Privacy Policy

1. Introduction & Scope

grAIm is a mobile AI assistant application published by Arklith Pty Ltd (ABN 37 697 489 820) ("Arklith", "we", "us", "our"). grAIm runs on your phone (Android and iOS) and provides a conversational assistant that learns about you over time through structured, on-device memory.

This Privacy Policy describes how Arklith handles information in connection with grAIm. It covers:

• What information grAIm processes on your device.
• What very limited information Arklith may receive from grAIm (essentially: crash and error reports you submit).
• What information you may share directly with third-party AI providers when you choose to connect them to grAIm.
• Your rights and choices.

What this policy does NOT cover:

• The privacy practices of any third-party AI provider you connect to grAIm. When you provide your own API keys ("BYOK" — Bring Your Own Key), your queries flow directly from your device to that provider under their terms and privacy policy, not ours. See §7.
• Any websites grAIm fetches at your request, search results returned by search engines you have configured, or content you choose to send via email through grAIm.
• The privacy practices of Apple, Google, or other platform operators that distribute grAIm.

2. Our Privacy-First Architecture (the differentiator)

grAIm is built on a principle that distinguishes it from most AI applications: your conversations, memories, and identity profile never leave your device in a form Arklith can read. This section explains how and why.

2.1 On-device storage and encryption

All of the data grAIm builds about you — conversation logs, structured memory items, your "identity profile" (what grAIm remembers about you), your daily logs, reminders, lists, and the embedding vectors that power memory search — is stored on your device in a local SQLite database and local files.

When you set up encryption (a one-time setup flow), all of this data is encrypted at rest using AES-256-GCM. The encryption key (Data Encryption Key, "DEK") is generated on your device and never leaves it in unwrapped form. The DEK itself is wrapped (encrypted) by a key derived from your password (PBKDF2 with 100,000 iterations) and stored in your phone's hardware-backed secure storage (Android Keystore or iOS Keychain).

A 24-word recovery phrase (BIP-39 standard, the same standard used by cryptocurrency wallets and password managers) acts as a backup unlock path if you forget your password. This phrase is generated and displayed to you once during setup; Arklith never sees it.

2.2 Bring Your Own Key (BYOK)

To talk to a large language model ("LLM" — the AI that generates responses), grAIm needs an API key for an LLM provider. You supply your own key. This means:

• Your messages and the responses to them flow directly between your device and the LLM provider you have chosen (for example, Anthropic, OpenAI, Google, DeepSeek, or xAI).
• Arklith does not sit in the middle of that traffic. We do not see, log, store, or process your conversations.
• Your billing relationship for LLM usage is with the LLM provider, not with us.
• Each LLM provider has its own privacy policy and terms; you are bound by those when you use their service through grAIm. See §7.

The same BYOK pattern applies to optional voice services, image generation, and image analysis providers.

2.3 What Arklith does receive

There is one narrow data path that flows from your device to Arklith infrastructure: crash reports and error reports that you choose to send, or that the app generates automatically when something goes wrong. These reports are sanitised on-device before transmission (see §3.2) and are used solely to fix bugs and improve reliability.

We do not run analytics services. We do not embed advertising SDKs. We do not maintain a profile of you. We do not have a server that mirrors your memory or conversations. We do not have the keys to decrypt your encrypted backups even when they are stored in our cloud storage provider.

3. Information We Collect

3.1 What we DO NOT collect

To be explicit, because it differs from competitor norms:

• We do not collect the content of your conversations. Messages you send to grAIm and responses you receive are not transmitted to Arklith. They live on your device. If you have connected an LLM provider via BYOK, they flow between your device and that provider directly.
• We do not collect your memory items, identity profile, lists, reminders, daily logs, or embeddings. These are stored only on your device.
• We do not collect your voice recordings, transcripts, or text-to-speech audio. Voice processing happens either on-device (depending on provider) or via a third-party voice provider you have configured. We have no copy.
• We do not collect your API keys. Your keys are stored only in your device's hardware-backed secure storage (Android Keystore / iOS Keychain).
• We do not collect your contacts, calendar, photos, location, or other phone-side data beyond what is strictly necessary for an app feature you have invoked (for example, you tap "add image", which opens the OS image picker; the image you select is stored on your device for grAIm's use, not transmitted to us).
• We do not use analytics SDKs, advertising IDs, behavioural tracking, fingerprinting, or third-party cookies.
• We do not sell or rent any data, ever.
• We do not collect any sensitive, health, emotional, or personal information you share with grAIm. grAIm is designed to keep your conversations on your device. Any information you share — including health concerns, emotional states, relationship details, personal history, or any other sensitive topics — remains on your device. Arklith has no access to this information, does not store it, and does not process it. It is not transmitted to Arklith infrastructure.

3.2 What we DO collect (very limited)

Crash reports and error reports. When grAIm encounters an error — whether a software bug, a failed API call to a third-party provider, or a crash — the app may send a sanitised diagnostic report to our error-reporting infrastructure (Supabase, see §7).

A report contains:

• A device identifier. A random opaque ID generated on first launch. It is not your phone number, IMEI, advertising ID, or any other persistent OS-level identifier — it is a string we generate and store locally for the sole purpose of correlating reports from the same device.
• The grAIm app version.
• The platform (Android or iOS) and OS version.
• Screen dimensions.
• The error type and error message (sanitised — see below).
• A stack trace (sanitised).
• A short snippet of the conversation around the error (sanitised), to help us reproduce the bug.
• Tool usage summary (e.g. "the app attempted a web_search and it failed"), with input/output snippets truncated to 200–300 characters and sanitised.
• The LLM provider ID and model ID that were active when the error occurred (e.g. anthropic / claude-sonnet-4).
• Network state (online / offline, connection type).
• A short list of memory item IDs that were active in the failing turn (IDs only — no content).
• A user-supplied note if you choose to add one when submitting the report.
• A severity tag and a short "source" tag (user_report, auto, etc.).
• An error hash for grouping duplicate reports.

Before transmission, every text field is run through an on-device PII sanitiser that redacts:

• Email addresses → [EMAIL]
• Phone numbers → [PHONE]
• API keys (Anthropic, OpenAI, xAI, Google/Gemini, ElevenLabs patterns) → [API_KEY]
• Bearer tokens → Bearer [TOKEN]
• IPv4 addresses → [IP_ADDR]
• File paths containing usernames → /Users/[USER]/...
• Long hex / base64 tokens (40+ characters) → [TOKEN]
• URLs containing embedded credentials → [AUTH_URL]
• Your name (as known to grAIm from its on-device identity profile) → [USER]
• JSON-embedded passwords → [REDACTED]

Authentication identifiers. An account is required to use grAIm. When you create an account:

• Your email address and (for password sign-in) a password hash are stored by our authentication provider (Supabase Auth).
• A user ID is associated with any cloud backups or wrapped encryption-key envelopes you opt into.

Encrypted cloud backups (if you opt in). If you enable encryption and opt into cloud backup, grAIm will upload an AES-256-GCM-encrypted blob of your memory data to our storage provider. The ciphertext is keyed by your password-derived (or recovery-phrase-derived) key. Arklith cannot read it. We can delete it on request; we cannot recover its plaintext.

3.3 What third parties collect (when you use them via grAIm)

When you connect a third-party provider via BYOK, that provider receives:

• Your messages (when you talk to that provider's LLM via grAIm).
• Whatever context grAIm assembles for the turn (relevant memory items, your identity profile sections that the LLM needs, the system prompt that defines grAIm's behaviour).
• Tool outputs that the LLM needs to see to complete its task (e.g. results of a web search, content of a fetched web page).

grAIm can connect to third-party LLM, voice, search, image-generation, and image-analysis providers that you choose to configure. The specific providers available depend on which API keys you supply. The app does not route your data through Arklith — when you use a third-party provider, your prompts, context, and any uploaded media flow directly from your device to that provider under their privacy policy and terms of service, not Arklith's.

When a third-party provider receives a request from your device, their privacy policy and terms govern that interaction. You are responsible for reviewing the privacy policy of any provider you choose to enable. Arklith is not a party to that data flow.

