Privacy Policy

1. Introduction

Eldhamshire LLC ("Eldhamshire," "Company," "we," "us," or "our") respects your privacy and is committed to protecting personal information. This Privacy Policy explains how we collect, use, disclose, retain, protect, and otherwise process information when you use RealU.

This Privacy Policy applies to the RealU website, mobile applications, software, AI-powered features, digital services, user accounts, communications, related products, and other services that link to this Privacy Policy.

By using RealU, you acknowledge that you have reviewed this Privacy Policy. Where applicable law requires consent, we will request consent before collecting, using, sharing, or otherwise processing information in a manner that requires consent.

2. About Eldhamshire LLC

Eldhamshire LLC is a software and technology company based in Frisco, Texas, United States. Eldhamshire develops digital platforms, software applications, artificial intelligence solutions, and technology products. RealU is operated by Eldhamshire LLC.

Contact: contact@eldhamshire.com. Website: https://www.eldhamshire.com/.

3. Summary of Important Privacy Points

• RealU may process sensitive wellness, habit, mental-wellness, emotional-state, substance-use, compulsive-behavior, relapse-risk, and recovery-related information if you choose to provide it.
• RealU uses AI features. Your prompts, conversations, check-ins, journal entries, goals, preferences, and usage signals may be processed by AI systems or AI service providers to provide the service.
• RealU is not an emergency service, healthcare provider, telehealth provider, therapist, rehabilitation facility, or medical device. Emergency and professional-care disclaimers are in the Terms and in the app where appropriate.
• We do not sell personal information for money. We do not use sensitive wellness or health-related information for third-party advertising or cross-context behavioral advertising unless this Privacy Policy is updated and legally valid consent is obtained where required.
• If RealU offers account creation, you may request account deletion through the app, a web resource if provided, or by contacting us, subject to legal retention exceptions.
• App-store privacy labels, Google Play Data safety disclosures, Health app declarations, permission prompts, and in-app disclosures must match this Privacy Policy and the app's actual data practices.

4. Information We Collect

The information we collect depends on how you use RealU, the features you enable, your device settings, app-store settings, and permissions you grant.

4.1 Information You Provide Directly

4.2 Information Collected Automatically

4.3 Information from App Stores, Service Providers, and Third Parties

We may receive information from app stores, payment processors, authentication providers, analytics providers, cloud vendors, AI service providers, customer-support tools, security vendors, and similar service providers. This may include purchase status, subscription status, device/app metadata, fraud signals, account identifiers, and support details.

If you choose to connect RealU to third-party services, wearable devices, Apple Health, HealthKit, Google Health Connect, calendars, contacts, or other integrations, we may collect information you authorize from those services. We will only enable such integrations if disclosed in the app and where required by platform rules and law.

5. Sensitive Information and Health-Related Information

RealU may involve Sensitive Information because users may submit information about mental wellness, emotional state, substance use, addictive or compulsive behaviors, relapse risk, habit patterns, goals, journaling, family matters, or other personal struggles.

Where required by law, we will ask for consent before processing Sensitive Information. You should not submit Sensitive Information unless you are comfortable with the processing described in this Privacy Policy.

We do not use Sensitive Information from RealU for third-party advertising, targeted advertising, or cross-context behavioral advertising unless this Privacy Policy is updated, required notices are provided, and legally valid consent is obtained where required. We do not sell Sensitive Information.

RealU is not intended to collect clinical records from healthcare providers, protected health information on behalf of HIPAA covered entities or business associates, or medical records unless Eldhamshire LLC enters a separate written agreement and implements legally required safeguards.

6. How We Use Information

7. AI Data Processing

RealU may use AI Features to process User Content, prompts, conversations, goals, check-ins, preferences, usage information, and other information to provide AI-assisted functionality. AI-related processing may occur through Eldhamshire systems and carefully selected third-party AI service providers.

AI service providers may process information on our behalf to provide, secure, monitor, and improve the Platform, subject to contractual restrictions where applicable. We do not authorize third-party AI providers to use identifiable Sensitive Information submitted in RealU to train their general public foundation models unless we disclose that practice and obtain legally required consent.

We may use de-identified, aggregated, redacted, or pseudonymized information to improve RealU, evaluate safety, debug systems, detect abuse, measure performance, and improve AI quality. We will use reasonable measures designed to prevent re-identification where information is treated as de-identified.

AI outputs are not reviewed by humans in every case. We may review limited content manually or through automated systems for support, safety, abuse prevention, legal compliance, or quality assurance, consistent with this Privacy Policy and applicable law.

8. Cookies, SDKs, Analytics, and Tracking Technologies

RealU may use cookies, local storage, mobile SDKs, pixels, analytics tools, crash reporting tools, and similar technologies for authentication, security, remembering preferences, improving functionality, measuring usage, diagnostics, fraud prevention, and platform performance.

We do not use Sensitive Information for third-party advertising or cross-context behavioral advertising unless this Privacy Policy is updated and legally valid consent is obtained where required. If we later introduce advertising or targeted advertising, we will update this Privacy Policy, app-store privacy disclosures, and consent controls before doing so.

You may be able to manage cookies through browser settings, device settings, operating-system privacy controls, app permissions, app settings, or legally recognized opt-out preference signals such as Global Privacy Control where applicable. Some features may not work properly if certain cookies or technologies are disabled.

9. How We Disclose Information

We may disclose information in the following situations:

We require service providers to process personal information only as reasonably necessary to provide services to us, maintain security, comply with law, and protect information consistent with this Privacy Policy and applicable requirements.

10. Platform-Specific Privacy Requirements

10.1 Apple App Store and iOS

For Apple App Store distribution, RealU should provide a privacy policy link in App Store Connect metadata and inside the app in an easily accessible location. If RealU collects user or usage data, requests protected device permissions, shares personal data with third parties, or shares personal data with third-party AI providers, those practices must be disclosed and consented to as required by Apple rules and applicable law.

If RealU uses Apple HealthKit, Clinical Health Records API, Motion and Fitness, or other Apple health-related frameworks, we will provide required disclosures and permission prompts and will not use data obtained through those frameworks for advertising, marketing, or other use-based data mining prohibited by Apple rules.

10.2 Google Play and Android

For Google Play distribution, RealU should complete the Data safety form accurately, including data collection, data sharing, security practices, account deletion, and third-party SDK behavior. If RealU allows account creation, RealU should provide an in-app path to request account deletion and a web resource where users can request account and associated data deletion where required.

If RealU offers health-related features or information, accesses health data, or processes personal or sensitive user data within Google Play's health policy scope, Eldhamshire LLC should complete the Health apps declaration and maintain an active, publicly accessible, non-geofenced, non-editable privacy policy URL. The in-app disclosures, permission prompts, and privacy policy should comprehensively describe access, collection, use, and sharing of personal and sensitive user data.

10.3 Other App Stores and Platforms

If RealU is distributed through Microsoft Store, Amazon Appstore, Samsung Galaxy Store, web app platforms, enterprise distribution, or other channels, we will endeavor to maintain disclosures consistent with those platform rules, including privacy notices, account deletion, purchase disclosures, age ratings, health-related disclosures, and permission explanations where required.

11. Health App, Wellness App, and Breach Notification Considerations

Because RealU may involve wellness and health-related user information, Eldhamshire LLC may be subject to laws and regulations that apply to health apps and vendors of personal health records depending on the features enabled and data integrations used.

If RealU experiences a security incident involving unsecured, individually identifiable health-related information and a breach notification law applies, we will evaluate and respond in accordance with applicable law, which may include notices to affected individuals, regulators, service providers, media, or other required parties.

This Privacy Policy does not mean RealU is a HIPAA covered entity or business associate. HIPAA may apply only if Eldhamshire LLC enters a legally appropriate relationship with a covered entity or business associate and signs required agreements. Otherwise, RealU is intended as a consumer wellness and self-management platform, not a HIPAA medical-record system.

12. Data Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information. These may include access controls, authentication, encryption in transit where appropriate, monitoring, logging, vendor review, least-privilege practices, security procedures, and incident response processes.

No internet, mobile, cloud, AI, or software system is completely secure. We cannot guarantee that unauthorized access, cyberattacks, data loss, outages, or security failures will never occur.

You are responsible for maintaining account security, using strong passwords, protecting your devices, logging out of shared devices, and promptly notifying us if you believe your account is compromised.

13. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing RealU, maintaining accounts, operating AI features, complying with legal obligations, resolving disputes, enforcing agreements, maintaining security, preventing fraud, supporting audits, and legitimate business purposes.

When information is no longer needed, we may delete, anonymize, aggregate, or de-identify it. Backup copies may persist for a limited period before being overwritten or deleted according to backup cycles.

14. Account Deletion and Data Deletion

If RealU supports account creation, you may request deletion of your account and associated personal information through the app if available, through a web resource if provided, or by contacting us at the email below. We will process deletion requests according to applicable law and platform requirements.

Deleting the app from your device does not by itself delete your account or cancel subscriptions. Account deletion may not automatically delete information we must keep for legal, security, fraud-prevention, accounting, compliance, backup, dispute-resolution, or legitimate business purposes.

If your subscription is managed by Apple, Google, or another app store, you may need to cancel the subscription through that app store or payment provider separately.

15. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights, subject to legal exceptions:

• Right to know whether we process your personal information.
• Right to access personal information and receive a portable copy where required.
• Right to correct inaccurate personal information.
• Right to delete personal information provided by or obtained about you.
• Right to opt out of sale of personal information, sharing for cross-context behavioral advertising, targeted advertising, or certain profiling where applicable.
• Right to withdraw consent where processing is based on consent.
• Right to limit certain uses or disclosures of Sensitive Information where applicable.
• Right to appeal a privacy-rights decision where applicable.
• Right not to be discriminated against for exercising privacy rights.

To submit a privacy request, contact us at contact@eldhamshire.com. We may need to verify your identity before responding. Authorized agents may submit requests where permitted by law and subject to verification.

16. U.S. State Privacy Disclosures

Residents of states with consumer privacy laws, including California, Texas, Virginia, Colorado, Connecticut, Utah, Oregon, Delaware, Iowa, Montana, New Jersey, Tennessee, and other states as they become effective, may have additional rights regarding personal information. We will honor applicable rights to the extent required by law.

We do not sell personal information for monetary compensation. We do not sell Sensitive Information. We do not knowingly sell or share personal information of children under 16.

If we engage in targeted advertising, cross-context behavioral advertising, sale, sharing, or profiling that requires opt-out rights, we will provide appropriate opt-out controls and update this Privacy Policy and platform disclosures before or at the time required.

17. California Notice at Collection

For California residents, the categories of personal information we may collect, the purposes of collection, and the categories of recipients are described throughout this Privacy Policy. We retain personal information according to the retention section above. We do not sell personal information for money and do not use Sensitive Information for purposes requiring a right to limit unless disclosed and permitted by law.

California residents may request access, correction, deletion, portability, information about categories of data and recipients, and opt-out rights where applicable. Submit requests using the contact information in this Privacy Policy.

18. Texas Privacy Notice

For Texas residents, we provide rights to access, correct, delete, obtain a copy of, and opt out of certain processing of personal data where required by the Texas Data Privacy and Security Act. We will not sell Sensitive Information without consent where the law requires consent. Submit Texas privacy requests using the contact information in this Privacy Policy.

If a Texas privacy request is denied and applicable law provides an appeal right, you may appeal by responding to our decision notice or contacting us with "Privacy Appeal" in the subject line.

19. International Users; EEA, UK, and Swiss Rights

RealU is operated from the United States. If you access RealU from outside the United States, your information may be processed in the United States and other countries that may have different data protection laws than your location.

Where GDPR, UK GDPR, Swiss data protection law, or similar laws apply, our legal bases may include performance of a contract, consent, legitimate interests, legal obligations, vital interests, and protection of rights. You may have rights to access, correction, deletion, restriction, objection, portability, withdrawal of consent, and complaint to a supervisory authority.

Where required for international transfers, we will use lawful transfer mechanisms such as standard contractual clauses, adequacy decisions, or other legally recognized safeguards.

20. Children and Minors

RealU is not directed to children under 13 and is generally intended for users 18 and older unless Eldhamshire LLC launches a separate minor-use experience with legally required parental or guardian consent and safeguards.

We do not knowingly collect personal information from children under 13 without legally valid consent. If we learn that we have collected personal information from a child under 13 without legally valid consent, we will take reasonable steps to delete the information or otherwise comply with applicable law.

Parents or guardians who believe a child has provided personal information to RealU may contact us at the email below.

21. Community Features and Public Sharing

If RealU offers community posts, peer support, anonymous support, comments, messages, public profiles, groups, or similar features, information you share may be visible to other users or recipients based on feature settings. Do not share information publicly that you want to keep private.

We may moderate community features, remove content, restrict users, investigate reports, and preserve or disclose content where reasonably necessary for safety, legal compliance, abuse prevention, or enforcement of the Terms. Community features should not be used for emergency support or professional advice.

22. Device Permissions

RealU may request device permissions such as notifications, camera, photos, microphone, contacts, motion/fitness, health data, location, or similar permissions only if a feature requires them. You can usually manage permissions through device settings. Some features may not work if permissions are denied.

We will endeavor to explain why permissions are requested before or at the time of collection where platform rules or law require prominent disclosure and consent. We should not require unnecessary permissions to access unrelated functionality.

23. Third-Party Links and Services

RealU may link to or integrate with third-party websites, services, app stores, APIs, payment providers, AI providers, analytics tools, cloud services, or support tools. Their privacy practices are governed by their own policies. We are not responsible for third-party privacy practices except where applicable law provides otherwise.

24. Do Not Track and Opt-Out Preference Signals

Some browsers and devices offer "Do Not Track" or opt-out preference signals. Because there is not one universal standard for every signal, our response may vary depending on applicable law, technical feasibility, and the signal used. Where required by law, we will honor legally recognized opt-out preference signals such as Global Privacy Control for applicable processing.

25. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates may occur due to legal requirements, platform requirements, product changes, AI vendor changes, data-practice changes, security improvements, or business changes.

For material changes, we may provide notice by email, in-app notice, website posting, app-store update, or other reasonable method. Where required by law, we will obtain consent before applying material changes to certain processing activities.

26. Contact Information

For privacy questions, requests, appeals, or concerns, contact: