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EchoTalks

Privacy Policy

This Privacy Policy explains how EchoTalks (the 'App') collects, uses, stores, shares, and protects your personal data. We know that information about your emotions, mental wellbeing, and personal experiences is especially sensitive, so we aim to collect only what is reasonably needed to run the App. By using the App, you acknowledge that you have read this Policy.

Version: 2026-07-10 Effective: 2026-07-10

1. Who We Are

EchoTalks is developed and operated by ECHOTALKS AI TECHNOLOGY LIMITED, a self-help mental-wellness and journaling app operated from Hong Kong. For the purposes of applicable data-protection law, we are responsible for deciding how personal data collected through the App is processed. For any privacy question or request, contact us at info@echo-talks.com.

2. Scope of This Policy

This Policy applies to information collected through the EchoTalks app, including account registration, AI conversations, mood tracking, journaling, weekly and monthly reviews, subscriptions, and customer-support communications. It does not apply to third-party services we do not control, such as the Apple App Store, Google Play, or independent websites we may link to.

3. Eligibility and Age

The App is intended only for users who are at least 13 years old. You must not use the App if you are under 13, and we do not knowingly collect personal data from anyone under 13. If we learn that an account belongs to someone under 13, we may suspend or delete it.

If you are 13 or older but under the age of majority where you live, please use the App with the knowledge and consent of a parent or guardian. A parent or guardian who believes an underage person has provided us with data may contact us at info@echo-talks.com.

4. Information We Collect

We collect:

  • Account information: your name or display name, email address, an authentication identifier, preferred app and AI-reply language, time zone, and account settings.
  • Wellness content you create: chat messages, journal entries and their summaries, mood ratings, weekly and monthly reviews, goals, and the AI 'memory' and inner-profile insights derived from your use (which may include an MBTI-style result and wellbeing signals).
  • Technical information: app version, device language, time zone, network status, and diagnostic logs needed to run and troubleshoot the service. Your IP address may be processed by our hosting infrastructure to keep the service secure; we do not use it to track you.
  • Subscription information: your plan and its status, received from our subscription provider. We do not receive your card or bank-account details.
  • Support information: the content of messages you send us.

We do not collect precise GPS location, your contacts, or biometric data; we do not read Apple Health or Health Connect; and we do not use your content for advertising.

5. How We Use Your Information

We use your information to:

  • create and run your account and deliver AI conversations, journaling, mood tracking, and reviews;
  • personalise responses using your AI 'memory', where you have enabled it;
  • process your subscription and provide customer support;
  • keep the App secure, prevent abuse, and diagnose technical problems;
  • comply with our legal obligations.

Where you give the optional 'help improve EchoTalks' consent, we may also use your information to evaluate and improve the App. That consent is optional, separate from the core Service, and can be changed at any time in Manage Account.

6. AI Processing

AI replies are generated using a third-party AI provider, not by EchoTalks staff. To generate a response, we send the provider your current message, a limited window of recent conversation, the AI 'memory' context (if enabled), and your chosen display name to personalise the reply. We do not send your email address or account identifier.

Our AI provider is Google's Gemini Enterprise Agent Platform, which processes your content using its Gemini model under Google's terms. We do not use your private content to train our own AI models. Because the provider may process your content outside Hong Kong, please also read section 9.

7. Automated Crisis and Safety Detection

To help keep you safe, the AI is designed to flag language that may indicate a crisis, such as thoughts of suicide or self-harm or danger to you or others. When this happens, the App may show crisis-support resources, including Hong Kong hotlines and emergency numbers.

This detection is automated and imperfect: it may miss a real crisis or misclassify a message. The App is not monitored by humans in real time. We do not contact emergency services, your family, or your friends, and the App cannot locate you. If you are in immediate danger, contact local emergency services directly. The crisis flag is not stored with your saved messages.

8. How We Share Information

We do not sell your personal data. We share it only with:

  • Service providers who run the App for us: our cloud host Amazon Web Services (hosting, database, authentication, and email verification), our AI provider Google (through the Gemini Enterprise Agent Platform), and our subscription provider RevenueCat (which receives a pseudonymous account identifier to manage your entitlement).
  • App stores and payment platforms: Apple and Google process your purchase under their own terms.
  • Legal and safety recipients: where we reasonably believe disclosure is required by law or necessary to protect the rights or safety of users or others.

Providers may process your information only for the agreed purposes.

9. International Data Transfers

Your account and content are stored on Amazon Web Services servers located in Singapore. To generate AI replies and related features, relevant content is sent to our AI provider, Google, which may process it in other countries or regions outside Hong Kong. Privacy laws in those places may differ from those in Hong Kong. By using the App, you understand that your content is processed in these locations to provide the Service.

10. Data Retention

We keep your account and content for as long as your account is active, so your history, journals, and AI 'memory' stay available to you, until you delete them. Messages in a private (incognito) chat are automatically deleted about 24 hours after they are created.

When you delete content, records, or your account, we remove the data within about 30 days, after which backup copies expire through normal rotation. We may keep limited information longer where needed for legal, security, or dispute-resolution purposes.

11. Deleting Your Data and Account

You can manage your data in the App:

  • 'Clear all records' permanently deletes your chats, journals, reviews, and AI memory while keeping your account and subscription.
  • 'Delete account' signs you out immediately and schedules your account and associated data for permanent deletion within about 30 days. This cannot be undone from the App.

Deleting your account does not cancel an Apple App Store or Google Play subscription (cancel that separately in your store account), and does not delete content already transmitted to our AI providers, which is governed by their own terms.

12. Your Privacy Rights

Depending on the law that applies to you, you may have the right to access, correct, or delete your personal data, withdraw consent, object to or restrict certain processing, request a copy of your data, and complain to a data-protection authority. To exercise a right, contact us at info@echo-talks.com; we may need to verify your identity first. In Hong Kong, you may also contact the Office of the Privacy Commissioner for Personal Data (PCPD).

13. Security

We use reasonable technical and organisational measures to protect your data, including encryption in transit, encryption of sensitive content such as your chats, journals, and AI memory using managed keys, authentication through AWS Cognito, and access controls.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Please keep your password confidential, secure your device, and tell us at info@echo-talks.com if you suspect unauthorised access.

14. Changes and Contact

We may update this Privacy Policy to reflect changes to the App, our providers, or the law. When we do, we will revise the 'Last updated' date and, for material changes, ask you to review and accept the updated Policy. For any privacy question or request, contact us at info@echo-talks.com.