Soul is a local-first orientation app for iOS and Apple Watch. It helps you check in, notice readings from your own context, and choose a next move. Soul is not a health, medical, mental-health, diagnostic, treatment, therapy, crisis, or emergency tool.
This policy explains how Soul handles personal data.
The controller for personal data processed in connection with Soul is:
| Detail | Current details |
|---|---|
| Legal entity | Tricker Labs LTD trading as Soul |
| Company number | 17239094 |
| Registered office | 124-128 City Road, London, England, EC1V 2NX |
| soul@trickerlabs.co.uk |
This controller is responsible for personal data processed in connection with Soul, except where third-party providers act under their own terms and privacy practices, such as Apple and iCloud, OpenAI (which powers Navigator), Cloudflare (which hosts Soul's managed AI gateway and this website), and support email providers.
Core personal data is stored on your device in Soul's app storage. This may include check-ins, notes, signal readings, summaries, Navigator conversations, Apple Health-derived body context, and settings.
When iCloud sync is available and enabled, Soul syncs some of this data through your own private iCloud (CloudKit) so it survives reinstalling the app and roams across your devices. This uses your Apple Account and iCloud; it does not pass through any Soul server, and Soul cannot read it. Your check-ins, Navigator turns, and orientation data sync this way. Raw Apple Health-derived body context stays on your device only and is not synced.
Apple processes iCloud data under Apple's own terms and privacy policy. You control iCloud in iOS Settings, and you can turn Soul's iCloud sync off.
| Data category | Examples | Where it is handled |
|---|---|---|
| App content | Check-ins, notes, signal readings, generated summaries, Navigator turns, and settings | On your device, and in your own private iCloud (CloudKit) when sync is enabled; never stored on a Soul server |
| Apple Health data | Heart rate, resting heart rate, heart-rate variability, movement, sleep analysis, and workouts | Read from Apple Health only with your permission; body context stays on device (not synced) unless included in a Navigator request you send |
| Navigator request content | Your message and the context categories you have allowed in Navigator's privacy settings | Sent only when you send a Navigator request, forwarded by Soul's managed gateway to OpenAI; what is forwarded to OpenAI carries no name, account, or device identifier |
| Subscription and usage | App Store subscription status, and coded Navigator usage records (time, model, token counts, and related service data such as your fair-use tier, never your words) for fair-use limits and cost analysis | Subscription status read locally from the App Store; your Apple-signed subscription confirmation is sent to Soul's gateway with each Navigator request to check your plan and is never forwarded to OpenAI; usage records are keyed to a one-way coded value that is stored without your name or account and is never placed in AI prompts |
| Support data | Information you send when you contact support, including screenshots, exports, logs, or messages you choose to include | Processed through the support channel you use |
| Website security and hosting records | IP address, request time, user agent, requested URL, and similar server-log data for soul.trickerlabs.co.uk | Processed by the website host for security, reliability, and abuse prevention |
Soul does not sell personal data, does not use third-party advertising, does not use data brokers, does not use cross-app tracking, and does not use Apple Health data for advertising, marketing, or use-based data mining.
Apple Health access is optional. Soul asks Apple Health for read permission before accessing selected health and fitness data. Soul does not write data back to Apple Health in the current release.
Soul uses Apple Health data as personal context inside Soul, such as sleep, heart, movement, workout, and freshness readings. Soul does not use Apple Health data to diagnose, treat, cure, prevent, or monitor any condition, and it does not make health or medical decisions for you.
Body context is off by default for Navigator. If you enable it in Navigator's privacy settings, Apple Health-derived summaries may be included in the request Soul forwards to OpenAI when you send a Navigator message.
You can grant, deny, or revoke Apple Health permissions in iOS Settings or the Apple Health app. If you revoke permission, Soul stops reading newly authorised Apple Health data.
Navigator AI features are optional and user-triggered. Soul never continuously uploads your data. A Navigator request happens only when you send one.
When you send a Navigator request, Soul builds selected context from your current app data, your privacy settings, and your message. You control which context categories are included through Navigator's privacy settings, and you can review exactly what a request will include.
Navigator runs through a Soul-managed AI gateway. Soul holds the AI provider credential and forwards your message and the context you allow to OpenAI to generate the reply, then returns it to you. Tricker Labs LTD is the controller for this processing, and OpenAI processes the request as Soul's AI provider under its own terms. You do not need your own ChatGPT or OpenAI account.
The request forwarded to OpenAI carries no name, account, or device identifier. To confirm your subscription, the app includes your Apple-signed App Store subscription confirmation with each request to Soul's gateway; the gateway uses it only to check your plan and derive the coded usage value described below, and never forwards it to OpenAI. Soul sends each request to OpenAI with provider-side storage turned off and keeps no server-side copy of the content. OpenAI may retain requests for a limited period for abuse monitoring under its API terms, and under those terms API requests like these are not used to train OpenAI's models.
