. Details of what is deleted, what we may need to retain, and how long it takes are set out in the Account Deletion section of our Privacy Policy at www.holopsy.ae. Deleting your account does not cancel a subscription — see section 6.6.

6. Subscriptions, billing and renewal

Some features of the Services require a paid subscription.

6.1 Plans and prices. Current plans (for example a monthly plan and a yearly plan) and their prices are displayed in the App, on the subscription screen, before you purchase, and may vary by country and currency. The price shown to you at the moment of purchase is the price that applies.

6.2 Where the payment happens. All subscriptions are sold through the app store from which you installed the App — the Apple App Store (on iOS) or Google Play (on Android). Payment is charged to your Apple ID account or your Google Play account at the confirmation of your purchase. We never receive or store your full card details; the app stores handle the payment and share only the subscription status and a transaction identifier with us.

6.3 Automatic renewal.Subscriptions renew automatically unless you cancel them. Your subscription will continue to renew for the same period (one month or one year, depending on the plan you chose), and your account will be charged for the renewal within 24 hours before the end of the current period, at the price in force for that plan (subject to section 6.7).

6.4 How to cancel. You can cancel your subscription at any time from your store account:

• On iOS: device Settings → tap your name → Subscriptions → Whyme → Cancel subscription.
• On Android:Google Play Store → Profile → Payments & subscriptions → Subscriptions → Whyme → Cancel subscription.

6.5 Effect of cancelling. Cancelling stops future renewals. Your access to the paid features continues until the end of the period you have already paid for, and then ends — we do not refund the current period. Cancelling does not delete your account, and deleting your account or uninstalling the App does not cancel your subscription.

6.6 Deleting the App or your account does not cancel your subscription. Subscriptions are managed by the app stores, not by us. You must cancel your subscription through your store as described in section 6.4, otherwise you will continue to be charged. This is also stated on our Account Deletion page at www.holopsy.ae.

6.7 Price changes. We may change subscription prices. Any price change will apply only to renewals that occur after the change, and, where required, after you have been informed and/or have agreed through the app store. You can always cancel before the change takes effect.

6.8 Free trials and introductory offers. If we offer a free trial or an introductory price, the specific conditions (length, price after the trial) are shown on the subscription screen before you start. Any unused part of a free trial is forfeited when you purchase a subscription.

6.9 Refunds. All purchases are processed by the app stores, and refunds are handled by Apple or Google under their own policies, not by us. If you believe you are entitled to a refund, request it from the store you purchased from:

• Apple: reportaproblem.apple.com
• Google Play: Google Play help centre — "Request a refund"

Where the law gives you a mandatory right of withdrawal (for example, consumers in the European Union), that right applies as provided by that law and is exercised in accordance with the app store's procedures. Because the Services are digital content supplied immediately, you may be asked to acknowledge that you lose the right of withdrawal once the content has been provided.

6.10 Promotional codes and credits. Promotional codes, credit balances, and discounts we issue are personal, have no cash value, cannot be exchanged or refunded, and may expire or be withdrawn in case of misuse, fraud, or breach of these Terms.

7. Apple-specific terms (iOS)

These clauses apply when you obtained the App from the Apple App Store. They are required by Apple and prevail over any conflicting term of these Terms in relation to your use of the App on an Apple device.

7.1 These Terms are concluded between you and Holopsy only, and not with Apple. Apple is not responsible for the App or its content.

7.2 The licence granted to you to use the App is a non-transferable licence to use the App on any Apple-branded products that you own or control, as permitted by the Apple Media Services Terms and Conditions, except that the App may be accessed by other accounts associated with you via Family Sharing or volume purchasing.

7.3Apple has no obligation whatsoever to furnish any maintenance or support services in respect of the App. Support is provided by us at admin@holopsy.ae.

7.4 In the event of any failure of the App to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the App to you (if any). To the maximum extent permitted by law, Apple has no other warranty obligation whatsoever with respect to the App, and any other claims, losses, liabilities, damages, costs or expenses attributable to any failure to conform to any warranty are our sole responsibility.

