Privacy Policy

Effective Date: June 2, 2026
Last Updated: September 1, 2026

1. Scope

This Privacy Policy applies to all products, software, websites, mobile applications, APIs, and related services provided by Celibrium, LLC ("Celibrium," "we," "our," or "us") (collectively, the Services).

This Privacy Policy should be read together with our:

• Terms of Service
• Data Retention & Account Deletion Policy
• AI Processing Consent
• Voice Cloning & Biometric Consent
• Family Access Authorization
• Other feature-specific notices presented within the Services

Where a feature-specific notice applies, that notice supplements this Privacy Policy for that feature.

2. Privacy by Design

Privacy is incorporated into the architecture of Celibrium rather than added after development.

Whenever reasonably practical, we design our Services to:

• collect only the information reasonably necessary to provide the requested Services;
• separate independent Legacies rather than merge identities;
• require explicit consent for sensitive processing activities;
• minimize disclosure of personal information;
• maintain clear boundaries between Users, Legacies, Voice Models, and Digital Twins;
• implement administrative, technical, and organizational safeguards appropriate to the sensitivity of the information entrusted to us.

Our privacy practices are guided by the principles established in the Celibrium Canon.

3. The Legacy Identity Principle

Every Digital Twin represents one individual—and one individual alone.

Each Digital Twin is generated exclusively from information intentionally documented for that person's Legacy.

Celibrium does not intentionally:

• combine identities;
• merge memories from unrelated individuals;
• use one person's Legacy to create another person's Digital Twin;
• train one customer's Digital Twin using another customer's Legacy.

Every Legacy remains separate.

Every identity remains distinct.

4. Information We Collect

The information we collect depends upon how you use the Services.

Account Information

When you create an account, we may collect:

• Name
• Email address
• Encrypted authentication credentials
• Recovery Code information
• Purchase status
• Account preferences

Legacy Information

You determine what becomes part of your Legacy.

This may include:

• Stories
• Memories
• Interview responses
• Personal experiences
• Values and beliefs
• Photographs
• Videos
• Documents
• Audio recordings
• Voice recordings
• Other User Content voluntarily submitted by you

Info Hub Information

The Info Hub is an everyday personal organiser. You decide what goes into it.

This may include:

• Contact details for the people and services you rely on, such as doctors, banks, insurers, schools, employers, and tradespeople
• Reference numbers such as policy, account, membership, or licence numbers
• Addresses, dates, and appointment details
• Details of vehicles, property, pets, and household services
• Documents and images you attach to an entry
• Private notes you mark Only me

The Info Hub never holds credentials. Celibrium does not ask for, and you should not store in the Info Hub, passwords, PINs, card or CVV numbers, answers to security questions, or account recovery codes. The Info Hub is a record of where your information lives and who to contact about it. It is not a place to keep the keys to it.

Standard Info Hub entries are visible to the Trusted People you have invited and who have accepted, so that the people who may need to find something can find it. You may mark any individual entry as Only me, and an entry marked Only me is never shown to a Trusted Person. A private note is always yours alone and is never inherited by a Trusted Person, whatever the entry it belongs to. Trusted People are view only: they cannot add, change, or delete anything.

Health Information

If you use the Medications & Supplements list inside the Info Hub's Medical area, we collect and store what you enter there: the name of a medication, over-the-counter product, vitamin or supplement, and optionally its dose, when you take it, whether it is taken only as needed, what it is for, who prescribed it, when you started it, whether you are still taking it, and any private note you add.

This information is linked to your account and is used for one purpose: to show it back to you, and to the trusted people you have invited and who have accepted, on the entries you have not marked Only me. A private note is never shown to anyone but you.

We do not use this information for advertising, tracking, personalisation, or training. We do not sell or share it. It is not sent to an AI provider and is not processed by any AI feature. We do not check, verify, or review it, and Celibrium does not provide medical advice or replace your doctor or pharmacist. It is deleted when you delete your account.

Celibrium does not offer, and this list does not provide, pharmacy management, refill tracking, pill identification, interaction checking, adherence monitoring, dose advice, or medication reminders.

Looking a product up. When you scan a barcode or ask Celibrium to look up a product while adding it, the barcode or the product name you typed is sent as a search query to two public United States government directories: the U.S. Food and Drug Administration's National Drug Code directory and the National Institutes of Health Dietary Supplement Label Database. This is done so the product's name and manufacturer can be filled in for you.

Only the code or the name is sent. Your account, your name, your email address, your dose, your schedule, your reason for taking it, your prescriber and everything else on your list stay with Celibrium. These are public reference directories rather than recipients of your Personal Information, they are not told who is asking, and the answer is used only to fill in the entry you are creating. Amount and frequency are never filled in from a label. Listing in a public directory is not FDA approval.

Voice Information

If you choose to create a Voice Clone, we collect the Voice Recordings necessary to generate your Voice Model.

Voice Cloning is optional.

Separate consent is required before Voice Recordings are processed for this purpose.

AI Interaction Information

When you interact with AI-powered features, we may collect:

• Questions submitted to your Digital Twin
• AI-generated responses
• Connection usage
• Operational logs necessary to provide AI-powered functionality

Technical Information

We automatically collect limited technical information necessary to operate and secure the Services, including:

• Device information
• Browser information
• Operating system
• IP address
• Authentication records
• Diagnostic information
• Security logs

We do not intentionally collect more technical information than is reasonably necessary to provide and protect the Services.

5. How We Collect Information

We collect information:

• directly from you when you create an account or contribute to your Legacy;
• from authorized family members or Legacy Contributors where permitted by the applicable product workflow;
• automatically through your use of the Services;
• from Authorized Service Providers acting on Celibrium's behalf.

We do not purchase personal information or identity profiles from data brokers.

6. Why We Process Information

We process information only for legitimate business purposes related to providing and improving the Services.

These purposes include:

Providing the Services

To:

• create and manage your account;
• preserve your Legacy;
• display your content;
• synchronize your information across devices;
• provide customer support.

AI Processing

Where authorized, we process information using artificial intelligence to:

• organize information;
• identify themes;
• retrieve relevant content;
• generate follow-up questions;
• search your documented Legacy;
• generate Digital Twin responses;
• improve the functionality, reliability, and safety of the Services.

AI Processing is performed solely to provide the Services you request.

Celibrium does not use your Legacy, Voice Recordings, Digital Twin, or other User Content to train shared AI models for other customers.

Voice Cloning

If you provide separate consent, Voice Recordings may be processed to create your Voice Model and enable Voice Cloning functionality.

Voice Cloning is entirely optional.

You may continue using Digital Twin features without creating a Voice Clone.

Security

We process information to:

• authenticate users;
• detect fraud;
• investigate suspected abuse;
• maintain system integrity;
• protect Users and the Services.

Billing

Where applicable, we process information necessary to:

• process payments;
• manage purchases;
• administer Connections and Companion Plans;
• maintain required financial records.

Payment card information is processed by our authorized payment processor and is not stored by Celibrium.

Legal Compliance

We may process information where necessary to:

• comply with applicable law;
• respond to lawful governmental requests;
• enforce our legal rights;
• protect the safety of our Users.

7. Legal Bases for Processing

For users located in jurisdictions requiring a legal basis for processing personal information, including the European Economic Area (EEA), United Kingdom, and similar jurisdictions, Celibrium processes information under one or more of the following legal bases:

Performance of a Contract

Processing necessary to provide the Services you request.

Consent

Processing that requires your affirmative permission, including Voice Cloning and other sensitive processing activities.

You may withdraw consent at any time where permitted by law.

Legitimate Interests

Processing necessary to:

• secure the Services;
• prevent fraud;
• improve reliability;
• diagnose technical issues;
• protect Users.

We balance these interests against your rights and freedoms.

Legal Obligations

Processing necessary to comply with applicable laws, regulations, court orders, and lawful governmental requests.

8. AI Processing

Artificial intelligence is fundamental to certain Celibrium Services.

AI Processing may assist in:

• organizing your Legacy;
• searching documented information;
• retrieving relevant memories;
• identifying themes;
• generating Digital Twin responses;
• improving accessibility and user experience.

AI Processing is performed only for authorized purposes consistent with this Privacy Policy and applicable user consent.

Where AI Processing is performed by an Authorized Service Provider acting on Celibrium's behalf, that provider is authorized to process only the information reasonably necessary to perform the requested function.

Celibrium does not use your Legacy, Voice Recordings, Digital Twin, or User Content to train AI models for other customers or unrelated third parties.

9. Digital Twins

A Digital Twin is an AI-generated representation created from the information intentionally documented for a specific individual's Legacy.

A Digital Twin:

• is not the individual it represents;
• possesses no consciousness, independent intent, legal authority, agency, or memory beyond the information intentionally documented for it;
• does not continue the existence or consciousness of any individual;
• is designed to generate responses only from the documented Legacy and authorized AI Processing.

Digital Twin responses are generated for informational and personal use. They should not be interpreted as authentic statements made by the represented individual and should not be relied upon as legal, medical, financial, or professional advice.

Celibrium designs its Digital Twins to acknowledge uncertainty when sufficient documented information is unavailable rather than intentionally generate unsupported information.

10. Voice Cloning & Biometric Information

Voice Cloning is an optional feature.

A Voice Model is created only after you provide separate, explicit consent through the Voice Cloning & Biometric Consent.

Where applicable law recognizes voiceprints or similar characteristics as biometric identifiers, Voice Recordings and Voice Models may constitute biometric information.

Celibrium processes Voice Recordings solely for the purpose of creating and providing the Voice Cloning functionality you request.

Voice Cloning is never required to use your Legacy or Digital Twin.

Voice Cloning Availability

The Voice Cloning feature is currently available to United States residents only. International users may use Celibrium to create and preserve their Legacy, but cannot create Voice Models at this time.

You may withdraw your consent and request deletion of your Voice Model in accordance with our Voice Cloning & Biometric Consent and our Data Retention & Account Deletion Policy.

Celibrium does not sell, lease, trade, or otherwise commercialize biometric information.

11. Authorized Service Providers

Celibrium works with carefully selected service providers that perform specific functions necessary to operate the Services.

These providers are permitted to access personal information only to the extent reasonably necessary to perform the services requested by Celibrium and are expected to protect such information in accordance with applicable contractual obligations and law.

Current material service providers include: Vercel (hosting), Supabase (database and secure storage), Anthropic (AI processing, including the Celibrium Guide website assistant), ElevenLabs (voice synthesis), Microsoft Azure Speech Services (transcription), Resend (transactional email), Stripe (payments), and — on our public marketing pages only, and only with your consent — Google (Google Analytics). The full list, with what each provider processes, is maintained on our Service Providers page.

Separately from these providers, Celibrium queries two public United States government reference directories — the FDA National Drug Code directory and the NIH Dietary Supplement Label Database — when you look up a medication or supplement by barcode or by name, as described under Health Information above. They receive only that search term, never Personal Information, and are reference sources rather than Authorized Service Providers.

Celibrium may replace or add Authorized Service Providers as the Services evolve.

Any replacement provider will be selected based on its ability to support the Services while protecting personal information in a manner consistent with this Privacy Policy and applicable law.

12. Information Sharing

Celibrium does not sell your Personal Information.

Except as described in this Privacy Policy, we do not disclose your Personal Information to third parties without your authorization.

We may share information only:

• with Authorized Service Providers acting on our behalf;
• with family members or other individuals you expressly authorize through the Services;
• when required by applicable law or valid legal process;
• to protect the rights, safety, security, or integrity of Celibrium, our Users, or others;
• in connection with a merger, acquisition, financing, asset sale, or similar business transaction.

If ownership of Celibrium changes, the acquiring organization will remain bound by the privacy commitments applicable to the transferred information unless you are notified otherwise and applicable law permits different treatment.

12A. Government Requests for Information

Celibrium respects the privacy of its Users and does not voluntarily disclose Personal Information to governmental authorities except as described in this Privacy Policy or as required by applicable law.

If we receive a request from a governmental authority, law enforcement agency, or court seeking access to Personal Information, we will review the request to determine whether it is legally valid and appropriately scoped before responding.

Where permitted by law and where doing so would not interfere with an active investigation or violate a legal obligation, Celibrium may notify the affected User before disclosing their information.

We disclose only the information we reasonably believe is required to comply with applicable law or a valid legal process.

12B. Transparency Regarding AI Providers

Celibrium may use one or more Authorized AI Service Providers to perform AI Processing on our behalf. These providers process information solely to deliver the AI-powered features you request and are not authorized to use your Legacy or User Content to create another customer's Digital Twin. Celibrium may replace Authorized AI Service Providers over time, provided any replacement is required to protect Personal Information in a manner consistent with this Privacy Policy and applicable law.

12C. Website Assistant (Celibrium Guide)

Our public websites offer the Celibrium Guide, an AI assistant that answers questions about our products, pricing, and privacy. The Guide is clearly labelled as an AI assistant, does not require an Account, and has no access to any Account, Legacy, Info Hub, or other User Content.

Messages typed into the Guide are sent to our Authorized AI Service Provider, Anthropic, which processes them to generate the response. Under Anthropic's commercial API terms, content sent through the API is not used to train Anthropic's models, and it is handled and retained only as those terms and our agreement with Anthropic allow. Celibrium does not store Guide conversations on its servers, and does not send their content to any analytics service. The conversation exists in your browser and ends when you close it.

Please do not enter passwords, payment card numbers, or other sensitive Personal Information into the Guide; it does not need them, and messages that appear to contain them are refused rather than processed.

13. International Data Transfers

Celibrium is headquartered in the United States.

Depending on where you access the Services, your information may be transferred to and processed in countries whose privacy laws differ from those of your home jurisdiction.

Where required by applicable law, Celibrium will implement appropriate safeguards for international transfers of personal information.

14. Security

Protecting your Legacy is fundamental to our mission.

Celibrium maintains administrative, technical, and organizational safeguards designed to protect Personal Information from unauthorized access, disclosure, alteration, destruction, or misuse.

These safeguards include appropriate authentication controls, encryption where appropriate, access controls, monitoring, logging, and security review processes.

No technology can guarantee absolute security. However, Celibrium continually evaluates and improves its security practices to reduce risk and protect the information entrusted to us.

15. Data Retention

Celibrium retains Personal Information only for as long as reasonably necessary to provide the Services, comply with legal obligations, resolve disputes, protect the security of the platform, and enforce our agreements.

Specific retention periods differ depending on the type of information involved.

Detailed information regarding:

• account deletion;
• recovery periods;
• Voice Model deletion;
• backup retention;
• deceased user accounts; and
• permanent deletion procedures

is available in our Data Retention & Account Deletion Policy, which forms part of Celibrium's overall privacy governance framework.

16. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

• access your Personal Information;
• correct inaccurate Personal Information;
• request deletion of Personal Information;
• receive a portable copy of certain information;
• withdraw consent where processing is based upon consent;
• object to or restrict certain processing activities;
• appeal certain privacy decisions where applicable law provides that right.

Where required by applicable law, Celibrium will respond to verified privacy requests within the time periods established by law.

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), including rights relating to Sensitive Personal Information.

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with comparable privacy legislation, you may also have the right to lodge a complaint with your local supervisory authority.

16A. Notice to California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

Categories of Personal Information We Collect

Depending on how you use the Services, Celibrium may collect the following categories of Personal Information:

• Identifiers (such as name and email address)
• Customer records information
• Commercial information relating to purchases
• Internet or network activity
• Audio information
• Visual information
• Biometric information (where Voice Cloning is enabled)
• Health information (where you use the Medications & Supplements list)
• Inferences generated through authorized AI Processing
• Sensitive Personal Information as defined by applicable California law

Sensitive Personal Information

Certain information processed by Celibrium, including Voice Recordings used for Voice Cloning, authentication credentials, precise account security information, and health information you enter into the Medications & Supplements list, may constitute Sensitive Personal Information under California law.

Celibrium uses Sensitive Personal Information only for purposes reasonably necessary to provide the Services requested by you, maintain security, comply with applicable law, and perform other purposes authorized by the CPRA.

Celibrium does not use Sensitive Personal Information to infer characteristics for advertising purposes.

Sale or Sharing of Personal Information

Celibrium does not sell or share Personal Information, Sensitive Personal Information, Legacy Information, Voice Recordings, Digital Twins, or User Content for cross-context behavioral advertising.

California Privacy Rights

Subject to applicable law, California residents may have the right to:

• Know the categories and specific pieces of Personal Information we collect;
• Request deletion of Personal Information;
• Request correction of inaccurate Personal Information;
• Obtain a portable copy of certain Personal Information;
• Limit the use and disclosure of Sensitive Personal Information where applicable;
• Be free from unlawful discrimination for exercising privacy rights.

To exercise these rights, please contact:

legal@celibrium.com

17. Children's Privacy

Celibrium is intended only for individuals eighteen (18) years of age or older.

We do not knowingly permit individuals under the age of eighteen to create Accounts.

If we become aware that Personal Information has been collected in violation of this policy, we will take reasonable steps to delete the information consistent with applicable law.

Certain Legacy content may include information about minors when submitted by a parent, legal guardian, or another individual legally authorized to provide such information as part of preserving family history. Such information is processed solely for the purposes requested by the account holder.

18. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time to reflect changes in our Services, technology, legal obligations, or business operations.

If we make material changes, we will provide notice through the Services, by email where appropriate, or by other means consistent with applicable law before the changes become effective.

The "Last Updated" date at the beginning of this Privacy Policy identifies the most recent revision.

19. Contact Us

If you have questions about this Privacy Policy or Celibrium's privacy practices, please contact us:

Celibrium, LLC

Baltimore County, Maryland, USA

Email: legal@celibrium.com

Final Statement

Privacy is not simply a legal obligation at Celibrium.

It is a commitment to responsible stewardship.

Every story, every memory, every voice, and every Legacy entrusted to us represents a real person and a family's history. Our responsibility is to protect that trust with transparency, respect, and integrity throughout the lifetime of the Services.