LEGAL

Privacy Policy

Effective September 17, 2026  ·  Last updated October 6, 2026  ·  العربية

Your inner world is sacred. This policy explains exactly what we collect, what leaves your device and where it goes, and what we will never do with it. It uses the same defined terms as the Terms & Conditions and the Refund & Returns Policy.

01

Who We Are

White Mirror Labs is a technology venture. We build AI-enabled tools for human wellbeing, designed around simplicity and minimalism — which is also how we approach data: we collect what the product actually needs, and nothing because it might be useful later.

The controller of your personal data is the founder of White Mirror Labs, operating it as an individual in the Arab Republic of Egypt at 128 Degla Gardens, October Gardens, Giza, Egypt. White Mirror Labs is a trading name and not yet an incorporated company; we will tell you before incorporation changes who controls your data. We handle personal data under Egyptian law, including the Personal Data Protection Law.

For anything in this policy, write to hello@whitemirrorlabs.com.

02

Scope & Terms Used

This policy covers the Site, the App and the sale of the Journal. The definitions are the ones set out in section 02 of the Terms; the ones that matter most here are:

the Site whitemirrorlabs.com, including the shop.
the App The White Mirror companion app for iOS and Android, and the web version at app.whitemirrorlabs.com.
the Journal The printed White Mirror Journal. Buying it is what generates order and delivery data.
the Trial The first 14 days of a new App account. It takes no payment details, so it generates no billing data at all.
your Entries Your journal entries, reflections and moods. Section 05 explains how they are protected.
03

What We Collect

When you browse the Site

Almost nothing. The Site sets no cookies and carries no advertising or social trackers. We count visits with Vercel Web Analytics, which works without cookies and without identifying you: it records the page viewed, the site that referred you, your country, and your browser and device type, and we only ever see these as totals. Our hosting provider keeps standard server logs, which include your IP address and the page requested, for security and reliability.

When you order the Journal
  • Your name, email address and phone number
  • Your delivery address: street, city and governorate
  • The order itself — product, quantity, amount, payment status, and delivery status once it ships

We never receive your card number. Payment happens on XPay's hosted checkout; we are told only whether it succeeded.

When you use the App
  • Account details: email address, and a password or a sign-in via Apple or Google
  • Profile details you enter: name, phone, delivery address for a future order, and your onboarding answers
  • Your Entries, and the mood recorded with them
  • Your practice history: meditation sessions, streaks and progress through the guided journey
  • Whether you rated an Insight useful, so the next one lands better
  • If you use the social features, the connections you make and the groups you join
Health data, if you allow it

The App can read sleep, steps, active energy, heart rate and mindfulness minutes from Apple Health or Health Connect. This is off unless you grant permission, and you can withdraw it at any time in your phone's settings. Section 06 explains the strict limit on what any of it can do.

When you contact us
  • Whatever you write to us, and the address you write from
  • Waitlist submissions: your name, email and, if you give it, your phone number, with the language and page you joined from. We keep these in our database to tell you when the Journal and app open, send you one confirmation email, and delete them if you ask
04

What We Do Not Do

These are commitments, not aspirations. If any of them changes, we will say so before it does.

  • We do not sell, rent or trade your personal data — ever, to anyone
  • We do not use your Entries to train machine learning models, our own or anyone else's
  • We do not use your Entries for advertising, targeting or profiling
  • We do not run advertising or marketing trackers on the Site
  • We do not store your card details
  • We do not read your Entries to improve the product; we read the numbers, not the writing
05

How Your Entries Are Protected

Your Entries are encrypted before they are stored. Each account has its own data key, which is itself held encrypted under a master secret kept in a separate secure store. A copy of the database on its own does not reveal anyone's writing.

The practical limit of this, stated plainly: the key is escrowed on our side rather than held only on your device, so this is strong protection against a database leak — it is not end-to-end encryption, and we could be compelled by a lawful order to produce data. Section 06 describes the one routine case in which entry text leaves our systems.

06

AI Features: What Leaves Your Device

Three features in the App send data to an AI provider. Each one runs only when you ask for it.

Insights When you request an Insight, the text of the entries being read is sent to OpenAI, which generates the reflection and returns it. The text is sent for that request only. It is not used to train a model.
Scanning (OCR) When you photograph a handwritten page, the image is sent to OpenAI to be transcribed into text. Scanning requires the Journal and is off during the Trial.
Guided meditation Session scripts are generated by OpenAI and spoken by ElevenLabs. Your Entries are not part of this.

Health data is treated far more narrowly. Exact figures never leave your phone. Heart rate variability, resting heart rate and active energy are never sent anywhere. What can accompany an Insight request is a coarse band and nothing else — for example "sleep: short, activity: typical" — used only to keep the tone of the reflection honest on an unusual week. The model is instructed never to quote, discuss or give advice about it.

These features are optional. Not using them means nothing is sent.

