Bondura, Inc. ("Bondura," "we," "us") provides AI-powered relationship and communication support through our mobile application, website, and related services (collectively, the "Services").

This Privacy Policy explains how Bondura collects, uses, shares, retains, and protects personal information about consumer and client users of the Services. It applies when you:

• Create or use a Bondura account
• Complete onboarding, personality, or check-in surveys
• Use chat features, including Self Chat, Partner Chat, and partner simulations
• Write journal entries or upload journal photos
• Make in-app purchases or subscribe to a plan
• Connect with a partner, group, or licensed therapist
• Contact support or interact with our website

Bondura is currently offered only to residents of the United States. A separate privacy policy applies to licensed clinicians who use the MyBondura therapist portal; this policy does not govern that relationship.

By using the Services, you acknowledge this Privacy Policy. Where required by law (including the Washington My Health My Data Act), Bondura obtains additional consent before collecting or sharing consumer health data.

Bondura collects the following categories of personal information:

Information You Provide Directly

• Account details: name, email address, login credentials, and password (handled through Amazon Cognito and never seen in plaintext by Bondura)
• Profile data: traits, communication style, attachment style, life context, preferences, profile photo
• Survey responses: onboarding, weekly check-ins, and other assessments
• Chat content: messages you send to the AI assistant or partner simulations
• Journal entries and journal photos
• Lists, memories, and other content you save inside the app
• Communications you send to Bondura (support requests, feedback)

Transaction Information

• Subscription and purchase records
• Token usage and balance
• Receipts and payment confirmations (payments themselves are processed by Apple through In-App Purchase; Bondura does not receive or store full payment card numbers)

Information Generated About You by the Services

• AI-generated insights, summaries, and inferred behavioral patterns derived from your chats, journal entries, and surveys
• Personality model outputs (Big Five, attachment style, communication style)
• Memory records that the assistant uses to maintain continuity across conversations

Information Your Therapist Provides Through Bondura

• Session notes, focus areas, and homework that a Therapist you are paired with publishes to you through the Bondura app. These notes appear in a dedicated section of your app history and may be referenced by Bondura’s AI when generating responses in your personal and partner chats. They are scoped to you only and are not visible to your partner or to any other Bondura user.

Technical and Usage Information

• Device type, operating system, app version, language, and time zone
• Log data, crash reports, and error diagnostics
• Usage telemetry such as feature interactions and session counts
• IP address and approximate (city-level) location
• Push notification tokens

Bondura does not currently use third-party advertising trackers, web analytics, or session replay tools.

Bondura is designed to support relationships, communication, and personal reflection. Much of the content you submit constitutes consumer health data or sensitive personal information under various state laws, including:

• Mental and emotional health status, reflections, and history
• Relationship dynamics, conflicts, and patterns
• Inferences about your psychological, communication, or attachment style
• Information about people close to you that you choose to share with the Services

Bondura treats this information as sensitive and does not use it for advertising, profiling for advertising, or sale. We also treat personal information of users who indicate they are between the ages of 16 and 17 as sensitive personal information across all jurisdictions.

If you reside in Washington State, additional rights and disclosures apply to your consumer health data. Please see our separate Consumer Health Data Privacy Policy.

Bondura uses personal information only for the following purposes:

• To provide, personalize, and improve the chat, journal, simulation, and insight features you request
• To generate personality profiles, AI summaries, and relationship analyses for your use and, where you authorize it, for your therapist
• To process subscriptions, in-app purchases, token balances, and refunds
• To diagnose product reliability issues, prevent abuse, and maintain the security of the Services
• To communicate with you about your account, important changes, and support requests
• To comply with legal obligations and respond to lawful requests

What We Do Not Do

• We do not sell personal information.
• We do not "share" personal information for cross-context behavioral advertising as those terms are defined under California law.
• We do not use your content (messages, journal entries, surveys, AI summaries, or personality data) to train, fine-tune, or evaluate any third-party foundation model or any Bondura proprietary machine learning model.
• We do not make decisions about you that have legal or similarly significant effects based solely on automated processing.

Bondura uses large language models hosted on Amazon Web Services (specifically Amazon Bedrock) to generate chat responses, partner simulations, journal insights, and session summaries. All AI inference happens within infrastructure covered by a Business Associate Agreement (BAA) with AWS.

