Legal

Privacy Policy

Effective date: August 10, 2026

This Privacy Policy explains how Elys Life collects, uses, stores, shares, and protects personal data when you use the Elys Life mobile application, website, and related services.

Controller / Operator: WorkWell Group L.L.C.-FZ, as operator of Elys Life

Privacy contact: support@elyslife.ai

Scope: Elys Life mobile app, website, and related customer support and communications

1. Who we are

Elys Life is a digital wellness service operated by WorkWell Group L.L.C.-FZ ("Elys Life", "we", "us", or "our"). For the purposes of applicable data protection laws, WorkWell Group L.L.C.-FZ is the data controller for the personal data described in this Privacy Policy, unless a different legal entity is expressly identified to you at the point of collection.

2. What this Privacy Policy covers

This Privacy Policy applies to personal data processed through the Elys Life mobile application, the Elys Life website, customer support communications, and other related services that link to or reference this Policy. This Policy does not cover third-party websites, applications, or services that are not operated by Elys Life, even if they are linked from within our app or website. Those third parties process your information under their own privacy notices.

3. Personal data we collect

Depending on how you use Elys Life, we may collect the following categories of personal data:

Account and contact information: such as your name, email address, login credentials, profile details, language preferences, and any information you provide when contacting support.
Onboarding and wellness information: such as answers you provide during onboarding, goals, check-ins, journal entries, program progress, reflections, and other content you choose to submit inside the service.
Chat and AI interaction data: such as messages you send to the Elys Life coach, feedback you provide, and generated responses needed to deliver, improve, and secure the service.
Health and fitness data: if you choose to connect Apple Health / HealthKit, Google Fit, Health Connect, or similar integrations, we may receive the specific health or activity data you authorize us to access, such as sleep, steps, activity, or other wellness metrics.
Subscription and transaction information: such as subscription status, plan type, renewal dates, country or region, and transaction identifiers provided by Apple, Google, or other payment partners. We do not receive your full payment card number when purchases are processed by app stores or payment processors.
Technical and usage data: such as device type, operating system, app version, unique identifiers, crash logs, IP address, approximate location derived from IP, and information about how you interact with the app or website.
Marketing and communications data: such as whether you open emails, your notification preferences, referral information, and responses to surveys or promotional campaigns, where permitted by law.

Where health or wellness data is treated as sensitive data under applicable law, we process that information only where we have an appropriate legal basis, including your consent where required. You can disconnect health-data integrations at any time through your device or account settings.

4. How we collect data

We collect personal data directly from you, automatically from your device or browser, from app stores and payment partners, and from third-party platforms or integrations that you choose to connect to Elys Life. Some data is required to provide the service. Other data is optional and depends on the permissions you grant, such as access to health integrations, push notifications, or marketing communications.

5. Why we use personal data

We use personal data for the following purposes:

to create and manage your account;
to deliver the Elys Life program, journaling tools, AI coach features, and progress tracking;
to connect and display health or activity data that you choose to share with us;
to process subscriptions, renewals, receipts, refunds, and account administration;
to personalize content, recommendations, and user experience;
to respond to support requests, troubleshoot problems, and communicate with you about the service;
to monitor performance, prevent fraud or misuse, improve reliability, and fix bugs;
to send service notices, security messages, and, where permitted, marketing communications;
to comply with legal obligations, enforce our terms, and protect our rights, users, and the public.

6. Legal bases for processing

Where applicable law requires us to identify a legal basis for processing, we generally rely on one or more of the following:

Performance of a contract: when processing is necessary to provide the app, maintain your account, or perform a subscription you requested.
Consent: when you choose to connect health data, enable certain permissions, or opt in to marketing where consent is required.
Legitimate interests: when necessary to improve the service, secure our systems, prevent abuse, understand usage, and support business operations, provided those interests are not overridden by your rights.
Legal obligations: when we must retain or disclose data to comply with tax, accounting, regulatory, law-enforcement, or other legal requirements.

7. How we share personal data

We may share personal data only as reasonably necessary for the purposes described above, including with:

Service providers: such as hosting, cloud infrastructure, analytics, customer support, email delivery, security, AI, and technical vendors acting on our instructions.
Platform providers and payment partners: such as Apple, Google, or other processors involved in subscriptions, payments, fraud checks, or app distribution.
Connected integrations: when you authorize connection to Apple Health, HealthKit, Google Fit, Health Connect, or similar services, data may be exchanged with those platforms in accordance with your permissions and their rules.
Professional advisers and authorities: where reasonably necessary for legal, compliance, accounting, insurance, regulatory, or law-enforcement purposes.
Corporate transactions: in connection with a merger, financing, acquisition, reorganization, sale of assets, or similar transaction, subject to appropriate safeguards.

We do not use health data from Apple Health / HealthKit, Google Fit, Health Connect, or similar health platforms for advertising, marketing by third parties, or any purpose prohibited by applicable platform rules or law.

8. International data transfers

Elys Life may use service providers and infrastructure located in different countries. As a result, your personal data may be transferred to and processed outside the country where you live. Where required by law, we will use appropriate safeguards for such transfers.

9. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy, including to provide the service, maintain business and legal records, resolve disputes, enforce agreements, and comply with legal obligations.

Retention periods may vary depending on the category of data, the sensitivity of the information, whether the account remains active, and applicable legal requirements. When data is no longer required, we will delete it, anonymize it, or securely de-identify it where feasible.

10. Security

We use reasonable technical, organizational, and administrative safeguards designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. However, no security measure is perfect, and we cannot guarantee absolute security.

11. Your privacy rights and choices

Depending on your location and applicable law, you may have the right to access, correct, update, delete, restrict, object to, or port certain personal data, and to withdraw consent where processing is based on consent.

You may also be able to manage permissions directly through your device settings, including permissions related to notifications, Apple Health / HealthKit, Google Fit, Health Connect, camera, microphone, or similar device features.

You may:

request access to the personal data we hold about you;
request correction of inaccurate or incomplete data;
request deletion of your account or certain data, subject to lawful exceptions;
withdraw consent for optional processing at any time;
object to certain processing or ask us to limit it;
request a portable copy of certain data where applicable;
lodge a complaint with a competent supervisory authority if you believe your rights have been violated.

To exercise privacy rights or request account/data deletion, contact us at support@elyslife.ai. We may need to verify your identity before fulfilling your request. We will respond within the time required by applicable law.

12. Cookies, SDKs, and similar technologies

Our website and app may use cookies, SDKs, pixels, local storage, and similar technologies to keep the service functioning, remember preferences, measure performance, understand usage, and improve reliability. Depending on your jurisdiction, you may be able to control certain technologies through browser settings, device settings, or consent tools.

13. Children

Elys Life is not intended for use by anyone under 13, and we do not knowingly collect personal data from children under 13. Where applicable law requires a higher age to consent to the processing of personal data, we do not knowingly collect personal data from users below that age without the consent of a parent or legal guardian. If you believe a child has provided personal data to us in violation of applicable law, please contact us so we can take appropriate steps.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the service, applicable law, or our data practices. When we make material changes, we will update the "Effective date" above and may provide additional notice where required.

15. Contact us

For privacy questions, requests, or complaints, please contact:

WorkWell Group L.L.C.-FZ, Elys Life operator, at support@elyslife.ai.