1. We Do Not Sell Your Data
Noema Cognition does not sell, rent, or share your personal data with third parties for advertising or marketing purposes. This applies to all users, regardless of location.
We do not use third-party advertising networks, behavioral tracking pixels, or data brokers. Our self-hosted analytics track usage patterns within the Noema platform only, and this data is never sold or shared externally.
Under CCPA and similar state laws, because we do not sell data, you do not need to opt out of any data sale — there is nothing to opt out of.
2. California Residents (CCPA / CPRA)
The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants California residents the following rights:
You have the right to know what personal information we collect about you, the purposes for which it is used, and the categories of third parties with whom it is shared.
You have the right to request deletion of your personal information, subject to certain exceptions (e.g., completing a transaction, security purposes, legal obligations).
You have the right to request correction of inaccurate personal information we hold about you.
We do not sell personal information. No opt-out is required, but this right is acknowledged.
You have the right to limit Noema's use of sensitive personal information to what is necessary to provide the service.
We will not discriminate against you for exercising any of your CCPA rights. We will not deny service, charge different prices, or provide a different quality of service.
Categories of personal information collected: Identifiers (email address), usage data (journal entries, mood ratings, feature interactions), audio data (voice journal recordings — transcribed immediately and audio discarded), inferences drawn from your content (AI-identified patterns). See our full Privacy Policy for complete detail.
Business purposes for collection: Providing the journaling and AI reflection service; analytics to improve the product; billing and subscription management; transactional emails and smart reminders.
3. Other U.S. State Privacy Laws
Noema Cognition recognizes privacy rights granted by the following U.S. state laws, and will honor requests from residents of these states accordingly:
| State | Law | Rights Honored |
|---|---|---|
| Colorado | Colorado Privacy Act (CPA) | Access, correction, deletion, portability, opt-out of profiling for decisions with legal effects |
| Virginia | Consumer Data Protection Act (CDPA) | Access, correction, deletion, portability, opt-out of targeted advertising and profiling |
| Connecticut | Connecticut Data Privacy Act (CTDPA) | Access, correction, deletion, portability, opt-out of targeted advertising and profiling |
| Utah | Utah Consumer Privacy Act (UCPA) | Access, deletion, portability, opt-out of sale and targeted advertising |
| Texas | Texas Data Privacy and Security Act (TDPSA) | Access, correction, deletion, portability, opt-out of sale and profiling |
| Oregon | Oregon Consumer Privacy Act (OCPA) | Access, correction, deletion, portability, opt-out of sale, targeted advertising, and profiling |
Regardless of your state, Noema Cognition will process deletion and access requests from any U.S. user. We apply baseline privacy rights to all users.
4. European Union & UK Residents (GDPR)
If you are located in the European Economic Area (EEA) or United Kingdom, the General Data Protection Regulation (GDPR) grants you the following rights:
- Right of access — request a copy of the personal data we hold about you
- Right to rectification — request correction of inaccurate data
- Right to erasure ("right to be forgotten") — request deletion of your personal data
- Right to data portability — receive your data in a structured, machine-readable format
- Right to restrict processing — ask us to limit how we use your data
- Right to object — object to processing based on legitimate interests or for direct marketing
- Rights related to automated decision-making — not to be subject to decisions based solely on automated processing that produce legal or significant effects
Our legal basis for processing your data is contract performance (providing the service you signed up for) and legitimate interests (improving the product via analytics). We do not rely on consent as a legal basis for core service functionality — consent is obtained separately for cookies and marketing communications.
You have the right to lodge a complaint with your local supervisory authority. In the EU, you can find your authority at edpb.europa.eu. In the UK, the relevant authority is the Information Commissioner's Office (ICO).
5. How to Exercise Your Rights
To submit a privacy rights request, use any of the following methods:
Email: privacy@noema-cognition.com
Subject line: Include "Privacy Rights Request" and your state or country
Contact form: noema-cognition.polsia.app/contact
We will respond to verifiable requests within 30 days (or within 45 days where permitted by applicable law, with notice). We may ask you to verify your identity before processing your request.
We will not charge a fee for processing your rights request unless it is unfounded, repetitive, or excessive. In those cases, we will notify you of any fees before processing.
6. Account & Data Deletion
You can request full deletion of your account and all associated data at any time. Here is exactly what happens:
- Submit a deletion request to privacy@noema-cognition.com with "Delete My Account" in the subject line
- We will confirm receipt within 3 business days
- Deletion will be completed within 30 days of your verified request
- You will receive a confirmation email when deletion is complete
What is deleted: All journal entries, mood data, AI-generated patterns and reflections, voice transcriptions, account credentials, and subscription data are permanently deleted from our systems.
What may be retained: Anonymized, non-identifiable usage analytics (no email, no content) may be retained for product analytics. Billing records may be retained for the period required by applicable law.
Voice journaling: Audio recordings are transcribed immediately upon submission and the audio file is permanently discarded. No audio is ever stored. This occurs before the transcript is saved — meaning deletion of your account removes transcripts but there is no audio to delete.
If Noema ceases operations: In the event Noema Cognition discontinues service, we will provide advance notice and a data export window. User data will be securely deleted rather than transferred to a third party, unless required by law or agreed to in writing by the user.
7. Non-Discrimination
Noema Cognition will not discriminate against any user for exercising their privacy rights. Specifically, we will not:
- Deny you access to the service
- Charge you different prices or provide a different quality of service
- Suggest that you will receive a worse experience if you exercise your rights
- Retaliate against you in any form for submitting a rights request
8. Contact Us
For any privacy-related questions, rights requests, or concerns:
Privacy inquiries: privacy@noema-cognition.com
General support: support@noema-cognition.polsia.app
Contact form: noema-cognition.polsia.app/contact
Response time: Within 30 days for rights requests; within 3 business days for general inquiries.
For the full description of our data practices, see our Privacy Policy. For cookie-specific rights, see our Cookie Policy.