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Everly legal

Privacy Policy

Effective date: 29 August 2026
Last updated: 29 August 2026

Everly respects your privacy and recognises that information shared through conversations with an AI companion can be highly personal.

This Privacy Policy explains how [LEGAL ENTITY NAME] ABN [ABN], trading as Everly (“Everly”, “we”, “us” or “our”), collects, holds, uses and discloses personal information in connection with the Everly mobile application, websites and web portals, telephone and voice services, AI conversations, diary, memory and conversation-summary features, family and carer features, subscriptions and purchased call minutes, customer support and related services.

This Policy describes our practices under the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and applicable State or Territory health privacy laws where they apply. Because Everly may receive health and other sensitive information through conversations, we take a cautious approach and design our practices on the basis that Australian privacy obligations for health and sensitive information may apply.

Everly
[LEGAL ENTITY NAME] ABN [ABN]
Privacy email: [PRIVACY EMAIL]
Support email: [SUPPORT EMAIL]
Website: [WEBSITE URL]
Postal address: [BUSINESS ADDRESS]

1. Who this Policy applies to

This Policy applies to personal information relating to people who interact with Everly: Account Holders who create or manage an account; Companions who primarily receive calls or have conversations; family members and carers with authorised access; and website, application and support-service users. The Account Holder and Companion may be the same person. Where one person establishes an account for another, this Policy applies separately to each person's information.

2. Our approach to privacy

We aim to collect only information reasonably necessary to provide Everly; explain when someone interacts with AI; give appropriate notice for third-party AI processing; seek separate consent where sensitive information requires it; respect a capable Companion's wishes; restrict family and carer access to authorised information; minimise raw-conversation collection and retention; avoid collecting information merely because it might later be useful; limit sensitive information sent to analytics and other providers; protect information with reasonable safeguards; and delete or de-identify it when no longer reasonably needed, subject to law.

3. Personal information; 4. Sensitive and health information

Personal information is information or an opinion about an identified or reasonably identifiable individual, whether or not it is true or formally recorded. For Everly, it can include contact information, family relationships, conversations, preferences, stories, activity and diary information.

Conversations may contain sensitive or health information, including dementia or cognitive impairment, physical or mental health, disability, medication, treatment, racial or ethnic origin, religious beliefs, sexual orientation, political opinions or other information classified as sensitive under Australian privacy law. A conversation can contain it even if nobody intended it to concern health. Where required, we obtain appropriate consent unless another lawful exception applies. Terms acceptance is not unlimited consent to every collection, use or disclosure; we collect sensitive information only where reasonably necessary for an Everly function or another lawful basis permits it.

5. Information we collect

5.1 Account, contact and Companion information

We may collect name, preferred name, email, telephone number, account identifier, login and authentication information, profile information, communication preferences and account settings. Where Everly is set up for another person, we may also collect their name, phone number, interests, conversational preferences, family relationships, information needed to personalise Everly, authorised-user information, and information about another person's authority or relationship where required.

5.2 Conversations, transcripts, diaries and memories

During a conversation, Everly processes spoken words. They may include life events, memories, family, friends, preferences, routines, interests, experiences, opinions, feelings, health, wellbeing and other personal matters. Voice audio is processed to conduct voice conversations. Everly does not intentionally store raw call audio in its own persistent application storage after a live conversation. Audio may be transmitted to telecommunications and AI providers, which may process or temporarily retain it under their configured services, contracts and legal requirements. If we introduce persistent raw-audio storage, we will give appropriate notice and obtain required consent first.

Everly may convert speech to temporary transcripts, summaries, diary entries, memories, mentioned names, interests, preferences, prior topics, important dates and other structured information. We distinguish temporary conversational information used to operate Everly from information intentionally retained as a memory, diary entry, summary or other user-facing feature. Where enabled, retained information may include stories, life events, relationships, interests and AI-generated summaries or diary entries. AI-generated information can be inaccurate; correct or delete it where functionality permits, or contact us for assistance.

5.3 Family, purchases, calls, devices and support

We may collect family or carer names, contact details, relationship to the Companion, invitation status, access permissions, account activity and reasonably required authority information. For subscriptions or Refill Minutes, we may receive product, status, transaction identifier, purchase date, renewal status, entitlement and minute-balance information. Marketplace payments do not ordinarily provide us complete payment-card information.

Everly and telecommunications providers may process originating and destination numbers, call identifiers, call times and duration, routing information, connection status, SIP or telecommunications metadata and technical call information. We may collect device/application identifiers, app version, operating system, IP address, browser, timestamps, crash and error information, network information and security events. Support interactions may provide contact details, request contents, relevant account and troubleshooting information, and correspondence.

5.4 Usage and analytics

We may collect only privacy-reviewed product and operational measures, such as controlled feature-use events, coarse device/app information, subscription tier, call-duration buckets and reliability outcomes. We use separate pseudonymous analytics identifiers rather than production database identifiers. We do not intentionally provide analytics providers with raw voice conversations, transcripts, diary or memory text, health information, names, contact details, raw URLs, free-form errors, AI prompts or AI-generated conversation responses.

6. Information we do not intentionally collect

Unless a feature specifically requires it with appropriate notice, Everly does not intentionally collect precise GPS location, a complete device address book, government identification documents, biometric identity templates, facial-recognition data or voiceprints used to identify a person. We process voice to conduct conversations, not to make a biometric identity profile, unless we separately disclose and lawfully introduce such a feature.

7. How we collect information

We collect information directly from you when you create or configure an account, communicate with Everly or contact support; from a Companion during calls or in-app conversations; from an Account Holder, authorised family member or carer authorised to provide information; automatically when an application, website or telecommunications service is used; from marketplaces and subscription providers to manage purchases; from telecommunications providers to establish calls; and from providers reasonably needed to operate, secure or support Everly.

8. Information about another person; 9. Capacity and supported decision-making

Only provide another person's information where you have an appropriate lawful basis or authority. Creating or paying for an account does not give unrestricted authority over a Companion's information. We may request information about the relationship, guardianship, enduring power of attorney, formal appointment or other authority recognised by law. Where the Companion can make the relevant privacy decision, we seek to respect it.

Dementia or another condition does not by itself mean a person cannot make every decision. Where reasonably practicable, Everly seeks to involve the Companion in decisions about the Service, memories, diaries, sharing, retention, access and withdrawal of consent. Where they cannot provide legally effective consent, we may obtain or disclose information to an appropriately authorised or legally recognised person where law permits, and may require evidence of authority before granting sensitive-information access.

10. Why we collect, use and disclose information

We use personal information where reasonably necessary to create and manage accounts; authenticate users; provide voice and text conversations; understand speech and generate AI responses; personalise and maintain continuity; create enabled memories, diary entries and summaries; manage authorised access; provide subscriptions and Refill Minutes; reconcile purchases; establish calls; provide enabled notifications and support; secure Everly; investigate fraud, abuse or unauthorised access; troubleshoot and improve reliability; comply with law and lawful requests; investigate incidents; and establish, exercise or defend legal rights. We do not use sensitive information for an unrelated purpose merely because we hold it.

11. Artificial intelligence services; 12. AI model training

Everly uses third-party AI and voice-processing services. Information necessary to provide a conversation may include live audio, text representing or derived from speech, relevant context, personalisation information and information needed for enabled features. We seek to limit it to what is reasonably necessary and use privacy-protective configurations appropriate to sensitivity. Providers may temporarily process or retain information under selected configurations and contracts. Before personal information is provided to an AI service, Everly will give notice and obtain required consent; a relevant notice may identify the provider, information, purpose, consequences of declining, recipient categories, overseas processing and this Policy. A material AI-processing change will lead to an updated Policy and additional notice or consent where required.

Everly does not use identifiable Companion voice information, conversations, transcripts, diaries, health information or other private conversation information to train general-purpose AI models. We seek contractual and technical arrangements limiting such provider use. We may use aggregated or appropriately de-identified information to improve performance, reliability and safety where permitted. A future materially different training use of identifiable personal or sensitive information will receive notice and required consent before use.

13. Family and carer sharing

Authorised sharing may include diary entries, summaries, memories, general activity information or information specifically available through the Service. Payment does not entitle an Account Holder to unrestricted private information. Where the Companion has capacity, we share only with their authority, where disclosure is reasonably expected and permitted by law, where another lawful basis applies, or where required by law. Where they cannot consent, disclosure occurs only as law permits; we may restrict or refuse access where an adequate lawful basis is unavailable.

14. Providers and disclosures; 15. Overseas processing

Trusted providers may include AI and voice processing, telecommunications and call routing, cloud hosting, storage and security, subscriptions and payments, analytics and monitoring, email and communications, support, professional advisers and platforms. They process information only as reasonably necessary for their Everly services or as law and our arrangements permit. We may provide more specific provider information in collection, AI-consent, permission, subscription or feature notices, or in response to an appropriate privacy request.

Everly is operated from Australia, but providers may use overseas infrastructure. Likely locations include the United States and United Kingdom; other countries may apply through global infrastructure and subprocessors. Where practicable, a current country list is available at [WEBSITE URL]/privacy/overseas-processing. Locations can depend on the service, routing, selected region, infrastructure and subprocessors. We take reasonable steps required by Australian privacy law to protect information with overseas recipients and review these disclosures after material changes.

16. Analytics; 17. Advertising; 18. Direct marketing

Analytics help us understand feature operation, use, reliability and general patterns, not create advertising profiles from sensitive conversations. We disable autocapture, session replay, automatic error/console collection, automatic page collection and IP/GeoIP enrichment. We do not intentionally send call audio, transcripts, diary or memory text, health details, Companion notes, AI prompts or AI responses to analytics providers.

Everly does not sell personal information or rent a Companion's health information, conversations, diaries, memories or profile to advertisers or data brokers, and does not currently use sensitive information for targeted advertising. Permitted direct marketing to an Account Holder will have an opt-out; transactional security, subscription, account, service and important privacy notices are not optional marketing. We do not use sensitive information for marketing unless law permits and required consent is obtained.

19. Push notifications; 20. Cookies

Enabled push notifications may use operating-system or platform providers for account or Service purposes. Because a notification can appear on a locked device, we seek to avoid unnecessary sensitive conversation or health detail in previews; change permissions in device settings. Websites may use cookies, local storage or similar technology to keep users signed in, maintain security, remember preferences, operate features and understand use. Required notices or choices will be provided. Third-party advertising cookies are not required for core companionship functionality.

21. Information security

We use reasonable technical and organisational safeguards against misuse, interference, loss, unauthorised access, modification and disclosure. Depending on the system, measures may include encrypted connections and stored information, access controls, authentication, secret management, logging, role-based permissions, network protection, backups, updates, monitoring and incident response. No internet-connected system is completely secure, so we seek to minimise sensitive-information amount and duration.

22. Retention; 23. Account deletion

Retention varies by purpose. Everly does not retain raw call audio in persistent application storage. Ordinary full transcripts, transcript-derived excerpts and redundant conversation summaries are deleted before 30 days unless an owner intentionally saves a transcript through an enabled feature.

Saved transcripts, diary entries and memories remain until an owner deletes them or the Companion account is deleted. Pseudonymous product analytics have a target maximum retention of 12 months and operational diagnostics a target maximum of 90 days; we verify and document the controls available from our deployed analytics provider. Call metadata and de-identified billing facts may be retained only for usage, accounting, fraud, disputes or legal obligations.

Any current household owner may request deletion of the entire Companion account. Everly suspends access immediately, provides a 24-hour support restoration window, then permanently deletes the Companion profile, content, photos, schedules, access relationships and Everly-controlled analytics mapping. Marketplace subscriptions must be cancelled separately through the marketplace.

24. Withdrawing consent; 25. Family-sharing permissions

Where processing relies on consent, you may withdraw it through available settings or by contacting us. Withdrawal does not affect prior lawful processing and may make some functionality unavailable, such as personalised memory continuity. Where available, a Companion or authorised person may review settings, approve or remove an authorised user, restrict information categories or withdraw sharing permission. Removing access prevents future access but cannot undo information lawfully viewed or received beforehand.

26. Access; 27. Correction; 28. Deletion requests

You may request access to information we hold. We may verify identity and authority, and aim to respond within a reasonable time, generally 30 calendar days. Australian law may permit refusal for some information, including unreasonable effects on another person's privacy; where required, we explain a refusal and complaint mechanisms. Request access at [PRIVACY EMAIL].

