PRIVACY POLICY

Peak Power EFT

INHERENCE® LLC

Last updated: Nov. 24th 2025

Your privacy matters to us. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use the Peak Power EFT application (“App”).

If you do not agree with this Policy, please do not use the App.

1. Data Controller

The data controller responsible for your personal data is:

INHERENCE® LLC
2113 Everglades Ln, #1061
The Villages, FL 32163
USA
apps@inherence.net

If you reside in the European Union (EU), United Kingdom (UK), or European Economic Area (EEA), INHERENCE® LLC is the controller under GDPR.

2. Information We Collect

We collect the following categories of personal data:

2.1. Information You Provide
  • First name
  • Email address
  • Password
  • Gender (used solely for linguistic adjustments in EFT rounds)
  • Preferred language of generated content
2.2. Information Generated Through App Use
  • Answers to the 9 onboarding/assessment questions
  • Emotional intensity ratings
  • Generated EFT rounds
  • Saved content in your personal Library
  • App settings and preferences
  • Interaction history within the App
2.3. Automatically Collected Information

Collected via Firebase, Google Cloud, or AWS:

  • Device information
  • App performance metrics
  • Crash logs
  • Anonymous usage analytics (e.g., time in app, feature usage)

The App does not collect precise geolocation or biometric data.

3. Purpose of Processing

Your data is processed to:

  • Create and manage your App account
  • Generate personalized EFT content
  • Adjust content to your language and linguistic form
  • Store your history of EFT rounds
  • Process payments through Stripe
  • Provide user support
  • Improve App performance and functionality
  • Ensure security and prevent misuse
  • Comply with legal obligations

We do not sell your personal data.

For users in the EU/EEA/UK, your data is processed under:

4.1. Contractual Necessity – Art. 6(1)(b)

For:

  • account creation and authentication
  • providing access to the App’s core features
  • generating personalized EFT content

For:

  • processing gender (linguistic adaptation only)
  • processing preferred language
  • any future marketing communications (if enabled)

You may withdraw consent at any time.

4.3. Legitimate Interests – Art. 6(1)(f)

For:

  • analytics and service improvement
  • fraud prevention
  • maintaining platform security

5. Sharing of Personal Data

We share data only with trusted service providers necessary for the functioning of the App.

5.1. Technical Infrastructure
  • Firebase (authentication, database, analytics)
  • Google Cloud Storage (file and content storage)
  • AWS (backup voice generation via Polly infrastructure)
5.2. AI Service Providers
  • OpenAI
    • Text generation
    • Voice generation

Data sent to AI providers includes only the content required to generate EFT sequences.

AI providers do not use your data to train their models.

5.3. Payment Processor
  • Stripe
    • Membership payments
    • Program purchases

Stripe collects and processes:

  • billing details
  • device and IP information
  • payment method information
  • fraud-prevention identifiers

We do not store full credit card details.

We may disclose data if required to:

  • comply with applicable law
  • respond to legal requests
  • protect rights, safety, or prevent fraud

We do not share your data with advertisers.

6. International Transfers

Your data may be processed in the United States or other locations where our service providers operate.

Transfers outside the EU/EEA/UK comply with:

  • Standard Contractual Clauses (SCCs)
  • Additional technical and organizational safeguards
  • GDPR-compliant transfer mechanisms

7. Data Retention

Your data is kept:

  • as long as your account remains active,
  • as long as needed to provide App functionality,
  • or as long as required by applicable law.

Backups stored in cloud systems (Firebase/Google Cloud/AWS) may persist temporarily after deletion before being overwritten.

7.1. Retention of EFT Sessions (User Content)

To ensure performance, system stability, and responsible data management, the App applies retention rules to content stored in your EFT Library:

  • Sessions that have not been opened or played for 12 months are moved to an Archived state. Archived content remains associated with your account but is removed from the active database.
  • Sessions that remain unused for 36 months are permanently deleted and cannot be restored.
  • Any session you open or revisit resets the retention timer, ensuring it stays available.
  • You retain access to previously generated sessions after your membership expires, as long as they fall within the retention period.
  • The App is not responsible for content that is deleted according to this retention policy.

8. Account & Data Deletion

You can request account deletion at any time by contacting:

apps@inherence.net

Upon deletion:

  • your account is permanently removed
  • your stored EFT rounds and Library content are erased
  • backups containing your data will be removed according to provider retention policies

If a future in-app deletion feature is added, this section will be updated.

9. AI Processing & Profiling

The App uses AI models exclusively to generate personalized EFT sequences based on:

  • your answers
  • emotional intensity ratings
  • language and linguistic gender (where applicable)

The App does not:

  • make automated decisions with legal or similarly significant effects
  • conduct profiling in the GDPR sense that impacts your rights

10. Your Data Rights (GDPR / UK GDPR)

If you are located in the EU, EEA, or UK, you have the right to:

  • Access your personal data
  • Rectification of incorrect data
  • Erasure (“right to be forgotten”)
  • Restriction of processing
  • Objection to processing based on legitimate interests
  • Data portability
  • Withdraw consent at any time
  • Receive information about data transfers outside the EU

To exercise these rights, contact: apps@inherence.net

11. Right to Lodge a Complaint

EU/EEA/UK users may submit a complaint to their local Data Protection Authority.

For Poland, this is:

President of the Personal Data Protection Office (UODO)

ul. Stawki 2
00-193 Warsaw
https://uodo.gov.pl

12. Security Measures

We implement industry-standard security measures, including:

  • encryption in transit (HTTPS/SSL)
  • secure cloud architecture (Firebase / Google Cloud / AWS)
  • access control and authentication safeguards
  • monitoring and logging
  • encryption at rest on cloud platforms

No system is fully secure, and users accept this inherent risk.

13. Children’s Privacy

The App is not intended for individuals under 18.

We do not knowingly collect data from minors.

Accounts identified as belonging to minors will be deleted.

14. Changes to This Policy

We may update this Privacy Policy from time to time.

Continued use of the App after updates constitutes acceptance of the revised Policy.

15. Contact Information

For questions about privacy or data protection:

apps@inherence.net

INHERENCE® LLC

2113 Everglades Ln, #1061
The Villages, FL 32163
USA