3.4 What web pages and search engines receive

When grAIm performs a web search or fetches a web page on your behalf, the search engine or destination website receives the search query or page request from your device. Arklith does not intermediate or log these requests. Outbound web traffic uses your device's normal network stack.

4. How We Use Information

The only information we receive (crash and error reports and authentication identifiers) is used solely for:

• Fixing bugs. When grAIm misbehaves, we use the diagnostic report to reproduce the problem in development and ship a fix.
• Improving reliability. Aggregate patterns in error reports (e.g. "feature X fails on Android 13") guide our engineering priorities.
• Authenticating you to features that require an account (cloud backup, cross-device key restore).
• Securing the service. Detecting abuse, fraud, or attacks against our infrastructure.
• Meeting legal obligations in narrow circumstances (see §5).

We do not use any of this information for:

• Advertising or marketing.
• Profiling or building a behavioural model of you.
• Training AI models.
• Selling or sharing with data brokers.
• Determining pricing or eligibility for any service.

5. Information Sharing & Disclosure

We do not sell, rent, trade, or otherwise commercially share any information about you.

We disclose information only in these narrow circumstances:

• Our infrastructure provider (Supabase) stores the crash and error reports you submit. Supabase processes data on our behalf as a sub-processor. It does not use the data for its own purposes. See §7.
• Compelled legal disclosure. If we receive a binding legal order from a competent authority (a court order, a warrant under the laws of the relevant jurisdiction), we may be required to disclose the limited data we hold. We will challenge overbroad requests where appropriate and will notify affected users where lawful to do so.
• Business transfer. If Arklith is acquired, merged, or its assets transferred, the receiving entity inherits the data and obligations of this policy. We will notify you in-app and via email (if we hold one) before any material change in custody.

6. Data Storage & Security

6.1 On-device storage

All user data managed by grAIm is stored on your device:

• Conversations, memory items, identity profile, daily logs, reminders, lists, embeddings: local SQLite database, optionally AES-256-GCM encrypted when you have set up encryption (see §2.1).
• Saved conversation logs: local JSON files in the app's private directory, encrypted when encryption is active.
• API keys and voice service credentials: hardware-backed secure storage (Android Keystore on Android, iOS Keychain on iOS) via expo-secure-store.
• Settings and preferences: local JSON files (no secrets — those live in secure storage).
• Avatar images, generated images, audio clips: local media files in the app's private directory.

6.2 Cold-boot unlock requirement

When encryption is enabled, the encryption key must be loaded into RAM via an explicit unlock action on every cold start of the app. We do not auto-unlock on app launch. Biometric unlock (fingerprint / face ID), when offered, requires an explicit user gesture.

6.3 Cloud storage of encrypted material

If you opt into cloud backup, the following are stored in our infrastructure (Supabase) as ciphertext that Arklith cannot decrypt:

• An encrypted blob of your memory data (AES-256-GCM under your DEK).
• Wrapped (encrypted) copies of your DEK, one per unlock slot you have configured (password, recovery phrase).
• A device identifier and your user ID, used to scope the rows so other users cannot access them.

6.4 Brute-force protection

The unlock flow is rate-limited: five failed password / recovery-phrase attempts trigger a five-minute lockout, persisted across app restarts. The same lockout applies to the typed-passphrase verification gate used before sensitive operations.

6.5 Honest framing

Encryption-at-rest only protects you if your device itself is secure. If you do not set a device PIN / biometric, or if you set a weak grAIm password, an attacker with physical possession of your device may be able to compromise your data. We strongly recommend:

• Set a device PIN or biometric lock.
• Choose a strong, unique password for grAIm encryption.
• Store your recovery phrase somewhere safe (offline, ideally on paper or in a dedicated password manager).
• Keep your phone's OS up to date.

If you lose your device, an attacker would need to defeat your device lock AND your grAIm password to access your data. If you have not enabled grAIm encryption, only the device lock stands between an attacker and your data.

