Last Updated: [publication date]

Company: Sync AI Technologies Inc. (“Sync,” “we,” “us,” or “our”)

Contact: privacy@talktosync.com

1. Scope & Applicability

This Privacy Policy governs how we collect, use, disclose, retain, and protect information in connection with your access to and use of our Application, website, and Services (collectively, the “Services”), including when you or other users access the Services through a third-party AI assistant connected to Sync’s Model Context Protocol (“MCP”) server (a “Connected AI Client”). It also describes your rights and choices regarding your information. By using our Services, you agree to the terms of this Privacy Policy.

If part of the Service is subject to additional privacy disclosures (e.g., for “consumer health data” in certain states), you will be presented a supplement or addendum at the time of your use.

2. Information We Collect

We collect information in several categories:

2.1 Information You Provide Directly

When you register, interact, or submit content, we may collect:

· Account & Identity Data — e.g. username, full name (if provided), age/birthdate, gender, email, phone number, location

· Profile & Preferences — photos, biography, ethnicity, interests, dating / relationship preferences, political preferences, education, career

· Compatibility / Coaching Inputs — answers, responses, journaling entries, reflections, feedback, traits or scores you submit

· Communications / Chat Data — messages, prompts, transcripts, user-to-user content (your choice of text, voice, video), including messages you send to Sync through a Connected AI Client

· Sensitive Information (Optional / Consent-Based) — e.g. sexual orientation, religion, health-related reflections, financial, voice/face biometric data (if enabled)

· Payment / Transaction Data — purchase history, billing address, transaction metadata (processed through third-party payment processors)

· Survey / Marketing Responses — if you voluntarily participate in surveys, promotions, or feedback requests

2.2 Automatically Collected / Generated Data

As you use our Services, we or our service providers may collect:

· Usage & Interaction Data — features you use, timestamps, click paths, navigation metadata, and requests made through a Connected AI Client

· Technical / Device Data — device model, OS/version, browser, app version, IP address, advertising identifiers, crash logs, OS-level analytics

· Location Data — coarse location (e.g., city), and precise location only if you enable and consent

· Inferences / Derived Data — compatibility scores, predicted preferences, trait scores, ranking outputs

2.3 Data from Third Parties

We may receive data from:

· Social / Identity Providers you choose to connect (e.g. Apple, Google)

· Connected AI Clients you authorize: the requests and context your AI assistant sends to Sync on your behalf, and connection data such as the name of the AI assistant and authorization tokens

· Publicly Available Sources (e.g., public social media, public records)

· Business Partners / Affiliates / Referral Services

· Service Providers (e.g. analytics, identity verification)

2.4 Data About Others

If you invite others to the app, share contact lists, or submit reports/information about third parties, you confirm you have authority to share that data.

3. Purposes & Legal Bases for Processing

We process personal data for the following purposes. Where applicable under state or federal law, we rely on the legal basis indicated:

Profiling / Automated Decisions

We may perform automated or algorithmic matching or coaching suggestions. These processes take into account your inputs, usage data, profile, and prior behavior. You may have limitations or opt-outs under applicable law for profiling with legal or significant effects; see Section 8.

4. Sharing & Disclosure

We may disclose personal data to:

4.1 Service Providers & Vendors

Those who help us run the Services (hosting, analytics, messaging, customer support, verification) under contract with usage restrictions.

4.2 Affiliates / Corporate Group

To sister or parent entities for business, safety, or operational coordination.

4.3 Business Transfers

In connection with a merger, sale, acquisition, or reorganization, we may transfer data to a third party.

4.4 Other Users

Depending on your settings, portions of your profile (photo, first name/initial, match prompts) may be visible to other users you match with or to whom Sync presents you as a potential match. Those users may see your profile in the Sync app or in a Connected AI Client they have authorized, as described in Section 4.8. Content you share publicly or in chats is visible to those recipients.

4.5 Legal & Safety Disclosures

We may share with law enforcement, regulators, courts, or third parties when required by law or to protect rights, safety, or property. We may also respond to subpoenas, court orders, or defend claims.

4.6 Aggregate / De-identified Data

We may share anonymized or aggregated data which cannot reasonably identify you individually.

4.7 AI Infrastructure and Data Processing

Sync uses third-party artificial intelligence (“AI”) infrastructure to power certain features of the Services, including matchmaking, compatibility analysis, coaching, and conversational interactions. We do not sell, monetize, or share users’ personal data with third-party AI providers for advertising, profiling, or any other purpose. This section describes how AI infrastructure is used and identifies our current AI data processors. It does not cover AI assistants that users choose to connect to Sync themselves, which are not Sync’s processors and are described in Section 4.8.

