VelaSleep Privacy Policy

Version: v0.2

Effective Date: May 22, 2026

Last Updated: May 22, 2026

This Privacy Policy explains how MOBIUS ENTERTAINMENT PTE. LTD. ("VelaSleep," "we," "us," or "our") collects, uses, discloses, stores, and protects personal information when you use the VelaSleep mobile application, websites, and related services (collectively, the "Services").

VelaSleep is an AI sleep companion app that helps users wind down, reflect, and play sleep-supportive audio experiences. VelaSleep is not a medical, mental health, diagnostic, therapeutic, emergency, or crisis service.

If you have questions about this Privacy Policy or our privacy practices, contact us at: support@mobiusplay.com.

1. Key Privacy Commitments

Here are the key things to know:

We do not save your raw voice recordings.
When you speak to Vela, your voice may be processed into text by us or our speech recognition service providers so Vela can understand and respond to you.
We may save conversation transcripts, chat history, sleep session activity, and preferences to your account to provide history, account sync, and personalization.
We may create a personalization profile, or "Vela memory," to help Vela remember what tends to help you wind down.
We do not use your private conversations with Vela to train AI models unless you give us permission.
You can clear your chat history or delete your account in the App.
When you delete your account, we delete or de-identify personal information associated with your account, including your conversation history and Vela memory, except where limited retention is required for legal, security, fraud prevention, accounting, dispute resolution, or compliance purposes.
We do not sell your personal information or share your conversation content for advertising or cross-context behavioral advertising.
Vela is an AI sleep companion, not a medical, mental health, emergency, or crisis service.

2. Who Can Use VelaSleep

VelaSleep is intended for users who are 18 years of age or older. We do not knowingly collect personal information from anyone under 18.

If we learn that we have collected personal information from a user under 18, we will take steps to delete it. If you believe someone under 18 has provided us with personal information, please contact us at support@mobiusplay.com.

We may implement age verification or age assurance mechanisms to enforce this requirement.

3. Personal Information We Collect

Depending on how you use the Services, we may collect the following categories of personal information.

3.1 Account Information

When you create or manage an account, we may collect information such as:

name or display name;
email address;
authentication provider, such as Apple, Google, or email;
account identifiers;
profile image or avatar, if you choose to provide one;
language and region settings; and
account status, such as free, trial, or premium.

3.2 Voice Processing Data

If you use voice features, your microphone audio may be processed in real time to create a text transcript so that Vela can understand and respond to you.

We do not save raw voice recordings. Voice audio may be temporarily processed by us or by third-party speech recognition service providers to provide voice interaction features. These service providers are contractually required to process audio data only according to our instructions, not retain raw audio beyond the time needed to generate a transcript, and not use your audio data for training their own models. We do not store raw voice recordings as part of your account history.

3.3 Conversation Data

We may collect and save:

text messages you type;
transcripts created from your voice input;
Vela's responses;
conversation history;
sleep session activity, such as when a session starts, ends, or triggers sleep-supportive audio; and
feedback or support messages you send to us.

3.4 Personalization Profile and Vela Memory

To make Vela more helpful over time, we may create a personalization profile, or "Vela memory," based on your interactions. This may include:

sleep preferences, such as how quickly you typically fall asleep;
calming routines and relaxation preferences;
content preferences, such as whether you prefer guided relaxation or quiet background sounds;
preferred voice or companion style;
stress level context you choose to share;
topics or approaches that help you wind down;
topics or approaches that do not help you; and
other preferences you choose to share with Vela.

During your conversations with Vela, including the initial personalization setup, Vela may ask you about sleep habits, stress levels, relaxation preferences, and similar topics to personalize your experience. You may also voluntarily share additional sleep, mood, or wellness-related information.

We do not require you to answer any specific question. If you choose not to respond, Vela will skip that topic, and the Services will continue to function using default settings.

Important: We do not treat information collected through Vela conversations as medical or diagnostic data. We use it only as described in this Privacy Policy, such as to provide AI sleep companion functionality, personalize your experience, support safety features, and operate the Services. VelaSleep does not use this information to provide medical advice, diagnosis, treatment, therapy, or emergency support. We strictly avoid medical or diagnostic language in all interactions.

In certain U.S. states, sleep and wellness-related information may be classified as "sensitive personal information" or "consumer health data" under applicable law. For additional information about your rights regarding such data, please see Section 15 (Information for California Residents) and Section 16 (Consumer Health Data — U.S. State Supplement) below.

3.6 Subscription and Purchase Information

If you purchase a subscription or other paid feature, payment processing may be handled by Apple, Google, Stripe, or another payment provider. We may receive limited information needed to provide and manage your subscription, such as:

product or subscription identifier;
subscription status;
renewal or expiration date;
purchase platform; and
transaction or receipt identifiers.

We do not receive or store your full payment card number from app store or payment providers.

3.7 Device, Usage, Analytics, and Diagnostics Data

We may collect technical and usage information such as:

device type, operating system, and app version;
IP address and approximate location derived from IP address;
feature usage and interaction events;
performance data;
crash logs and error reports;
network and connection information; and
notification tokens, if you enable push notifications.

4. How We Use Personal Information

We use personal information to:

provide, operate, maintain, and improve the Services;
process voice input into text so Vela can respond;
generate AI responses and sleep-supportive interactions;
save and display conversation history;
sync your account across devices;
personalize future sessions through Vela memory;
play and recommend sleep-supportive audio experiences;
manage subscriptions, trials, and account status;
provide customer support;
send service-related notices, security alerts, and product updates;
send optional marketing communications if permitted by law and your choices;
analyze performance, fix bugs, and improve reliability;
detect, prevent, and respond to fraud, abuse, security incidents, and misuse;
comply with legal obligations; and
enforce our terms, policies, and rights.

5. Voice and Audio Processing

VelaSleep uses your microphone only when you choose to speak to Vela or enable voice features.

When you speak to Vela, your voice may be processed in real time to create a text transcript. This transcript helps Vela understand your request and respond to you.

We do not save raw voice recordings. Voice audio may be processed temporarily by us or by third-party speech recognition service providers, but raw voice recordings are not stored in your account history. Our speech recognition service providers are contractually prohibited from retaining raw audio beyond the time required to process your request and from using your audio data to train their own models.

You can manage microphone access through your device settings.

6. Conversations, Transcripts, and Chat History

We may save your text messages, voice transcripts, Vela's responses, and sleep session activity in your account. We use this information to provide conversation history, account sync, continuity between sessions, safety features, and personalization.

You can clear your chat history in the App. Clearing chat history may remove past conversations from your account experience, but it may not remove limited records that we are required or permitted to retain for legal, security, fraud prevention, accounting, dispute resolution, or compliance purposes.

7. Personalization and Vela Memory

Vela may become more personalized over time based on your interactions. We may create Vela memory to help Vela remember preferences and patterns that may make future sleep sessions more helpful.

Vela memory may include your sleep preferences, calming routines, content preferences, companion style preferences, and what has or has not helped you in past sessions.

You can delete your account in the App. Account deletion deletes or de-identifies Vela memory associated with that account, except where limited retention is required for legal, security, fraud prevention, accounting, dispute resolution, or compliance purposes.

We may also provide additional controls to reset or manage personalization.

8. AI Service Providers and Third-Party Data Processing

We use third-party service providers to help us provide the Services. These may include providers for:

cloud hosting and storage;
speech recognition (ASR);
AI language model processing;
text-to-speech (TTS) or voice generation;
analytics and product measurement;
crash reporting and diagnostics;
authentication;
customer support;
payments and subscription management;
email and service communications; and
security, fraud prevention, and compliance.

8.1 AI Language Model Providers

Conversation data — subject to data minimization measures — may be transmitted to third-party AI language model providers solely to generate conversational responses within the app's core functionality. We may use more than one AI language model provider, including as fallback when a primary provider is unavailable.

These providers are contractually required to:

process your data only in accordance with our agreements and solely for the purpose of providing the AI language model service to us;
not use your data for training their own AI models or for any other purpose;
implement appropriate technical and organizational security measures;
delete or return your data upon termination of the service relationship; and
provide the same or equivalent protection of user data as stated in this Privacy Policy.

8.2 Speech Recognition and Voice Generation Providers

Voice audio may be temporarily processed by third-party speech recognition providers to convert your speech into text, and text may be processed by third-party voice generation providers to produce Vela's spoken responses. These providers are subject to the same contractual protections described above.

We do not share your conversation content with advertisers for advertising or cross-context behavioral advertising.

We may disclose personal information if required by law or if we believe disclosure is necessary to protect the rights, safety, and security of VelaSleep, our users, or others.

9. Model Training and Service Improvement

We do not use your raw voice recordings to train AI models.

We do not use your private conversations with Vela to train AI models unless you give us permission. If we offer optional programs to help improve Vela using conversation data, we will explain what data is used and ask for your consent where required.

We may use aggregated, de-identified, or anonymized information to understand and improve the Services, provided that this information does not reasonably identify you.

10. Subscriptions and Payments

Subscriptions, free trials, renewals, cancellations, and refunds may be handled by the applicable app store or payment provider, such as Apple, Google, or Stripe.

Deleting your VelaSleep account does not automatically cancel an active subscription purchased through an app store or payment provider. You should manage or cancel your subscription through the platform where you purchased it.

We may process limited subscription information to provide paid features, verify access, prevent fraud, and comply with accounting and legal obligations.

11. Analytics, Diagnostics, and Notifications

We may use analytics and diagnostics tools to understand how the Services are used, improve performance, fix bugs, and maintain reliability.

If you enable push notifications, we may process a notification token to send service-related notifications, sleep reminders, subscription notices, or other messages according to your settings. You can manage push notifications through the App or your device settings.

We do not use conversation content for advertising.

12. Cookies and Similar Technologies

We may use cookies, web beacons, device identifiers, and similar technologies on our websites and in the App to collect usage information, provide analytics, and support functionality.

We do not use cookies or similar technologies to serve behavioral advertising within the App. If we use analytics SDKs or similar tools, these tools collect technical and usage data as described in Section 3.7 and are subject to our data processing agreements.

You can manage cookie preferences through your browser or device settings, or through any cookie consent tool we provide on our websites.

13. How Long We Keep Information

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Our general retention practices are:

Raw voice recordings: not saved.
Conversation transcripts and chat history: retained until you clear them, delete your account, or we no longer need them to provide the Services.
Vela memory and personalization profile: retained until you delete your account or we no longer need them to provide personalization.
Subscription and transaction records: retained as needed for subscription management, accounting, tax, fraud prevention, dispute resolution, and legal compliance.
Diagnostics, security, and operational logs: retained for a limited period needed to operate, secure, debug, and improve the Services.
Aggregated, de-identified, or anonymized information: may be retained for analytics, research, and service improvement where it does not reasonably identify you.

When retention is no longer necessary, we delete, de-identify, or anonymize personal information according to our data retention practices and applicable law.

14. Data Breach Notification

In the event of a security breach resulting in unauthorized access to, or accidental or unlawful destruction, loss, alteration, or disclosure of your personal information, we will notify affected users and applicable regulatory authorities as required by applicable law. We will provide such notification within the timeframes required by applicable law and will include information about the nature of the breach, the data affected, and the steps we are taking in response.

15. Information for California Residents

This section provides additional disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA").

15.1 Categories of Personal Information Collected

The following table describes the categories of personal information we have collected from California consumers in the preceding twelve (12) months, along with our business purposes for collection and categories of third parties to whom we may disclose this information.

Category	Examples	Business Purpose	Disclosed To
Identifiers	Name, email, IP address, device identifiers, account ID	Provide Services, account management, security	Cloud hosting, authentication, analytics providers
Internet or electronic network activity	App usage, feature interactions, pages viewed, session data	Service improvement, analytics, debugging	Analytics providers, crash reporting services
Audio, electronic, or similar information	Voice transcripts (not raw audio)	Provide conversational AI functionality	AI language model providers, speech recognition providers
Inferences	Sleep preferences, personalization profile, Vela memory	Personalization, content recommendations	AI language model providers (for response generation)
Commercial information	Subscription status, purchase history	Subscription management, fraud prevention	Payment processors, subscription management services
Geolocation data	Approximate location derived from IP address	Service localization, analytics	Analytics providers
Sensitive personal information	Sleep habits, stress level, wellness preferences shared in conversations	Personalization of sleep companion experience	AI language model providers (for response generation)

15.2 Your California Privacy Rights

If you are a California resident, you have the right to:

Know what personal information we collect, use, disclose, and sell or share;
Access the specific pieces of personal information we have collected about you, including in a portable format;
Correct inaccurate personal information;
Delete personal information we have collected from you;
Opt out of the "sale" or "sharing" of personal information;
Limit the use and disclosure of sensitive personal information to purposes necessary to provide the Services; and
Not be discriminated against for exercising your CCPA rights.

VelaSleep does not sell personal information for monetary consideration. We do not share personal information for cross-context behavioral advertising.

If our practices change, we will update this Privacy Policy and provide a "Do Not Sell or Share My Personal Information" link as required by law.

15.4 Sensitive Personal Information

We may collect sensitive personal information as described in Section 3.5 (wellness and sleep-related information shared in conversations). We use this information only as necessary to provide the Services you request, specifically to personalize your sleep companion experience. We do not use sensitive personal information for purposes beyond what is necessary to provide the Services.

You have the right to limit the use and disclosure of your sensitive personal information. To exercise this right, contact us at support@mobiusplay.com.

15.5 Exercising Your Rights

To exercise your California privacy rights, contact us at support@mobiusplay.com or use the controls available in the App (such as clearing chat history or deleting your account).

We may verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf, but we may require verification that the agent is authorized to act for you.

We will respond to verifiable consumer requests within 45 days, or notify you if we need an extension as permitted by law.

15.6 Retention

We retain personal information for no longer than is reasonably necessary for the purposes described in this Privacy Policy. See Section 13 for details.

16. Consumer Health Data — U.S. State Supplement

This section supplements our Privacy Policy for users in states with consumer health data laws, including Washington's My Health My Data Act, Connecticut's Data Privacy Act, and Nevada's SB 370.

16.1 Consumer Health Data We Collect

Through your use of the Services, we may collect the following categories of consumer health data:

sleep preferences and habits;
stress level and relaxation preferences;
wellness-related information you share in conversations with Vela; and
sleep session activity, such as session timing and content played.

16.2 Purpose of Collection

We collect consumer health data for the following purposes:

to provide the AI sleep companion functionality;
to personalize your sleep experience through Vela memory;
to recommend sleep-supportive audio content; and
to operate and improve the Services.

Consumer health data may be shared with:

AI language model providers, solely to generate conversational responses;
Speech recognition and voice generation providers, solely to process voice interactions;
Cloud hosting providers, to store and sync your account data; and
Government agencies, when required by law.

We do not sell consumer health data. We do not share consumer health data for advertising purposes.

16.4 Your Rights

Depending on your state of residence, you may have the following rights with respect to your consumer health data:

Access your consumer health data;
Delete your consumer health data, and have our affiliates, service providers, and contractors delete it;
Withdraw consent for collection and sharing of your consumer health data; and
Obtain a list of all third parties and affiliates with whom we have shared your consumer health data.

To exercise these rights, contact us at support@mobiusplay.com. We will respond within the timeframes required by applicable law.

17. Information for Individuals in the EEA, UK, and Switzerland

This section provides additional information for individuals in the European Economic Area ("EEA"), United Kingdom ("UK"), and Switzerland (collectively, "Europe").

17.1 Data Controller

MOBIUS ENTERTAINMENT PTE. LTD. is the data controller for personal data processed under this Privacy Policy. You may contact us at support@mobiusplay.com.

