How we handle
your information.

1. Who this Policy applies to

This Privacy Policy ("Policy") applies when you use Maibel's websites, payment and onboarding flows, Telegram-based services, Evren, the 14-day Founding Beta, support channels, or other services that link to this Policy (together, the "Services").

Maibel Pte. Ltd. is responsible for personal data collected through the Services. For questions or requests, contact our Data Protection Officer at mabel@maibel.com.

2. What we collect

Information you provide

We may collect:

• Account and contact information, such as your name, preferred name, email address, Telegram username, Telegram user identifier, and contact details.
• Eligibility and onboarding information, such as age confirmation, time zone, wellness priorities, goals, routines, preferences, constraints, accessibility needs, and what support you would like from Evren.
• Conversation and memory information, including messages you send to Evren, your reactions, choices, mission or pact progress, and summaries or memory records created to support continuity.
• Support and feedback information, including survey answers, beta feedback, bug reports, complaints, requests, and communications with the Maibel team.
• Safety-related information you choose to share, which may include distress, crisis-adjacent statements, or other highly sensitive information.

Information collected automatically or from service providers

We may also collect:

• Usage and event data, such as onboarding completion, message timestamps, interaction state, feature use, delivery status, errors, and engagement with scheduled or proactive messages.
• Technical and diagnostic data, such as device or browser information, IP address where made available by a provider, application logs, model and prompt version, safety-routing metadata, error traces, and deployment or incident evidence.
• Payment and transaction information from Stripe, such as payment status, amount, currency, transaction identifier, and limited billing details. Maibel does not receive your full card number.
• Information from platforms you use to access the Services, such as Telegram and Google Forms, subject to their own terms and privacy practices.

3. How and why we use personal data

We collect, use and disclose personal data only for purposes that a reasonable person would consider appropriate in the circumstances and that we have notified to you, including to:

• Provide, authenticate, administer and personalise the Services.
• Match onboarding and payment records to the correct Evren account.
• Maintain conversation continuity and retrieve relevant memories.
• Generate replies, small actions, reminders, missions and other wellness support.
• Apply safety routing, respond to crisis-adjacent signals, prevent harmful outputs, and protect users and others.
• Provide customer support, investigate incidents, repair errors and validate deployments.
• Evaluate behavioural quality, emotional consistency, reliability, fairness, and safety.
• Administer the Founding Beta, measure participation, process payments and manage refunds.
• Protect the security and integrity of the Services, enforce our terms, prevent abuse, and comply with law.
• Send operational messages about your account, the beta, security, service changes or requests.
• Use optional feedback, research participation, or de-identified excerpts for product improvement where we have given you a meaningful choice.

Where consent is required, you may withdraw it by contacting us. Withdrawal does not affect processing already carried out lawfully and may mean we cannot continue providing features that require the relevant data.

4. How AI and human review are involved

Evren uses generative AI and other automated systems to interpret messages, retrieve relevant context, generate responses, schedule or select interactions, and apply safety and behavioural rules.

AI can make mistakes, misunderstand context, generate inaccurate information, or respond inconsistently.

Authorised Maibel team members and contractors may review limited conversation content, account records, evaluation cases, prompts, model outputs, logs and incident evidence where reasonably necessary for support, safety, quality evaluation, debugging, abuse prevention, or legal compliance.

We restrict access to authorised team members and contractors who require the information for an approved operational purpose.

Maibel does not present Evren as human, conscious, sentient, or capable of human feelings. Our design objective is to support your wellbeing and agency, not to replace human relationships, manipulate emotions, or induce dependency.

5. Sensitive wellness information and model improvement

Your conversations may reveal health, mental-health, relationship, sexuality, religious, financial or other sensitive information.

Please avoid sharing unnecessary identifiers, secrets belonging to others, passwords, financial account details, or information you do not want processed.

We may use conversation data as needed to provide the Services, preserve continuity, carry out safety checks, investigate incidents, and evaluate whether Evren is behaving as intended. These are core operating purposes of the beta.

We will not use sensitive conversation content to train a third-party foundation model unless we clearly explain the proposed use and obtain any separate consent required by law.

If we invite you to allow de-identified excerpts or data for broader research or improvement, that choice will be optional. Refusing will not affect your participation unless we expressly state otherwise before collection.

De-identification reduces risk but may not eliminate it. We apply access controls and data minimisation even where direct identifiers have been removed.

6. Safety, crisis-adjacent interactions and emergencies

Evren is not an emergency service and is not continuously monitored by a human.

Maibel does not guarantee that Evren will detect distress, self-harm, abuse, medical danger, or other emergencies.

