PRIVACY POLICY - FourVirtues

Effective: 24th October 2025

The FourVirtues Mobile application ("FourVirtues", "we", "us" or "our") is owned and operated by ELM APPS LTD. We are committed to protecting the privacy and security of your personal information.

WHAT IS THE PURPOSE OF THIS POLICY?

At ELM APPS LTD, we respect your privacy and are committed to protecting your personal information. The FourVirtues App is designed to operate with minimal data collection. We do not run in-app accounts or request personal identifiers such as your name or email address. Your writings, including journals, reflections, and notes remain stored on your device and, if enabled, in your private iCloud account in accordance with your Apple settings. We do not access, receive, or store this content on our servers.

When you use the FourVirtues AI features, the text you provide is securely sent to OpenAI’s API to generate a response, which is then returned to your device. We do not retain or process your writings beyond what is necessary to deliver that response. Apple manages billing, subscriptions, and iCloud services under its own terms and privacy policies.

If you have any concerns about how your information is handled, you may contact us at support@elmapps.co.uk or raise a concern with the Information Commissioner’s Office (ICO) in the United Kingdom. The applicable legal framework is the UK GDPR and relevant European Union data privacy regulations.

YOUR CONSENT

By using the FourVirtues App, you acknowledge and provide your explicit and informed consent to the processing of any personal data that may arise from your use of the App, in accordance with Article 9(2)(a) of the UK GDPR.

This consent is provided voluntarily and solely for the purpose of enabling the App’s features and delivering its services. We process only the limited data necessary to operate the App and do not collect personal identifiers such as your name or email address.

You have the right to withdraw your consent or object to processing at any time without affecting the lawfulness of prior processing. To do so, please contact us at support@elmapps.co.uk. Upon withdrawal, certain App functions may no longer operate as intended.

DATA CONTROLLER

The data controller responsible for your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 is:

ELM APPS LTD
Registered in England and Wales
Email: support@elmapps.co.uk

ELM APPS LTD determines the limited purposes and means of processing any personal data collected through the FourVirtues App. We do not process, store, or share your personal writings or reflections, which remain solely on your device or within your private iCloud account managed by Apple.

For features involving artificial intelligence (AI), text input is transmitted securely to OpenAI’s API solely to generate a response. ELM APPS LTD does not retain or further process this data once the response is delivered.

OUR PRIVACY PROMISE

We value your privacy and data security:

  • We do not use your data for commercial purposes.
  • We comply with the UK GDPR and relevant European Union (EU 2016/679) regulations regarding your privacy.
  • We will never sell your data.
  • You control your data.

HOW WE COLLECT YOUR PERSONAL INFORMATION

The FourVirtues App is designed to collect and process as little personal data as possible. We do not operate user accounts and do not ask for personal identifiers such as your name, email address, or contact details.

Writings and Reflections: Your journals, reflections, and notes are stored locally on your device and, if enabled, in your private iCloud account. This data is not transmitted to or accessed by ELM APPS LTD. Storage, backup, and security for this content are governed by your Apple settings and Apple’s privacy policies.

AI Features: When you use the AI-assisted features (such as Reflection Mode, Decision Mode, or Chat with the Author), the text you input along with only the minimal contextual information necessary is securely sent to OpenAI’s API to generate a response. The resulting text is then displayed back to you. We do not store or reuse your input or generated responses on our servers.

Billing and Subscriptions: All billing, renewal, and subscription management are handled directly by Apple through in-app purchases. We do not collect or process payment details. Apple’s own privacy policy and App Store terms apply to these transactions.

Technical and Diagnostic Data: The App may collect limited, anonymised technical information (such as crash reports or performance metrics) through Apple’s developer tools to maintain functionality and improve stability. This information does not identify you personally and is processed in accordance with Apple’s developer privacy framework.

We use all collected data solely for the purpose of providing and improving the App’s features, maintaining security, and ensuring a stable user experience. No data is sold, shared, or used for profiling, tracking, or marketing purposes.

WHAT DATA WE HANDLE

The FourVirtues App is designed to operate with minimal data processing. We only handle limited information necessary to provide and maintain the App’s features. The categories of data are set out below:

Data You Create in the App (Journals, Reflections, and Notes): Your writings and reflections remain entirely within your control. They are stored locally on your device and, if enabled, within your private iCloud account, depending on your Apple settings. We do not receive, host, or access this content at any time.

Inputs You Send to AI Features: When you use AI-enabled functions such as Decision Mode, Reflection Mode, or Chat with the Author, the text you type (along with minimal context generated by the App) is securely transmitted to OpenAI’s API to produce a response. We do not store or retain these inputs or outputs on our servers.

Support Communications: If you contact us for assistance, we will receive the information you choose to provide—typically your email address, message content, and any attachments. This data is used solely to respond to and resolve your enquiry.

Device and Technical Data: We do not embed third-party analytics, tracking tools, or advertising SDKs. Apple may, with your consent, share anonymised crash or diagnostic data to help improve stability. We do not use this data to identify or profile you.

HOW WE USE YOUR INFORMATION

We use data strictly to enable the features of the FourVirtues App and to maintain a secure, reliable user experience. We do not collect personal identifiers, track user activity, or use your information for advertising, profiling, or resale.

