Privacy Policy

Last Updated: 12/9/2025

Welcome to Settle, provided by Sola Studios, LLC (“Sola Studios,” “we,” “us,” or “our”).

Your privacy is central to our mission. We built Settle to help you manage stress and build self‑awareness, and we know that requires a safe, private environment.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the “App”) and website (collectively, the “Services”). By using Settle, you agree to the collection and use of information in accordance with this policy. This policy is part of our Terms of Service.

Important Notices

Not a Healthcare Provider.
 Settle is a consumer wellness and educational app. We are not a healthcare provider, and the Services do not constitute medical advice, diagnosis, or treatment. Sola Studios is not a HIPAA‑covered entity, and the information you provide through Settle is not protected health information (PHI) under HIPAA. However, we recognize that the wellness information you share with us is sensitive, and we treat it with heightened care as described in this policy.

Sensitive Health and Wellness Data.
 Settle collects information about your stress levels, mood, energy, physical state, and wellness practices. Under various privacy laws, this information may be classified as “sensitive personal data,” “consumer health data,” or similar categories that receive enhanced legal protections. We describe how we handle this data throughout this policy and in our state‑specific disclosures below.

1. Information We Collect

We collect information to provide a personalized wellness experience. We categorize this into four types: information you provide, wellness and health‑related data, automatically collected data, and information related to payments.

A. Information You Provide

  • Account Registration. When you create an account, we collect your name, email address, password, and general location (country/region). We also assign an internal user ID associated with your account so we can recognize you in our systems.
  • User Content. This includes data you voluntarily enter into the App, such as journal entries, notes, goal check‑ins, and routine builders.
  • Communications. If you contact us via email (e.g., help@withsettle.com) or participate in surveys, we collect the content of your message and contact details.

B. Wellness and Health‑Related Data (Sensitive Data)

We collect information about your physical and mental wellness to personalize your experience. This data may be considered sensitive personal data or consumer health data under applicable laws. We collect:

  • Nervous System Score (Onboarding Quiz). During onboarding, we ask questions about your physical and emotional state (e.g., stress levels, posture habits, perceived immune health). Providing this information is voluntary but helps us tailor the App to your needs.
  • Mood and Energy Logs. Data about your reported mood, energy levels, and emotional state.
  • Usage Activity. Which practices you engage with (e.g., specific breathwork exercises, somatic movements, or soundscapes) and the duration and timing of your sessions.

How We Protect This Data.
 We treat wellness and health‑related data as sensitive:

  • We do not sell your wellness and health‑related data.
  • We do not use your wellness and health‑related data for third‑party advertising.
  • We do not share your wellness and health‑related data with advertisers.

We also apply enhanced security measures to protect this data. See Sections 5, 7, 9, and 12 for more details.

C. Information Collected Automatically

  • Device Information. We collect data about the device you use, such as device model, operating system (iOS/Android), unique device identifiers, and IP address.
  • Usage, Analytics, and Diagnostics. We use third‑party analytics tools to understand how users navigate the App, which features are most popular, and to collect crash logs, performance data (such as load times and responsiveness), and other diagnostic information so we can identify and fix bugs and improve stability. These tools act as our service providers and are contractually required to use your data only to provide services to us.
  • Advertising and Attribution Data. We may receive limited information about how you found the App—such as which ad or marketing campaign you interacted with and related campaign identifiers—from advertising partners and mobile measurement tools. We use this to measure and improve the performance of our own marketing and user acquisition efforts, as described in Section 4.
  • Cookies and Similar Technologies. If you visit our website, we may use cookies and similar technologies to remember your preferences and analyze traffic. See Section 12 for more details.

D. Payment Information

If you purchase a subscription, your payment is processed by third‑party platforms (such as the Apple App Store, Google Play, or payment processors like Stripe). Sola Studios does not store your full credit card or banking information. We only receive transaction receipts or tokens to validate your subscription status, and we maintain records of your subscription plan and purchase history (for example, dates of purchase, renewal, or cancellation).

2. How We Use Your Information

We use your data to operate Settle and improve your experience, specifically to:

  • Provide and Maintain the Services. To create and manage your account, calculate your Nervous System Score, track your streaks or history, and deliver wellness content.
  • Personalization. To recommend specific practices (for example, suggesting a “Posture Reset” exercise based on your quiz results or recent activity) and customize your home feed.
  • Communication. To send you technical notices, security alerts, onboarding messages, and support responses via our communication providers (for email, in‑app, and push notifications).
  • Internal Research and Development. To analyze aggregate trends (for example, “Most users with high stress prefer 4‑7‑8 breathing”) and develop new content and features. When we conduct this analysis, we use aggregated or de‑identified data that cannot reasonably identify you.
  • Safety, Security, and Compliance. To monitor for fraudulent activity, prevent misuse of the Services, enforce our Terms of Service, and comply with legal obligations.

We may use automated systems and simple recommendation algorithms to support personalization and analytics, but we do not use your private journal entries or wellness data to train third‑party AI models for their own purposes.

3. Legal Basis for Processing (EEA, UK, and Switzerland)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data based on the following legal grounds:

  • Contract Performance. Processing necessary to provide the Services you requested, including account creation, personalization, and delivering wellness content.
  • Consent. Where you have given explicit consent, such as for marketing emails, optional wellness assessments, or the collection and use of certain sensitive wellness data. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
  • Legitimate Interests. Processing necessary for our legitimate interests, such as improving the Services, conducting analytics, preventing fraud, and ensuring security, provided these interests are not overridden by your rights and freedoms.
  • Legal Obligation. Processing necessary to comply with applicable laws, regulations, or legal processes.

If you are in the EEA, UK, or Switzerland, you also have additional rights described in Section 8.

4. Marketing Communications

We value your trust and are transparent about how we communicate with you.

  • First‑Party Marketing. We may use your email address to send you newsletters, wellness tips, or offers for Settle subscriptions. You can opt out of these at any time by clicking “Unsubscribe” in any marketing email or by adjusting your preferences in the App (where available).
  • No Third‑Party Targeted Advertising Using Wellness Data. We do not use your Nervous System Score, quiz answers, journal entries, mood logs, or other wellness‑related data to target you with third‑party advertisements, and we do not share your wellness data with advertisers.
  • Lookalike Audiences. We may share your email address (in hashed form) with advertising platforms such as Meta and Google to create “lookalike” audiences—groups of people with similar characteristics to our existing users—for advertising purposes. Under some U.S. state privacy laws, this may be considered “sharing” personal information for targeted advertising. We do not share your wellness data (such as your Nervous System Score, mood logs, or journal entries) for this purpose. You can opt out of this practice at any time by emailing help@withsettle.com with the subject line “Opt‑Out of Ad Targeting.”

5. How We Share Your Information

We do not sell your personal data. We share your information only in the following limited circumstances:

A. Service Providers

We share data with trusted third‑party vendors who help us operate the Services. These may include:

  • Cloud hosting and database providers
  • Analytics and performance monitoring tools
  • Customer support and helpdesk platforms
  • Email, SMS, and push‑notification providers
  • Subscription and payment infrastructure providers
  • Mobile measurement and attribution tools

These providers are bound by data processing agreements and are contractually prohibited from using your personal information for any purpose other than providing services to us. Our service providers may change over time; you can contact us if you have questions about our current vendors.

B. Aggregated/De‑Identified Data

We may share aggregated or de‑identified data (data that cannot reasonably identify you) for research, marketing, or industry analysis. For example, we may share statistics about how many users complete certain types of sessions, without identifying individual users.

C. Legal Requirements and Safety

We may disclose information if required to do so by law or in the good‑faith belief that such action is necessary to:

  • Comply with a legal obligation or legal process (for example, a subpoena or court order);
  • Protect the rights, property, or safety of Sola Studios, our users, or the public; or
  • Detect, prevent, or address fraud, security, or technical issues.

D. Business Transfers

If Sola Studios is involved in a merger, acquisition, financing, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will take reasonable steps to require the receiving entity to honor this Privacy Policy and will notify you of any material changes and choices you may have.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law.

Examples:

  • Account Data. We keep your account information while your account is active. When you request account deletion, we delete your personal data promptly (typically at the time of deletion), except for records we must retain for legal, tax, or compliance purposes.
  • Wellness Data. Your journal entries, mood logs, quiz responses, and practice history are kept while your account is active so you can see your history. When you delete your account, we delete this wellness data promptly, unless we are required by law to keep it longer.
  • Analytics Data. Analytics data is generally retained for up to 14 months in line with our analytics providers’ default settings, after which it is deleted or de‑identified.
  • Support Communications. Support and feedback communications are typically retained for up to 3 years after resolution to help us improve our support and resolve any disputes.