If the system detects language suggesting serious or imminent risk, it may:

• Change the conversation flow.
• Encourage you to contact local emergency services or a qualified professional.
• Surface crisis resources where available.
• Limit normal companion behaviour.
• Flag the interaction for authorised human review.

Where permitted or required by law, and where we reasonably believe disclosure is necessary to respond to a serious threat to life, health or safety, we may disclose limited information to emergency services, authorities or another appropriate person.

Maibel may be unable to identify your location or contact anyone on your behalf.

7. When we disclose personal data

We do not sell personal data.

We may disclose personal data only as reasonably necessary to:

• Service providers that host, secure, analyse or support the Services, such as Telegram, Google Cloud and Gemini, Supabase, Google Forms, Stripe, and selected monitoring or communications providers.
• Professional advisers, auditors, insurers, and transaction counterparties under appropriate confidentiality obligations where reasonably necessary.
• Authorities, courts, emergency services or other persons where required or permitted by law, or to protect rights, safety, security and the integrity of the Services.
• A successor or purchaser in connection with a merger, financing, reorganisation, sale of assets or similar transaction, subject to appropriate safeguards.

Where service providers process personal data on Maibel's behalf, we take reasonable steps to limit their processing to the services they provide to us. Certain platforms may process information independently under their own terms and privacy policies.

8. Overseas processing

Maibel is based in Singapore, but our service providers and team members may process personal data in other countries. Those countries may have different data-protection laws.

Where the Singapore Personal Data Protection Act 2012 applies, we take reasonable steps to ensure that overseas recipients provide a standard of protection comparable to the protection under the Act, including through contractual protections, vendor review and access controls where appropriate.

9. Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including maintaining conversation continuity, supporting users who return after time away, evaluating safety and reliability, investigating incidents, complying with legal and accounting obligations, resolving disputes, and establishing or defending legal claims.

Retention periods vary according to the type, sensitivity and purpose of the information. We periodically review retained information and delete, anonymise or place it beyond use when it is no longer required.

Payment and accounting records may be retained for the period required under applicable Singapore tax, accounting and corporate laws.

Information that no longer reasonably identifies an individual may be retained for longer for statistical, safety, research and service-improvement purposes.

You may request earlier deletion of your personal data. We may retain limited information where reasonably necessary to comply with law, prevent fraud or abuse, protect safety or security, resolve a dispute, or establish or defend legal claims.

Deletion from active systems and encrypted backups may not occur immediately and remains subject to reasonable technical limitations.

10. Security

We use reasonable administrative, technical and organisational safeguards appropriate to the nature of the data and the stage of the Services.

These measures may include:

• Encryption in transit and at rest where supported.
• Access restrictions.
• Separated development and production environments.
• Logging and credential controls.
• Vendor management.
• Testing and incident response.
• Data minimisation.

No system is perfectly secure.

You are responsible for securing your Telegram account, devices and access credentials and for notifying us promptly if you suspect unauthorised access.

11. Your choices and rights

Subject to applicable law and reasonable verification, you may:

• Ask what personal data we hold about you and how it has been used or disclosed.
• Ask us to correct inaccurate or incomplete personal data.
• Request a copy or export of available account or conversation data.
• Ask us to delete personal data or chat history, subject to legal, safety, security and technical limitations.
• Withdraw consent for a use that depends on consent.
• Opt out of optional research, testimonial, marketing, or broader improvement uses.
• Stop using Evren or request account closure without being pressured to remain.

Send requests to mabel@maibel.com. We may ask for information reasonably necessary to verify your identity and locate your records. We will respond within the time required by applicable law.

12. Age eligibility

The Founding Beta is intended only for people aged 18 or older.

Do not use or register for the Founding Beta if you are under 18.

If we learn that we collected personal data from a person under 18 through the beta, we may suspend the account and delete the data, subject to safety and legal requirements.

13. Relationship safety and user agency

Maibel aims to design relational AI that supports life beyond the relationship with AI.

We therefore aim to:

• Make it clear that Evren is AI rather than a human.
• Avoid designs intended to manipulate emotions, exploit vulnerability, induce dependency, or damage real-world relationships.
• Respect refusals, pauses, silence, boundaries and requests to stop.
• Provide practical ways to exit, close an account, and request deletion.
• Use safety evaluation and incident review across the service lifecycle.
• Encourage appropriate real-world support when the user's needs exceed Evren's role.

14. Changes to this Policy

We may update this Policy as the Services, laws or our practices change.

We will post the updated version and revise the effective date. If a change materially affects how we use personal data, we will provide additional notice and seek consent where required.

15. Contact and complaints