07

How We Use Your Information

  • To take your order, deliver the Journal, and handle returns and refunds
  • To create and run your account, and to unlock it when you redeem a Serial
  • To store your Entries and show them back to you
  • To produce an Insight, transcribe a scanned page, or generate a meditation when you ask for one
  • To send you order confirmations, delivery updates and account notices
  • To send you marketing email only if you have opted in, with an unsubscribe link every time
  • To answer your questions and support requests
  • To keep the Services secure and to investigate fraud or abuse
  • To meet our legal, tax and accounting obligations in Egypt
08

Our Legal Basis

Performing a contract Delivering the Journal, running your account, and providing the features you ask for
Explicit consent Your Entries, moods and health data. Egyptian law treats data revealing psychological or physical health as sensitive personal data, so we process it only on the explicit consent you give when you create your account, and health data only after you also grant access on your phone
Consent Marketing email and the optional AI features. Withdrawable at any time, without losing anything else
Legitimate interests Keeping the Services secure, preventing fraud, and understanding aggregate usage
Legal obligation Keeping commercial and tax records as Egyptian law requires

Where the GDPR applies to you as well, these are the Article 6 bases we rely on, and health data is processed only on your explicit consent.

09

Who Else Sees Your Data

We do not sell your data. These are the processors we rely on to operate, and precisely what each receives:

Supabase Accounts, database and file storage. Holds your account, profile, orders and your encrypted Entries.
Vercel Hosting for the Site and our server functions. Standard request logs.
XPay Payments. Receives your name, email, phone, delivery address and the amount, and handles the card details we never see.
OpenAI Insights, scanning and meditation scripts. Receives entry text, scanned page images, or coarse health bands — only when you use those features. See section 06.
ElevenLabs Speaks the meditation script aloud. Receives the generated script, not your Entries.
Resend Transactional and contact email. Receives your email address and the message.
Apple and Google If you sign in with them, they confirm your identity and share your email address. App distribution only otherwise.
Delivery couriers Your name, phone and delivery address, to bring you the parcel.
Legal authorities Only where a valid legal order requires it, or to protect someone's safety.
A future buyer If the business is sold or merged, with notice to you beforehand and no change to this policy without it.
10

International Transfers

Our providers operate outside Egypt, so your data is processed abroad — chiefly in the European Union and the United States. We tell you this before you create an account, and we transfer your data abroad on the basis of the explicit consent you give at that point, for the purpose of providing the Services to you. Every provider in section 09 processes your data only on our instructions and under its own data protection commitments. If you do not consent, we cannot provide the App, because it cannot run without these providers; the Site and ordering the Journal do not require an account.

11

Cookies & Similar Technologies

The Site sets no cookies. There is no analytics cookie, no advertising cookie and no consent banner, because there is nothing to consent to.

The App stores a sign-in token and your local preferences on your own device so you are not signed out between visits. This is strictly necessary to keep you logged in, and clearing the App's data or signing out removes it.

12

How Long We Keep It

  • Your Entries and profile: for as long as your account exists. Deleting your account deletes them.
  • Order and payment records: 5 years from the transaction, to meet Egyptian commercial and tax record-keeping requirements. These survive account deletion because the law requires it.
  • Support email: 2 years from the last message in the thread.
  • Marketing preferences: kept indefinitely, so that an opt-out stays honoured.
  • Server and security logs: up to 12 months.
  • Data sent to an AI provider: retained by that provider under its own policy for abuse monitoring, then deleted. It is not retained by us beyond the result shown to you.

When a period ends, we delete the data or irreversibly anonymise it.

13

Your Rights

Under the Egyptian Personal Data Protection Law — and under the GDPR where it applies to you — you have the right to:

Know Be told what we hold about you and why
Access Get a copy of your personal data
Correction Have inaccurate or incomplete data fixed
Deletion Have your data erased, except records we must keep by law
Portability Receive your Entries in a machine-readable format
Objection Object to processing based on legitimate interests, and to direct marketing at any time
Restriction Limit processing to a specified purpose
Breach notice Be told if your personal data is involved in a breach
Withdraw consent Turn off health access, AI features or marketing without losing the rest of the App
Complain Complain to the Egyptian Personal Data Protection Centre, or to your local data protection authority

Write to hello@whitemirrorlabs.com. We decide on every request within 6 working days, and if we refuse any part of it we tell you why. Exercising a right is free, and we will not treat you differently for it.

14

Deleting Your Account

You can delete your account from within the App, without asking us. Deletion removes your Entries, your profile and your social connections. It does not remove order records we are required to keep, and it does not un-redeem a Serial — a Serial is spent once and cannot be reused on a new account.

15

Children's Privacy

The Services are for people aged 16 and over. We do not knowingly collect data from anyone younger. If you believe a child has given us their data, write to hello@whitemirrorlabs.com and we will delete it promptly.

16

Security

Your Entries are encrypted at rest as described in section 05. Data in transit is encrypted with TLS. Access to production data is restricted, and database access rules are enforced per account so one person cannot reach another's records. Payment card data never touches our systems.

No system is perfectly secure. If a breach affects your personal data, we notify the Personal Data Protection Centre within 72 hours and you within 3 working days, as Egyptian law requires. If you suspect your account has been accessed, contact us at once.

17

Changes to This Policy

We will update the "Last updated" date above whenever this policy changes. For a material change — particularly a new processor receiving your Entries, or a new use of your data — we will email account holders before it takes effect, and where the change relies on consent we will ask for it rather than assume it.

This policy is published in Arabic and English. If the two differ, the Arabic version prevails.

18

Contact Us

Any question about your data, or any request to exercise a right, goes to one address.

White Mirror Labs
128 Degla Gardens, October Gardens
Giza, Egypt

Email:  hello@whitemirrorlabs.com

We decide on privacy requests within 6 working days.

This Privacy Policy was written to be read — not just to comply.
If any part of it is unclear, please reach out. Your trust is the foundation of everything we build.