SPIRAL PRIVACY POLICY

Effective Date: September 22, 2026

Spiral is operated by Eternal444 LLC (“Eternal,” “we,” “us,” or “our”). This Privacy Policy explains how information is handled when you use the Spiral mobile application (“Spiral” or the “App”).

1. THE SHORT VERSION

Spiral is designed to help you work through thoughts, worries, decisions, and situations by turning what you submit into a structured reflection.

To do that, the content you submit to Spiral must be processed by the services that power the App, including our backend infrastructure and artificial intelligence service providers.

We do not sell your personal information, and we do not use the thoughts you submit to Spiral for advertising.

Spiral does not currently require you to create an account.

2. INFORMATION YOU PROVIDE

When you use Spiral, you may choose to provide information such as:

• The thoughts, situations, questions, or concerns you enter into Spiral;

• Responses you provide while using features such as Still Spiraling or Deeper Focus;

• Information submitted when requesting a personalized action plan; and

• Content necessary to generate narration or other features you choose to use.

Because Spiral is a reflection tool, what you choose to enter may sometimes be personal or sensitive. You control what you choose to submit.

Please avoid entering information about another person that you do not have the right to provide.

3. HOW YOUR CONTENT IS PROCESSED

When you request a Reality Check or use certain other Spiral features, the information necessary to fulfill that request is transmitted securely to Spiral’s backend infrastructure for processing.

Spiral currently uses services provided by Supabase for backend infrastructure and OpenAI for artificial-intelligence functionality. Information you submit may therefore be transmitted to and processed by these providers when necessary to provide the feature you requested.

For example, processing may be necessary to:

• Generate a Reality Check;

• Respond when you use Still Spiraling or Deeper Focus;

• Create a personalized action plan; or

• Generate narration.

OpenAI does not use data submitted through its API to train its models by default unless the API customer affirmatively opts in to data sharing. OpenAI may retain certain API data for limited periods for purposes such as abuse monitoring, security, and legal compliance, subject to its applicable policies and the configuration of the services we use.

We use service providers to operate Spiral. Their handling of information is also subject to the applicable agreements and privacy practices governing those services.

4. INFORMATION STORED ON YOUR DEVICE

Spiral stores certain information locally on your device so the App can function and preserve your experience.

Depending on how you use Spiral, this may include:

• Saved Spiral content and session information;

• App preferences and settings;

• Usage or allowance information;

• Subscription-related state;

• Cached narration files;

• Profile or onboarding preferences; and

• A device-specific installation identifier stored using Apple’s Keychain technology.

The installation identifier helps Spiral distinguish an installation of the App and support functionality such as security and usage management. It is not intended to identify you by your real-world identity.

5. SUBSCRIPTIONS AND PAYMENTS

Paid Spiral subscriptions are purchased and managed through Apple’s App Store and StoreKit systems.

Apple processes your payment transaction. Eternal444 LLC does not receive your complete payment-card information from Apple.

We may receive information necessary to determine your subscription status, such as whether a subscription is active and which Spiral plan applies to you.

6. PHOTO LIBRARY ACCESS

If you choose to save a Spiral share card to your photo library, Spiral may request permission to add that image to your Photos library.

Spiral does not require general access to your personal photo library simply to use the core reflection experience.

7. ANALYTICS, ADVERTISING, AND TRACKING

Spiral does not currently use a third-party advertising network or third-party analytics SDK.

We do not use the thoughts you submit to Spiral to serve you targeted advertisements.

We do not sell your personal information.

If we materially change our analytics or tracking practices in the future, we will update this Privacy Policy and make any disclosures or obtain any permissions required by applicable law or platform rules.

8. SECURITY

We use technical and organizational measures designed to protect information processed through Spiral. These include encrypted network connections and security measures within the App and its backend infrastructure.

No method of electronic transmission or storage can be guaranteed to be completely secure, however, and we cannot promise absolute security.

9. DATA CONTROLS AND DELETION

Spiral provides controls for deleting saved Spiral content and resetting certain locally stored App data.

Some technical information used for security or installation integrity, such as a device-specific installation identifier stored in Apple’s Keychain, may not be removed by an ordinary in-app data reset.

You may contact us at support@eternal444.com with privacy or data-related questions.

As Spiral’s backend and security architecture evolves, we may provide additional controls for information maintained by our services.

10. DATA RETENTION

Locally stored information remains on your device according to the operation of the App and the controls available to you.

Information transmitted to our service providers may be retained as necessary to provide and secure their services and according to the applicable service-provider arrangements and legal requirements.

We do not promise a specific retention period where we cannot accurately control or guarantee one.

11. CHILDREN’S PRIVACY

Spiral is not directed to children under 13, and we do not knowingly collect personal information from children under 13.

If you believe a child under 13 has provided personal information through Spiral, please contact us at support@eternal444.com.

Additional age restrictions may apply depending on your location or the requirements of the App Store.

12. ABOUT SPIRAL

Spiral is an AI-powered reflection tool designed to help users examine thoughts, assumptions, possibilities, and next steps. Spiral is not a therapist, medical provider, mental-health professional, crisis service, or substitute for professional care.

Because users may choose to discuss personal matters in Spiral, consider what information you are comfortable submitting.

If you are experiencing an emergency or believe you or another person may be in immediate danger, contact appropriate emergency services or crisis resources rather than relying on Spiral.

13. INTERNATIONAL PROCESSING

The services used to operate Spiral may process information in locations different from where you live. Information may therefore be processed in jurisdictions with different data-protection laws, subject to applicable legal requirements and service-provider safeguards.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy as Spiral evolves, including when we add or change features, service providers, or data practices.

When we make material changes, we will update the effective date and provide any additional notice required by applicable law.

15. CONTACT US

For questions about this Privacy Policy, Spiral, or your information, contact:

Eternal444 LLC

Email: support@eternal444.com

Website: eternal444.com