AI inputs may include:

• Messages you send during a chat or simulation
• Your profile, personality, and life context data
• Selected prior conversation history and committed memories
• Survey responses and journal entries you have authorized for that feature
• Session notes a paired Therapist has published to you through the Bondura app

AI-generated content can be inaccurate, incomplete, or out of date. It is not medical, legal, financial, or emergency advice. If you are in crisis, call or text 988 (the Suicide & Crisis Lifeline) or your local emergency number. Bondura is not a substitute for professional care.

Bondura is offered as a therapeutic support tool only when used together with a licensed clinician. When used without a therapist connection, Bondura is a relationship and reflection product and not a behavioral health treatment.

You may choose to pair your Bondura account with a licensed therapist or therapy practice ("Therapist"). When you do, the Therapist is a "covered entity" under the federal Health Insurance Portability and Accountability Act ("HIPAA"), and Bondura acts as a "business associate" of the Therapist with respect to your protected health information ("PHI"). Bondura has a Business Associate Agreement in place with every Therapist whose practice receives PHI through the Services.

When you pair with a Therapist, you are separately asked to sign a HIPAA Authorization that describes:

• The specific categories of information that may be disclosed to the Therapist (for example, chat content, survey responses, journal entries, and AI-generated summaries, depending on the sharing mode you choose)
• The Therapist and practice authorized to receive that information
• The purpose of the disclosure (to support your therapeutic care)
• The expiration of the Authorization (by default, one year from the date you sign, or earlier if you revoke)
• Your right to revoke the Authorization at any time without affecting your right to continue therapy
• A notice that information disclosed to the Therapist may be re-disclosed by them and may no longer be protected by federal privacy rules

Your Therapist will also give you a separate Notice of Privacy Practices that describes how their practice handles your PHI. That notice is provided by the Therapist, not by Bondura.

You can change your sharing mode, mark individual conversations as not shared, switch to incognito mode for a session, or revoke your Authorization entirely from inside the Bondura app at any time. Revoking your Authorization does not undo disclosures that were already made and does not require you to end your therapeutic relationship.

Information your Therapist has already accessed or that has been generated for your Therapist (for example, an AI session-preparation summary) may continue to exist in your Therapist's records after you delete your Bondura account or revoke your Authorization. That information is governed by your Therapist's Notice of Privacy Practices and applicable medical-record retention laws.

You have the right under 45 C.F.R. § 164.528 to receive an accounting of certain disclosures of your PHI. You can review the activity log of your Therapist's access to your data inside the app under Settings → Privacy → Data Sharing History.

Session Notes Your Therapist Publishes to You

Your Therapist may publish session notes, focus areas, or homework directly to you through the Bondura app. These notes appear in a dedicated section of your in-app history. When the Bondura AI generates responses in your personal and partner chats, it may reference these notes as context so that your AI experience reflects the work you and your Therapist are doing together. These notes are scoped to you only. Your partner does not see them and does not receive AI inferences derived from them in their own Bondura experience. You can review the full history of notes your Therapist has published to you inside the app at any time.

Bondura shares personal information only as described below.

Subprocessors and Service Providers

Bondura uses a small set of subprocessors to operate the Services. Each subprocessor is contractually limited to processing your information on Bondura's behalf and only for the purposes described in this Privacy Policy. Subprocessors handling PHI operate under a Business Associate Agreement.

• Amazon Web Services, Inc. ("AWS"): hosting, database (Amazon RDS), authentication (Amazon Cognito), file storage (Amazon S3), email delivery (Amazon SES), large language model inference (Amazon Bedrock), push notification delivery (Amazon SNS), and operational logging. Covered by a Business Associate Agreement with AWS.
• Apple Inc.: App Store distribution, In-App Purchase processing for subscriptions and token purchases, and delivery of push notifications via the Apple Push Notification service. Push notification payloads contain no protected health information.
• Cloudflare, Inc.: DNS resolution only for the bondura.app domain. No protected health information transits Cloudflare infrastructure.

Bondura maintains an up-to-date list of subprocessors at contact@bondura.app on request.

People You Choose to Share With

• A partner, group member, or other Bondura user you explicitly pair or share content with inside the app
• A Therapist you have paired with, to the extent of your active HIPAA Authorization

Legal and Safety

• When required by valid legal process (subpoena, court order, or governmental request) and only to the extent legally required
• To protect the rights, property, or safety of Bondura, our users, or the public, including in connection with a suspected violation of our Terms or applicable law
• In connection with a corporate transaction (merger, acquisition, or asset sale), in which case any successor will be bound by this Privacy Policy or provide notice of any material change

All Bondura infrastructure and personal information is hosted in the United States. Bondura does not transfer personal information outside the United States.

