Privacy Policy.

1. What we collect, and why

The table uses the categories California law asks for. “Life of the account” means the data is deleted with your account (see section 11 for the schedule).

We do not collect precise geolocation, government identifiers, or biometric identifiers used to recognise you. We do not knowingly collect anything from a person under 18.

2. Where it comes from

• You: forms, sign-up, onboarding, everything you say to the coach, uploads, settings.
• Your device: the browser and app send technical details, your time zone, and, with your permission, Apple Health readings.
• Services you connect: Oura, WHOOP and Apple Health (health data), Plaid (bank data).
• Our payment processors: Whop and Stripe tell us what you bought.
• Our own software: the profile, scores, digests and memory are inferred from the above.

3. How we use it, and on what basis

• To provide the service you signed up for: the account, the coach, the hypnosis audio, MER, progress and streaks, support. Legal basis (EEA/UK): performance of our contract with you.
• With your consent, which you can withdraw at any time: health and wearable data; cookies and advertising pixels (in the EEA, UK and Switzerland); marketing email; the application call and texts; a voice sample; the bank connection.
• For our legitimate interests, balanced against yours: keeping the service secure and free of abuse, measuring which pages work, improving the product from aggregate patterns, defending legal claims. You may object (section 13).
• To meet legal obligations: tax and accounting records, responding to lawful requests, honouring your rights.

We do not use your content, your profile or your health or bank data for advertising, and we do not sell personal information for money.

4. How the AI works with your data

The coach and the hypnosis writer are large language models run by third-party providers. To answer you, the relevant part of your conversation, your profile and, if connected, a short health or finance digest is sent to the provider as a prompt and the reply comes back. Text goes to Anthropic. Live voice calls, the “Listen” read-aloud on coach replies and dictation go to OpenAI. The hypnosis script and, if you recorded one, your voice sample go to the audio renderer we run on RunPod, fal or Modal.

• No training on your content. We do not train or fine-tune any model on your conversations, profile, audio, health or bank data. Our providers process it under commercial API terms that bar them from training on it.
• Provider retention. OpenAI is told to keep no recording of your live calls (storage off). Anthropic may hold prompts briefly to detect abuse under its API terms, then deletes them. The audio renderer receives a time-limited link to your voice sample and does not keep a copy after rendering.
• Your voice. A voice sample is used only to speak your own sessions in your voice, only after you tick the separate consent when recording it, and only while it exists in your account.
• People. Nobody at Marczell AI reads your coaching conversations or your MER intake as a matter of course. Staff see your support messages, and, if you ask for a human review (section 5), the person reviewing sees what the review needs.

5. Your profile, and decisions made by software

Marczell AI builds a behavioural profile of you: eleven scores (for example awareness, identity, confidence, execution), your core values, the loops it notices, a short narrative, and a “coaching memory” of facts you have told the coach. It is built from your onboarding answers, your conversations and, if connected, your wearable and bank digests. It changes what the coach says and what your hypnosis audio contains.

• See it: Identity shows the profile and scores; Coach memory shows the facts.
• Correct it: edit or remove any fact on the Coach memory page; the coach uses the corrected version from the next message.
• Pause it: Settings → “Pause profiling” stops the profile and scores being updated from new sessions. Coaching continues from the conversation itself. Your existing profile stays until you delete it or your account.
• Ask a person: Privacy request → “Ask a person to review an automated decision”. A member of our team reviews and answers.

Decisions our software makes on its own, and what you can do: (a) the MER safety screen declines to generate a session when your intake indicates you are in danger now, are suicidal, or the situation is ongoing, and shows you crisis resources and a route to a person instead: nothing is charged, and you can ask for human review; (b) support requests are sorted by an AI assistant, which answers routine questions itself and routes money, access, legal and privacy matters to a person; (c) your membership tier decides which features you can use, from your purchase. None of these produces legal effects, and every one can be reviewed by a person on request.

