Last Updated: October 13, 2025

This policy applies to all products built and maintained by Adler.

This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Adler). We refer collectively to these categories of individuals as "you" throughout this policy.

However, this policy does not cover information about a customer’s end users that Adler receives from a customer, or otherwise processes on a customer’s behalf, in connection with the services provided by Adler to the customer pursuant to an applicable services agreement (including the content of messages of customer end users ("End User Communications")). Adler processes End User Communications under the instructions of the relevant customer, which is the "data controller" or "business" (or occupies a similar role as defined in applicable privacy laws), as described in the applicable services agreement between such customer and Adler. Adler’s obligations as a "data processor" or "service provider" with respect to such information are defined in such services agreement and applicable data protection addendum and are not made part of this policy.

If you are a customer’s end user and you have questions about how your information is collected and processed through the services, please contact the organization who has provided your information to us for more information.

Additional information for California residents, as well as for individuals in the EEA, UK, and Switzerland can be found at the end of this Privacy Policy.

We may change this Privacy Policy from time to time. If we make changes, we will revise the date at the top of the policy and, in some cases, we may provide you with additional notice.


What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity and access

When you sign up for Adler’s product, we ask for identifying information such as your name, email address, gender, age group, ethnicity, and maybe your company name and occupation. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We sometimes also can give you the option to add a profile picture that displays in our products.
We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.

Information We Collect When You Use the Services or Interact with Us

When you use the Services or interact with us, we collect the following information about you:

Usage information: the sessions you use, audio content you listen to, screens or features you access, and other similar types of usage information.

Transactional information: information about a purchase, such as product description, price, subscription or free trial expiration date, and time and date of the transaction.

Log information: the web browser you use, app version, access times and dates, pages viewed, your IP address, and the page you visited before navigating to our websites.

Device information: information about the computer or mobile device you use to access the Services, including the hardware model, operating system and version, device identifiers set by your device operating system, and mobile network information.

Communications: we may record our communications including chat messages, phone, or video calls, such as when you utilize our chat-bot or provide us with feedback or market research.

Information We Infer or Generate When You Use the Services

When you use the Services, we infer or generate the following information about you:

User ID: a user ID that we will associate with your account.

Derived information: information about you based on other information we have collected. For example, like most platforms, we use your IP address to derive the approximate location of your device. We may also use information we collect about you to help determine the likelihood of you continuing to use the Services in the future.

Billing information

If you sign up for a paid Adler product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit Adler’s servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.

Product interactions

We currently store your data on Google’s firebase studio server, the content that you upload or receive or maintain in your Adler product accounts. This is so you can use our products as intended, for example, to go through a reflection session followed by AI-driven analysis. We keep this content as long as your account is active. If you delete your account, we’ll delete the content within 60 days.

General Geolocation data

For most of our products, we log the full IP address used to sign up a product account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active.

Website interactions

We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active.

AI data processing and integrations

Adler employs Google’s Gemini AI integration to help analyze the input users share during their emotional self-reflection. While agentic AI usage is new to the world and has its limitations, at Adler we believe that limited and controlled use of AI can serve for the better of humankind, especially when it comes to running exploratory analysis of semantic text and psychological feelings to enhance one’s own understanding of emotional regulation and underlying processes.

To provide the service to our users, we share your reflection input data from every session with the 3rd party, being represented by Google via Gemini AI model integration in the Adler app. We do it solely for the purpose of conducting your input analysis in terms of psychological patterns identification, providing structured feedback based on your input. Your reflection session data is then stored on Adler’s firebase designated server. We do not permit Google using your personal data in any way other than running it through the Gemini AI model for analysis. The model is not enabled to store, remember, cache any context behind your input data.

By accepting our privacy policy, you provide Adler permission to share your protected data with Google for the purpose of running an exploratory, AI-driven analysis under condition that your data is not shared or used for other commercial or non-commercial purposes outside of Adler app’s operation used to enable us to provide you the services.

Advertising and Cookies

Adler may run contextual ads on various third-party platforms such as Google, Reddit, and LinkedIn. Users who click on one of our ads will be sent to the Adler marketing site. Where permissible under law, we may load an ad-company script on their browsers that sets a third-party cookie and sends information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form.

We also may use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics.

A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off.

Voluntary correspondence

When you email Adler with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.
We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

How we approach mobile app permissions

We offer optional desktop and mobile web app views for Adler. Because of how the platforms are designed, both web app versions may request your consent before accessing contacts, calendar, camera, and other privacy-sensitive features of your device. Consent is always optional and our apps will function without it, though some features may be unavailable.

