Privacy & Consumer Health Data Notice

This Notice describes how Borta Enterprises LLC ("Emma," "we," "us," or "our") collects, uses, discloses, retains, and protects personal data in the Emma web application. It also serves as our Consumer Health Data Notice for information that identifies or can reasonably be linked to an individual's physical or mental health.

1. Scope and controller

Borta Enterprises LLC determines why and how Emma processes personal and consumer health data and is the data controller. This Notice applies to Emma's consumer website, account, conversations, recaps, couples features, billing state, and support communications. It does not govern a third-party site you choose to visit.

2. Categories of data, sources, and purposes

Category and sourceExamplesWhy we process it
Account and consent data, directly from youName, e-mail, password hash, user ID, age confirmation, legal versions and timestampsCreate and secure the account, authenticate you, record consent, communicate, and honor rights
Consumer health and conversation data, directly from you and generated from your useMessages about thoughts, feelings, symptoms, relationships, preferences, AI replies, recaps, themes, and embeddingsGenerate and moderate replies, preserve a useful recap, personalize later sessions, provide couples sessions, and maintain safety
Couples data, from the payer and linked partnerPartner e-mail, invitation and link state, speaker identity, shared messages and recapsInvite a consenting adult, provide the shared feature, assign plan access, and retire shared history when unlinked
Billing data, from you and StripeStripe customer and subscription IDs, plan, status, renewal date, cancellation stateCreate and administer subscriptions, prevent duplicate charges, reconcile webhooks, and support deletion. Card details go directly to Stripe and are not stored by Emma.
Security and technical data, automatically from requests and infrastructureIP address, request time, route and status class, browser/network headers, rate-limit state, aggregate uptime and usage countersDeliver pages, prevent abuse, diagnose failures, monitor availability, and investigate security events. Operational metrics do not intentionally contain chat content.
Support and e-mail data, directly from you and our mail providerSupport message, reset-code delivery, partner invitation delivery, delivery statusRespond, recover accounts, deliver invitations, and troubleshoot

3. Sensitive consumer health data and consent

Conversation and recap data may reveal mental or physical health, diagnoses you mention, emotional state, relationships, sexual orientation or activity, addiction, trauma, or other highly sensitive facts. We process this data only to provide, personalize, secure, and maintain the features you request; comply with law; or protect a person from serious harm where law permits. We do not use geofences around health facilities and do not sell consumer health data.

Before account creation, you must affirmatively consent to this processing separately from accepting the Terms. You can withdraw consent by stopping use and deleting the account in Settings, or by contacting us. Because processing this data is necessary to generate Emma's support, withdrawal means we cannot continue providing conversation features.

4. Disclosures and processors

We disclose only the data reasonably needed for these purposes:

We require processors to act under our instructions, protect confidentiality, and use data only for contracted services. We do not disclose consumer health data to an independent third party for its own marketing or advertising purpose.

5. No sale, targeted advertising, or profiling

We do not sell personal or consumer health data, exchange it for targeted advertising, or profile you to make a legal or similarly significant decision. Emma currently loads no advertising pixel or cross-site behavioral analytics. If this changes, we will update this Notice and obtain consent where required.

6. Retention

7. Your rights and how to exercise them

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

Delete the account directly in Dashboard → Settings, or e-mail dborta0@gmail.com with "Privacy Request" in the subject. State the right you want to exercise and the account e-mail. We will verify the request before releasing or changing data and will respond within the period required by applicable law. Authorized agents must provide evidence of authority, and we may still verify the request with the consumer.

If we deny a request, reply with "Privacy Appeal" and explain why you disagree. A different reviewer will consider the appeal. We will not discriminate against you for exercising a privacy right.

8. Cookies and browser storage

Emma uses a first-party, HttpOnly, Secure session cookie for authentication. It is necessary to provide the signed-in Service and expires after a short session window. The browser also uses tab/session storage for non-secret account-interface state and in-memory storage for chat display. A small local-storage lease coordinates open dashboard tabs. We do not currently use advertising cookies. Browser requests to Stripe are subject to Stripe's necessary payment technology.

9. Security

We use safeguards including TLS, password hashing, least-privilege database roles, private service networks, signed billing webhooks, authentication and session revocation, request validation, rate limits, restricted browser policies, backups, and monitoring. No system is perfectly secure. Do not send information that is unnecessary for the support you want. If you believe data was exposed or misused, contact dborta0@gmail.com promptly.

10. Health-data incidents

We maintain an incident-response process. If a breach of unsecured, individually identifiable health information triggers the FTC Health Breach Notification Rule or another law, we will notify affected individuals, regulators, and others as required. This paragraph is not a statement that every incident or every Emma record falls under a particular law.

11. Adults only and HIPAA status

Emma is limited to adults 18 and older and is not directed to children. Emma is not offered on behalf of a hospital, insurer, or other HIPAA covered entity, and we do not represent that ordinary Emma accounts are governed by HIPAA or protected by therapist-patient privilege. Do not upload a provider's medical record or another person's health information unless you are legally authorized and it is necessary.

12. U.S. processing and changes

Emma is operated in the United States and its providers may process data in the U.S. We may update this Notice as the product, providers, or law changes. If a change materially expands how we use sensitive data, we will provide notice and request renewed consent before the new use where required.

13. Contact

Privacy contact and controller:
Borta Enterprises LLC
E-mail: dborta0@gmail.com