To keep Navigator fast and fair, Soul keeps usage records (when a request was made, which model answered, token counts, and related service data such as your fair-use tier, never the content) keyed to a one-way coded value derived from your App Store subscription. That value is never placed in the AI prompt and is stored without your name or account; it cannot be linked back to your subscription without a secret key Soul holds separately. The gateway runs on Cloudflare infrastructure, which processes standard connection records, such as IP address and request timing, to deliver and protect the service.
Soul does not use your app data, Apple Health data, prompts, or Navigator replies for advertising.
Your subscription includes generous monthly use of Navigator. If your use goes well beyond that in a month, Navigator stays available in a lighter mode rather than being cut off, and Soul may slow or limit unusually heavy or automated activity to keep the service fast and fair for everyone.
Soul does not upload product diagnostics or product analytics to Tricker Labs. If you contact support, you choose what details, screenshots, exports, logs, or messages to send.
Please do not send private notes, Navigator replies, provider credentials, screenshots, or exports unless you are comfortable sharing them. If you send support material, Tricker Labs LTD may use it privately to troubleshoot, answer your request, improve reliability, and understand product defects.
TestFlight and App Store distribution may provide Tricker Labs LTD with Apple-generated crash reports, tester feedback, and privacy-preserving App Store Connect analytics. Soul does not add its own third-party analytics SDK or remote diagnostics pipeline. Apple's own terms and privacy practices apply to Apple developer services and App Store analytics.
Soul's support and policy pages are hosted at soul.trickerlabs.co.uk. The deployed Soul policy content does not show advertising cookies or third-party behavioural analytics for the Soul support and policy pages.
The website host may process normal hosting and server logs, such as IP address, request time, requested URL, user agent, and error information, for security, reliability, debugging, and abuse prevention.
Soul uses data for these purposes:
| Data | Retention |
|---|---|
| App data on device | Stored until you delete it in Soul or uninstall the app. |
| App data synced to your iCloud | Held in your own private iCloud until you delete it in Soul (the deletion syncs) or remove it through your iCloud controls. Soul keeps no copy on a Soul server. |
| Apple Health-derived body context | Stored on device only (not synced) until cleared through Soul or the app is uninstalled. |
| Navigator request content | Forwarded to OpenAI with provider-side storage turned off; OpenAI may retain requests for a limited period for abuse monitoring under its API terms. Soul keeps no server-side copy of the request. |
| Navigator usage records | Coded records of when Navigator was used, which model answered, token counts, and related service data such as your fair-use tier, held at Soul's gateway in pseudonymised form, on infrastructure in Western Europe, for fair-use limits and cost analysis. They contain none of your words, are stored without your name or account, and are deleted automatically after 24 months. |
| Support correspondence and support material you send | Up to 2 years after the last interaction, unless a longer period is needed for legal, safety, abuse-prevention, or dispute reasons. |
| Website security and hosting records | Processed by the website host for a short period for delivery, security, reliability, debugging, abuse prevention, and aggregated hosting metrics. |
You can request deletion of personal data Soul controls by emailing soul@trickerlabs.co.uk. Because Soul is designed without a general Soul account in the current release, Tricker Labs LTD may need information from you to identify the relevant support thread or other data.
You can:
Soul is not a crisis service and does not monitor you for emergencies. The app does not contact emergency services, crisis lines, clinicians, family members, or other people on your behalf.
If you are in immediate danger, may harm yourself or someone else, or need urgent help, contact local emergency services, a crisis line, or another appropriate urgent support service in your area.
If UK GDPR or EU GDPR applies to you, you may have rights to access, correct, delete, restrict, object to, or receive a portable copy of personal data processed by Soul. You may also have the right to withdraw consent where processing is based on consent and to complain to your local data protection authority. In the UK this is the Information Commissioner's Office (ico.org.uk).
Soul's main legal bases are:
Soul is operated by Tricker Labs LTD from the United Kingdom. Third-party providers, such as Apple and iCloud, OpenAI (which powers Navigator), Cloudflare (which hosts Soul's managed AI gateway and this website), and support email providers, may process data in other countries under their own terms and privacy practices.
In particular, when you use Navigator, Soul's managed gateway forwards your request to OpenAI, which may process it outside the UK. Where personal data leaves the UK, Soul relies on safeguards recognised under UK GDPR, such as adequacy regulations or data-processing agreements incorporating standard contractual clauses and the UK addendum, together with each provider's own commitments. Navigator usage records are held on infrastructure located in Western Europe.
Soul is intended for users aged 13 or over. Users under 13 should not use the app.
Soul does not knowingly collect personal data from users under 13. If a parent or guardian believes someone under 13 has provided personal data through a channel controlled by Soul, email soul@trickerlabs.co.uk so the data can be reviewed and deleted where appropriate.
Soul uses on-device storage, your own private iCloud for sync, iOS Keychain for supported secrets, and Apple Health permission controls. Navigator requests to OpenAI travel over encrypted connections. No app or transmission method can guarantee perfect security.
You are responsible for protecting your device and Apple Account and for understanding your iCloud settings.
Soul may update this policy as the product changes. Material changes to managed AI providers, remote diagnostics, remote analytics, account systems, Apple Health handling, subscriptions, or data sharing will be reflected in an updated policy before or when those changes are introduced.