When we access or disclose your information

We may disclose information about you as follows and as otherwise described in this Privacy Policy or at the time of collection:

With companies and contractors that perform services for us, including email service providers, payment processors, fraud prevention vendors, analytics providers, advertising partners, and other service providers;

To accountants, auditors, lawyers, and other outside professional advisors to Adler, subject to appropriate contractual obligations of confidentiality;

If we believe disclosure is in accordance with, or required by, applicable law or legal process, including court order, subpoena, or other lawful requests by public authorities to meet national security or law enforcement requirements;

If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, or to protect the rights, property, and safety of Adler or others, or if it is necessary for the establishment, exercise or defense of legal claims;

In connection with any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

Between and among Adler and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;

If your Adler subscription has been provided to you by someone else, like your employer or a family member who invited you to use one of their dependent subscriptions, we may inform them that you have signed up for the subscription they offered you;

If your Adler subscription was obtained through a third-party promotion, such as bundled with a third-party service or offered through a promotional code distributed by that third party, we may inform them that you redeemed the offer; and

With your consent or at your direction. For instance, you may choose to share actions you’ve taken through the Services using “share” or similar features or by linking your Adler account with third-party services.
We may also disclose aggregated or other information not subject to obligations under the data protection laws of your jurisdiction with third parties.

To provide products or services you’ve requested. We use some third-party subprocessors such as Firebase CLI to help run our applications and provide the Services to you. We also use third-party processors for other business functions such as managing newsletter subscriptions, sending customer surveys (i.e. Qualtrics), and providing our company storefront. Please, feel free to reach out to us via our website to receive a full list of 3rd party subprocessors employed by Adler.

We may disclose your information at your direction if you integrate a third-party service into your use of our products.

No Adler team human looks at your content except for limited purposes with your express permission, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to the legal process (see "When required under applicable law" below).


To exclude you from seeing our ads. Where permissible by law and if you have an Adler account, we may disclose a one-way hash of your email address with ad companies to exclude you from seeing our ads.
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses that violate the User Content and Conduct as described in the Terms of Service. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.

Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.
When required under applicable law. Adler is a U.S. company and all data infrastructure is located in the U.S.

• Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if U.S. law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside the U.S. if compelled by the U.S. government through procedures outlined in a mutual legal assistance treaty or agreement. It is Adler’s policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.

• Preservation requests. Similarly, Adler’s policy is to comply with requests to preserve data only if compelled by the U.S. Federal Stored Communications Act, 18 U.S.C. Section 2703(f), or by a properly served U.S. subpoena for civil matters. We do not disclose preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period.

• If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.

Finally, if Adler is acquired by or merges with another company — we don’t plan on that, but if it happens — we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.

Your rights with respect to your information

At Adler, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:

• Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.

• Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.

• Right to Correction. You have the right to request correction of your personal information.

• Right to Erasure / “To Be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfillment of some data deletion requests may prevent you from using Adler services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.

• Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.

• Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of your personal information. (Again: we never have and never will sell your personal data.)

• Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.

• Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party. If you want to export data from your accounts, you can do so by leaving a data extraction request via the contact form on our website.

• Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.


In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us via our website contact form. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.


How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. In addition, we go to great lengths to secure your data at rest. For more information about how we keep your information secure, please reach out to us.
What happens when you delete content in your product accounts
In some of our products, we give you the option to discard content. Anything you trash in your product accounts while they are active will be kept in an accessible trash can for about 25 days (it varies a little by appropriate case). After that time, the trashed content cannot be accessed via the application and we are not able to retrieve it for you. The trashed content may remain on our active servers for another 30 days, and copies of the content may be held in backups of our application databases for up to another 30 days after that. Altogether, any content trashed in your product accounts should be purged from all of our systems and logs within 90 days.

If you choose to cancel your account, your content will become immediately inaccessible and should be purged from our systems in full within 60 days. This applies both for cases when an account owner directly cancels and for auto-canceled accounts. Please refer to our Cancellation policy in the Terms of Service for more details.

Data retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.

Location of site and data

Our products and other web properties are operated in the United States. If you are located in the European Union, UK, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.

When transferring personal data from the EU

The European Data Protection Board (EDPB) has issued guidance that personal data transferred out of the EU must be treated with the same level of protection that is granted under EU privacy law. UK law provides similar safeguards for UK user data that is transferred out of the UK. Accordingly, Adler has adopted a data processing addendum with Standard Contractual Clauses to help ensure this protection.

There are also a few ad hoc cases where EU personal data may be transferred to the U.S. in connection with Adler operations, for instance, if an EU user signs up for our newsletter or participates in one of our surveys or buys swag from our company online store. Such transfers are only occasional and data is transferred under the Article 49(1)(b) derogation under GDPR and the UK version of GDPR.

Changes and questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.
Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by reaching out to us via the website communication form and we’ll be happy to try to answer them!


Information for California Residents

This section provides additional disclosures required by the California Consumer Privacy Act, as amended.
Please see the chart below for a list of the personal information we have collected about California consumers in the last twelve (12) months, along with our business and commercial processing purposes and categories of third parties to whom this information may be disclosed. For more details about the personal information we collect, including the categories of sources, please see the Collection of Information section above.

Categories of personal information we collect

Identifiers, such as your name, phone number, email address, social media handle, and unique identifiers (like IP address) tied to your browser or device. Characteristics of protected classifications under state or federal law, such as gender and age. Commercial information, such as your payment information and Adler product or service purchases. Approximate geolocation data. Internet or other electronic network activity, such as browsing behavior and information about your usage and interactions with the Services. Audio, electronic, visual, or similar information, such as profile photo or personal information you may provide during customer support calls and call recordings. Professional, employment, and education information, such as information about your employer or professional background that you voluntarily provide to us. Other personal information you provide, including opinions, preferences, goals, and previous meditation experience and other personal information contained in product reviews, surveys, or communications. Inferences drawn from the above, such as product interests and purchasing insights.
Business or commercial purposes for which we may use your information
Perform or provide the services, such as to maintain accounts, provide customer service, process orders and transactions, and verify customer information. Improve and maintain the Services, such as by improving the Services and developing new products and services. Debug, such as to identify and repair errors and other functionality issues. Communicate with you about marketing and other relationship or transactional messages. Analyze usage, such as by monitoring trends and activities in connection with use of the Services. Personalize your online experience, such as by tailoring the content and ads you see on the Services and on other platforms based on your preferences, interests, and browsing behavior. Legal reasons, such as to help detect and protect against security incidents, or other malicious, deceptive, fraudulent, or illegal activity.

Parties with whom information may be shared

Companies that provide services to us, such as those that assist us with customer support, subscription and order fulfillment, advertising measurement, communications and surveys, data analytics, fraud prevention, cloud storage, bug fix management and logging, and payment processing. Third parties with whom you consent to sharing your information, such as with social media services or academic researchers. Government entities or other third parties for legal reasons, such as to comply with law or for other legal reasons.


California consumers have the rights described above under the Privacy Rights section. We use cookies and similar tracking technologies, and we allow our advertising partners to use such technologies, so we can, among other things, show you ads promoting Adler on other websites and services. These activities may be considered “sales,” “sharing,” or “targeted advertising” under certain privacy laws. You can opt out of these practices by visiting Adler.com/optout. We do not knowingly “sell” or “share” personal data about consumers under the age of 16.

Notice of Financial Incentives: We offer various financial incentives. For example, we may provide incentives to customers who participate in a survey or provide testimonials. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name and email address) and information about your experiences using the Services. You can opt into a financial incentive by following the sign-up or participation instructions provided, and, for any ongoing benefits, you can opt out at any time, such as by following the unsubscribe instructions in the applicable program’s terms or by contacting us. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.
We retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.


Information for Individuals in EEA, Switzerland, and UK

The sections below apply to you if you use the Services while in the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”). Adler is the data controller for personal data governed by this Privacy Policy.


Data Retention

We retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.

Data Subject Requests

Subject to certain limits and conditions provided under law, in addition to the rights described under the Privacy Rights section above, you have the right to:

1. Object to certain processing (like receiving direct marketing), or request that we restrict processing in certain circumstances (like to retain but not further process pending resolution of a claim).
2. Withdraw any consent you have provided.
3. Request that Adler transfer certain data to another data controller.
4. File a complaint regarding our data protection practices with a supervisory authority.

Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en.
If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
If you are in the United Kingdom, please see this site for contact details: https://ico.org.uk/global/contact-us/.

If you would like to exercise any of these rights and can't do so directly via the Services or your device, you may contact us via the designated contact form on our website.