Privacy Policy

Golden 3 Pty. Ltd. (ABN 74 010 545 892) ("Golden 3", "we", "us", "our") operates Heartell — a personal companion app — and the heartell.me website (together, the "Service").

This Privacy Policy explains how we collect, use, disclose, and protect personal information when you use the Service. We handle personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

By using the Service, you agree to the collection and use of information in accordance with this policy. Terms used here have the same meanings as in our Terms of Service unless otherwise defined.

Effective date: 2026-07-23 · Last updated: 2026-10-22

1. What we collect

Information you provide

Account and contact details — such as your name or preferred name, email address, and identifiers provided when you sign in (for example, with Apple).
Memories, stories, and media — content you add so the companion can talk with you about your life (text, photos, voice notes, and similar). Photos — including photos of your face used for the optional portrait feature — are handled as described in Section 4.
Voice notes — an audio recording you send us, for example a WhatsApp voice note or an audio file attached to an email. We store that recording. The app does not record voice notes. This is not hands-free voice mode (Section 5).
Messages — what you exchange with the companion in the app, or by email. Text from the optional hands-free voice mode is a message of this kind (Section 5).
Support communications — information you send when you contact us for help.

Information collected automatically

Device and technical data — device type, operating system, app version, language, time zone, and identifiers needed to run the app.
Usage and diagnostic data — how the app is used and error logs, to operate and improve the Service.
Network data — such as IP address, used at a high level for security and delivery of the Service.

Subscription information

Subscriptions are sold and billed through the Apple App Store. We receive subscription status information (for example, whether a subscription or trial is active). We do not receive or store your full payment-card details.

Website

The heartell.me website uses cookies and similar technologies needed to serve the pages. It also uses the Meta Pixel so we can measure advertising (for example, that someone reached this site from an ad, joined the waitlist, or clicked through to the App Store). Meta may receive page-view and those event data and set cookies for that purpose.

If you join the waitlist, we collect the email address you submit so we can contact you about early access and special offers. We do not sell it.

2. How we use information

We use personal information to:

provide, personalise, and operate the companion (including remembering what you choose to share);
generate the companion's written and spoken replies (see Section 3);
process and manage subscriptions;
respond to support requests and send service-related notices;
send you occasional personal notes from your companion by email, and route your email replies to the right companion (see below);
keep the Service secure, diagnose problems, and improve it; and
comply with law and enforce our terms.

We may create de-identified or aggregated information that no longer identifies you and use it to understand and improve the Service.

Emails from your companion

Your companion may occasionally send you a short personal note at the email address on your account. When you reply, we use your email address to recognise you and pass your reply to the companion who wrote to you. That reply becomes part of your conversation, the same as a message in the app. These notes are occasional, not a newsletter. If you would rather not get them, tell your companion, in the app or by replying, and they will stop. Emails we must send to run your account, such as a sign-in code, are not affected.

3. Artificial intelligence

Heartell's companion is powered by artificial intelligence. To generate replies (and voice, where used), we send relevant content — your messages and the memories needed for context — to third-party AI service providers that process it on our behalf. The specific providers we use may change (including failover between providers).

We instruct providers to use that content to provide the service to us. We do not allow third-party providers to use your content to train their general models.

The optional portrait feature also uses a third-party AI provider on our behalf; that is described in Section 4.

Hands-free voice input is described in Section 5. For that mode we send the text of what you said, not the audio.

4. Your photos and face data

The short version: Heartell does not use facial recognition and does not collect biometric identifiers. We do not create faceprints, facial geometry maps, or any biometric template, and we do not use facial recognition to identify you or anyone else. Photos you choose to share are used only to screen them for safety, to draw your stylized illustrated portrait if you use the portrait feature, and to show them back to you as your own keepsakes.

The portrait feature

When you set up Heartell (and later from your profile) you can optionally share a photo of yourself and receive a stylized, cartoon-style illustrated portrait. This step is optional and can be skipped. If you use it:

On your device, Apple's on-device face detection may suggest how to frame the square crop. That detection runs entirely on your phone and nothing from it is sent to us — only the crop you confirm.
On our servers, your photo goes through one automated check that classifies the image (for example: one face, a group, a pet), notes roughly where a face sits in the frame so the picture can be framed, and screens it for safety. Images that appear to show minors or unsafe content are rejected and no portrait is generated. This produces simple notes about the image — never a biometric template, and the notes themselves cannot identify you or anyone else.
Your photo is processed by a third-party AI service provider acting on our behalf to perform the safety screening and to draw the illustration. This processing is transient, and we do not allow providers to use your content to train their models. We never sell photos of you, never share them with advertisers or data brokers, and never use them for identification, authentication, profiling, or advertising.
Your original photo and the illustrated portrait are saved to your account as your own keepsakes and are shown only to you.

