Privacy Policy
Effective Date: July 1, 2026
Last Updated: July 1, 2026
This Privacy Policy constitutes a legally binding agreement between you and manipulight ("we," "us," or "our"). manipulight is an independently operated online service based in Ukraine. For legal notices, dispute resolution, or as required by applicable law, the full legal identity of the operator is available upon reasonable request to support@manipulight.com. This document details our data collection, processing, and retention practices. By accessing or using our Service, you explicitly consent to the practices described in this Policy.
1. Information We Collect
We operate on a principle of data minimization, collecting only the data strictly necessary for the technical and commercial operation of the Service. We collect the following categories of information:
- Account Data: We receive your email address, unique account identifier (UUID), and authentication tokens from our identity and payment providers (e.g., Whop, Google OAuth). If you sign in via email, your password is stored as a salted cryptographic hash — we never store your password in plain text. We do not collect your physical address, phone number, or government-issued identification.
- User-Generated Content: Screenshots and images you upload to the Service for analysis, as well as the text extracted from those screenshots via optical character recognition (OCR).
- Subject Metadata: If you choose to use organizational features such as the Journal, you may provide a textual name or alias for a profile (e.g., a label like "Alex" or "Partner") purely to help you organize your own analyses. This label is provided voluntarily by you, is never required to use the Service, and we do not extract or infer it from your uploaded content. Note: if you enable the Sharing feature (Section 3) for an analysis linked to a profile, that profile alias may become visible to anyone who accesses the resulting shared link — see Section 3 for details.
- Payment Information: All payments are processed by our payment processor, Whop, which acts as the merchant of record for all transactions. We do not receive, process, or store your full card number, CVC, or other sensitive payment credentials. We retain only limited transaction metadata (e.g., plan purchased, transaction date, subscription status) necessary to administer your account.
- Technical and Log Data: To operate, secure, and troubleshoot the Service, our infrastructure providers automatically log limited technical data, including IP address, browser/device type, request timestamps, and error logs. We do not use this data for advertising, behavioral tracking, or analytics profiling.
- Communications: If you contact us (e.g., via support@manipulight.com), we retain that correspondence to respond to you and maintain a record of support history.
2. Ephemeral Image Processing and Anonymization
We employ strict ephemeral processing for all image uploads to protect your privacy and the privacy of third parties contained within your images:
- Zero Image Retention: Images uploaded to our servers are buffered into volatile memory or temporary storage solely for the duration of the Optical Character Recognition (OCR) and text extraction processes. Upon completion of the analysis job, all image binaries are immediately and permanently purged from our infrastructure via automated background routines.
- PII Scrubbing: Prior to analyzing the extracted text, our internal pipelines employ Natural Language Processing (NLP) to detect and redact Personally Identifiable Information (PII) — such as names, phone numbers, and addresses — replacing them with generic placeholders. PII scrubbing operates on the extracted conversation text used for analysis; it does not remove a profile alias you have separately and deliberately assigned yourself (see Section 1.3).
- No Visual Datasets: We do not build any facial recognition, image-fingerprinting, or visual dataset from user-submitted screenshots.
3. Sharing Features
The Service allows you to optionally generate a shareable view of a specific analysis — for example, to show it to a friend, partner, or professional. If you enable sharing for an analysis:
- The shared view may include the conversation excerpts, our AI-generated tags and commentary, and any profile alias you assigned to that analysis.
- The resulting link is accessible to anyone who has it. We do not require the recipient to have an account or log in to view it, and we do not verify who a link is subsequently forwarded to.
- Shared links are excluded from search engine indexing, but we cannot guarantee a link will never be captured, screenshotted, or redistributed once shared, since that happens outside our systems and outside our control.
- You can disable sharing for an analysis at any time from within the app, which deactivates the link going forward. Deleting the underlying analysis or your account also automatically deactivates any associated shared links.
Because sharing an analysis may expose information about a third party referenced in your conversation — including any alias you assigned to them — to people outside your account, you are solely responsible for deciding whether and with whom to share. See Section 3 of our Terms of Service for the representations and warranties that apply when you choose to share content.
4. Persistent Data and Cryptographic Security
Data that must be retained to provide you with historical analysis records is subjected to rigorous cryptographic protection:
- At-Rest Encryption: Extracted chat texts, resulting analysis tags, and custom profile names are encrypted at rest using industry-standard symmetric encryption algorithms (AES-256 or equivalent).
- Transient Decryption: Decryption occurs only transiently, in memory, at the moment your analysis is generated or retrieved — data is never persisted in decrypted form on disk.
- Blind Indexing: We utilize cryptographic blind indices to search encrypted records (such as profile names) without exposing the plaintext data to database administrators or backend logs.
- Data in Transit: All data in transit between your device and our servers is encrypted via TLS.
- Access Controls: Access to production data is restricted to the minimum necessary for operating and maintaining the Service.
No security system is perfect, and we cannot guarantee absolute security. If we become aware of a data breach affecting your personal information, we will notify affected users and relevant authorities as required by applicable law, without undue delay.
5. Artificial Intelligence and Sub-Processors
To perform complex behavioral analysis, we route anonymized, scrubbed text through secure Application Programming Interfaces (APIs) provided by third-party Large Language Model (LLM) operators, accessed via OpenRouter as a routing intermediary.