7.5 We, and not Apple, are responsible for addressing any claims you or any third party may have relating to the App, including: (i) product liability claims; (ii) any claim that the App fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection, privacy, or similar legislation.

7.6 In the event of any third-party claim that the App or your possession and use of the App infringes that third party's intellectual property rights, we, and not Apple, will be solely responsible for the investigation, defence, settlement and discharge of any such claim.

7.7 You represent and warrant that (i) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a "terrorist supporting" country, and (ii) you are not listed on any U.S. Government list of prohibited or restricted parties.

7.8 You must comply with any applicable third-party terms of agreement when using the App (for example, your mobile network operator's data terms).

7.9Apple, and Apple's subsidiaries, are third-party beneficiaries of these Terms, and upon your acceptance of these Terms, Apple will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as a third-party beneficiary.

8. Google Play terms (Android)

These clauses apply when you obtained the App from Google Play:

• The App is licensed, not sold, to you, for use strictly in accordance with these Terms and the Google Play Terms of Service.
• Google is not a party to these Terms and has no obligation to provide support or maintenance for the App.
• Google Play's refund policy governs refund requests for purchases made through Google Play.

9. Your content

9.1 The Services let you create and store content — messages exchanged with the AI mentor, session notes, tasks, journal entries, questionnaire answers, uploaded files, and similar material ("Your Content").

9.2You keep ownership of Your Content. We do not claim ownership of it.

9.3 You grant us a limited, worldwide, non-exclusive licence to host, store, process, transmit, and display Your Content — solely to operate, provide, secure, and improve the Services for you, and to comply with the law. This licence ends when you delete Your Content or your account, except where we are required to retain certain records by law (see the Privacy Policy).

9.4 You are responsible for Your Content and confirm that you have the right to upload it, and that it does not infringe anyone's rights or break any law.

9.5 Do not use the Services to store content you cannot afford to lose. While we take reasonable care, we do not guarantee that content will never be lost or corrupted.

10. Acceptable use

You agree not to:

• use the Services for any unlawful, harmful, abusive, defamatory, or fraudulent purpose;
• attempt to reverse-engineer, decompile, disassemble, copy, modify, or create derivative works of the App, except to the extent permitted by law;
• extract, scrape, or harvest data from the Services, or use them to train another AI system without our written permission;
• probe, scan, or test the vulnerability of the Services, or bypass or circumvent security, authentication, or usage limits;
• interfere with, overload, or disrupt the Services or the infrastructure they run on;
• impersonate any person, or misrepresent your identity or affiliation;
• use the Services to provide medical, psychological, or therapeutic advice to others;
• resell, sublicense, or commercially exploit the Services without our written permission;
• remove or obscure any proprietary notices, trademarks, or copyright statements.

We may suspend or terminate access for any breach of this section.

11. Artificial intelligence — limitations

11.1 Parts of the Services are generated by artificial intelligence models. AI output can be incomplete, inaccurate, outdated, biased, or simply wrong, even when it appears confident.

11.2 AI-generated content is provided for general personal development purposes only and does not constitute advice of any kind.

11.3 You must not rely on the Services to make important decisions about your health, safety, finances, or legal situation.

11.4 To provide the Services, your messages may be processed by third-party AI providers acting on our instructions. See the Privacy Policy for details.

12. Intellectual property

12.1 The Services — including the App, its software, design, text, graphics, logos, trademarks, programmes, questionnaires, and all related content (other than Your Content) — are owned by Holopsy or its licensors and are protected by intellectual property laws.

12.2 We grant you a personal, non-exclusive, non-transferable, revocable licence to use the App on devices you own or control, for your own personal, non-commercial use, subject to these Terms.

12.3 You may not use our name, logo, or trademarks without our prior written consent.

13. Availability and changes to the Services

13.1 We aim to keep the Services available, but we do not guarantee uninterrupted or error-free operation. The Services may be unavailable during maintenance, updates, or due to factors beyond our control (including your network and the app stores).

13.2 We may add, change, or remove features, or discontinue the Services (or part of them), at any time. If we discontinue a paid subscription service, we will handle it fairly, in accordance with applicable law and the app stores' rules.

