Privacy Policy

1. Scope and who we are

EMOTIONX PTE. LTD. ("EmotionX," "we," "us," or "our") operates fine, a personal wellness application that offers journaling, check-ins, interactive exercises, audio experiences, and AI-assisted conversations.

This policy applies to information handled through fine and the services that support it. It does not cover third-party products you choose to access outside fine, which are governed by their own terms and privacy notices.

This website. To learn which pages and links bring people here, thefineapp.com uses PostHog (hosted in the United States) to count visits without cookies or any identifier stored on your device. For each page view we receive the page address, the site you came from, and any campaign tags in the link (such as utm_source), plus your IP address and browser details, which PostHog uses to derive an anonymous visitor count that resets every day, so a visit cannot be linked to your visits on other days. We do not use this for advertising, do not build profiles, and do not record invite codes from invite links. When you tap an App Store or Google Play link, we record that tap and add a campaign tag to the link so we can see which campaign led to an install.

2. Information we handle

The information we handle depends on the features you choose to use. It may include:

3. How we use information

We use information to:

• create and secure your account, authenticate you, and sync your content;
• provide journaling, check-ins, interactive wellness experiences, voice features, and other functionality you request;
• generate AI-assisted responses and personalize your experience;
• store and display content you choose to save, including media and location tags;
• send service messages, respond to support requests, and communicate important product or policy updates;
• detect fraud, abuse, security incidents, and technical problems;
• measure reliability and improve fine, including through product analytics where enabled; and
• comply with law and enforce our agreements.

In fine's Privacy settings, the Help improve fine control lets you turn off conversation learning and associated product analytics for your account.

4. AI, voice, and audio

When you use chat, rewriting, guided conversation, transcription, or similar features, the content you submit may be sent, with your permission, to contracted AI, speech, or infrastructure providers so the feature can respond. We limit this processing to delivering and improving fine, maintaining safety, and supporting your choices described in this policy.

Microphone access begins only when you use a voice-enabled feature or grant the related permission. Some live experiences, including Vocal Release, analyze sound in real time and are designed not to keep the source recording. Audio or video that you intentionally record, attach, or save is stored as part of your content until you delete it or your account.

We do not authorize service providers to use your private content for their own advertising, and we do not use it for third-party targeted advertising.

AI providers

fine asks before it sends anything to a third-party AI provider. When you set up your profile, fine shows what it sends and who receives it, and asks whether to allow AI features. Until you allow them, a feature that needs AI asks again before it sends anything. If you choose Not now, nothing is sent to these providers, and the features that do not need AI still work. You can turn AI features on or off at any time in Settings → Account & Privacy → Data Privacy → AI features.

With your permission, fine sends your messages and any photo or file you attach, your voice while you use a voice feature, the Mind Canvas entries you save, and your check-ins, what fine remembers from earlier conversations, and profile basics such as your name, age and work. It is used to write fine's replies and reflections, turn speech into text and text into speech, check conversations for safety, and tailor your Daily Card and Insights to you.

The providers that receive it run AI models, speech, safety checks, and live voice calls for fine. fine names its main AI providers in the app when it asks for your permission. Under our agreements with them, they may use this information only to provide these features to you, and we require them to protect it with the same or equal protection described in this policy.

5. When we share information

We do not sell your personal or sensitive information. We may disclose information only in the following circumstances:

• Service providers. Companies that help us provide authentication, database and file storage, cloud hosting, AI features (see AI providers), push notifications, subscription management, analytics, customer support, and crash diagnostics.
• Authentication providers. Apple or Google may process information when you choose their sign-in option.
• At your direction. When you intentionally share, export, or send content to another person or service.
• Legal and safety reasons. When reasonably necessary to comply with law, protect rights and safety, investigate abuse, or respond to a valid legal request.
• Business changes. As part of a merger, financing, acquisition, reorganization, or sale of assets, subject to appropriate notice and safeguards.

Our service providers may process information only for contracted purposes, and we require them to protect it with the same or equal protection described in this policy.

6. Health and wellness data

fine may let you enter wellness information or, where supported, choose to connect a health platform such as Apple Health. We access connected health information only after you enable the integration and grant the relevant platform permissions.

We use this information to provide the wellness feature you request. We do not sell health data, use it for targeted advertising, or share it with data brokers. You can disconnect a health integration through fine or your device settings.

7. Retention and deletion

We retain account information and user content while your account is active and as needed to provide the features you use. Diagnostic, security, and support records are retained only for as long as reasonably necessary for those purposes or to meet legal obligations.

You can delete individual content where fine provides that control, or permanently delete your account in Settings → Account & Privacy → Account Information → Delete Account. If you cannot access fine, use the deletion request at the top of this page or email business@thefineapp.com.

Account deletion removes the account and associated user data from active systems. Limited information may be retained when required for security, fraud prevention, dispute resolution, or law. Residual copies in encrypted backups expire through our normal backup rotation and are not restored except for disaster recovery.

8. Your choices and rights

Depending on where you live, you may have rights to access, correct, export, restrict, object to processing of, or delete your personal information. You may also withdraw consent where processing is based on consent.

• Manage app permissions in your iOS or Android device settings.
• Turn AI features on or off at any time in fine's Privacy settings.
• Use fine's Privacy settings to control conversation learning and analytics.
• Delete content and your account using fine's in-app controls.
• Contact us to make a privacy request or ask a question.

We may need to verify your identity before acting on a request. We will respond in accordance with applicable law.

9. Security and international transfers

We use administrative, technical, and organizational safeguards designed to protect information, including encrypted transmission, access controls, and protected storage. No system is completely secure, so we cannot guarantee absolute security.

EmotionX is based in Singapore, and our service providers may process information in other countries. Where required, we use appropriate safeguards for international transfers. Privacy laws in those countries may differ from the laws where you live.

10. Age requirement

fine is intended for people aged 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided information to fine, contact us so we can investigate and delete it where appropriate.

11. Changes to this policy

We may update this policy as fine and our legal obligations evolve. We will post the revised version here, change the "Last updated" date, and provide additional notice in fine when a change is material.

12. Contact us and our data protection representatives

For privacy questions, rights requests, or account deletion requests, contact:

Data controller: EMOTIONX PTE. LTD.
3 Fraser Street, #04-23A, Duo Tower, Singapore 189352
business@thefineapp.com

Data Protection Officer: You can contact our DPO at business@thefineapp.com. Please mark your message “DPO enquiry”.

Please include the email address associated with your fine account when making an account-specific request.

EU/EEA data protection representative

We have appointed Data Protection Representative Limited (trading as DataRep) as our data protection representative in the European Union and European Economic Area under the EU GDPR.

Postal address: DataRep, 77 Camden Street Lower, Dublin, D02 XE80, Ireland.

UK data protection representative

We have appointed Data Protection Representative Limited (trading as DataRep) as our data protection representative in the United Kingdom under the UK GDPR and Data Protection Act 2018 (as amended).

Postal address: DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom.

To raise a question or exercise your data protection rights through either representative, email datarequest@datarep.com with “FINE, EmotionX” in the subject line, or use DataRep’s online request form.

Address postal enquiries to DataRep and refer to FINE, EmotionX in the correspondence so that your request reaches the representative and can be directed to us. We may request evidence of your identity before responding to an account-specific request.

For information about how DataRep handles your information, see DataRep’s privacy notice.

13. EU Digital Services Act legal representative

EMOTIONX PTE. LTD. (trading as FINE, EmotionX) has appointed Data Protection Representative Limited (trading as DataRep) as its legal representative under Article 13 of the EU Digital Services Act.

For Digital Services Act enquiries, concerns about our digital service, or reports of illegal content, you may contact DataRep using:

• Email: digitalrequest@datarep.com, quoting “FINE, EmotionX” in the subject line.
• Online: DataRep’s request form.
• Post: DataRep, 77 Camden Street Lower, Dublin, D02 XE80, Ireland. Address your letter to DataRep and refer to FINE, EmotionX in the correspondence.
• Telephone: +353 (1) 919 8899. DataRep may ask you to follow up by email so that your request is understood correctly.