Privacy & Consumer Health Data Notice
This Notice describes how Borta Enterprises LLC ("Emma," "we," "us," or "our") collects, uses, discloses, retains, and protects personal data in the Emma web application. It also serves as our Consumer Health Data Notice for information that identifies or can reasonably be linked to an individual's physical or mental health.
Key facts
- Emma is a direct-to-consumer AI support tool, not a licensed provider or HIPAA-covered clinical service.
- Your messages can contain sensitive consumer health data. We ask for express consent before processing them.
- We do not sell personal data and do not use it for targeted advertising.
- OpenAI processes the content needed for AI replies, moderation, recaps, and embeddings; Stripe processes payments; AWS hosts the Service.
- You can request access, correction, deletion, or a portable copy and can appeal a denied request.
1. Scope and controller
Borta Enterprises LLC determines why and how Emma processes personal and consumer health data and is the data controller. This Notice applies to Emma's consumer website, account, conversations, recaps, couples features, billing state, and support communications. It does not govern a third-party site you choose to visit.
2. Categories of data, sources, and purposes
| Category and source | Examples | Why we process it |
|---|---|---|
| Account and consent data, directly from you | Name, e-mail, password hash, user ID, age confirmation, legal versions and timestamps | Create and secure the account, authenticate you, record consent, communicate, and honor rights |
| Consumer health and conversation data, directly from you and generated from your use | Messages about thoughts, feelings, symptoms, relationships, preferences, AI replies, recaps, themes, and embeddings | Generate and moderate replies, preserve a useful recap, personalize later sessions, provide couples sessions, and maintain safety |
| Couples data, from the payer and linked partner | Partner e-mail, invitation and link state, speaker identity, shared messages and recaps | Invite a consenting adult, provide the shared feature, assign plan access, and retire shared history when unlinked |
| Billing data, from you and Stripe | Stripe customer and subscription IDs, plan, status, renewal date, cancellation state | Create and administer subscriptions, prevent duplicate charges, reconcile webhooks, and support deletion. Card details go directly to Stripe and are not stored by Emma. |
| Security and technical data, automatically from requests and infrastructure | IP address, request time, route and status class, browser/network headers, rate-limit state, aggregate uptime and usage counters | Deliver pages, prevent abuse, diagnose failures, monitor availability, and investigate security events. Operational metrics do not intentionally contain chat content. |
| Support and e-mail data, directly from you and our mail provider | Support message, reset-code delivery, partner invitation delivery, delivery status | Respond, recover accounts, deliver invitations, and troubleshoot |
3. Sensitive consumer health data and consent
Conversation and recap data may reveal mental or physical health, diagnoses you mention, emotional state, relationships, sexual orientation or activity, addiction, trauma, or other highly sensitive facts. We process this data only to provide, personalize, secure, and maintain the features you request; comply with law; or protect a person from serious harm where law permits. We do not use geofences around health facilities and do not sell consumer health data.
Before account creation, you must affirmatively consent to this processing separately from accepting the Terms. You can withdraw consent by stopping use and deleting the account in Settings, or by contacting us. Because processing this data is necessary to generate Emma's support, withdrawal means we cannot continue providing conversation features.
4. Disclosures and processors
We disclose only the data reasonably needed for these purposes:
- OpenAI: prompts, relevant recent recaps and preferences, AI output, and text needed for moderation and embeddings. OpenAI states that API data is not used to train its models unless the API customer opts in. Under standard API controls, abuse-monitoring logs may contain prompts and responses and may be retained for up to 30 days, with longer retention in limited safety or legal circumstances. Moderation endpoint data has different retention handling. See OpenAI's API data controls.
- Amazon Web Services: compute, network, database volumes, and backup infrastructure used to host Emma in the United States.
- Stripe: identity, billing-contact, payment, customer, subscription, fraud-prevention, and transaction information needed to process and manage payments. Card data is collected in Stripe-hosted elements.
- Transactional e-mail provider: e-mail address and message content needed for password-reset codes, partner invitations, operational notices, and support.
- Professional and legal recipients: limited information if reasonably necessary for security response, legal compliance, audit, insurance, or professional advice and subject to appropriate confidentiality.
- A linked partner: shared Couples messages, speaker attribution, link state, and shared recaps. A linked partner does not receive your private solo transcript through the intended product flow.
We require processors to act under our instructions, protect confidentiality, and use data only for contracted services. We do not disclose consumer health data to an independent third party for its own marketing or advertising purpose.
5. No sale, targeted advertising, or profiling
We do not sell personal or consumer health data, exchange it for targeted advertising, or profile you to make a legal or similarly significant decision. Emma currently loads no advertising pixel or cross-site behavioral analytics. If this changes, we will update this Notice and obtain consent where required.
6. Retention
- Active messages: raw session messages remain while the session is open and are removed from the active conversation store after a recap is successfully created. Failed or interrupted recap work may delay removal until recovery completes.
- Recaps, preferences, account and billing state: retained while the account is active so the requested personalization and account features work.
- Couples data: invitation contact details expire or are cleared when an invitation expires, fails, or is withdrawn. Shared history is retired when either member unlinks or a controlling Couples subscription ends.
- Reset and verification state: expires on short security windows and is removed by scheduled cleanup.
- Webhook, security, and operational records: content-free or minimized records are retained only as long as reasonably needed for reconciliation, abuse prevention, reliability, and legal obligations.
- Deletion and backups: account deletion removes active account, conversation, recap, preference, relationship, and app-owned Stripe customer data. Rolling backups may retain a deleted record for up to 30 days before expiration, unless preservation is legally required.
7. Your rights and how to exercise them
Depending on where you live, you may have the right to:
- confirm whether we process your data and access it;
- correct inaccurate data;
- delete data, including data obtained from another source;
- receive a portable copy in a readily usable format;
- withdraw sensitive-data consent; and
- opt out of sale, targeted advertising, or significant-decision profiling (we do not currently perform these activities).
Delete the account directly in Dashboard → Settings, or e-mail dborta0@gmail.com with "Privacy Request" in the subject. State the right you want to exercise and the account e-mail. We will verify the request before releasing or changing data and will respond within the period required by applicable law. Authorized agents must provide evidence of authority, and we may still verify the request with the consumer.
If we deny a request, reply with "Privacy Appeal" and explain why you disagree. A different reviewer will consider the appeal. We will not discriminate against you for exercising a privacy right.
8. Cookies and browser storage
Emma uses a first-party, HttpOnly, Secure session cookie for authentication. It is necessary to provide the signed-in Service and expires after a short session window. The browser also uses tab/session storage for non-secret account-interface state and in-memory storage for chat display. A small local-storage lease coordinates open dashboard tabs. We do not currently use advertising cookies. Browser requests to Stripe are subject to Stripe's necessary payment technology.
9. Security
We use safeguards including TLS, password hashing, least-privilege database roles, private service networks, signed billing webhooks, authentication and session revocation, request validation, rate limits, restricted browser policies, backups, and monitoring. No system is perfectly secure. Do not send information that is unnecessary for the support you want. If you believe data was exposed or misused, contact dborta0@gmail.com promptly.
10. Health-data incidents
We maintain an incident-response process. If a breach of unsecured, individually identifiable health information triggers the FTC Health Breach Notification Rule or another law, we will notify affected individuals, regulators, and others as required. This paragraph is not a statement that every incident or every Emma record falls under a particular law.
11. Adults only and HIPAA status
Emma is limited to adults 18 and older and is not directed to children. Emma is not offered on behalf of a hospital, insurer, or other HIPAA covered entity, and we do not represent that ordinary Emma accounts are governed by HIPAA or protected by therapist-patient privilege. Do not upload a provider's medical record or another person's health information unless you are legally authorized and it is necessary.
12. U.S. processing and changes
Emma is operated in the United States and its providers may process data in the U.S. We may update this Notice as the product, providers, or law changes. If a change materially expands how we use sensitive data, we will provide notice and request renewed consent before the new use where required.
13. Contact
Privacy contact and controller:
Borta Enterprises LLC
E-mail: dborta0@gmail.com