Privacy Policy
Last updated: 11 August 2026 · Version gary-privacy-v1-draft-2026-08
1. Who we are
Gary is a general-wellbeing companion provided by Pleso Therapy sp. z o.o. (“Pleso”, “we”, “us”), a company registered in Poland (KRS 0000980227, REGON 522652856, NIP 5783155594), registered office at ul. 12 Lutego 25/7, 82-300 Elbląg, Poland. We are the controller of the personal data described here.
- Data Protection Officer: Marta Gajewko - iod@pleso.me
- General enquiries: hello@pleso.me
If you have any question about this policy or your data, contact our Data Protection Officer at iod@pleso.me.
2. What this policy covers
This policy explains what personal data Gary collects, why, on what legal basis, who we share it with, how long we keep it, and the rights you have. It covers the Gary web app and the accounts and features within it. It does not cover third-party services we link to. Gary is offered in Poland. We follow EU data protection law - the General Data Protection Regulation (GDPR), the Polish Personal Data Protection Act, and the Polish rules implementing the EU ePrivacy Directive for cookies and similar technologies.
Gary is a wellbeing companion, not a medical device, and not an emergency service. It does not diagnose, treat, or monitor any medical condition. If you are in crisis, use the support routes shown in the app (in Poland: Centrum Wsparcia 800 70 2222, free and 24/7, or 112 in an emergency).
3. The short version
- Gary is for adults (18+).
- You choose what to share. Your wellbeing answers are stored only if you give explicit consent, and only to give you a tailored experience.
- We store this in the UK (London) - a country the European Commission recognises as providing adequate protection. We never sell it, never use it for advertising, and never put it into analytics.
- Your daily mood and “key moments” stay on your device. Your chat is stored on your device too; each message you send is processed briefly by us and our AI provider to generate a reply, and not kept afterwards.
- You can withdraw any consent, and access or delete your data, at any time in Account settings.
- Optional AI features run on Google Vertex AI - some requests in an EU region, some on Google’s global infrastructure. We send your chat messages and a minimised summary of your profile, with no account identifier attached - never your name, email, or free-text notes.
4. The data we collect, why, and our legal basis
All health-related data below is special-category data under GDPR Article 9. We process it only with your explicit consent (Article 9(2)(a)), which also provides our Article 6(1)(a) basis. You can withdraw consent at any time (section 9).
| Data | What it is | Why | Legal basis |
|---|---|---|---|
| Account identifier | An anonymous account ID; or, if you sign in with Google, your name and email | To create and secure your account and keep your data across sessions and devices | Art. 6(1)(b) performance of a contract; Art. 6(1)(f) legitimate interest in account security |
| Age confirmation | The fact that you confirmed you are 18+ (we do not store your date of birth) | To keep Gary to its intended adult audience | Art. 6(1)(c) legal obligation / Art. 6(1)(f) legitimate interest |
| Wellbeing answers | Your structured answers - goals, mood, sleep, energy, what helps you, and similar (a “Health Profile”) | To build your personal wellbeing profile and tailor Gary to you | Art. 9(2)(a) + Art. 6(1)(a) explicit consent |
| “About you” note | Free text you optionally add to your profile | To let Gary keep in mind what you choose to tell it | Art. 9(2)(a) + Art. 6(1)(a) explicit consent |
| Podcast check-ins | Whether a short audio helped (a 1-5 self-report) | To reflect back and improve what we offer you | Art. 9(2)(a) + Art. 6(1)(a) explicit consent |
| Consent records | Which consents you gave or withdrew, when, and the wording you saw | To demonstrate and honour your consent choices | Art. 6(1)(c) legal obligation; Art. 9(2)(a) as the condition record |
| Product analytics | How you use the app (screens, taps, progress through flows) via PostHog - never your wellbeing answers | To understand what works and improve the product | Art. 6(1)(a) consent (opt-in); the Polish ePrivacy implementation for any device storage |
| AI processing | Your chat messages, plus a minimised, allow-listed summary of your profile, sent to an AI model with no account identifier attached, to generate responses (see section 6) | To provide AI-generated companion responses and audio | Art. 9(2)(a) + Art. 6(1)(a) explicit consent |
| Technical/security data | Minimal server logs needed to run and secure the service | Security, fraud/abuse prevention, service reliability | Art. 6(1)(f) legitimate interest |
Data that stays on your device. Your daily mood check-in, your “key moments” list, and a local copy of your latest quiz answers are stored only in your browser’s local storage and are not sent to our servers. Your ongoing chat with Gary is also stored only on your device; each message you send is processed transiently by us and our AI provider to generate a reply, and not retained. Clearing your browser data removes these. We cannot see or recover them.
We do not collect data from children, sell your data, use it for advertising, or use it to build profiles for any purpose other than tailoring Gary to you.
5. Age
Gary is intended for people aged 18 and over. We ask you to confirm you are 18+ before onboarding. We do not knowingly collect data from anyone under 18. If you believe someone under 18 has used Gary, contact us at iod@pleso.me.
6. How we use AI (transparency)
Some Gary features use artificial intelligence (large language models) to generate responses and short audio.
- Where it runs.AI processing runs on Google Vertex AI. Some requests are processed in an EU region; others use Google’s global multi-region infrastructure, which is not tied to one country - we use whichever gives the best model available.
- What we send. Two things: the messages you write in the chat, so the model can reply to them, and an approved, minimised summary of your profile. Requests carry no account identifier - not your Gary account ID, and not a stand-in ID either. We do not send your name, email, phone, or your free-text notes. We do not store your messages on our servers - your chat lives on your device.
- No training on your data. The AI provider does not use your data to train its models.
- Not a clinician. The AI is a supportive wellbeing companion. It does not diagnose or treat any condition, and it does not make decisions that produce legal or similarly significant effects about you. Under the EU AI Act it operates as a limited-risk system: you are always told you are interacting with AI.
- Your control.AI features are on only if you give the “Let Gary use AI” consent, and you can withdraw it at any time in Account settings, which turns AI features off for you.
7. Who we share data with (processors)
We use trusted providers who process data on our behalf, under contract, only for the purposes above. We do not sell your data or share it with advertisers.
| Provider | Role | Location |
|---|---|---|
| Google Cloud / Firebase | Sign-in, database, and hosting of your Health Profile and consent records (Authentication, Data Connect / Cloud SQL for PostgreSQL) | Database + consent records: UK (London). Sign-in: US. App hosting: EU (Netherlands). |
| PostHog | Product analytics (only if you opt in) | EU (Frankfurt), via our first-party reverse proxy; IP capture off |
| Google Vertex AI | AI-generated responses (only if you consent) | EU region, or Google’s global multi-region infrastructure |
We may disclose data if required by law, or to protect the rights, safety, or property of you, us, or others. The always-current, named register of the third-party tools used in Gary is kept in our Cookie & Third-Party Tools Policy.
8. Where your data is stored and international transfers
Your Health Profile and consent records are stored in the United Kingdom (London). The app itself is hosted in the EU (Netherlands), and your sign-in data (Firebase Authentication) is held in the United States.
The UK is covered by a European Commission adequacy decision, so storing your Health Profile there needs no additional safeguard: the law treats it as equivalent to keeping it inside the EEA.
For the transfer of sign-in data to the United States we rely on the EU Standard Contractual Clauses in Google’s Data Processing Addendum, together with a transfer impact assessment and, where Google is certified, the EU-US Data Privacy Framework. If you would rather not have sign-in data leave the EU, you can use Gary as a guest without a Google account.
9. Keeping and deleting your data; withdrawing consent
- Retention. We keep your Health Profile and account data until you delete your account or withdraw the relevant consent. Consent records are kept for the life of your account plus 3 years afterwards, to evidence your choices. Product-analytics data is retained for 14 months.
- Withdrawing consent.You can withdraw any consent at any time in Account → Privacy & consent. Withdrawing “Store my wellbeing answers” stops new answers being saved, and you can choose whether to keep or delete what is already stored. Withdrawing does not affect processing that already happened.
- Deleting your account. You can permanently delete your account and all associated data, including your Health Profile, from Account settings. This cannot be undone.
10. Your rights
Under the GDPR you have the right to: access your data; correct it; delete it; restrict or object to processing; data portability; and withdraw consent at any time. You will not be subject to a decision based solely on automated processing that has a legal or similarly significant effect on you.
To exercise these rights, use Account settings where available, or contact us at iod@pleso.me. We respond within one month.
If you are unhappy with how we handle your data, you can complain to the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, “UODO”), the Polish supervisory authority: ul. Stanisława Moniuszki 1A, 00-014 Warszawa - uodo.gov.pl - 22 531 03 00.
You can also complain to the supervisory authority in the EU country where you live or work, if that is not Poland.
11. Security
We use industry-standard measures to protect your data, including encryption in transit and at rest, access controls, and storage with reputable EU cloud providers. Health Profile components are excluded from analytics. No method is perfectly secure, but we work to protect your data and to notify you and UODO of a qualifying breach as required by law.
12. Crisis and emergencies
Gary is not an emergency or crisis service and cannot provide urgent help. If you or someone else is at risk, contact the support routes shown in the app - in Poland, Centrum Wsparcia on 800 70 2222 (free, 24/7), the Kryzysowy Telefon Zaufania on 116 123 (free, every day 2pm-10pm), or 112 in an emergency.
13. Changes to this policy
We may update this policy. If we make a material change, we will tell you in the app and, where required, ask for fresh consent. The “Last updated” date at the top shows the current version.
14. Contact
Pleso Therapy sp. z o.o., ul. 12 Lutego 25/7, 82-300 Elbląg, Poland · Data Protection Officer: iod@pleso.me · General enquiries: hello@pleso.me