You may request correction of inaccurate, out-of-date, incomplete, irrelevant or misleading information, and may have in-app correction tools. We do not charge for correction requests and generally aim to respond within 30 calendar days. You may also request deletion of particular information without deleting an account; whether it can be deleted depends on service needs, others' privacy, transactions or disputes, legal retention and other permitted reasons. Contact [PRIVACY EMAIL].

29. Anonymity and pseudonyms; 30. Automated processing

Where practical, general enquiries may be made without identifying yourself, and a preferred name may work for some features. Anonymous service use can be impracticable when we need information to create accounts, authenticate access, connect calls, manage subscriptions, associate memories, manage permissions or protect sensitive information. We do not require extra identifying information where unnecessary.

Automated systems and AI understand conversations, generate responses and summaries, create diary entries, identify context and personalise interactions. Everly does not currently use information to make automated decisions significantly affecting legal rights or similar interests, such as healthcare, treatment, employment, insurance, credit, housing or legal entitlements. If that changes, we will assess impacts and update this Policy and relevant notices first.

31. Data breaches; 32. Legal disclosures; 33. Business transactions

We maintain processes to investigate, contain, remediate and assess suspected privacy or security incidents, and make notifications required by law. Where the Notifiable Data Breaches scheme applies to an eligible breach, we notify affected individuals and the Office of the Australian Information Commissioner as required, along with applicable State or Territory health-data obligations.

We may use or disclose information as reasonably necessary or permitted by law: where required or authorised by Australian law, in response to a valid court or tribunal order, to investigate fraud/unlawful activity, protect Everly security, establish/exercise/defend rights, or address a serious threat where law permits. We do not voluntarily provide sensitive information merely because someone asks. In a merger, acquisition, restructuring, financing or sale, information may be disclosed where law permits, with appropriate confidentiality and privacy protections; any new operator remains subject to applicable privacy obligations.

34. Children

Everly is primarily for adults and older people; Account Holders must be at least 18. We do not knowingly collect sensitive information directly from children without appropriate authority and safeguards. Contact us if you believe a child unexpectedly provided information.

35. Privacy complaints

To complain, contact [PRIVACY EMAIL] or [BUSINESS ADDRESS] with enough information to investigate. We will acknowledge complaints as soon as reasonably practicable and aim to investigate and provide a substantive response within 30 days; if more time is needed, we will explain why and provide a timeframe. If unsatisfied, you may complain to the Office of the Australian Information Commissioner (OAIC), oaic.gov.au, telephone 1300 363 992. A State or Territory privacy or health-privacy regulator or other dispute body may also have jurisdiction.

36. Changes; 37. Accessibility; 38. Contact us

We update this Policy where reasonably necessary for material changes to collection, use, sharing, AI processing, provider categories, overseas processing, retention or law. The date at the top shows the most recent update. Where a change materially affects sensitive-information handling or consent, we will provide additional notice and obtain required new consent. An infrastructure or provider change does not necessarily require an update where the processing, recipient category and implications remain materially the same.

Everly is intended to be usable by older people and people with accessibility needs. To request this Policy in an accessible format, contact [PRIVACY EMAIL]; we will take reasonable steps to provide it appropriately.

Everly
[LEGAL ENTITY NAME] ABN [ABN]
Privacy contact: [PRIVACY CONTACT / PRIVACY OFFICER]
Email: [PRIVACY EMAIL]
Support: [SUPPORT EMAIL]
Website: [WEBSITE URL]
Postal address: [BUSINESS ADDRESS]

Privacy summary

  • Everly is an AI companion, and conversations can contain highly personal and sensitive information.
  • Everly does not intentionally store raw call audio in its own persistent application storage after a live conversation, although telecommunications and AI providers may process voice information to provide the conversation.
  • Everly uses third-party AI and voice services. Relevant provider information is identified in applicable privacy or consent notices where appropriate.
  • Everly does not use identifiable Companion conversations, diary information or health information to train general-purpose AI models, does not sell personal information, and does not intentionally send conversations or health information to product analytics providers.
  • Family members do not gain unrestricted access merely by creating or paying for an account; we seek to respect a capable Companion's privacy decisions.
  • Providers for AI, telecommunications, cloud infrastructure, subscriptions, analytics and platforms may process some information outside Australia.
  • You can request access, correction or deletion, withdraw applicable consent, or make a privacy complaint by contacting Everly.