What Data Is Sent to AI Providers. When you use Sync’s matchmaking and coaching features, your conversation text is sent to third-party AI data processors for processing. All requests are routed through Sync’s backend infrastructure. No account-level identifiers — such as email addresses, user IDs, or other account data — are included in the requests sent to AI data processors. However, conversation text may contain personal details you choose to share during your conversations (such as your name, relationship history, or preferences). This conversation text is transmitted as an anonymous session with no linkage to your Sync account.

AI Data Processors. Sync currently uses the following third-party AI data processors:

· OpenAI, PBC (“OpenAI”) — provides AI language model infrastructure. OpenAI processes conversation text on Sync’s behalf to support matchmaking analysis, compatibility scoring, coaching conversations, and profile generation features. OpenAI acts solely as a data processor and does not use this data to train its foundation models or for model improvement.

· ElevenLabs, Inc. (“ElevenLabs”) — provides AI voice synthesis technology. ElevenLabs receives only text content generated by Sync itself — not user-generated content or personal data of any kind — and converts it to audio for Sync’s voice-enabled features. No user data is transmitted to ElevenLabs.

We may engage additional AI data processors in the future. If we do, we will update this section accordingly.

Data Protection. Each third-party AI data processor we engage is bound by contractual terms that require the provider to: (i) process data solely on Sync’s behalf and not for its own independent purposes, including the training of AI models; (ii) maintain industry-standard administrative, technical, and physical safeguards, including encryption in transit (TLS 1.2 or higher) and encryption at rest for any data stored, even temporarily, during processing; (iii) not retain input or output data beyond the duration necessary to complete the processing request; and (iv) not attempt to re-identify, correlate, or link any data received from Sync to any individual or data set. These contractual terms ensure that each third-party AI data processor provides the same or equal protection of user data as described in this Privacy Policy. We retain full control over user data and determine the purposes and means of processing. AI data processors act solely as infrastructure providers and processors.

4.8 Connected AI Clients (MCP)

Sync offers an MCP server that lets users access Sync from third-party AI assistants, such as Claude (provided by Anthropic, PBC) and ChatGPT (provided by OpenAI). A user chooses whether to connect their AI assistant to Sync. The provider of a Connected AI Client is not Sync’s data processor: it receives information at the direction of the user who connected it and handles that information under its own terms and privacy policy, not this one. The contractual protections described in Section 4.7 do not apply to Connected AI Clients.

When you use your own Connected AI Client. Sync sends your AI assistant the information needed to answer your requests, which may include your conversations with Sync, your SoulPrint insights, your matches and compatibility information, and the profiles, including photos, of other users Sync presents to you. Your AI assistant’s provider may keep this information in your conversation history and use it as its own terms allow, which may include improving its models depending on your settings with that provider.

When another user views your profile through their Connected AI Client. If Sync presents you as a potential match to a user who uses Sync through a Connected AI Client, Sync sends that user’s AI assistant the same profile information that user would see in the Sync app: your photos, first name, age, general location, biography, prompts, and compatibility information such as SoulScore results. Sync does not send your email address, phone number, precise location, payment information, or your private conversations with Sync. The provider of that user’s AI assistant receives and may store your profile information as part of that user’s conversation history.

Your consent and choices. We ask for your consent before your profile is shown through Connected AI Clients. You can withdraw this consent at any time in your account settings or by emailing privacy@talktosync.com, and you can disconnect your own Connected AI Client at any time in your account settings or in the AI assistant. Withdrawing consent or deleting your account stops future display but cannot remove information already delivered to an AI assistant’s provider. Users are prohibited by our Terms of Use from copying, storing, or re-sharing other users’ profiles through Connected AI Clients.

5. Sensitive, Biometric & Coaching-Risk Disclosures

Because Sync provides coaching and analysis:

· Sensitive / biometric data is collected only with explicit consent and used solely for disclosed purposes (e.g. face/voice identity verification).

· We will store biometric data in encrypted form and delete after termination or within a defined retention period, unless law requires otherwise.

· Sync does not send biometric data to Connected AI Clients. Sensitive information is shown through Connected AI Clients only if you have chosen to display it on your profile and have consented to display through Connected AI Clients.

· Coaching outputs, compatibility scores, or trait inferences are not guarantees of outcome, safety, or mental/relationship health.

· Users must not rely solely on such outputs for critical decisions (e.g. quitting professional therapy, entering into dangerous situations).

· We disclaim liability for user choices made based on coaching content, as explained in our Terms of Use / End User License Agreement.

6. Data Retention

We retain data only as long as needed to fulfill the purposes in this Policy, or as required by law.

Typical retention practices may include:

· Active accounts: profile and usage data

· Deleted / closed accounts: we may retain data for a “safety window” (e.g. 3–12 months) to investigate misconduct

· Transaction records / logs: per applicable law (e.g. 7–10 years for tax / audit)

· Biometric / sensitive data: deleted or de-identified within a specified timeframe after account closure

· Information delivered to a Connected AI Client: retained by that AI assistant’s provider under its own retention policy; Sync cannot delete it from the provider’s systems

After the retention period, data is securely deleted, anonymized, or aggregated.