6. Health and wearable data

If you connect Oura, WHOOP or Apple Health we collect heart rate, heart-rate variability, sleep stages and timing, recovery or readiness, respiratory rate, skin temperature deviation, blood-oxygen average, activity, steps and workouts, and we infer from them a short daily digest that the coach reads. This is special-category data in the EEA and UK and “consumer health data” under Washington and Nevada law, so:

• We ask for your explicit consent, in its own box with its own wording, before the first connection. Nothing is read until you tick it. The wording, its version, the time, your hashed IP and browser are recorded.
• It is used only to personalise your coaching and hypnosis. It is never used for advertising and never sold or shared for advertising.
• The daily readings live in our database in the United States. A summary, not raw readings, reaches the AI provider inside your prompts.
• Disconnecting a device withdraws consent: that device’s readings and what we inferred from them are deleted, and the coach stops seeing them.

Our standalone Consumer Health Data Privacy Policy sets this out in the form Washington and Nevada require.

7. Bank and financial data

If you connect a bank through Plaid, we receive your account names and types, the last four digits, balances and a rolling window of transactions; if you upload statements, the AI reads them to build the same digest. The coach sees a digest (income rhythm, spend shape, commitments, margin), never individual transactions. Access tokens are stored encrypted, transactions are deleted after 90 days, and disconnecting removes the connection at Plaid as well as here. Plaid’s own policy governs its handling of your bank login, which we never see.

8. Advertising, cookies and tracking

We share some personal information with advertising partners for cross-context behavioural advertising. When ad sharing is on, the Meta Pixel and Hyros run on our public pages and receive identifiers (their cookie ids and, for Meta, a hashed match key), internet activity (the pages you view and the actions you take, such as signing up) and inferences drawn from them, so we can measure campaigns and show ads to people like our members. We do not sell personal information for money. We never share your conversations, profile, health or bank data with advertisers.

• Your Privacy Choices. Turn ad sharing off at any time at Your Privacy Choices (also linked in the footer as required by California law). We also honour the Global Privacy Control browser signal as a valid opt-out request: when your browser sends it, ad sharing is off and stays off.
• EEA, UK and Switzerland. No advertising or analytics tag loads until you choose “Accept all” on the consent banner. “Reject all” is one tap and equally prominent. Your choice is stored with its version and time and can be changed on the same page.
• First-party analytics. We record page views on our own site (path, referrer, campaign tags, device type, approximate location, hashed IP) to see which pages work. In the EEA and UK this runs only with your consent.

The cookies we set:

9. Who receives your information

We share personal information only with providers that process it for us under contract, with partners you choose to connect, with advertising partners as described in section 8, and where the law requires. Our processors, by role:

• Hosting, database and file storage: Vercel (application), Supabase (database and files, hosted in the United States), Cloudflare (network and video delivery), Inngest (background jobs; job records can contain the content a job worked on).
• AI model providers: Anthropic (text), OpenAI (voice calls, read-aloud, dictation), and our audio renderer on RunPod, fal and Modal (hypnosis scripts and voice samples); ElevenLabs for sound effects only.
• Email, messaging and CRM: Resend (email delivery), GoHighLevel (applicants’ contact details, income and budget ranges and the consent record, so a head coach can call), Slack (internal notices to our team about applications, sign-ups and sales), Google Sheets (a sales ledger of email and amount), Firebase (push notifications).
• Payments: Whop and Stripe. We never see your full card number.
• Partners you connect: Oura, WHOOP, Apple Health, Plaid.
• Advertising partners: Meta, Hyros (section 8).
• Legal: when a law, court order or lawful request requires it, to protect someone’s safety, or in a merger or sale, in which case this policy continues to apply to your data.

10. International transfers

We are in the United States and our providers are mostly there too, so if you use the service from elsewhere your data is transferred to the United States. Where we transfer personal data from the European Economic Area, the United Kingdom or Switzerland, we rely on the European Commission’s Standard Contractual Clauses (and the UK Addendum) in our contracts with each provider, supplemented by encryption in transit and at rest and access controls. A copy of the clauses is available on request.

11. How long we keep it

The schedule below is enforced by scheduled jobs in our systems, not just written here. A legal hold can pause deletion of a specific account when the law requires us to preserve records; we tell you if that happens to yours, unless the law forbids it.

12. Security and breaches

Data is encrypted in transit and at rest, bank access tokens are encrypted separately, row-level access rules keep each member’s data to that member, staff access is limited and logged, and the most sensitive text (your MER intake) is readable by no one but you. No system is perfectly secure. If we become aware of a personal-data breach affecting your information, we will notify the relevant supervisory authority within 72 hours where required, notify you without undue delay where the breach is likely to put you at high risk, and follow the notification laws of your U.S. state.

