Legal
Privacy Policy
Last updated: 21 September 2026
This Privacy Policy explains how Circle of Nine Ltd collects, uses, stores and shares personal data when you use MANWRD. It applies to the MANWRD app, manwrd.com and related support communications.
1. Data controller and contact
Circle of Nine Ltd is the controller of personal data processed for MANWRD. Our company number is 14648127 and our registered office is 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. For privacy questions or requests, email hello@manwrd.com.
2. Personal data we collect
| Category | Examples | Why we use it |
|---|---|---|
| Account and profile data | Email address, password hash, display name if supplied, Apple sign-in identifier, language, timezone and account settings | Create and secure your account, authenticate you and personalise the Service |
| Conversation and coaching data | Chat messages, Mentor responses, session titles and summaries, reflections, commitments, tasks and check-ins | Provide the coaching conversation and Service features |
| Memory data | Facts or commitments derived from your conversations, including any memory sensitivity setting | Personalise future Mentor responses when memory is enabled |
| Subscription data | Subscription status, entitlement and purchase receipt information | Confirm and manage your paid access |
| Device and notification data | Push token, platform and last-seen data | Send notifications you choose to receive |
| Service reliability data | Limited events about failed responses, safety rules and service errors | Keep the Service secure, reliable and safe |
| Website technical data | IP address and browser requests handled by hosting providers. Anton and Inter (website typefaces) are self-hosted; your browser does not request them from Google or any other external service. | Deliver and secure the website |
3. Sensitive information
You may choose to discuss sensitive matters in the chat, including information about health, mental health, sexuality, religious or philosophical beliefs, relationships, substance use or other highly personal subjects. Please do not share sensitive personal data unless you are comfortable with it being processed to provide the chat response.
If you provide sensitive personal data, it may be stored in your conversation history and transmitted to Anthropic as part of the conversation context. Our app will present a specific AI Processing Notice before chat use. Where consent is required by applicable law for sensitive-data processing, we will request it expressly and record it. You can withdraw consent at any time, but this may mean you cannot continue to use chat features that require the processing.
4. How we use personal data and our legal bases
- To create your account, authenticate you, provide chat, memory, coaching, subscription and support features: performance of our contract with you.
- To keep MANWRD secure, prevent abuse, maintain records, improve reliability and protect our rights: our legitimate interests, balanced against your rights and interests.
- To send optional push notifications or process sensitive memory where we ask for a choice: your consent. You can change notification and memory choices in Settings.
- To comply with legal obligations, enforce our Terms and respond to valid legal requests: legal obligation or our legitimate interests, as applicable.
5. Who receives personal data
We do not sell personal data, share it with data brokers or use it for cross-app advertising tracking. We use carefully selected service providers to operate MANWRD:
| Provider | Purpose | Data involved |
|---|---|---|
| Railway | Hosting, database, cache and application logs | Application data, including account, conversation and memory data |
| Anthropic | AI model inference and safety classification | Conversation text, relevant memories and contextual prompts needed to generate a response |
| Brevo | Transactional email delivery | Email address, email subject, verification or password-reset email content and delivery metadata |
| Apple | Sign in with Apple, push notifications and App Store subscriptions | Identity-token exchange, push token/notification payload and purchase or receipt information as relevant |
| Expo, only for legacy push tokens | Legacy push notification relay | Device token and notification payload for affected legacy devices |
These providers act on our instructions where they process personal data for us, except where they determine their own purposes under their own legal obligations. Their own privacy information may also apply to data they receive directly from you through their platforms, such as App Store purchases.
6. International transfers
Our production hosting is currently located in the United States, and Anthropic processes chat content through its services. This means that personal data may be transferred outside the United Kingdom and European Economic Area. Before such transfers, we put in place the safeguards required by applicable data-protection law, which may include approved contractual safeguards such as the UK International Data Transfer Addendum or EU Standard Contractual Clauses, together with supplementary measures where appropriate. You can contact us for information about the safeguard relevant to your data.
7. Memory controls
Ordinary memory is enabled by default. You can turn it off in Settings. When memory is off, MANWRD stops creating new memories and does not retrieve existing memories for new Mentor responses; existing memories remain stored until you delete them or delete your account. You can view, edit, export and delete individual memories, or delete all memories, in Settings. Sensitive memory is off by default and requires a separate affirmative choice.
8. Retention and deletion
We keep account data, conversations, memories, notification records and service data while your account remains active because the Service has no automatic deletion period. You may delete your account at any time in Settings > Account > Delete Account. Account deletion immediately removes your account and related live application data, including conversations, memories, devices and push tokens. Individual chat conversations cannot currently be deleted separately; you can delete memories separately.
Some records may remain outside our live application database for limited periods: anonymised reliability events may remain without a user identifier; email-delivery records may remain with Brevo; and provider backups or logs may retain data for their normal retention periods. Anthropic-held records are governed by Anthropic's applicable terms and retention practices. Deleting your MANWRD account does not delete records held by Apple, including purchase records, and does not cancel an App Store subscription.
9. Security
We use reasonable technical and organisational measures designed to protect personal data, including encrypted connections, password hashing, authentication controls and rate limiting. No online service can guarantee absolute security. Keep your account credentials confidential and contact us if you suspect unauthorised use.
10. Your rights
Depending on applicable law, you may have rights to request access to, correction of, deletion of, restriction of, objection to, or portability of your personal data; to withdraw consent; and to complain to a data-protection authority. You can export certain data in the app through Settings > Account > Export My Data. To make a request, contact hello@manwrd.com. We may need to verify your identity before acting on a request. We normally respond within the period required by law.
If you are in the UK, you may complain to the Information Commissioner's Office at ico.org.uk. If you are in the EEA, you may also contact your local supervisory authority.
11. Automated processing
MANWRD uses AI to generate responses and service safeguards to detect certain safety or reliability events. We do not make decisions based solely on automated processing that produce legal effects or similarly significant effects about you.
12. Children
MANWRD is not for anyone under 16. We do not knowingly collect personal data from people under 16. If you believe a child has created an account, contact hello@manwrd.com so that we can investigate and take appropriate action.
13. Changes to this Policy
We may update this Policy when the Service, our processing or applicable law changes. We will post the updated version here and, where a change is material, provide additional notice through the Service or by email.
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