Privacy Policy

1. Who we are and what this policy covers

WINR Games Inc. (“WINR Games”, “we”, “us” or “our”) operates Patch, an AI companion for voice and typed conversations. We are responsible for the personal information we collect and determine how it is used for Patch. Where applicable data-protection law uses the term, we are the controller.

This policy covers Patch’s mobile and tablet apps, accounts, conversations, purchases, memory features, notifications and related customer support. It explains what we collect, why, who processes it, how long it is retained and your choices. It does not govern a Store, sign-in provider or external service acting independently under its own privacy notice.

The Privacy Officer can be reached at info@meetpatch.app (attention: Privacy Officer). WINR Games Inc. is based in Toronto, Ontario, Canada. We can provide this policy in an accessible format on request.

2. The most important facts

• Patch is AI. Your messages and live speech are processed by our systems and contracted AI or speech providers so Patch can respond and remember relevant context.
• We do not save raw conversation audio in Patch’s own systems. We do save text transcripts, which can include what you say, what you type and Patch’s replies. Provider processing and retention are separate and explained in Schedule B.
• Transcripts and memories can be linked to your account. They are personal information, even if we use an internal identifier or remove your name from a particular request.
• Information from conversations may be sensitive, including information about health, mood, relationships, beliefs and other private matters. Share only what you choose and avoid identifying other people unnecessarily.
• Our Firebase behavioural analytics events do not include the words in your conversations. Analytics identifiers may still be personal information.
• You can request access, correction, export or deletion. Stopping payment, deleting a visible item and deleting your account are different actions, as explained below.
• We do not sell personal information, use private conversations for targeted advertising, or train general-purpose AI models on your conversations. The details and boundaries are in section 6.

3. Information we collect and its sources

We receive information directly from you, from your device and use of Patch, from Apple or Google for sign-in and purchases, and from the AI processing that creates responses, summaries and memories. Schedule A connects each category to its purposes and recipients.

Account and onboarding information. This includes the name or preferred name you give us, the account identifier and email made available by your sign-in provider, any Apple private relay email used, profile details you choose to add, authentication and session information, onboarding answers and completion status. Apple or Google may provide only some of these fields depending on your choices. We do not receive your sign-in password.

Conversation information. When you use voice, audio must be transmitted and processed during the session. We retain text transcripts of conversations and related session information, such as times, duration, interruptions or completion. Typed messages and AI replies form part of the conversation record. A conversational onboarding flow also processes personal information even when no transcript is displayed on screen.

Memories and app records. We process summaries, preferences, topics and follow-up information derived from conversations; Threads and their steps and status; Keepsakes and return times; open loops; greetings based on context; check-in selections; Quilt events, dates and captions; and notification content. Some of this is generated or inferred by AI, rather than directly stated by you, and it may be wrong. A Keepsake confirmation is not the only way information becomes part of Patch’s memory.

Sensitive information. Depending on what you share and how it is summarized, conversation records may reveal physical or mental health, emotional state, disability, intimate relationships, sexuality, religion, ethnicity, financial difficulties or other sensitive matters. Mood check-ins explicitly capture a chosen emotional state. We do not need identity documents, full payment-card details or passwords for conversations; please do not include them.

Device and usage information. We process technical and operational data needed to connect your device, keep the Service working, measure use and enforce plan allowances. This may include IP address, app and operating-system version, device type, language, time zone, app-instance or device identifiers, session timestamps, feature interactions, connection failures and error or performance information.

Notification settings. These include permission status, the device’s push token, time zone, daypart choices, quiet hours and delivery or interaction information. Notification text may contain personal context from a conversation.

Purchase information. We receive Store transaction identifiers or receipts, product and plan identifiers, entitlement status, purchase and renewal dates, trial eligibility and relevant billing, refund or cancellation status. The Store processes payment-card or bank details under its own policies; we do not receive your full payment-card details through in-app billing.

Support and rights requests. We collect the contact information, correspondence, problem description and attachments you send us, relevant technical details, and records of how we resolve the request. If you submit an AI-response report, it can include the reported response and relevant context identified in the reporting flow.

Consent and eligibility records. We record the choices necessary to respect your permissions and demonstrate compliance, such as acceptance and consent versions, timestamps, withdrawal requests, arbitration opt-out notices and age-eligibility confirmation.

Patch does not currently offer therapist access, public conversation sharing or a social feed as part of the features described here. We do not request your contact book, precise GPS location, photo library or health-platform records for the current companion features. Voice is processed for conversation, not to create a voiceprint for identifying you. If a new feature needs additional information or permission, we will explain it before collection.