No Third-Party Training: We select LLM sub-processors on terms under which they are prohibited from utilizing your inputs or our outputs to train, fine-tune, or improve their foundational models. Because these are third-party services outside our direct control, we cannot make representations about providers beyond what their own terms guarantee, and we encourage you not to submit information beyond what is necessary for your analysis. A current summary of the AI sub-processors we use is available upon request at support@manipulight.com.
6. Internal Model Training and Usage Analysis
By default, we collect and store anonymized versions of the extracted conversation texts (stripped of PII) in secure, internal datasets. We use this aggregated, de-identified data solely to evaluate accuracy, debug edge cases, and train or fine-tune our own proprietary scrubbing and analysis algorithms.
Opt-Out Right: You maintain full control over your participation in our internal training programs. You may revoke your consent at any time by navigating to your Account Settings and toggling the "Opt-out of AI training" switch. Once toggled, your future data will be excluded from our training datasets.
7. Third-Party Analytics, Tracking, and Cookies
We do not deploy third-party web analytics (e.g., Google Analytics), marketing cookies, or tracking pixels to monitor your behavioral flow across our application. We do not sell, rent, or trade your personal information to data brokers or advertising networks.
We use only cookies that are strictly necessary for the Service to function (e.g., keeping you logged in). We do not currently use analytics, advertising, or cross-site tracking cookies. If this changes in the future, we will update this Policy and, where required, request your consent.
8. Where Your Data Is Stored
Our database (Neon PostgreSQL) and application hosting (Railway) are located in the United States. If you access the Service from outside the United States, including from the European Economic Area, the United Kingdom, or elsewhere, your information will be transferred to and processed in the United States. Where required, we rely on the compliance frameworks and contractual safeguards offered by our infrastructure providers to support such transfers.
9. Data Retention
- Encrypted message text and analysis history are retained for as long as your account remains active, since ongoing access to your history is a core part of the Service (e.g., the Journal feature).
- You may delete individual analyses at any time from within the app.
- If you delete your account using the in-app account deletion feature, your account data — including all encrypted message text and analyses — is permanently and immediately deleted from our production database. A residual copy may persist for a short period in encrypted backups used solely for disaster-recovery purposes; these backups are cycled and fully purged on a rolling basis within 30 days and are never accessed for any purpose other than restoring service in the event of catastrophic data loss.
10. Your Rights
Regardless of your location, you may at any time:
- Access the personal information we hold about you
- Correct inaccurate information
- Delete your account and associated data (self-service, in-app)
- Export your data in a portable format, by request to support@manipulight.com
10.1 If You Are in the EEA, UK, or Switzerland
Where the GDPR or UK GDPR applies to our processing of your data, our legal bases are: performance of a contract (providing the Service you signed up for), your consent (where applicable), and our legitimate interests (e.g., security and fraud prevention). You have the right to lodge a complaint with your local data protection supervisory authority. As a small, individually operated service without an established presence in the EU or UK, and given the limited and occasional nature of our processing of EU/UK resident data at this stage, we have not yet appointed a formal Article 27 representative; direct any GDPR-related request to support@manipulight.com and we will respond directly. AI-generated analyses are informational and provided to you for your own review — no automated decision with legal or similarly significant effect is made about you.
10.2 If You Are a California (or Other U.S. State) Resident
We do not sell or share your personal information, and we do not process it for cross-context behavioral advertising. While our current scale may fall below certain thresholds that trigger mandatory compliance under laws such as the CCPA/CPRA, we extend the same core rights described above to all users as a matter of policy, regardless of where you live.
11. Requests From Individuals Referenced in Another User's Content
Our Service is designed for a user to analyze their own private conversations. In some cases, another individual referenced within a user's conversation — including someone who has viewed content via the Sharing feature described in Section 3 — may contact us directly, even though they do not hold an account with us.
If you are not a manipulight account holder but believe your personal information appears within another user's private conversation content or a shared analysis, you may submit a request (e.g., regarding access or erasure) to support@manipulight.com. Because we cannot independently verify the identity of individuals referenced within another user's private content, and because such requests directly affect another person's account and personal data, we will:
- (a) request reasonable proof of your identity and the basis of your request;
- (b) evaluate the request in light of applicable law, including exemptions that may apply where the underlying processing relates to another individual's personal or household activity, or to the establishment, exercise, or defense of legal claims; and
- (c) where appropriate and not otherwise legally restricted, may notify the relevant account holder that such a request has been received.
We aim to respond within the timeframe required by applicable law (e.g., one month under GDPR, extendable in complex cases where necessary). Submitting such a request does not guarantee removal of the content, and we reserve the right to decline a request where we determine, in our reasonable judgment, that a legal exemption applies or that granting the request would facilitate harm to the account holder.
12. Children's Privacy
The Service is not directed to, and is not intended for use by, anyone under the age of 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have done so, we will delete that information promptly.
13. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email and/or a prominent notice on the Service before the changes take effect.
14. Contact Information
For formal privacy inquiries, data subject access requests, or to exercise your statutory rights, please contact us at support@manipulight.com.