We may retain aggregated or de‑identified information (which cannot reasonably be linked back to you) for analytics, research, and business purposes. Anonymized data, such as anonymized identifiers used by third‑party analytics services, may persist in those systems even after your personal data has been deleted.

Where required by laws such as Washington’s My Health My Data Act, we will also address deletion of consumer health data in backup and archival systems, deleting it or securely isolating it within the timeframes required by law.

7. Security and Breach Notification

We implement reasonable administrative, technical, and physical security measures to protect your personal information, including:

  • Encryption of data in transit and at rest where appropriate
  • Secure cloud infrastructure
  • Access controls and logging
  • Internal policies and training

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security.

Breach Notification.
 If we become aware of a security incident that compromises the confidentiality or integrity of your personal information, including wellness data, we will notify you and any applicable regulators in accordance with applicable laws and regulations, including, where applicable, the U.S. Federal Trade Commission’s Health Breach Notification Rule and similar state laws.

8. Your Rights and Choices

You have control over your data. Depending on where you live, your rights may include:

  • Access. Request a copy of the personal data we hold about you.
  • Correction. Request correction of inaccurate or incomplete data.
  • Deletion. Request deletion of your personal data. You can delete your account directly in the App (where available) or by emailing help@withsettle.com.
  • Portability. Request a copy of your personal data in a structured, machine‑readable format, where technically feasible.
  • Restriction. Request that we limit the processing of your data in certain circumstances.
  • Objection. Object to certain processing based on our legitimate interests, including profiling.
  • Withdraw Consent. Where we process data based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.
  • Opt‑Out of Marketing. Unsubscribe from marketing emails via the “Unsubscribe” link in any email or by replying “STOP” to SMS messages (if applicable).
  • Push Notifications. Manage notification preferences in your device settings or in‑app settings (where available).

Additional Rights for EEA/UK/Swiss Residents.
 If you are in the EEA, UK, or Switzerland, you also have the right to:

  • Object to processing based on legitimate interests;
  • Request restriction of processing in certain cases;
  • Lodge a complaint with your local data protection authority.

How to Exercise Your Rights.
 To exercise any of these rights, contact us at help@withsettle.com with the subject line “Privacy Request.” We may need to verify your identity before fulfilling your request. We will respond within the timeframe required by applicable law (typically 30–45 days). Where permitted by law, we may extend this period and will notify you of any extension and the reasons for it. We will not discriminate against you for exercising your privacy rights.

9. International Data Transfers

Sola Studios is based in the United States. If you access the Services from the EEA, UK, Switzerland, or other regions with data protection laws, your personal data will be transferred to and processed in the United States and possibly other countries where our service providers are located.

For transfers from the EEA, UK, or Switzerland to the United States or other countries that may not provide the same level of data protection, we rely on appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission and/or UK Information Commissioner’s Office, and we implement additional technical and organizational safeguards where required. Our service providers maintain SCCs or equivalent safeguards in their data processing agreements where applicable.

If you are in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with your local data protection authority about our data practices.

If required by law, we will appoint an EU/UK representative and update this section with their contact information. In the meantime, you can contact us directly at help@withsettle.com for any EU/UK privacy questions.

10. Children’s Privacy

Settle is not intended for children under the age of 16. We do not knowingly collect personal data from children under 16. If we discover that we have collected such information, we will take steps to delete it. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at help@withsettle.com.

11. U.S. State‑Specific Privacy Rights

Certain U.S. states provide residents with additional privacy rights. This section supplements the rest of the policy.

A. California Residents (CCPA/CPRA)

If you are a California resident, you may have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

  • Right to Know. The right to know the categories of personal information we collect, the purposes for which we use it, and the categories of third parties to whom we disclose it.
  • Right to Access. The right to access specific pieces of personal information we hold about you, subject to verification.
  • Right to Delete. The right to request deletion of certain personal information, subject to exceptions.
  • Right to Correct. The right to request correction of inaccurate personal information.
  • Right to Non‑Discrimination. The right not to receive discriminatory treatment for exercising your privacy rights.
  • Right to Limit Use of Sensitive Personal Information. We only use sensitive personal information (including wellness data) for purposes permitted under CPRA, such as providing the Services you request, securing the Services, and performing internal operations.

We do not sell your personal information. We may “share” your email address (in hashed form) with advertising platforms for lookalike audience targeting, which may constitute “sharing” under the CPRA. You have the right to opt out of this sharing by emailing help@withsettle.com with the subject line “Opt‑Out of Ad Targeting.” We do not sell or share your sensitive personal information (including wellness data) for advertising purposes.

Categories of Personal Information Collected (Past 12 Months).
 We may have collected the following categories of personal information:

  • Identifiers (e.g., name, email address, IP address, device identifiers)
  • Commercial information (e.g., subscription history)
  • Internet or electronic activity (e.g., app usage, analytics data)
  • Sensitive personal information (e.g., wellness data including mood logs, stress assessments, and certain health‑related responses)
  • Inferences (e.g., personalization preferences based on your usage)

To exercise your California rights, contact us at help@withsettle.com and indicate that you are a California resident making a CCPA/CPRA request.

B. Washington Residents (My Health My Data Act)

If you are a Washington resident, you have specific rights under Washington’s My Health My Data Act regarding “consumer health data,” which includes information about your mental health, wellness, and related conditions. This Privacy Policy is intended to serve as our Consumer Health Data Privacy Policy for Washington residents.

  • Consent. We obtain your consent to collect consumer health data when you use the Services and provide wellness information (for example, during the onboarding quiz and when you log mood or energy).
  • Right to Know. You have the right to confirm whether we are collecting, sharing, or selling your consumer health data, and to access that data.
  • Right to Delete. You have the right to request deletion of your consumer health data, including from our backups and archives within the timeframes allowed by law.
  • Right to Withdraw Consent. You may withdraw your consent to our collection and use of consumer health data at any time by deleting your account or contacting us.
  • No Sale of Consumer Health Data. We do not sell your consumer health data.

To exercise your rights under Washington law, contact us at help@withsettle.com with the subject line “Washington Privacy Request.” If we deny your request, you may appeal by responding to our decision. If your appeal is denied, you may contact the Washington State Attorney General.

C. Other U.S. State Privacy Laws

Residents of other U.S. states with comprehensive privacy laws (such as Colorado, Connecticut, Virginia, Utah, Nevada, Oregon, Texas, Tennessee, Minnesota, Maryland, and others) may have similar rights, which can include:

  • The right to access, correct, or delete your personal data;
  • The right to obtain a portable copy of certain personal data;
  • The right to opt out of targeted advertising, sale of personal data, or certain forms of profiling; and
  • Additional rights regarding sensitive personal data, including health data.

Where these laws apply, we will honor your rights in accordance with the relevant statute. To exercise your rights, contact us at help@withsettle.com and indicate your state of residence. If we deny your request, you may have the right to appeal our decision and, if your appeal is denied, to contact your state attorney general.

12. Cookies and Similar Technologies

When you visit our website, we may use cookies and similar tracking technologies to collect information automatically.

  • Essential Cookies. Required for the website to function properly (for example, to keep you logged in and maintain security). These cannot be disabled in our systems.
  • Analytics Cookies. Help us understand how visitors use our website (for example, pages visited, time on site). We use this information to improve our website and Services.
  • Preference Cookies. Remember your preferences and settings (for example, language or display options).

Your Cookie Choices.
 When you visit our website, you may be presented with a cookie banner that allows you to accept or reject non‑essential cookies where required by law. You can also manage cookies through your browser settings. Disabling certain cookies may affect site functionality.

EEA and UK Visitors.
 If you are located in the EEA or UK, we will obtain your affirmative consent before placing non‑essential cookies (such as analytics or advertising cookies) on your device, as required by applicable law.

Global Privacy Control and Similar Signals.
 Some browsers and browser extensions allow you to send privacy preference signals, such as Global Privacy Control (GPC), to websites you visit. Our website infrastructure may not currently recognize or act on all such signals. We are evaluating these mechanisms and will honor browser‑based opt‑out signals to the extent required by applicable law as our tools and processes evolve. This section may be updated as our implementation changes.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the “Last Updated” date above. For significant changes, we may also notify you via email or in‑app notification. We encourage you to review this policy periodically.

14. Contact Us

If you have questions about this Privacy Policy or our data practices, or if you would like to exercise your privacy rights, please contact us:

Sola Studios, LLC (Settle)
 5900 Balcones Drive, Suite 100
Austin, TX 78731, USA

Email: help@withsettle.com

For privacy‑specific inquiries or rights requests, please email help@withsettle.com with the subject line “Privacy Request.”