4. Why we use information

We use account and authentication information to create and protect your account, remember onboarding status, sync your experience across supported devices and respond to requests.

We use conversation content, transcripts and relevant memories to understand a message, generate a reply, transcribe speech, synthesize a voice response, maintain conversational context and provide the memory-based features you request. We use check-ins and app records to provide Threads, Keepsakes, Quilt entries, greetings and follow-up prompts. Those functions personalize Patch using information and inferences about your interests or circumstances.

We use subscription and usage information to validate purchases, restore entitlements, apply disclosed conversation allowances, process billing support and prevent misuse of free offers.

We use notification settings and relevant context to deliver the nudges you enable. We use account contact information for important service, security, privacy and billing notices. We do not send promotional email or text messages without the consent or other permission required by law, and any optional marketing message includes an appropriate opt-out.

We use limited operational records to prevent unauthorized access and fraud, investigate errors and abuse, maintain reliability, respond to reports, protect safety, comply with law and establish or defend legal claims. Access to conversation content for these purposes is restricted as explained in section 7.

We use behavioural analytics to understand which features work and where flows fail. Analytics events exclude the words in your conversations. The specific analytics choices and identifiers are described in section 8. New unrelated uses of sensitive information require a separate legal basis and, where required, fresh express consent.

5. How AI and speech processing work

Patch can operate using a speech-to-speech system, or a combination of speech recognition, language models and voice synthesis. A voice request may therefore involve audio becoming text, text and relevant memories being processed to generate a reply, and that reply becoming speech. Typed conversations omit the input speech-recognition step but may still produce a spoken reply. Multiple contracted providers may perform different parts of this process.

Information sent to a provider can include live audio, typed messages or transcripts, relevant conversation history, summaries and memories needed for the current response, instructions, session identifiers and technical metadata. We limit what we send to what is appropriate for the function. Text-to-speech providers may receive reply text that itself contains personal information. Replacing a name with an internal identifier does not eliminate the sensitivity of that content.

Schedule B identifies the current material providers and the functions they perform. At present, Patch uses xAI’s Grok service for speech-to-speech conversations. The main policy does not commit to a particular model name or version. We can change, add or combine providers, provided we maintain the protections promised here, update relevant disclosures and obtain any additional permission required before the affected processing begins. Continued use alone is not a substitute for required express permission to share personal data with a new AI provider.

Before sending conversation information to a third-party AI provider, we explain the relevant data and recipient and request the permission required by applicable law and platform rules. If you do not permit processing necessary for a conversational feature, that feature cannot operate. Declining optional analytics or notifications does not, by itself, prevent basic conversation access under an eligible plan.

AI-generated information can be inaccurate. We offer access and correction routes for retained personal information, including relevant inferences. Patch is not intended to make decisions about employment, credit, insurance, healthcare eligibility or other matters with legal or similarly significant effects. Any automated account or safety restriction can be referred to support for human review. We will disclose a different significant automated-decision practice before introducing it and provide any rights required by law.

6. Training, advertising and de-identification

Our commitments:

• We do not sell your personal information, disclose it for cross-context behavioural advertising, or use conversation content, memories or check-in information to build advertising audiences.
• We do not use your private conversation content to train or fine-tune general-purpose AI models, and do not authorize our AI or speech providers to do so. Using context to answer you or create your personal memories is not the same as training a model.
• We do not enable a provider’s optional contribution of your content for model improvement. If we propose an optional research or training program in the future, it will require a distinct notice and affirmative choice, and will not begin merely because we update this policy.
• We do not create a publicly accessible transcript dataset or use private conversation excerpts in marketing without separate permission.
• We may use aggregate operational statistics, such as the percentage of sessions affected by a connection failure, to evaluate reliability and product use. Where we call data “anonymous”, it must no longer reasonably identify a person under applicable law. We apply appropriate safeguards and do not attempt to re-identify genuinely anonymized data, except where law permits testing the effectiveness of safeguards.

An account-linked transcript, an AI memory, an internal identifier or a record with names removed remains personal information when a person can reasonably be identified or the record can be reconnected to their account. A proposal to use conversation-derived datasets beyond the purposes described here requires a separate assessment and disclosure.

7. Who can receive or access information

Contracted service providers. We use providers for AI and speech processing, hosting and storage, authentication, notifications, analytics and support, as applicable. We give them access appropriate to their functions and require contractual safeguards and restrictions suitable for the information. Schedule B identifies our current providers and describes their roles and processing arrangements. We remain responsible for information entrusted to processors as applicable law requires.

