Privacy Policy

Last updated: March 2026

1. Who we are

LightPath Manifest ("we", "our", or "the app") is the data controller for the personal data we process in connection with the LightPath Manifest mobile application. For contact details and how to exercise your rights, see section 16.

2. Scope and applicability

This Privacy Policy applies to the LightPath Manifest app and our related services. It describes how we collect, use, disclose, and protect your information. We aim to comply with applicable privacy and data protection laws globally, including:

• European Union / European Economic Area and United Kingdom: General Data Protection Regulation (GDPR) and UK GDPR
• United States (California): California Consumer Privacy Act (CCPA) as amended by the CPRA, and California Online Privacy Protection Act (CalOPPA)
• United States (Nevada): Nevada Revised Statutes Chapter 603A
• Brazil: Lei Geral de Protecao de Dados (LGPD)
• Canada: Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial laws
• Australia: Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs)
• Japan: Act on the Protection of Personal Information (APPI)
• South Korea: Personal Information Protection Act (PIPA)
• India: Digital Personal Data Protection Act (DPDP Act)
• Other jurisdictions with similar data protection requirements

3. Your content - processed on your device

We do not upload, store, or process your journal content, intention text, or ritual completion content on our servers by default. The app stores core journey data locally on your device. We do not receive the content of your private journal entries.

4. Information we collect

4.1 Information you give us

• Communications: If you contact us (e.g. support or feedback), we collect what you send (e.g. email address, message content).
• Preferences: In-app settings and preferences (e.g. reminders, haptics, sounds, profile name) stored on your device.

4.2 Information we collect automatically

• Device and app information: Device type, operating system and version, app version, language, and similar technical data.
• Usage data: General product interaction and feature usage if analytics are enabled in future updates.
• Identifiers: Where necessary, we or our providers may use identifiers such as advertising identifiers, subject to your device choices.

4.3 Information we do not collect

We do not collect private journal text content or sealed intention content on our servers as part of normal app operation.

4.4 CCPA categories (California)

For California residents, personal information categories may include identifiers (e.g. email if you contact us), internet/electronic activity (app usage), and inferences derived from these. We do not offer financial incentives for your personal information.

5. Legal basis for processing (EEA/UK and similar jurisdictions)

• Performance of a contract: Providing app functionality you request.
• Legitimate interests: Product improvement, security, and support.
• Consent: Optional processing where required by law.
• Legal obligation: Compliance with applicable legal requirements.

6. How we use your information

• Provide, operate, and maintain the app
• Send push reminders if enabled
• Respond to support requests
• Improve reliability and user experience
• Comply with legal obligations and enforce terms
• Protect users and platform security

We do not sell your personal information.

7. Sharing and disclosure

We may share information only with service providers under strict agreements, platform providers (e.g. Apple), legal authorities when required, or in business transfer scenarios. Where required, international transfers use appropriate safeguards.

8. Data retention

We retain data only for as long as needed for app functionality, support, legal compliance, dispute resolution, and security. You may request deletion where applicable.

9. Security

We implement appropriate technical and organizational safeguards. Core private practice data remains local to your device.

10. Children

The app is not directed to children under 13 (or higher where local law requires). If you believe a child submitted personal information, contact us for removal.

11. Do Not Track and similar signals

Our app does not currently respond to Do Not Track signals due to lack of universal standards. You can manage tracking permissions through iOS settings.

12. Region-specific notices

12.1 EEA and UK

You may have rights to access, rectify, erase, restrict, object, portability, withdraw consent, and lodge complaints with supervisory authorities.

12.2 California (CCPA/CPRA, CalOPPA)

You may have rights to know, access, delete, correct, and opt out of sale/share (we do not sell/share as defined under CCPA/CPRA).

12.3 Nevada

Nevada residents may submit opt-out requests under applicable law; we do not sell personal data under Nevada definitions.

12.4 Brazil (LGPD)

LGPD rights include access, correction, anonymization/deletion, portability, and consent withdrawal where applicable.

12.5 Canada (PIPEDA)

Canadian users may request access and correction and withdraw consent subject to legal restrictions.

12.6 Australia (APPs)

Australian users may request access/correction and file complaints with OAIC if applicable.

12.7 Other regions

Users in Japan, South Korea, India, and other jurisdictions may exercise applicable local privacy rights.

13. How to review your data and exercise your rights

• Contact us using section 16 details.
• We respond within applicable legal timelines.
• We may verify identity before fulfilling requests.
• You may lodge complaints with your local authority where permitted.

14. Cookies and similar technologies

The mobile app does not use browser cookies. If we operate web tracking in future web properties, we will update policy disclosures.

15. Changes to this policy

We may update this policy from time to time. Material changes will be reflected with an updated date and additional notice where legally required.

16. Contact and data protection inquiries

For privacy-related requests, questions, or complaints, use our Contact page details. We respond according to applicable laws.