6.6 No retention by default beyond functional need

• Crash and error reports: retained only as long as needed to diagnose and fix the underlying issue, then deleted. A de-identified summary note may be retained for reference (e.g. "fixed crash X in v1.2").
• Cloud-encrypted backups: retained until you delete them or your account.
• Authentication records: retained for as long as your account exists; deleted on account closure.

6.7 Factory reset / app uninstall

If you uninstall grAIm or factory-reset your device:

• All on-device data is removed by the OS as part of standard uninstall behaviour.
• Cloud-encrypted backups, if any, persist until you delete them via account closure (see §8) — but remain unreadable to anyone other than the holder of your password / recovery phrase.

7. Third-Party Service Providers (Sub-processors)

The following services process limited data on Arklith's behalf to operate grAIm:

BYOK providers (LLM, voice, search, image) are not sub-processors — they are services you connect directly via your own API keys. See §3.3.

8. Your Rights & Choices

Specific rights depend on your jurisdiction (see §11). Rights that apply universally because of grAIm's architecture:

8.1 Access

The data grAIm builds about you lives on your device. You have full access to it through the app:

• Memory items, identity profile, daily logs, lists, reminders: browseable in-app.
• Conversation history (current session and saved logs): viewable in-app.
• Settings: viewable and editable in-app.

For data Arklith holds (crash reports, account information, encrypted cloud backups if any):

• You may request a copy via the account settings page in the app, or by contacting privacy@arklith.com.au. We will provide the data within a reasonable timeframe at no cost.

8.2 Deletion

• On-device data: uninstall the app, or use the in-app vault-reset / data-wipe flow if available. Factory-resetting the device removes everything OS-side.
• Crash reports already submitted: email the privacy contact (§15) requesting deletion; we will action within the timeframe required by your jurisdiction. Note that diagnostic data is sanitised on transmission and cannot generally be re-tied to you absent the device identifier.
• Cloud-encrypted backups: use the in-app deletion flow, or request deletion via the privacy contact.
• Account closure: request account deletion via the account settings page in the app; this deletes authentication records and any rows scoped to your user ID.

8.3 Portability

• On-device data: grAIm provides export of memory, logs, and settings (see in-app Settings → Memory / Logs export). Exports may be encrypted or plaintext, at your choice — encrypted backups are restorable on a fresh installation of grAIm; plaintext exports are human-readable.
• Data held by Arklith: on request, we will provide an export of the limited data tied to your account / device identifier in a structured, commonly-used, machine-readable format.

8.4 Correction

• On-device data: you control it; edit directly in-app.
• Account information: edit via account settings; for fields not directly editable, contact the privacy contact (§15).

8.5 Opt-out of crash reports

You may turn off automatic crash and error reporting in Settings. During the beta period, crash and error reporting is required and this option is not available; it will become available once grAIm exits beta.

8.6 Withdrawal of consent

Where we rely on your consent for any processing (e.g. cloud backups, optional account sign-in), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

9. Children's Privacy

grAIm is intended for use by adults aged 18 and over. We do not knowingly collect personal information from anyone under 18. If you are under 18, do not install or use grAIm. If we become aware that we have collected information from a person under 18, we will delete it.

10. International Data Transfers

grAIm is published from Australia. The sub-processors we use host data as follows:

• Supabase — India (Mumbai region)
• Expo / EAS — United States

When you connect a third-party provider via BYOK, your data flows directly to that provider, which may be located in any jurisdiction depending on your selection. You are responsible for assessing the jurisdictional implications of provider choice.

For users in the European Economic Area or the United Kingdom, transfers of personal data to countries that the European Commission / UK ICO has not deemed adequate are protected by Standard Contractual Clauses (SCCs) and any supplementary technical safeguards required under Schrems II case law.

11. Jurisdiction-Specific Provisions

11.1 Australia — Privacy Act 1988 and the Australian Privacy Principles (APPs)

Australian users are protected by the Australian Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles regulated by the Office of the Australian Information Commissioner (OAIC).

Under the APPs, Australian users have rights to:

• Be notified about collection practices (APP 1, APP 5).
• Choose not to identify themselves where practical (APP 2).
• Access their personal information (APP 12) and request correction (APP 13).
• Have their personal information held securely (APP 11).
• Have their personal information used only for the purpose for which it was collected, or a directly related secondary purpose (APP 6).

