Privacy Policy

Effective May 15, 2026 · Last revised: May 15, 2026

1. Who we are

MØMENTÜM is an AI psychological coaching application developed and operated by MØMENTÜM Inc. (incorporation in progress, Canada).

Privacy Officer: Alexandre Silva Pessoa
Clinical Advisor: Stéphanie Laforte, Psy.D
Contact: privacy@momentumapp.live

2. Information we collect

We collect only the information necessary to provide our services:

• Identity: first name, email address (via Clerk)
• Profile: pronouns, goals, coaching mode, chosen coach
• Coaching sessions: conversation content (AES-256-GCM encrypted)
• Private journal: personal entries (encrypted)
• Check-ins: mood score, free notes (encrypted)
• Onboarding questionnaire: responses (encrypted)
• Notifications: device token, preferred time
• Audit logs: system actions (Law 25 compliance)

3. Purpose

Your information is used exclusively to:

• Provide personalized AI psychological coaching
• Detect distress signals and redirect to appropriate resources
• Personalize the experience based on your profile and goals
• Ensure security and legal compliance
• Enable quarterly clinical review by Stéphanie Laforte, Psy.D

We never sell your data. We do not use it for advertising.

4. Legal basis

Processing is based on your explicit consent obtained at registration, in accordance with Quebec Law 25 (Act to modernize legislative provisions as regards the protection of personal information) and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

5. Security measures

• AES-256-GCM encryption for all psychological data
• Secure authentication via Clerk (SOC 2 Type II)
• Row Level Security on all database tables
• Mandatory 2FA for administrators
• Full audit logging of sensitive data access
• TLS 1.3 transport encryption (HTTPS only)
• Hosted in Canada (Supabase + Vercel)

6. Data retention

• Coaching sessions, journal, check-ins: 2 years after last activity
• Distress episodes: 5 years (mental health legal requirement)
• Audit logs: 2 years (Law 25)
• Profile: until account deletion
• Push subscriptions: until opt-out or account deletion

7. Your rights

Under Quebec Law 25, you have the following rights:

• Access: view your data via Settings → My data
• Rectification: update your profile in Settings
• Deletion: complete data erasure within 30 days via Settings → Delete my account
• Portability: JSON export on request
• Opposition: disable notifications, delete journal, close account

To exercise your rights: privacy@momentumapp.live

8. Third parties & sub-processors

We engage the following providers, each subject to strict contractual obligations:

• Anthropic (Claude) — Coaching content generation via API. No data retained by Anthropic.
• ElevenLabs — Voice synthesis. Audio data not stored.
• Deepgram — Voice transcription. Data not stored.
• Clerk — Authentication. SOC 2 Type II certified.
• Supabase — Database. Hosted in Canada.
• Vercel — App hosting. SOC 2 Type II certified.
• Resend — Transactional emails.

9. Cookies

MØMENTÜM uses only strictly necessary cookies for the operation of the service (authentication, language preferences, consent). No advertising or third-party tracking cookies are used.

10. Changes to this policy

We may update this policy at any time. Material changes will be communicated by email at least 30 days before taking effect. The current version is always available on this page.

11. Contact & complaints

For any questions about this policy or to exercise your rights: privacy@momentumapp.live

You may also file a complaint with the Commission d'accès à l'information du Québec (CAI) if you believe your rights have not been respected.