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: 2026-07-23


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).
  • Messages — what you exchange with the companion in the app.
  • 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 only the cookies and similar technologies needed to serve the pages.


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;
  • 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.


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.


4. How we share information

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.
  • 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.

5. 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.


6. 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.

You may ask us to access, correct, or delete personal information we hold about you, subject to legal limits. Contact us using Section 10. 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.


7. 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.


8. 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.


9. 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.


10. Contact

For privacy questions or to exercise your rights:

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