  • Service Delivery: Any limited data processed (such as your text inputs for AI features) is used only to generate real-time responses.
  • Device and iCloud Storage: Your journals and notes remain entirely within your control.
  • Technical Performance: Anonymous diagnostic data may be used to improve the App’s stability.
  • Compliance and Safety: Minimal data may be processed if required by law.

LAWFUL BASIS FOR PROCESSING DATA

PurposeDataLegal Basis
Provide AI features (generate responses)Your AI inputs and necessary context sent to OpenAIPerformance of a contract
Operate the app (local storage/sync you enable)Your writings in your iCloud/local devicePerformance of a contract
Customer supportYour emails to usLegitimate interests
Security and fraud preventionMinimal technical information as neededLegitimate interests
Legal complianceRecords needed to comply with lawLegal obligation

We do not use your data for marketing, analytics, or behavioural tracking. All processing is carried out under the lawful bases of consent (Article 6(1)(a)) and legitimate interests (Article 6(1)(f)).

COOKIE POLICY

The FourVirtues App does not use cookies or tracking technologies for analytics, marketing, or user profiling. We do not embed third-party advertising or analytics software within the App. Where the App relies on Apple’s platform services (for example, iCloud or in-app purchases), Apple may use cookies or similar technologies under its own privacy and cookie policies.

NO TRACKING OR THIRD-PARTY ANALYTICS

The FourVirtues App does not include tracking software, analytics tools, advertising identifiers, or third-party SDKs that monitor user behaviour. We do not track your activity within the App, build user profiles, or share any information with advertisers or external analytics providers.

WHO RECEIVES OR PROCESSES YOUR DATA

We share or transmit data only where necessary to operate the FourVirtues App and deliver its features. The following parties may receive or process limited data:

  • Apple (iCloud and App Store Services) – Storage, syncing, and billing are managed directly by Apple Inc.
  • OpenAI (AI Processing) – Your text inputs are securely transmitted to OpenAI’s API.
  • Email and IT Service Providers – Support queries are processed securely for response purposes.

We do not sell, rent, or trade personal data under any circumstances.

INTERNATIONAL DATA PROCESSING

Some of our technology partners may process data outside the United Kingdom.

  • OpenAI (AI Features): Data may be processed in the United States or other jurisdictions.
  • Apple (iCloud and App Store Services): Data may be processed in global data centres.

All transfers are protected by the UK GDPR safeguards, including adequacy decisions or contractual clauses.

DATA SECURITY

We take your privacy and data protection seriously and follow appropriate technical and organisational measures in line with the UK GDPR to safeguard your information.

All data transmitted to OpenAI’s API is encrypted (TLS/HTTPS). We do not host or store your writings. Keep your device and iCloud secured with passcode or two-factor authentication.

DATA RETENTION

Types of DataWhere it is storedDo we access or store it?How long we keep itPurpose/Notes
Journals, Reflections, NotesOn your device/iCloudNoFully controlled by youSupport your use of the App
AI Feature InputsSent to OpenAI APINoNot retained by usGenerate AI responses
Support CommunicationSecure email systemYesUntil resolvedRespond to enquiries
Device / Technical DataApple systemsNoControlled by AppleImprove reliability

YOUR RIGHTS

Under the UK GDPR, you have rights to:

  • Access your data (Art. 15)
  • Rectify inaccuracies (Art. 16)
  • Request erasure (Art. 17)
  • Restrict processing (Art. 18)
  • Object to processing (Art. 21)
  • Data portability (Art. 20)
  • Withdraw consent at any time

Complaints can be made to the ICO via www.ico.org.uk or by calling 0303 123 1113.

CHILDREN'S PRIVACY

Our services are not directed to children under 16 years of age. We do not knowingly collect data from anyone under 16. If you believe that a child has provided information, contact support@elmapps.co.uk immediately.

NOTICE FOR UK USERS’

UK residents benefit from protections under UK law, including the UK GDPR. To exercise rights, contact support@elmapps.co.uk.

NOTICE FOR EU USERS’

EU residents benefit from protections under the European Union GDPR. To exercise rights, contact support@elmapps.co.uk.

ADDITIONAL NOTES ON AI FEATURES

When using the AI-assisted tools within the FourVirtues App:

  • Avoid including names or personal identifiers in prompts.
  • AI output may contain errors or bias. Treat responses as philosophical, not professional advice.
  • “Chat with the Author” uses public-domain Stoic writings and is not endorsed by any author’s estate.

Use your own judgement when interpreting AI-generated content.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Updates will appear in the App with a new “last updated” date.

COMPLAINTS OR CONCERNS

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your data, please contact us:

Email: support@elmapps.co.uk
Postal Address: FourVirtues App, c/o ELM APPS LTD, London, United Kingdom

We aim to respond to privacy-related enquiries within 30 days.

If you remain dissatisfied, you may contact the Information Commissioner’s Office (ICO):
Website: www.ico.org.uk
Telephone: 0303 123 1113

Last Updated 24th October 2025

© 2025 ELM APPS. All rights reserved.
ELM APPS LTD, 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM