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Privacy Policy

Last updated: April 16, 2026

Palaestra is a judgment training system for founders. Your decision data is the core of the product — it’s how the system learns your patterns and helps you improve. This policy explains exactly what we collect, why, and what we will never do with it.

We do not sell your data. Ever.

We do not share your data with advertisers or for cross-context behavioral advertising.

We do not use your content to train third-party foundation AI models.

Your reflections, decisions, and Ledger entries are encrypted before they leave your device. They are stored in encrypted form on our servers. We cannot read them. When you request an AI Judgment Report, your device decrypts the data temporarily and sends it to our analysis system, which processes it and discards the input. At no point is your unencrypted text stored on our servers or accessible to Palaestra staff.

We do not track your location, contacts, or any data outside the app.

Controller and Contact

Palaestra Labs is the data controller for the personal information described in this policy. You can reach our privacy team at privacy@getpalaestra.com. For legal or regulatory notices, write to legal@getpalaestra.com.

EU Representative (Article 27 GDPR). For users in the European Union and European Economic Area, our appointed Article 27 representative is [EU representative name and address]. You may contact them directly regarding the processing of your personal data.

UK Representative (Article 27 UK GDPR). For users in the United Kingdom, our appointed UK Article 27 representative is [UK representative name and address].

What We Collect

DataWhat It IncludesWhy
Trial decisionsWhich option you chose, how long you hesitated, whether your choice matched the historical outcomeTo compute your accuracy patterns across decision domains
ReflectionsThe text you write in response to decision scenarios (encrypted client-side)To identify recurring patterns in your decision psychology
Ledger entriesReal-life decisions you log, your conviction score, temperature, pressure tags, expected outcome, domain, and settlement outcome after 90 days (encrypted client-side)To assess your conviction calibration over time
Decision patternsStatistical analysis of your accuracy across domains and cognitive trapsTo generate your Judgment Report and adapt your training
Protocol answersYour responses to guided Decision Protocol questions (encrypted client-side)To structure your thinking and create documented, pre-registered decisions
Account infoDisplay name, email address, identity selectionAuthentication and personalization
Device and diagnosticDevice model, OS version, app version, anonymized crash logsStability monitoring and bug fixing
Purchase recordsSubscription status, transaction identifiers from App Store / Play / RevenueCatBilling and entitlement management
Website dataIP address, browser type, page views on judgment.trainingSecurity and basic analytics (no cross-site tracking)

We collect this information directly from you (when you create an account, complete trials, or write Ledger entries), automatically from your device (diagnostics and telemetry), and from our processors (RevenueCat, Apple, Google for subscription status).

Third-party personal information in your Ledger. Decision Ledger entries may contain the personal data of identifiable third parties (for example, co-founders, employees, candidates, or investors you name in a decision). You are responsible for having a lawful basis to enter such information. We process that information as a processor on your behalf, encrypted and inaccessible to our staff, and we will delete it when you delete the entry or your account.

Lawful Basis for Processing (EU / UK)

If you are in the EU, EEA, or UK, we rely on the following lawful bases under GDPR Article 6 and UK GDPR for each processing purpose:

PurposeLawful Basis
Providing the Service, account creation, subscription managementContract (Art. 6(1)(b))
Security, fraud prevention, diagnostic crash reportingLegitimate interests (Art. 6(1)(f))
Pattern Map profiling and adaptive curriculumConsent (Art. 6(1)(a)) — granular opt-in; you can withdraw at any time
Marketing emails (The Judgment Briefing)Consent (Art. 6(1)(a)) — you may unsubscribe at any time
Complying with legal obligations (tax, regulatory requests)Legal obligation (Art. 6(1)(c))
Responding to data subject requestsLegal obligation (Art. 6(1)(c))

Where the content of your Ledger reveals categories of data protected under GDPR Art. 9 (for example, political opinion or health inferences), we rely on your explicit consent for such processing and you may withdraw that consent by deleting the relevant entry.

How Your Data Is Protected

Sensitive text — your reflections, Ledger entries, and protocol answers — is encrypted using AES-256-GCM before it reaches our servers. Even in a worst-case database breach, an attacker would get ciphertext, not your actual decisions and fears.

Your data is stored on Supabase (US data center) with row-level security ensuring that only your authenticated session can access your records. Authentication tokens are stored in your device’s secure enclave, not in general app storage. We maintain industry-standard administrative, technical, and physical safeguards, but no system is perfectly secure.

Breach Notification

If we become aware of a personal-data breach that is likely to result in a risk to your rights and freedoms, we will notify our lead supervisory authority within 72 hours where required under GDPR Art. 33, and we will notify affected users without undue delay where required under GDPR Art. 34 or equivalent laws (including CCPA/CPRA, Singapore PDPA, Brazil LGPD, and Canadian PIPEDA).

International Data Transfers

Your data is stored on Supabase servers located in the United States. If you access Palaestra from the EU, EEA, UK, Brazil, or another jurisdiction with cross-border transfer restrictions, your personal data is transferred to the US and to subprocessors in the US and elsewhere. We rely on the following transfer mechanisms:

You may request a copy of the SCCs or equivalent safeguards by emailing privacy@getpalaestra.com.

Subprocessors

We share the minimum data necessary with the following subprocessors. Each is bound by a Data Processing Agreement that requires GDPR-grade safeguards.

ServiceWhat It ReceivesPurpose
Supabase (US)Account info, encrypted decisions and reflectionsAuthentication and data storage
RevenueCat (US)App user ID, subscription status, transaction identifiersSubscription and entitlement management
PostHog (US)Anonymous event counts only — no personal text, no reflections, no decisionsProduct analytics (privacy-first mode)
Sentry (US)Anonymized crash reports, device and OS metadataError monitoring and diagnostics
Resend (US)Your email address and message content when you submit the contact formTransactional and contact email
Beehiiv (US)Your email address if you subscribe to The Judgment Briefing newsletterNewsletter delivery
Vercel (US)IP address and standard request logs for judgment.trainingWebsite hosting
Apple / GooglePlatform-level account, subscription, and diagnostic signalsApp distribution and sign-in

We do not use advertising SDKs, tracking pixels, or data brokers. We will update this list and notify you before adding any new subprocessor that materially changes how your data is handled.

Cookies and Website Tracking

The judgment.training website uses a small number of strictly necessary cookies (session continuity, CSRF protection) that do not require consent under the ePrivacy Directive and EDPB Guidelines 05/2020. We do not set advertising or cross-site tracking cookies. If we add any non-essential cookies in the future, we will present a prior-opt-in consent banner with granular controls before any such cookie is set.

Data Retention

We retain personal data only as long as needed for the purposes set out in this policy:

DataRetention
Account infoUntil account deletion; then fully removed within 30 days
Trial decisions, reflections, Ledger entries, protocol answersUntil you delete the entry or your account; then removed within 30 days
Purchase recordsSeven (7) years after the transaction, as required by tax and commercial-records law
Diagnostic and crash logsNinety (90) days, then anonymized or deleted
Website access logsThirty (30) days
Marketing-consent recordsDuration of subscription plus three (3) years, per CASL requirements
Data-subject-request recordsThree (3) years for regulatory audit

If you delete your account, all data is permanently and irreversibly removed from active systems within 30 days. Encrypted backups may persist for up to 90 additional days before rotation. We do not soft-delete or deactivate.

Your Rights

You can export all your data at any time. The “Download Your Data” option in the app produces a complete JSON file containing every decision, reflection, Ledger entry, and protocol answer associated with your account. You can delete your account at any time from the Profile screen.

To exercise any right below, email privacy@getpalaestra.com. We will respond within 30 days (GDPR / UK GDPR / LGPD / PIPEDA) or 45 days (CCPA / CPRA), as applicable. We will verify your identity before fulfilling a request.

European Union, European Economic Area, and United Kingdom

Under GDPR and UK GDPR you have the right to: access your data (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection (Art. 21), and not to be subject to solely automated decision-making that produces legal or similarly significant effects (Art. 22). You may withdraw consent at any time where processing is based on consent. You also have the right to lodge a complaint with your supervisory authority — for UK users, the Information Commissioner’s Office (ico.org.uk).

California Residents (CCPA / CPRA)

To exercise California rights, email privacy@getpalaestra.com with the subject “California Privacy Request.” You may also designate an authorized agent.

Canada (PIPEDA, CASL, Quebec Law 25)

Our designated Privacy Officer can be reached at privacy@getpalaestra.com. You have the right to access, correct, and withdraw consent for the processing of your personal information under PIPEDA and, for Quebec residents, under Law 25 (including the right to data portability). Our newsletter uses CASL-compliant express opt-in consent with unsubscribe in every message; we retain consent records for three years.

Brazil (LGPD)

Our appointed Encarregado (DPO) can be reached at privacy@getpalaestra.com. Under LGPD Articles 18 and 20 you have rights analogous to GDPR, including the specific right to review of automated decisions. To exercise these rights, email with subject “LGPD Request.”

Australia (Privacy Act 1988)

You may access and correct your personal information under Australian Privacy Principles 12 and 13, and complain to the Office of the Australian Information Commissioner (oaic.gov.au). We handle cross-border disclosures in accordance with APP 8 and remain accountable for our overseas subprocessors’ handling of your data.

South Africa (POPIA), Singapore (PDPA), Thailand (PDPA)

Users in South Africa, Singapore, and Thailand have rights analogous to those described above, including access, correction, deletion, and objection. For breach-notification purposes, we comply with the 3-day threshold under Singapore PDPA and the equivalent requirements under POPIA and Thailand PDPA. To exercise these rights, email privacy@getpalaestra.com.

Analytics

We use PostHog in privacy-first mode. Autocapture is disabled. We receive only explicitly defined events: event type, timestamp, numeric identifiers, and categorical values (like decision domain or trap tag). We never receive the text of your reflections, decisions, or protocol answers through analytics.

On iOS, our analytics implementation does not use your Identifier for Advertisers (IDFA) and does not trigger an App Tracking Transparency prompt. PostHog receives no cross-app tracking data.

Automated Analysis and Pattern Map

Palaestra analyzes your decision history to generate your Judgment Report and adapt your training curriculum (the “Pattern Map”). This is automated profiling under GDPR Art. 4(4) and Automated Decisionmaking Technology under the CPRA. It is advisory only and does not produce legal or similarly significant effects without your active participation.

You have the right to (i) request information about the logic of the Pattern Map, (ii) request human review of any output you disagree with, (iii) express your point of view and contest the output, and (iv) opt out of the Pattern Map at any time without losing access to the rest of the Service. Brazilian users have the explicit review right under LGPD Art. 20. To exercise any of these rights, email privacy@getpalaestra.com.

Children

Palaestra is designed for adult founders and business operators. We do not knowingly collect personal information from anyone under the age of 16, and we do not direct the Service to children. If you believe a child under 16 has provided us with personal information, contact privacy@getpalaestra.com and we will delete it promptly.

Changes to This Policy

If we make material changes, we will notify you through the app or by email before the changes take effect, with a reasonable notice period where required by applicable law. Continued use of the Service after a change takes effect constitutes acceptance.

Contact

Questions about your data? Contact Palaestra Labs at privacy@getpalaestra.com.