Privacy Policy

Our Commitment to Your Privacy

We remember your story because that's how we help you grow. Not to sell it. Not to share it. To be there for you in a way no one else can.

This Privacy Policy explains how Ferni AI, Inc. ("Ferni," "we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our AI coaching services, including our website (ferni.ai), mobile applications, phone services, and any related services (collectively, the "Services").

Effective Date: December 31, 2025
Last Updated: October 10, 2026

Information We Collect

We collect information in several ways to provide you with personalized coaching:

Information You Provide Directly

Information Collected Automatically

Information from Third Parties

• Authentication providers: If you sign in via Google or Apple, we receive your name and email
• Google Calendar and Gmail: Only if you connect them. See Google User Data
• Payment processors: Transaction confirmation from Stripe (we never see your full card number)
• Analytics services: Aggregated usage patterns (not linked to your conversations)

Sensitive Information

During coaching conversations, you may share sensitive information including health concerns, financial situations, relationship details, or emotional states. We treat all conversation content with the highest level of protection and never use it for purposes other than providing your coaching service.

How We Use Your Information

Your information serves one purpose: helping you grow. Here's specifically how:

Providing Our Services

• Delivering personalized AI coaching through our team of specialists
• Maintaining conversation continuity and memory across sessions
• Processing voice calls and text interactions
• Sending coaching reminders, check-ins, and follow-ups (with your consent)
• Managing your account and subscription

Improving Our Services

• Analyzing usage patterns to enhance features (aggregated, not individual)
• Training and improving our AI models (see AI & Machine Learning section)
• Debugging technical issues
• Conducting research to better understand coaching effectiveness

Communications

• Sending service-related announcements and updates
• Responding to your inquiries and support requests
• Delivering SMS messages (only with your explicit consent)
• Marketing communications (only with your opt-in consent)

Safety & Security

• Detecting and preventing fraud, abuse, and security incidents
• Enforcing our Terms of Service
• Complying with legal obligations
• Protecting the rights and safety of our users and third parties

Legal Bases for Processing (GDPR)

For users in the European Economic Area, United Kingdom, and Switzerland, we process your personal data based on the following legal grounds:

Where we rely on consent, you may withdraw it at any time by contacting us at privacy@ferni.ai or adjusting your settings in the app.

Data Sharing & Disclosure

We do not sell your personal information. We share your data only in limited circumstances:

Service Providers

We work with trusted partners bound by strict data protection agreements:

Legal Requirements

We may disclose your information when required by law, including:

• Valid legal process (subpoenas, court orders, government requests)
• To protect the safety of any person
• To investigate potential violations of our Terms
• To protect our legal rights

We will notify you of legal requests unless prohibited by law or court order, and we will challenge requests we believe are overly broad or inappropriate.

Business Transfers

If Ferni is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you via email and/or prominent notice on our website of any change in ownership and your choices regarding your information.

With Your Consent

We may share information for other purposes with your explicit consent.

Data Retention

We retain your information for as long as necessary to provide our Services and fulfill the purposes described in this policy:

When you delete your account, we will delete or anonymize your personal information within 30 days, except where retention is required for legal compliance or legitimate business purposes (such as fraud prevention).

Data Security

We implement comprehensive security measures to protect your information:

Technical Safeguards

• Encryption in Transit: All data transmitted to and from our Services uses TLS 1.3 encryption
• Encryption at Rest: All stored data is encrypted using AES-256 encryption
• Access Controls: Role-based access with multi-factor authentication for all team members
• Infrastructure Security: Hosted on SOC 2 Type II certified cloud infrastructure (Google Cloud)
• Network Security: Firewalls, intrusion detection, and DDoS protection
• Vulnerability Management: Regular security assessments and penetration testing

Organizational Safeguards

• Minimal Access: Team members access personal data only when necessary for their role
• Security Training: All employees complete security awareness training
• Vendor Assessment: Third-party vendors undergo security review before engagement
• Incident Response: Documented procedures for detecting, responding to, and reporting breaches
• Audit Logging: All access to sensitive data is logged and monitored

Breach Notification

In the event of a data breach affecting your personal information, we will notify you within 72 hours (as required by GDPR) via email and/or in-app notification. We will also notify relevant regulatory authorities as required by law.

International Data Transfers

Ferni is based in the United States, and your information is processed and stored primarily in the United States. If you're located outside the U.S., your information will be transferred to and processed in the U.S.

Transfer Mechanisms

For transfers from the European Economic Area, United Kingdom, or Switzerland, we rely on:

• Standard Contractual Clauses (SCCs): EU-approved contractual terms with our service providers
• Data Processing Agreements: Binding contracts ensuring equivalent protection
• Adequacy Decisions: Where applicable, transfers to countries with adequate data protection

Our cloud infrastructure providers maintain certifications including SOC 2, ISO 27001, and comply with the EU-U.S. Data Privacy Framework.

Your Privacy Rights

Depending on your location, you have various rights regarding your personal information:

Rights for All Users

• Access: Request a copy of your personal data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your data (subject to legal retention requirements)
• Export: Download your conversation history and account data
• Opt-Out: Unsubscribe from marketing communications at any time
• SMS Opt-Out: Text STOP to cancel SMS messages

Additional Rights (EEA, UK, Switzerland)

• Restrict Processing: Request limitation of how we use your data
• Data Portability: Receive your data in a structured, machine-readable format
• Object to Processing: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent where processing is based on consent
• Lodge a Complaint: File a complaint with your local data protection authority

Exercising Your Rights

To exercise any of these rights:

• Email:privacy@ferni.ai
• In-App: Settings → Privacy → Manage My Data
• Mail: Ferni AI, Inc., Attn: Privacy, [Address]

We will respond within 30 days (or 45 days for complex requests, with notice). We may need to verify your identity before processing requests.