17.2 Legal Bases for Processing

We process your personal data on the following legal bases:

Purpose	Legal Basis
Providing and maintaining the Services, including account management and conversation functionality	Necessary for the performance of our contract with you
Personalization through Vela memory	Necessary for the performance of our contract with you
Processing voice input to generate text transcripts	Necessary for the performance of our contract with you
Analytics, performance monitoring, and service improvement	Our legitimate interest in improving the Services
Security, fraud prevention, and abuse detection	Our legitimate interest in protecting the Services and users
Marketing communications	Your consent
Compliance with legal obligations	Necessary to comply with applicable law

17.3 Sensitive Data

If you choose to share information about your health, stress, sleep issues, or similar topics in conversations with Vela, this information may be considered "special category data" under the GDPR. By continuing to share such information after being informed through this Privacy Policy, you provide your explicit consent to our processing of this data as described herein. You may withdraw consent at any time as described in Section 17.5, though withdrawal will not affect the lawfulness of processing conducted prior to withdrawal.

We do not actively solicit special category data, and the Services are designed to function without it. If you choose not to share such information, Vela will use default settings.

17.4 International Data Transfers

We process and store personal data in the United States and other countries where we or our service providers operate. When we transfer personal data from Europe to countries not recognized as providing an adequate level of data protection, we implement appropriate safeguards, such as Standard Contractual Clauses adopted by the European Commission.

You may request a copy of these safeguards by contacting us at support@mobiusplay.com.

17.5 Your European Privacy Rights

In addition to the rights described elsewhere in this Privacy Policy, individuals in Europe have the right to:

Object to processing based on legitimate interests;
Restrict processing in certain circumstances;
Data portability — receive your personal data in a structured, commonly used, machine-readable format;
Withdraw consent at any time where processing is based on consent; and
Lodge a complaint with your local data protection authority.

To exercise your rights, contact us at support@mobiusplay.com. We will respond within 30 days, or notify you if we need an extension as permitted by law.

17.6 Data Retention

We retain personal data for no longer than is necessary for the purposes for which it is processed. See Section 13 for details.

18. Your Choices and Controls

Depending on your location and how you use the Services, you may have choices and controls such as:

access or update your account information;
clear your chat history;
delete your account;
manage microphone access through your device settings;
manage push notifications;
opt out of marketing communications;
manage subscription settings through the relevant app store or payment provider;
limit the use of sensitive personal information (California residents); and
contact us to exercise privacy rights available under applicable law.

19. Account Deletion and Data Deletion

You can delete your account in the App.

When you delete your account, we delete or de-identify personal information associated with your account, including your account profile, conversation history, sleep session history, and Vela memory.

We may retain limited information where necessary for legal, security, fraud prevention, accounting, dispute resolution, or compliance purposes. We do not use retained de-identified or limited records to personalize Vela for you after your account is deleted.

If your personal information has been processed by service providers, we instruct them to delete or de-identify it according to our agreements with them and applicable law, unless limited retention is required or permitted.

20. Safety, Crisis, and Emergency Limitations

VelaSleep is not an emergency service, crisis hotline, medical provider, mental health provider, therapist, or substitute for professional care.

If you may harm yourself or others, or if you are experiencing a medical or mental health emergency, call your local emergency number immediately. In the United States and Canada, you can call or text 988 for the Suicide & Crisis Lifeline. In the United States, you can also text HOME to 741741 to reach the Crisis Text Line.

Vela may provide supportive language or crisis resource information, but VelaSleep does not provide emergency response, clinical monitoring, diagnosis, treatment, or therapy.

21. Security

We use technical, organizational, and administrative safeguards designed to protect personal information. These safeguards may include encryption in transit and at rest, access controls, logging, monitoring, vendor review, and data minimization practices.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work to protect your information and improve our safeguards over time.

22. International Data Transfers

We may process and store personal information in the United States, Canada, and other countries where we or our service providers operate. These countries may have privacy laws that differ from those in your location.

When we transfer personal information internationally, we take steps designed to protect it as required by applicable law, including, where applicable, the use of Standard Contractual Clauses.

23. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice as required by law, such as through the App, by email, or by posting an updated version.

The "Last Updated" date at the top of this Privacy Policy indicates when it was most recently revised.

24. Contact Us

If you have questions, requests, or concerns about this Privacy Policy or our privacy practices, contact us at:

VelaSleep Privacy Team

Legal Entity: MOBIUS ENTERTAINMENT PTE. LTD.

Email: support@mobiusplay.com