13.3 We may release updates to the App. You may need to install them to keep using the Services.

14. Disclaimers

To the fullest extent permitted by law, and without excluding any right you have as a consumer under mandatory law:

14.1 The Services are provided "as is" and "as available", without warranties of any kind, express or implied, including any implied warranties of merchantability, fitness for a particular purpose, accuracy, or non-infringement.

14.2 We do not warrant that the Services will meet your expectations, produce any particular personal result, or that any error will be corrected.

14.3 We do not warrant the accuracy, completeness, or usefulness of any content or AI-generated output in the Services.

14.4 Nothing in these Terms excludes liability that cannot be excluded by law — for example, liability for death or personal injury caused by our negligence, or for fraud.

15. Limitation of liability

15.1 To the maximum extent permitted by law, Holopsy shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or for any loss of profits, revenue, data, goodwill, or opportunity, arising out of or in connection with your use of (or inability to use) the Services.

15.2 To the maximum extent permitted by law, our total aggregate liability for all claims relating to the Services shall not exceed the greater of (a) the amount you paid us through the Services in the twelve (12) months preceding the event giving rise to the claim, and (b) USD 50.

15.3 We are not liable for the acts or omissions of third parties, including the app stores, network operators, hosting providers, speech-to-text providers, and AI model providers.

15.4 Some jurisdictions do not allow certain limitations, so some of the above may not apply to you. In that case, our liability is limited to the minimum permitted by law.

16. Indemnity

You agree to indemnify and hold harmless Holopsy, its officers, directors, employees, and agents against any claims, losses, liabilities, damages, and reasonable costs (including legal fees) arising from: (i) your breach of these Terms; (ii) your misuse of the Services; or (iii) your violation of any law or third-party right — including content you upload.

17. Termination

17.1 You may stop using the Services and delete your account at any time.

17.2 We may suspend or terminate your access if you materially breach these Terms, if we are required to by law, or if we discontinue the Services. Where reasonably possible, we will give you notice.

17.3 On termination, your licence to use the App ends, and sections which by their nature should survive (including sections 9.3, 12, 14, 15, 16, 18, and 19) will continue to apply.

17.4 Termination of your account does not automatically cancel a subscription purchased through an app store (see section 6.4).

18. Changes to these Terms

18.1 We may update these Terms from time to time — for example, to reflect new features, or changes in the law.

18.2 The updated version will be published at www.holopsy.ae with a new "Last updated" date, and, where the changes are significant, we will notify you in the App or by email before they take effect.

18.3 By continuing to use the Services after the effective date, you accept the updated Terms. If you do not agree, you must stop using the Services and may delete your account.

19. Governing law and disputes

19.1 These Terms are governed by the laws of the United Arab Emirates, as applied in the Emirate of Dubai, without regard to conflict-of-law rules.

19.2 Any dispute arising out of or relating to these Terms or the Services shall be subject to the exclusive jurisdiction of the courts of Dubai, United Arab Emirates, subject to any mandatory consumer-protection rights you may have in your country of residence.

19.3 Before starting proceedings, we ask that you contact us at admin@holopsy.ae so we can try to resolve the matter informally.

20. Miscellaneous

20.1 Entire agreement. These Terms, together with the Privacy Policy, constitute the entire agreement between you and us regarding the Services, and replace any prior agreement on that subject.

20.2 Severability. If any provision is found to be invalid or unenforceable, the remaining provisions remain in full force.

20.3 No waiver. Our failure to enforce a provision is not a waiver of it.

20.4 Assignment. You may not assign these Terms without our consent. We may assign them in connection with a merger, acquisition, or sale of assets.

20.5 Language. These Terms are drafted in English. Any translation is provided for convenience only; in case of discrepancy, the English version prevails.

20.6 Force majeure. We are not liable for delays or failures caused by events beyond our reasonable control.

21. Contact

Questions about these Terms?

HOLOPSY GLOBAL EVENTS ORGANIZING & MANAGING FZCO

Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates

Email: admin@holopsy.ae

Phone: +971 55 308 8814

Whyme is a personal development and mentoring application. It is not a medical service and does not provide medical, psychological, or therapeutic advice, diagnosis, or treatment.