Unshakable — Privacy Policy

# Unshakable — Privacy Policy

Last updated: August 11, 2026

Unshakable, Inc. ("Unshakable," "we," "us") respects the sensitive nature of any personal information you provide to us. We have created this Privacy Policy in order to demonstrate our commitment to the privacy of those who use our mobile application and a number of related services (our "Services"). This Privacy Policy describes our information collection, storage and disclosure practices and the choices you have regarding how your personal information is collected and used by us and our service providers. By accessing and using our Services, you consent to the collection, use and disclosure of information through our Services as described in this Privacy Policy.

Please read this carefully. Unshakable is an emotional wellness application. The information you choose to share with it — daily check-ins, journal and workbook entries, and conversations with our AI coaching feature ("Coach CHELSKO") — can be deeply personal. This Policy explains exactly what happens to it.

Residents of the European Economic Area ("EEA"), which includes the member states of the European Union ("EU"), should consult the sections of this policy relating to "EEA Residents" and "International Data Transfers" for provisions that may apply to them.

California residents should consult the section titled "Your California Privacy Rights" for rights that apply to them.

We reserve the right to change this Privacy Policy at any time. In the event we make changes to this Privacy Policy, such policy will be re-posted in the "Privacy" section of our application with the date such modifications were made indicated at the top of the page, or we may contact you to inform you about the revisions with a link to the revised Privacy Policy. All changes are effective on the date listed at the top of this page and will apply to all information that we have about you. Your continued use of our Services after any change is posted indicates your acceptance of the changes and your continued consent to our processing of your Personal Information. If at any point you do not agree to any portion of the Privacy Policy then in effect you should immediately stop using our Services. Because this Privacy Policy contains legal obligations, we encourage you to review it carefully. If you have any questions concerning this Privacy Policy or our information collection, storage and disclosure practices, please contact us at [email protected] or mail us at Unshakable, Inc., 31212 Bailard Rd, Malibu, CA 90265.

## Personal Information That We Collect and How We Use It

Unshakable collects Personal Information about you when you use our Services. "Personal Information" is information that may be used to directly or indirectly identify you, including your name, e-mail address, or other information about you. The majority of such Personal Information is collected when you register to use our application, use our Services, subscribe, request information or updates, or otherwise provide us with your contact information.

In general, the type of Personal Information we collect includes, but is not limited to:

Account information. Your e-mail address and, if you provide it, your first name or display name. If you sign in with Apple or Google, we receive the identifying information those services provide, such as your name and e-mail address (including a private relay address if you choose to hide your e-mail from us).

Content you create ("Wellness Content"). Your daily check-ins and mood selections, journal and workbook entries, gratitude and challenge responses, session plays and playback progress, scripture reads, and the messages you exchange with Coach CHELSKO. This is the most sensitive category of information we hold, and we treat it accordingly.

Progress and gamification data. Experience points, levels, streaks, program and workbook completion, and the dates on which you completed activities. To count a "day" correctly for you, we store your device's time zone in your profile.

Subscription status. Whether you hold an active subscription, which tier, and its renewal status, as provided to us by our subscription and payment processors. We do not receive or store your full payment card number.

Device and usage data. Basic technical information used to operate the Services — such as device type and operating system version, app version, and general usage events. The current release does not collect crash reports or error traces; see "Non-Identifiable Data" below.

Communications. Any correspondence you send to us, including support requests.

We and our service providers use that data to: (i) enable you to log in and use the Services; (ii) allow you to subscribe to our Services and manage entitlements; (iii) personalize the Services, including selecting sessions, programs, and prompts relevant to you and generating coach responses relevant to what you share; (iv) maintain your progress, streaks, and history; (v) guard against potential fraud and abuse and enforce usage quotas; (vi) contact you if there is a problem with your account; (vii) provide answers to your inquiries or questions; and (viii) maintain regular communication with you as may be necessary to inform you of updates and other information regarding Unshakable and our Services.

## Sensitive Information and Health Data

The Wellness Content you provide may reveal information about your emotional or mental state. We want to be direct about how we treat it:

- We do not sell it. We do not rent it. We do not trade it. Not to advertisers, not to data brokers, not to anyone.

- We do not use it for advertising or ad targeting, and we do not permit our service providers to do so.

- We do not publish it. Unshakable is not a social or public-posting platform; your Wellness Content is visible to you, and is not shared with other users.

- We limit internal access. Access to systems containing Wellness Content is restricted to personnel who need it to operate, secure, or support the Services.

- Unshakable is not a covered entity or business associate under HIPAA, and the Services are not a medical record. Your Wellness Content is not protected health information under that law.

You may optionally tell us how central faith is to your recovery, so that we can decide whether to include scripture-based content in what we show you. This is a single, optional preference you can change or leave unset at any time in your profile, and it is used only to personalize content within the Services. Apart from that preference, we will never ask you to submit Personal Information related to racial or ethnic origin, political opinions, religious beliefs, biometric or genetic information, or precise health diagnoses, and we ask you to use caution when submitting information through the Services.

## Artificial Intelligence Processing

When you send a message to Coach CHELSKO, the following are transmitted to our third-party AI provider, which generates a response and returns it to us: that message; recent conversation context; relevant excerpts of our own coaching library; and your recent check-in entries — including the mood, emotions, intensity, worry, gratitude, and written reflections you have logged. Check-in content is included so that the coach can respond to how you have actually been feeling rather than to the message alone. This processing is necessary to provide the feature.

- Our AI provider processes this content on our behalf, as our service provider, under a contract that restricts its use of the content to providing the service to us.

- Your conversations are not used to train third-party foundation models under our current provider arrangements.

- Requests to the AI provider are made by our servers, not by your device, and our provider credentials are never exposed to the application.

- We may retain a copy of your chat history in your account so that you can see your conversation and so that context carries between sessions. You can delete this history by deleting your account.

- We may review a limited amount of AI interaction data for safety, abuse prevention, and quality purposes.

Automated safety systems may flag content that suggests risk of harm. These systems do not constitute monitoring by a clinician, and the Services are not monitored in real time. If you are in crisis, call or text 988 (the 988 Suicide and Crisis Lifeline) or your local emergency services.

## Social Networks and Third-Party Sign-In

If you choose to connect to us through a third-party service such as Apple or Google, we may collect Personal Information from your profile on such service, such as your name, user name, and e-mail address, as permitted by that service and your settings within it. You should check the privacy policy of each such service before using these features.

## Non-Identifiable Data and Aggregated Personal Information

Unshakable and third parties performing services for us may collect technical data related to your use of the Services, such as device type and operating system, app version, application logs, and the dates and times that you use the Services. The current release of the application does not collect device identifiers or advertising identifiers, and crash and error reporting is not enabled. If we enable crash and error reporting in a future release, we will update this Policy and our App Store privacy disclosures before doing so. On any web pages we operate, cookies may be used to keep track of your session and preferences; you can set your web browser to inform you when cookies are set, or to prevent cookies from being set altogether, though if you decline to use cookies you may experience reduced functionality.

Our service providers for this purpose currently include Supabase (hosting, authentication, and database), RevenueCat (subscription entitlement management), and the Apple App Store and Google Play (distribution and in-app purchases). We do not use analytics, third-party advertising networks, or ad-tracking SDKs in the application.

Diagnostic data and similar information may be aggregated or anonymized for administrative purposes. Unshakable may, for example, use aggregated information to improve the usability of the Services and to evaluate which features are useful to our users.

## How and When Your Information Is Shared With Other Parties

Unshakable does not sell, trade or license Personal Information about its users for marketing purposes. We do, however, work with a number of trusted partners who perform vital functions as part of our operations, including hosting our database, processing payments for subscriptions, and generating AI coach responses. We do not share your Personal Information unless it is necessary to fulfill our responsibilities.

The categories of service providers we currently use are:

| Provider | Function | What it receives |

|---|---|---|

| Supabase | Hosting, authentication, database | Account information, Wellness Content, progress data |

| OpenAI | AI coach responses | Your chat messages, your recent check-in entries (including mood, emotions, and written reflections), and relevant context |

| RevenueCat | Subscription entitlements and webhooks | Account identifier, subscription status |

| Apple App Store / Google Play | App distribution and in-app purchases | Purchase and billing data (they process your payment method) |

| Stripe (via web checkout, where offered) | Web billing | Payment and billing data you submit at checkout |

| Apple / Google | Sign-in | Authentication identifiers |

Personal Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services. Our partners are contractually required to keep your Personal Information private and secure and to use it only for the purposes we specify.

Additional Sharing of Information. We may share your Personal Information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your Personal Information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your Personal Information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Services, or to protect the rights, property or personal safety of Unshakable, its users, or others.

Business Transfers. If Unshakable is involved in a merger, acquisition, financing, reorganization, or sale of assets, your Personal Information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your Personal Information, and any acquirer will remain bound by the commitments in this Policy unless and until you are given notice of, and consent to, a different policy.

We will not share your Personal Information if such sharing is prohibited by applicable privacy and data protection law, including the EEA's General Data Protection Regulation.

## EEA Residents

This section of the Privacy Policy is applicable to residents of the European Economic Area ("EEA"). The EEA consists of the member states of the European Union — Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden — as well as Iceland, Liechtenstein, and Norway. This section also applies to residents of Switzerland and of the United Kingdom (which falls under the jurisdiction of the UK General Data Protection Regulation ("UK GDPR"), under which Unshakable remains compliant). Residents of the EEA, the UK and Switzerland are referred to here as "EEA Residents."

All processing of Personal Information of EEA Residents is performed by Unshakable in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 ("GDPR").

Under the GDPR and UK GDPR, Unshakable is the controller of the Personal Information of EEA Residents, and our service providers act as processors. The legal bases on which we rely are:

- Performance of a contract — to create and maintain your account, deliver the Services you have requested, and manage your subscription.

- Your explicit consent — for the processing of Wellness Content, which may reveal information concerning your mental health. You may withdraw this consent at any time by deleting the applicable content or your account; withdrawal does not affect the lawfulness of processing carried out before withdrawal.

- Legitimate interests — to secure the Services, prevent fraud and abuse, diagnose errors, and improve the Services, provided those interests are not overridden by your rights.

- Legal obligation — where we are required to retain or disclose information by law.

Rights of EEA Residents. Subject to the conditions set out in the GDPR and UK GDPR, you have the right to request access to your Personal Information; to request rectification of inaccurate information; to request erasure ("the right to be forgotten"); to request restriction of processing; to object to processing carried out on the basis of legitimate interests; to data portability; and to withdraw consent. You also have the right to lodge a complaint with your local supervisory authority. To exercise these rights, contact us at [email protected] with the subject line "GDPR Data." We will respond within one month, subject to any extension permitted by law.

We do not carry out automated decision-making that produces legal or similarly significant effects concerning you. The AI coaching feature generates conversational text only; it does not make decisions about your access to the Services, your subscription, or any other legal or significant matter.

## International Data Transfers

If you are resident outside the United States, including in the EEA, we transfer Personal Information provided by you for processing in the United States. By providing Personal Information to Unshakable for the purpose of obtaining Services, you consent to the processing of such data in the United States. The transfer of your Personal Information to the United States is necessary for the performance of a contract between you and Unshakable for obtaining Services. Where required, such transfers are made under the European Commission's Standard Contractual Clauses or another lawful transfer mechanism.

Please note that the United States does not have data protection laws equivalent to those in the EEA and other jurisdictions.

## Communications Regarding Our Services

Marketing communications. We may send you e-mail notifications from time to time with offers, suggestions and other information. You may "opt out" from receiving such communications by following the "Unsubscribe" instructions provided in the e-mail.

Push notifications. The application may send push notifications, such as check-in and streak reminders. You may disable push notifications at any time in your device settings.

Legal or security communications. We also send notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection; in other cases, these notifications involve changes to various legal agreements, such as this Privacy Policy or the Terms of Use. Generally, you may not opt out of such e-mails, and the sending of such updates does not negate your obligation to inform yourself of the most recently updated terms and conditions we apply to our users.

Account and subscription communications. If you subscribe to our Services, we may send you communications regarding such Services, including customer support and responses to questions regarding the operation of the Services. Generally, you may not opt out of such e-mails.

## Accessing Your Personal Information

Registered users of our Services can view and update their profile information within the application, and can review the check-ins, journal entries, workbook entries, and chat history stored in their account.

## Deleting Your Information

You can delete your account at any time from the Account screen in the application. Deleting your account permanently erases your profile, your Wellness Content, your progress data, and your chat history from our live systems, and it cannot be undone. You may also contact us at [email protected] with a deletion request.