13. Your rights, and how to use them

Everyone, wherever they live, can use every right below. Start at Privacy request, or email [email protected] with “Privacy” in the subject. Several rights are self-serve today: download your data from Settings, delete your account at Delete account, change ad sharing at Your Privacy Choices, edit what the coach remembers at Coach memory, pause profiling in Settings, unsubscribe from marketing with one click in any email.

Everywhere

• Know what we hold about you and get a copy in a portable file.
• Correct anything that is wrong.
• Delete your data.
• Opt out of the sharing of your information for advertising, and of profiling.
• Limit the use of your sensitive information to what the service needs.
• Withdraw any consent you gave, with effect from then on.
• Have a person review a decision made by software.
• Not be treated differently for using these rights.

California, Virginia, Colorado, Connecticut, Texas, Oregon, Montana and other U.S. states

We answer within 45 days; if we need longer, we tell you why and take at most 45 more. If we decline all or part of a request you may appeal within 45 days by replying on the same request or choosing “Appeal” on the form; we answer the appeal within 45 days and, if we still decline, tell you how to contact your state Attorney General. An authorised agent may act for you with your written permission; we will ask you to confirm it.

European Economic Area, United Kingdom and Switzerland

You also have the rights to restrict processing, to object to processing based on our legitimate interests, and to lodge a complaint with your supervisory authority. We answer within one month, extendable by two months for complex requests, and we tell you if we extend.

How we verify it is you

If you are signed in, that is the verification. If you write from outside your account, we email a link to the address on file and act only after you confirm it; for deletion or a full copy we may ask one more question only you can answer. Requests are free unless they are repetitive or plainly unfounded, in which case we may charge a reasonable fee or decline and tell you why.

14. Age

Marczell AI is for adults. You must be 18 or older to create an account or to apply, and we ask you to confirm it when you sign up. We do not knowingly collect personal information from anyone under 18; if we learn that we have, we delete the account and its data. If you believe a minor has an account, email [email protected].

15. Calls and text messages

When you apply for Marczell AI at www.marczellai.com/apply, we collect your name, email address, mobile number, the income range and the development-investment range you select, the page you applied from, your device’s time zone, and technical details including your browser user agent and a one-way hashed form of your IP address.

Before you can submit that form you must tick a box giving your express written consent to be contacted at the number you provided, including by phone calls and text messages that may be sent using automated technology or prerecorded messages. That consent is not a condition of any purchase. We store the exact wording of the disclosure you agreed to, the version of that wording, the date and time, the hashed IP address, the user agent and the page, so that the record of what you agreed to can be produced later. The same record, with your contact details and the ranges you chose, is passed to GoHighLevel, the system our coaches call from.

Message and data rates may apply and message frequency varies. Calls are placed between 8am and 9pm in your local time zone. You can withdraw your consent at any time by replying STOP to any text message, or by emailing [email protected]; reply HELP to any text message for help. When you withdraw, we mark your number do-not-contact and stop calling and texting it, including on any later application made from the same number.

16. Marketing email

Service email (your audio is ready, a receipt, a security notice, a check-in you asked for) is part of the service. Marketing email is sent only if you have opted in, and every marketing email carries a one-click unsubscribe that works without signing in. You can also change every email preference in Settings.

17. Changes to this policy

When we change this policy we update the version and the date at the top. For material changes, and for any change to how we handle health, biometric or financial data, we show every member a notice in the app and ask for consent again where consent is the basis; continued use alone is not treated as agreement to a material change.

Version 2026-09-16 (this version): full rewrite. New: statutory category table; the AI and profiling sections; health-data consent at connection and the standalone Consumer Health Data Privacy Policy; bank data; the disclosure that we share for advertising, Your Privacy Choices and Global Privacy Control; EEA/UK consent banner; the cookie table; named processors; the transfer mechanism; the retention schedule; breach notification; rights for every U.S. state with an appeals route and timeframes; the request form; age raised to 18.

May 14, 2025: previous version.

18. Contact us

Questions, requests, complaints:

• Email: [email protected] (put “Privacy” in the subject)
• Form: www.marczellai.com/privacy/request
• Phone: 818-230-6474
• Mail: Marczell Klein Corp, 3400 Cottage Way, STE G2-6406, Sacramento, CA 95825, United States