Storage, retention, and deletion

Your photo, your portrait, and the screening information are stored on our own servers, hosted in the United States, and are kept while your account is active. If you delete your account (in the app under Settings → Subscription & account, or by emailing us), everything — including your photos, your portrait, and the screening information — is permanently deleted after a short 72-hour grace period. You can also ask us at any time to delete a specific photo (see Section 12).

The AI service provider retains request and response copies, encrypted, for up to 30 days for abuse and audit, then deletes them. They are not used to train models.

5. Voice input

The short version: Hands-free voice mode is optional. Speech is turned into text on your device. We do not record, store, or transmit the audio from this mode, and we do not create a voiceprint or identify who is speaking. The only thing we receive from this mode is the text of what you said, and that text is handled like any other chat message.

Hands-free voice mode

In chat you can tap the microphone button and speak instead of typing. You can skip it and keep typing. If you use it:

On your device, Apple's speech recognition turns what you say into text, and that recognition runs on the device. The microphone is used only while the voice screen is open and the app is in the foreground. Closing it, leaving the app, or locking the screen stops listening immediately.
We do not receive the audio from this mode. It is not recorded, not stored, and not sent to us or to Apple. We do not create a voiceprint, a speaker template, or any other biometric identifier from your voice.
What we do receive is the finished text, sent over an encrypted connection, in the same way as a message you typed. That text is a normal chat message. It is used to generate the companion's reply (Section 3) and is kept and deleted with your other messages (Section 8).
If a reply is already being read aloud when you leave the app, playback of that reply may finish in the background. The microphone is not used in the background. Speaking over a reply that is playing stops the playback.

The text of a hands-free message is deleted with the rest of your account. In the app that is Settings → Subscription & account, or you can email us. Deletion is permanent after a 72-hour grace period. We do not keep the audio from hands-free voice.

A voice note is different. A voice note is an audio recording you send us another way, such as WhatsApp or email, and we store that recording (Section 1). The app does not record voice notes, and hands-free mode does not create one.

This section does not describe dictation offered by the iOS keyboard.

We do not sell your personal information.

We share personal information only as needed:

Service providers who help us run the Service (including AI, hosting, and related infrastructure), under arrangements that require them to protect the information and use it only for us.
Apple, for app distribution, sign-in, push notifications, and subscription billing.
Meta (Facebook / Instagram), for advertising measurement on this website (Meta Pixel).
Legal and safety — where we reasonably believe disclosure is required by law, or is necessary to protect rights, safety, or property.
Business transfers — if Golden 3 is involved in a merger, acquisition, or sale of assets, information may transfer as part of that transaction, subject to this policy.

If you open the app from an ad or a link, we may receive the labels on that link and keep them with the account. A later screen may use those labels. This does not add an advertising-tracking prompt and does not collect an advertising identifier.

7. Overseas disclosure

We are based in Australia. Some service providers (including AI providers) may store or process information outside Australia. Where we disclose personal information overseas, we take reasonable steps consistent with APP 8 so that it is handled in a way that is consistent with this policy.

8. Retention and your rights

We keep personal information while your account is active and for a reasonable period afterwards as needed to provide the Service and meet legal or dispute-resolution needs, then delete or de-identify it.

Photos of your face and stylized portraits follow the specific schedule in Section 4.

Text from hands-free voice input is an ordinary chat message. We do not keep the audio from hands-free voice. That text follows the same retention and account-deletion rules as your other messages (Section 5). A voice note you send us is a stored recording and is kept with your other content (Section 1).

You may ask us to access, correct, or delete personal information we hold about you, subject to legal limits. Contact us using Section 12. We will respond within the timeframes required by law.

If you are unhappy with how we handle your information, you may complain to us first, and then to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

9. Children

The Service is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, contact us and we will delete it.

10. Security

We take reasonable steps to protect personal information using technical and organisational measures. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Changes to this policy

We may update this policy from time to time. If we make material changes, we will take reasonable steps to let you know (for example, in the app or on the website). The “Last updated” date at the top shows when it last changed. Continued use of the Service after changes take effect means you accept the updated policy.

12. Contact

For privacy questions or to exercise your rights:

Golden 3 Pty. Ltd. (ABN 74 010 545 892) — Heartell Privacy Email: supportht@heartell.me