7. Your Rights and Choices

Depending on your state or where you reside, you may have:

· Access / Portability — receive a copy of your data

· Correction — ask us to amend inaccuracies

· Deletion / Erasure / Right to be forgotten

· Opt-out of profiling or targeted advertising

· Withdraw consent (for processing based on consent), including consent to display your profile through Connected AI Clients

· Object to certain processing or request restriction

· Disconnect any Connected AI Client you have authorized

To exercise your rights, contact us at privacy@talktosync.com (or via in-app settings). We may require identity verification.

We honor recognized universal opt-out signals (e.g. Global Privacy Control) where legally required.

We will respond to such requests within the timelines mandated by applicable law.

8. Additional Disclosures & State-Specific Notices

California (CPRA / California Privacy Act)

· We do not “sell” personal information in the traditional sense; but if we “share” data for cross-context targeted ads, you may opt out.

· Sync does not receive payment or other consideration for sending profile information to a user’s Connected AI Client, and does so only to provide the Services that user requested.

· You may designate an agent to submit requests.

· Non-discrimination for exercising rights (subject to permitted differences).

Colorado, Virginia, Utah, Connecticut, Texas

· You have rights to access, correct, delete, and opt out of profiling.

· We may provide a data protection assessment to relevant regulators on request (Texas).

Washington / Nevada – Consumer Health Data (CHD) Laws

· If you record well-being or “health reflections,” that may constitute CHD, subject to heightened restrictions.

· We will provide separate notice and consent before collecting CHD.

· We will not use geofencing around health-care facilities or sell CHD.

· Sync does not send consumer health data to Connected AI Clients without your separate consent.

Illinois – Biometrics / BIPA

· For biometric data, we will obtain written or electronic consent, provide a retention policy, and ensure deletion timelines.

This Privacy Policy is supplemented as needed by state-specific addenda; if conflict arises, the stricter provision prevails for your jurisdiction.

9. Security

We employ administrative, physical, and technical safeguards such as encryption in transit and at rest, access controls, audits, and security assessments. Certifications or audits may be maintained. Each Connected AI Client connection is authorized by the individual user, is limited to that user’s account, and can be revoked at any time. We rate-limit and monitor MCP requests to detect scraping and misuse. However, no system is perfectly secure; we cannot guarantee absolute security.

10. International Data Transfers

Because we are U.S.-based and use global vendors, your information may be transferred to servers or processors in locations with different privacy laws. Where required, we use safeguards such as standard contractual clauses (SCCs), binding agreements, or other lawful transfer mechanisms. Providers of Connected AI Clients may process information in other countries under their own transfer mechanisms.

11. Changes to This Policy

We may update this Privacy Policy as our Services evolve, new features are added, or legal requirements change. When changes are material, we will notify you (e.g. via in-app banner, email). Continuing to use the Services after the effective date means you accept the revised policy.

12. Children & Minors

Our core matchmaking Services are intended for users 18 or older. Minors under 18 may not use dating features. If we offer coaching or reflective features for teens, we will do so only with parental consent and compliance with applicable law. We do not knowingly collect personal data from children under 13; if discovered, we will delete it.

13. Third-Party Links & Integrations

Our Services may include links to third-party websites, platforms, or tools. We are not responsible for their privacy practices or content. Always review the privacy policies of such third parties before sharing data. This includes the providers of any Connected AI Client you choose to use with Sync.

14. Cookies, Tracking & Analytics Technologies

We and our service providers may use cookies, SDKs, pixel tags, web beacons, local storage, fingerprinting, or similar tools to collect data about your use of the Services and other websites/applications. These tracking technologies support analytics, fraud prevention, ad targeting (where permitted), and feature optimization. You may manage or disable cookies or limit tracking via device or browser settings, but that may degrade functionality.

15. Liability Limitations & Disclaimers

To the extent permitted by law, Sync is not liable for damages arising from your reliance on coaching content, compatibility scores, or interactions with other users. We disclaim warranties (express or implied) about fitness, accuracy, or non-infringement. Our liability to you is capped (as set in the Terms of Use / End User License Agreement). Use of the Services is at your own risk.

16. Contact & Privacy Requests

If you wish to exercise your rights, ask questions, or submit complaints, contact:

Privacy Team

Sync AI Technologies Inc.

Email: privacy@talktosync.com

Address: 131 Continental Drive, Suite 305, City of Newark, County of New Castle, Delaware, 19713

If you disagree with our privacy practices or our handling of your data, you may also lodge a complaint with your applicable state attorney general or privacy regulator.