Complaints: you may contact us first (§15). If unresolved, you may lodge a complaint with the Office of the Australian Information Commissioner (oaic.gov.au).

11.2 European Union — GDPR

For users in the European Economic Area, the United Kingdom, and Switzerland, the General Data Protection Regulation applies.

Data controller: Arklith Pty Ltd (ABN 37 697 489 820), 210 Macquarie Rd, Springwood NSW 2777, Australia.

Lawful bases for processing (Article 6 GDPR):

• Article 6(1)(b) — performance of a contract: for processing strictly necessary to provide the app and account features you have requested (e.g. cloud backup, authentication).
• Article 6(1)(f) — legitimate interests: for crash and error reporting — our legitimate interest in fixing bugs and maintaining a working app, balanced against the limited and sanitised nature of the data collected. You may object to this processing under Article 21. During the beta program, crash and error reporting cannot be disabled, because it is essential to the purpose of the beta. If you object under Article 21 while using a Beta version, we may not be able to give effect to that objection until grAIm exits beta; you can end the processing at any time by ceasing use of the Beta.
• Article 6(1)(a) — consent: where specifically requested (e.g. enabling cloud backup, enabling debug log streaming).

Data Protection Officer: Arklith is not required to appoint a DPO under Article 37. All privacy queries route via the contact in §15.

Your rights under GDPR include:

• Right of access (Article 15)
• Right to rectification (Article 16)
• Right to erasure / "right to be forgotten" (Article 17)
• Right to restriction of processing (Article 18)
• Right to data portability (Article 20)
• Right to object (Article 21)
• Right not to be subject to automated decision-making (Article 22) — Arklith does not perform any automated decision-making with legal or similarly significant effects.
• Right to lodge a complaint with a supervisory authority (Article 77). For users in the EU, the lead supervisory authority is the data protection authority of your member state of residence.

International transfers: see §10.

11.3 California (CCPA / CPRA)

For California residents, the California Consumer Privacy Act as amended by the California Privacy Rights Act applies.

Categories of personal information NOT collected by Arklith:

• Identifiers other than the random device ID generated locally for crash-report correlation
• Commercial information
• Biometric information (Arklith infrastructure holds none)
• Internet or other network activity beyond crash-report metadata
• Geolocation data
• Sensory data
• Professional or employment-related information
• Education information
• Inferences drawn from the above to create a profile

Categories collected, used for the purposes in §4, retained per §6.6:

• Identifiers: random device ID, app version, OS version, platform; (if you sign in) email address and authentication identifiers.
• Limited diagnostic information (crash/error reports, sanitised).

Sale / sharing: Arklith does NOT sell or share (as those terms are defined under CCPA/CPRA) any personal information.

Your rights as a California resident:

• Right to know what we have collected.
• Right to delete.
• Right to correct.
• Right to limit use of sensitive personal information (we do not collect sensitive personal information as defined under CPRA).
• Right to opt out of sale / sharing — not applicable, as we do not sell or share.
• Right to non-discrimination for exercising your rights.

To exercise these rights, contact us (§15). We will verify the request by reference to your device ID or account email.

11.4 Other jurisdictions

For users in jurisdictions not listed above (e.g. Canada PIPEDA, Brazil LGPD, Japan APPI, South Korea PIPA), we apply the principles set out in this policy and any applicable local law. We will respond to verified rights requests from users in those jurisdictions on a reasonable basis. If there is a conflict between local law and this policy, local law applies for users in that jurisdiction.

12. Cookies & Tracking

grAIm is a native mobile application. It does not use web cookies, browser storage, advertising IDs, fingerprinting, beacons, pixel tags, or any third-party tracking technology.

• We do not embed Google Analytics, Firebase Analytics, Mixpanel, Amplitude, Segment, or any analytics SDK.
• We do not embed advertising SDKs.
• We do not request or use the platform advertising identifier (IDFA on iOS, AAID on Android).
• We do not engage in cross-app tracking.