U.S. State Privacy Rights

California (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act and California Privacy Rights Act:

• Right to Know: Categories and specific pieces of personal information collected
• Right to Delete: Request deletion of personal information
• Right to Correct: Request correction of inaccurate information
• Right to Opt-Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising
• Right to Limit Use of Sensitive Information: We only use sensitive information for service delivery
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

To exercise these rights, contact us at privacy@ferni.ai or call 1 (888) 598-3952.

Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA)

Residents of these states have similar rights to access, correct, delete, and obtain a copy of personal data, as well as opt out of targeted advertising (which we do not conduct) and profiling. Appeals may be submitted to privacy@ferni.ai.

Do Not Track

Our Services do not currently respond to "Do Not Track" browser signals, as there is no industry standard for this. However, you can manage cookies and tracking through your browser settings.

Children's Privacy

Ferni is designed for adults and is not intended for users under the age of 16 (or the applicable age of digital consent in your jurisdiction).

• We do not knowingly collect personal information from children under 16
• We do not knowingly allow children to register for or use our Services
• We do not knowingly market to children

If you believe a child under 16 has provided us with personal information, please contact us immediately at privacy@ferni.ai. We will promptly delete such information.

For users between 16-18, we recommend parental involvement in their use of our Services.

Cookies & Tracking Technologies

We use cookies and similar technologies to provide, secure, and improve our Services:

Types of Cookies

Managing Cookies

• Browser Settings: Most browsers allow you to block or delete cookies
• Cookie Banner: Use our cookie preference center when you first visit
• Opt-Out Links:Google Analytics Opt-Out

Note: Blocking essential cookies may prevent you from using certain features of our Services.

For detailed information, see our Cookie Policy.

AI & Machine Learning

Ferni is an AI-powered service. Here's how we use AI and handle your data in that context:

How AI Powers Your Coaching

• Our AI specialists (Ferni, Maya, Peter, Alex, Jordan, Nayan) use large language models to understand and respond to you
• Your conversation history enables personalized, continuous coaching
• AI analyzes patterns in your conversations to provide relevant insights
• Voice recognition identifies you for seamless phone interactions

AI Model Training

If you choose to opt in (available in settings), anonymized and aggregated conversation patterns may be used to improve Ferni's coaching capabilities. You can withdraw this consent at any time.

Automated Decision-Making

Ferni does not make legally or similarly significant decisions about you through purely automated means. Our AI provides coaching suggestions and insights, but you always maintain full control over your decisions and actions.

Google User Data

You choose whether to connect your Google account. Each connection asks Google for only what that feature needs, and you can turn it off at any time.

What we access, and why

• Google Calendar (if you connect it): we read and update your calendar events so Ferni can tell you what's coming up, schedule things you ask for, and remind you.
• Gmail, "send email as me" (only if you turn it on): permission to send email from your Gmail address. Ferni uses it only to send an email you asked Ferni to send, from your own address. This permission cannot read your inbox, and we do not read it. We also receive your email address, so we can show you which account mail goes out from.

How we use it

• Only to provide or improve the features you can see and turned on.
• Never for advertising, never sold, and never used to build user profiles for anyone else.
• Never used to train or improve AI models, including our own and any third party's. The opt-in described under AI & Machine Learning does not include Google user data.
• No person at Ferni reads it, except when you ask us to (for example, for support), when it's needed for security (for example, investigating abuse), or to comply with the law.
• We transfer it only as needed to provide those features (for example, to the AI model that answers you during a conversation), to comply with the law, or as part of a merger or acquisition with notice to you.

Storage, retention and deletion

• The access tokens Google gives us are stored encrypted. We keep them until you disconnect the feature or delete your account.
• For an email Ferni sends from your Gmail, our service logs record that an email was sent and Gmail's message ID, never its content.
• Turning off "send email as me" deletes our copy of that permission. Deleting your Ferni account also asks Google to revoke it.
• You can remove Ferni's access to your Google account at any time at myaccount.google.com/permissions.

Changes to This Policy

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

• We'll update the "Last Updated" date at the top
• For material changes, we'll provide prominent notice (email, in-app notification, or banner) at least 30 days before they take effect
• We'll maintain an archive of previous versions upon request
• Continuing to use our Services after changes take effect means you accept the updated policy

If you disagree with any changes, you may delete your account before the new policy takes effect.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Privacy Questions:privacy@ferni.ai
• Data Protection Officer:dpo@ferni.ai
• General Support:hello@ferni.ai
• Phone:1 (888) 598-3952
• Mail: Ferni AI, Inc., Attn: Privacy Team, [Address]

EU/UK Representative

For users in the European Economic Area or United Kingdom, our representative can be contacted at eu-representative@ferni.ai.

Supervisory Authority

If you're in the EEA/UK and believe we've violated your data protection rights, you have the right to lodge a complaint with your local supervisory authority.

Last thought: We built Ferni because we believe everyone deserves someone who truly listens and remembers. That trust is the foundation of everything we do. Thank you for letting us be part of your story.