Some information may remain in encrypted archived or backup copies for a limited period for our records or as otherwise required by law; those copies are overwritten on a rolling basis and are not used to restore deleted accounts. Aggregated or de-identified data that can no longer be associated with you may be retained.

Deleting your account does not cancel a subscription purchased through the Apple App Store or Google Play. You must cancel the subscription separately through your app store account settings to avoid further charges.

## Personal Information Retention

We retain the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Accounts that remain inactive for one hundred eighty (180) days may be terminated in accordance with the Terms of Use.

## Links to Other Sites

If you follow any links that direct you away from our Services, including links to social media sites or to sites for payment options, this Privacy Policy will not apply to your activity on the other sites you visit. We do not control the privacy policies or the privacy practices of any third parties, nor do they ours.

## Privacy in Submitted Materials and User Content

If you submit any content to us you must abide by the Terms of Use for conditions relating to such materials. We ask you to use caution when submitting information through the Services, and to avoid including the private information of other people — such as their full name, phone number, or address — in the content you create.

## Security Policy

We take commercially reasonable steps to protect our users' Personal Information against unauthorized disclosure or loss. These measures include encryption of data in transit and at rest, row-level access controls that restrict each account's data to that account, server-side enforcement of subscription entitlements and quotas, and the deliberate design choice of never exposing our AI provider credentials to the mobile application.

However, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us. You engage in such transmissions at your risk. You are responsible for maintaining the confidentiality of your account credentials and for restricting access to your device.

If you believe your Personal Information is being improperly used, or that your account has been compromised, please immediately notify us at [email protected].

## Children's Privacy

The Services are restricted to individuals who are at least eighteen (18) years old and of legal age to form a binding contract in their place of residence. No portion of the Services is directed to children. Consequently, we do not knowingly collect personal identifying information from any person we know is under 18, and we do not knowingly collect information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete that information as quickly as possible. If you are a parent or guardian and you believe your child has provided us with Personal Information, please contact us at [email protected].

## Your California Privacy Rights

The following section pertains to the rights of individuals or households in California ("California consumers").

Civil Code Section 1798.83. Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer's Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes.

Rights under the CCPA/CPRA. The California Consumer Privacy Act, as amended (California Civil Code Section 1798.100 et seq.), provides California consumers with rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The categories of Personal Information we collect are described above but differ for individual consumers depending on the Services used.

Under the CCPA, qualifying California consumers may have the following rights:

Right to Know and Right to Delete. A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell, and the right to submit requests to delete Personal Information. When we receive a request to know or delete from a California consumer, we will confirm receipt of the request within 10 days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.

Right to Correct. A California consumer has the right to request that we correct inaccurate Personal Information that we maintain about them.

Right to Limit Use of Sensitive Personal Information. To the extent the Wellness Content you provide constitutes sensitive personal information, we use it only to provide the Services you have requested and for the purposes permitted under the CCPA — never to infer characteristics about you for advertising.

**No Sale or Sharing.** We do not sell Personal Information, and we do not share it for cross-context behavioral advertising, as those terms are defined under the CCPA. We have not done so in the preceding twelve months.

Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.

Right for Disclosure of Information. A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect. Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, the consumer's account with us, or the security of our systems or networks. We also will not disclose California consumers' social security numbers, driver's license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.

Submitting Requests. If you are a California consumer and would like to make any requests under the CCPA, please direct them as follows:

> Unshakable, Inc., Attention: Privacy Compliance

> 31212 Bailard Rd

> Malibu, CA 90265

> [email protected]

Verifying Requests. If we receive any request we will use a two-step process for online requests where the California consumer must first clearly submit the request and then separately confirm the request. We will use other appropriate measures to verify requests received by mail. In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name and the e-mail address on record with us, so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver's license numbers, account numbers, credit or debit card numbers, or medical information with requests. If requests are unclear or submitted through means other than outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.

California Do Not Track Disclosures. Although some browsers currently offer a "do not track" ("DNT") option, no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers' DNT signals.

## Your Rights and Obligations

We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at [email protected]. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.

If you use the Services, you are responsible for maintaining the confidentiality of your account and for restricting access to your device, and you agree to accept responsibility for all activities that occur under your account.

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Contact: [email protected] · Unshakable, Inc., 31212 Bailard Rd, Malibu, CA 90265