The "Allow Tracking" iOS App Tracking Transparency prompt is not displayed because grAIm performs no tracking that would trigger it.

13. Data Breach Notification

If Arklith experiences a data breach involving information we hold, we will:

• For Australian users — follow the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act, including notification to the OAIC and to affected individuals where there is a likely risk of serious harm.
• For EU/EEA/UK users — notify the competent supervisory authority within 72 hours where the breach is likely to result in a risk to the rights and freedoms of natural persons (Article 33 GDPR), and notify affected individuals without undue delay where the risk is high (Article 34 GDPR).
• For California users — comply with the breach-notification requirements of California Civil Code §§ 1798.29 and 1798.82.

Practical scope of breach impact. Because Arklith holds almost no user data — the only personal information we hold is sanitised crash reports, debug log lines (when enabled), authentication identifiers (if you signed in), and ciphertext blobs we cannot decrypt — the impact of any breach of Arklith infrastructure is structurally limited. An attacker who exfiltrates our entire Supabase contents would obtain encrypted blobs they cannot read, plus sanitised diagnostic text from which most PII has been redacted. This is by design.

A breach of your own device (theft, malware, OS compromise) is not within Arklith's control. Your device security choices (PIN/biometric, OS updates) and the strength of your grAIm encryption password are your primary defence in that scenario.

14. Changes to This Policy

We may update this policy from time to time. When we do:

• We update the "Last updated" date at the top.
• For material changes (changes to what data we collect, how we use it, who we share it with, or your rights), we will provide notice through an in-app notification and, where applicable, require fresh consent before the change applies to your account.
• For non-material changes (clarifications, corrections, contact-detail updates), the updated text takes effect on the "Last updated" date without specific notice.

Your continued use of grAIm after a non-material change indicates acceptance. Material changes require active consent.

15. Contact Us

Privacy contact: privacy@arklith.com.au

Postal address: 210 Macquarie Rd, Springwood NSW 2777, Australia

Australian privacy officer: privacy@arklith.com.au

We aim to respond to privacy queries within 30 days. For urgent matters (data breach, account compromise, time-sensitive rights request), please mark your message "URGENT — Privacy".

If you are dissatisfied with our response, you may also contact your local data protection authority:

• Australia: Office of the Australian Information Commissioner — oaic.gov.au
• EU: your member state's data protection authority — list at edpb.europa.eu
• UK: Information Commissioner's Office — ico.org.uk
• California: California Privacy Protection Agency — cppa.ca.gov

16. Definitions

• Arklith — Arklith Pty Ltd (ABN 37 697 489 820), the legal entity publishing grAIm.
• API key — a credential issued by a third-party AI provider that authorises grAIm to make requests on your behalf to that provider.
• BYOK (Bring Your Own Key) — the model in which you supply your own API key for an AI service, forming a direct relationship between you and that service. Arklith does not intermediate or pay for the API usage.
• DEK (Data Encryption Key) — the symmetric key that encrypts your on-device data when encryption is enabled. Generated on-device, never transmitted in plaintext.
• KEK (Key Encryption Key) — a key derived from your password (or recovery phrase) that wraps the DEK.
• Identity profile — grAIm's structured on-device record of what it has learned about you and itself (sections like name, location, preferences, communication style). Stored as on-device memory items.
• Memory item — a single piece of structured on-device knowledge in grAIm's memory system (a fact, a preference, a list entry, a learned skill).
• OTA update — an over-the-air update of grAIm's JavaScript bundle delivered via the Expo platform, separate from full app-store releases.
• PII (Personally Identifiable Information) — information that identifies, relates to, or could reasonably be linked to a particular individual.
• Sanitised — text that has been run through an on-device redactor that replaces patterns matching emails, phone numbers, API keys, tokens, file paths, IP addresses, and the user's name with neutral placeholders.
• Sub-processor — a third-party that processes data on Arklith's behalf in the course of providing a service to Arklith (e.g. Supabase, Expo).
• Third-party AI provider — an external service (e.g. Anthropic, OpenAI, Google) that you connect to grAIm via BYOK and that processes your messages directly.