Our personnel. Authorized personnel may access limited personal information when necessary to resolve a support request, investigate a specific security or safety issue, meet a legal obligation or maintain the Service. Conversation-content access is restricted to personnel who need it for an approved purpose, subject to confidentiality, access controls and audit procedures. We do not conduct routine human review of private conversations for product research. If we introduce an optional review program, we will explain it and obtain any required separate permission before it begins.

Stores and sign-in services. Apple and Google receive information needed to deliver their own sign-in, purchase and platform services and act under their own policies for those functions. We process purchase tokens and entitlement information supplied by the relevant Store to validate purchases. We do not send conversation content to a Store merely to verify a purchase.

At your direction. If you export information or send a report or attachment, the recipient or destination you choose receives that information. Keep exported files secure. Your own sharing may place copies beyond Patch’s deletion controls.

Legal and safety circumstances. We may disclose the minimum information reasonably necessary when required or permitted by law, such as in response to a valid legal demand, to protect rights, or to address an emergency threatening someone’s life, health or security. We assess requests and give notice when appropriate and lawful. This does not mean that Patch has human emergency monitoring or guarantees intervention.

Business changes. Personal information may be transferred in a proposed or completed merger, financing, acquisition, restructuring or sale only with the safeguards, purpose restrictions and notices required by applicable law. Prospective recipients must protect the information appropriately, and a transaction does not itself authorize new advertising or training uses.

We do not routinely provide conversations to your therapist, employer, family or friends. No affiliation with another company is, by itself, permission to share your private content with it for its own purposes.

8. Permissions, analytics and device privacy

Microphone permission is used for voice conversation. You can deny or revoke it in device settings and use typing where available. We do not use microphone permission to listen continuously when you are not using a voice feature. Permission to access the microphone is separate from permission for third-party AI processing.

Notifications are optional. You can manage available nudge settings inside Patch and notification permission and preview visibility through your operating system. A personalized nudge may reveal a sensitive subject to anyone who sees your screen, smartwatch or notification history. Turning notifications off stops future delivery as implemented by the device; it does not delete the source memory or copies already displayed.

Patch uses Google Analytics for Firebase to report behavioural events. Our analytics events exclude conversation content. App-instance identifiers, event history, purchase events and device characteristics may still be personal information. We use analytics for product measurement, not advertising. We do not collect advertising identifiers for this purpose or enable personalized-advertising uses of Patch analytics.

Optional product analytics are off until you choose to allow them, and you can change that choice in Patch’s privacy settings. Necessary service and security records are processed separately. Disabling optional analytics does not remove information already lawfully collected; you can request deletion where applicable. No conversation text, names, email addresses, check-in values, health inferences or sensitive notification text is placed into behavioural analytics events. We configure event-level analytics retention to two months. Google removes expired records through its monthly deletion cycle, which can extend actual removal beyond the configured period. Aggregate statistics that do not identify you may be kept longer.

The backend holds Patch’s account and memory records. The app keeps limited cached information so it can display some screens offline; the current app does not store conversation transcripts in its local cache. Exports, screenshots, notification history and device-level backups that you create or control can contain information separately from our backend. Protect your device and take care when sharing it.

9. Where information is processed

WINR Games is based in Canada. Our primary backend is hosted by Amazon Web Services in its US East region in the United States. Our AI, analytics and platform providers may process information in the United States and other countries where they or their authorized service providers operate. Schedule B describes the current providers and their roles.

Information processed outside your province or country may be subject to the laws of the destination and accessible to its courts, law-enforcement or national-security authorities. We assess transfers and use contractual and other safeguards required by the laws that apply. A consent to use Patch is not a waiver of those safeguards.

Where European, UK or Swiss transfer rules apply, we use an applicable adequacy decision or appropriate contractual transfer mechanism and supplementary measures where needed. Contact the Privacy Officer for information about relevant safeguards or a copy where legally available, with confidential details redacted as appropriate.

10. How long information is retained

We retain personal information only for an identified purpose and an appropriate period, considering the sensitivity of the information, account activity, the feature you requested, legal requirements, disputes and security needs. Not every record needs the same period. The following schedule applies to ordinary operations. The limited exceptions below apply only where necessary and lawful. Scheduled deletion removes data from active systems; residual backups follow the separate backup rule.

Deleting a visible Thread, completing a step, resolving a Keepsake or disabling a nudge may change that feature’s record without automatically erasing the original transcript, independent summaries or related Quilt entries. Contact the Privacy Officer for deletion of the underlying personal information. The deletion control explains which records it removes.