Bondura retains personal information only as long as needed for the purposes described in this Privacy Policy. Specific retention periods are:

• Chat messages: up to 2 years from creation, or until you delete the conversation or the related therapist link is dissolved, whichever comes first
• Journal entries (including photos and chunks): up to 2 years from creation, or until you delete the entry
• AI-generated summaries created for a paired Therapist: up to 7 years, to match clinical record-retention norms
• Long-term memory records used by the assistant: up to 2 years from creation; older memories are pruned automatically
• Survey responses: up to 2 years from submission
• Account profile (name, email, login record): for the life of your account
• Audit logs (therapist access, administrative access, security events): 6 years, to meet HIPAA minimum retention
• Transactional records required for tax, accounting, or dispute resolution: as required by law

When you delete your account, Bondura performs a synchronous hard delete of your data across approximately forty database tables, removes your Amazon Cognito record, and deletes your associated journal photos and other media from S3. Bondura's automated database backups roll off on a 7-day cycle, after which deleted information no longer exists in any Bondura backup. S3 object versions are expired on a separate lifecycle window. After deletion, a small "tombstone" record is retained (containing no identifying information) to prevent token replay from recreating your account.

As described in Section 6, information already shared with a Therapist before deletion may continue to exist in your Therapist's records under their own policies.

Bondura uses technical and organizational safeguards designed to protect your information, including:

• Encryption in transit (TLS) and at rest (AES-256 at the storage layer)
• Authentication and authorization through Amazon Cognito with refresh-token rotation
• Network isolation of database and operational logs inside a private AWS VPC
• Row-level security in the database to enforce per-user and per-role data access
• Audit logging of administrative and therapist access to client data
• Certificate pinning on the mobile app
• Regular vulnerability monitoring and security review of code changes

No internet-connected service can guarantee absolute security. If Bondura discovers a security incident that affects your information, we will notify you (and, where you have paired with a Therapist, your Therapist's practice) without unreasonable delay and within the timeframes required by HIPAA and applicable state law.

Depending on where you live, you may have the right to:

• Know what personal information Bondura has collected about you and how it is used
• Receive a portable copy of that information
• Correct inaccurate personal information
• Delete your account and the personal information associated with it
• Limit Bondura's use of sensitive personal information to providing the Services you requested
• Opt out of "sale" or "sharing" of personal information (Bondura does not sell or share)
• Not receive discriminatory treatment for exercising any of these rights

In-app privacy controls include:

• Conversation deletion and incognito-mode conversations
• Therapist sharing controls and HIPAA Authorization revocation
• Data Sharing History (therapist access log)
• Full account deletion (Settings → Privacy & Safety → Delete Account)
• Data export (request via contact@bondura.app while in-app export is being rolled out)

To exercise a right that is not available in-app, contact us at contact@bondura.app. Bondura will respond within the timeframes required by applicable law (generally 45 days under California law). We may need to verify your identity before fulfilling the request.

California Residents

In the prior 12 months Bondura has collected the categories of personal information described in Section 2, for the purposes described in Section 4, from the sources described in Section 2, and disclosed information only to the subprocessors and recipients described in Section 7. Bondura does not sell or share personal information and has not done so in the prior 12 months. Bondura does not have actual knowledge of selling or sharing the personal information of consumers under 16 years of age. You may designate an authorized agent to submit requests on your behalf by providing written authorization. Bondura does not currently honor Do Not Track or global privacy control signals because it does not engage in advertising-driven tracking.

Washington Residents

See our Consumer Health Data Privacy Policy at /wa-consumer-health for additional rights and disclosures under the Washington My Health My Data Act, including the right to withdraw consent and to request a list of categories of consumer health data Bondura has collected and shared.

Bondura is not directed to and does not knowingly accept users under the age of 16. If we learn that personal information of a user under 16 has been collected, we will delete it. If you believe a minor has provided information to Bondura, please contact contact@bondura.app.

Bondura treats personal information of any user identified as 16 or 17 as sensitive personal information and does not use it for any secondary purpose beyond providing the Services.

Bondura may update this Privacy Policy from time to time. If a change is material, we will update the effective date and provide notice via the app, the website, or email before the change takes effect. Your continued use of the Services after the effective date of an update constitutes acknowledgment of the updated policy, except where applicable law requires additional consent.

Bondura's Privacy Officer is Cole Meyer. To exercise a privacy right, ask a question, or file a complaint, contact contact@bondura.app.

You also have the right to file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights if you believe Bondura has violated your rights under HIPAA. You will not be retaliated against for filing a complaint.