Draft, pending legal review. This document hasn’t been reviewed by a solicitor and may change before Mira launches. Placeholders in [square brackets] are still to be filled in.
Legal
Privacy policy
Draft dated 23 October 2026
How Mira handles personal data. For the short version, see our five privacy promises.
1. Who we are
Mira is provided by [company name], registered in Ireland under company number [number], at [registered address] (“we”, “us”). For anything to do with your data, contact us at [privacy contact email]. We are the data controller for the personal data described here. [Data protection officer details, if one is appointed.]
2. Mira Companion: what we process and where
Mira Companion has no accounts. What you do in the app is stored in your browser, on your device:
- your conversations with Mira (cleared when you close the tab, unless you choose to keep them);
- your mood check-ins, journal entries and saved reflections;
- your first name and the goals you chose, if you entered them;
- a count of today’s messages, for the Free plan’s daily allowance.
When you send a message, the recent part of your conversation, the goals you chose and today’s mood are sent over an encrypted connection to our servers (hosted by Vercel, with functions in Dublin) and on to our AI provider, Anthropic, which writes Mira’s reply. Before anything leaves your device, your first name, email addresses, phone numbers, Eircodes, PPS numbers, bank and card numbers are replaced with placeholders.
Please don’t include other people’s names or details. Unlike your own first name, they aren’t removed automatically yet, so they would be sent to our AI provider with your message.
We do not store your messages on our servers or in our logs. Our logs record only technical information, such as message counts and error types.
3. Health and wellbeing information
What you tell Mira may reveal information about your health or wellbeing, which is a special category of personal data under Article 9 of the GDPR. We process it only to provide the service you ask for, on the basis of your explicit consent, which you give when you start using Mira and can withdraw at any time by stopping use and deleting your data from the app. [Lawful basis and Article 9 condition to be confirmed in legal review.]
4. Early-access sign-ups
If you join early access, we keep your email address, which product you’re interested in, any plan you chose, and the date and time you agreed to be contacted. This is stored in private storage provided by Vercel in Dublin. We use it only to tell you when your place is ready, on the basis of your consent. You can ask us to delete it at any time.
5. Payments
Paid plans are not on sale yet. When they are, payments will be handled by Stripe. Your card details go directly to Stripe and are never seen or stored by us. We receive your email address and the status of your subscription so we can provide the plan you paid for.
6. Who processes your data for us
- Vercel Inc.: hosting, our servers and early-access storage. [Data processing agreement and transfer safeguards to be confirmed.]
- Anthropic PBC (United States): writes Mira’s replies. [Data processing agreement, zero data retention and no-training terms to be put in place before launch.]
- Stripe: payments, once paid plans go on sale.
- Resend (EU region): sends the early-access confirmation email to the address you give us.
- Sentry (EU region, Frankfurt): error reports, so we can fix things that break. Reports contain the error, the page address and your browser type. They never include what you type, your conversations, your email address or your IP address.
Some of these providers are based outside the European Economic Area. Where your data is transferred outside the EEA, it will be protected by safeguards such as the European Commission’s Standard Contractual Clauses. [Transfer mechanism for each provider to be confirmed in legal review.]
7. What we don't do
- We don’t show advertising or use what you share to target you.
- We don’t sell your data.
- We don’t use your conversations to train AI models.
- We don’t share anything you tell Mira with a therapist, employer or anyone else.
8. How long we keep data
- Data in the app stays on your device until you delete it, using “Delete everything” in the You screen, or by clearing your browser’s site data.
- Early-access emails: until Mira launches and we’ve told you, or until you ask us to delete them. [Retention period to be confirmed.]
- Rate-limit records use a one-way hash of your IP address and expire within 24 hours.
9. Your rights
You have the right to access, correct, delete, restrict or object to the use of your personal data, to data portability, and to withdraw consent at any time. To use these rights, contact [privacy contact email]. Data stored only on your device can be deleted by you directly in the app.
You can also complain to the Data Protection Commission in Ireland (dataprotection.ie).
11. Age
Mira is for adults aged 18 and over. If you’re under 18 and need someone to talk to, Childline (1800 66 66 66) and Jigsaw are there for you.
12. If you're in crisis
Mira is not an emergency service. If you’re at risk, please contact Emergency services (112 or 999), Samaritans (Freephone 116 123), Text About It (Text HELLO to 50808), Pieta (1800 247 247 or text HELP to 51444). More at Safety and support.
13. Changes to this policy
We’ll update this policy whenever how Mira handles data changes, and show the date at the top. Questions in the meantime: [privacy contact email].