Cancelling a subscription does not by itself delete your account or retained content. Information retained after a subscription lapses remains subject to this schedule and your rights. We do not keep records indefinitely just because you might subscribe again.

11. Account deletion and what remains

In the app, use the account-deletion control in Patch’s privacy settings and follow the confirmation steps. You may need to reauthenticate, including through Apple where applicable. You can also request deletion without reinstalling the app by emailing info@meetpatch.app with the subject “Patch account deletion”. We take reasonable steps to verify that the request is yours; we will not ask for unnecessary sensitive identity documents.

After a verified deletion request, we close the account and remove associated personal information from active systems within 30 days. This includes retained transcripts, summaries, derived memories, open loops, Threads, Keepsakes, check-ins, Quilt data, notification schedules and identifiers, subject to the limited exceptions described here.

We notify relevant contracted processors to delete information under our control in accordance with applicable law and their processing arrangements. Provider content that was never persisted does not require deletion from a retained content store. Schedule B describes current provider content-retention arrangements.

Limited information may remain where reasonably required for tax or accounting obligations, a specific legal hold, dispute, fraud or security investigation, or to document consent, deletion or other compliance activity. We isolate retained information, limit access and use to that purpose, and delete it when the justification ends. We will explain any applicable restriction on your request, subject to law.

Residual backup copies are removed within the backup period in section 10. If a backup is restored, we reapply deletion requests before using restored information for normal service operations. Copies you exported or shared, and records a Store must retain independently, are outside our direct control.

Deletion does not necessarily cancel Apple or Google Play billing. Cancel the subscription through the purchasing Store as explained in the Terms. We make billing help available during deletion. You do not have to keep your account or your private conversations merely to exercise cancellation or billing rights.

12. Your choices and privacy rights

You can use the available account controls to update profile details, adjust nudges and permissions, export data or request erasure. The in-app export is a convenient product feature; a formal access request can include personal information beyond what a particular export screen displays.

You may contact the Privacy Officer to request access to information we hold about you, an explanation of its uses and disclosures, correction of inaccurate information, or deletion. You may also withdraw consent to consent-based processing, subject to lawful restrictions explained to you. If you withdraw permission necessary for conversation processing or memory, affected features may no longer work. We will not force you to accept an unrelated optional use to obtain the core service.

Withdrawal does not retroactively make earlier lawful processing unlawful. We stop the affected future use and explain what information must still be retained and why. Where asking Patch to forget something does not trigger the verified privacy process, use the Privacy screen or contact us instead.

We verify requests proportionately, using existing account information where possible. We respond within the period required by the law that applies. For a PIPEDA access request, this is normally 30 days, with only a legally permitted extension and notice. We explain a refusal or partial response and the available complaint route, unless law prevents us from doing so. Any fee is limited to what law permits and is explained in advance; requests are generally handled without charge.

Where permitted by law, an authorized representative may act for you after we verify their authority. Exercising privacy rights will not result in unlawful discrimination. You may complain to the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/ or to the competent provincial or other privacy regulator; you do not have to contact us first.

13. Additional regional rights

These provisions apply only where the relevant law applies to you and our processing. They do not represent that every law applies to every user or that the app is offered in every territory.

Québec. Contact our Privacy Officer regarding access, rectification, withdrawal of consent and other applicable rights, including qualifying portability requests. Where required, we inform you about identification, localization or profiling technologies and available activation controls, obtain express consent for sensitive information, and assess relevant transfers outside Québec. You may complain to the Commission d’accès à l’information at https://www.cai.gouv.qc.ca/. Any applicable rights concerning a decision based exclusively on automated processing are preserved.

United States. Depending on your state and the law’s scope, you may have rights to know or access categories and specific personal information, correct it, delete it, obtain a portable copy, opt out of sale, targeted advertising or certain profiling, limit certain sensitive-information uses, withdraw consent, or appeal a decision about a request. Submit a request or appeal to info@meetpatch.app, or use the in-app Privacy controls. We explain verification, timing, any lawful exception and an available regulator complaint route in our response.

The no-sale and no-targeted-advertising commitments in section 6 apply across Patch. Where a legally recognized opt-out preference signal applies to a relevant processing activity, we honour it as required. For the preceding 12 months, or the shorter time Patch has been operating, the applicable categories collected and disclosed for business purposes are those described in this policy and Schedule A: identifiers and contact information, commercial information, internet or app activity, audio and other user content, and sensitive information and inferences where provided or generated. We have not sold this information or shared it for cross-context behavioural advertising. We use sensitive information for the requested service and the limited purposes described here, not unrelated advertising.

Consumer health data. Mood selections, private conversations and inferences may be consumer health data even though Patch is not a medical service. Where applicable, you can ask whether we collect or disclose that data, request access or deletion, withdraw consent, and appeal a refusal by emailing info@meetpatch.app. We do not sell consumer health data or use it for advertising. Additional consumer-health-data notices and consent requirements apply where required by local law; those protections supplement this policy.

EEA, UK and Switzerland. Where applicable, rights may include access, rectification, erasure, restriction, portability, objection and withdrawal of consent, as well as a complaint to your local supervisory authority. Contact the Privacy Officer to exercise them. We normally respond within one month where the GDPR or UK GDPR applies, with extensions only as those laws permit. Our Privacy Officer is your contact at info@meetpatch.app. Any legally required local representative and contact details will be identified in the regional notice available to you when the Service is offered in your market.

For processing subject to the GDPR or UK GDPR, we rely on: contract necessity for essential non-sensitive account, transaction and requested service functions; explicit consent for sensitive conversation and mood information, including relevant AI-derived health information; consent for optional analytics or optional marketing where required; legitimate interests for proportionate non-sensitive security, fraud prevention and service administration, after balancing your rights; and legal obligation for required records and disclosures. Sensitive information also requires a valid additional legal condition; general contract or legitimate-interest language alone is insufficient.

14. Children and age eligibility

Patch is intended for people who are at least 18 and have reached the age of majority where they live if that age is higher. We do not knowingly offer accounts to people below that threshold.

If we learn that an ineligible person has an account, we take appropriate steps to restrict access and delete their personal information, subject to a limited legal preservation requirement. If you believe a child has provided information to us, contact info@meetpatch.app. An adult discussing family life should avoid providing identifying details about a child unless necessary and lawful.

15. Security and confidentiality

We use administrative, technical and physical safeguards appropriate to the sensitivity of the information. These include encrypted connections, encryption of stored sensitive content, restricted access, separation of duties where appropriate, access review, protection of credentials and an incident-response process. Access to sensitive content is limited to approved purposes.

Authorized Patch systems and AI processors access conversation content to provide the Service. Encryption protects transmission and storage; it does not prevent that processing.

No service can guarantee perfect security. If an incident occurs, we investigate, take appropriate containment and remediation steps and notify affected people, regulators and others when required by applicable law. Keep your sign-in account and devices secure, and report suspected unauthorized access to info@meetpatch.app.

16. Changes to this policy

We update this policy when our practices or legal requirements change, including when we add or replace an AI or speech provider. We publish a new revision date and give prominent notice of a material change through the app or another appropriate channel. Where required, we obtain new express consent before beginning the changed processing.

A revised policy does not retroactively authorize a new use of information that needed consent. For a new optional use of sensitive information, we ask separately. The provider schedule can be maintained separately for clarity, but changing it does not bypass notice, permission, contractual or transfer requirements.

Schedule A. Data Uses

This schedule is part of the policy. The provider arrangements are described in Schedule B. Information is not automatically provided to every listed recipient.

Schedule B. Current service providers and processing

Live processing can involve temporary buffers and technical or billing metadata even when conversation-content retention is disabled. Zero Data Retention at an AI provider does not mean that Patch’s transcripts, memories or operational account records are deleted immediately.

We may add or replace speech recognition, language generation, voice synthesis or other contracted processors. Before new personal-data routing begins, we update this schedule and the relevant in-app disclosure, complete appropriate provider and transfer checks, and obtain any permission the law or Store rules require.

Provider reference information:

• xAI business terms: https://x.ai/legal/terms-of-service-enterprise
• xAI data processing addendum: https://x.ai/legal/data-processing-addendum
• xAI API security: https://docs.x.ai/developers/faq/security
• AWS privacy: https://aws.amazon.com/privacy/
• Firebase privacy and security: https://firebase.google.com/support/privacy
• Apple privacy: https://www.apple.com/legal/privacy/
• Google privacy: https://policies.google.com/privacy

These provider notices do not replace our disclosures or make you a party to our supplier agreements.

Contact the Privacy Officer

WINR Games Inc., operator of Patch

Toronto, Ontario, Canada

Email: info@meetpatch.app

For deletion, use the subject “Patch account deletion”. For other access, correction, consent or privacy questions, use “Patch privacy request”.