Instead of dense legal language designed to protect us, this document outlines our commitments to you, written in plain English.
Documents Index
Your Data RightsOur CommitmentsWhat We Never DoHow the AI Assistant WorksData PortabilityAccount DeletionWho Can Use PholuSubscriptions and BillingCopyright and Reporting InfringementDispute ResolutionView Privacy PolicyComplete Ownership: All photos, voice recordings, journal entries, and memories you create belong to you. Pholu claims no rights over your content.
No Advertising: We never analyse your memories for advertising, behavioural profiling, or sale to third parties. Pholu is subscription-funded only.
Encryption Commitment: Your memories are encrypted on your device with keys we never hold, which protects them against database breaches and unauthorised access. Hardware-backed vault encryption with the Pholu Key is still in development, and we will say so plainly until it ships.
Offline-First: We commit to keeping Pholu usable without internet. Your memories stay available on your device regardless of our server status.
No Unencrypted Upload: Your memories are encrypted on your device before syncing to the cloud. We do not have access to unencrypted content.
No Content Surveillance: The app ships without advertising or third-party analytics SDKs. We never monitor what you write, photograph, or say inside the app.
Scoped Context: When you use the assistant, your request is proxied through our backend to a third-party model provider, along with only the memories relevant to what you asked.
No Training: Your content is never used to train a model, and the assistant is optional. Each plan includes a monthly request allowance, listed on the pricing section.
Full Export: At any time you can export your complete archive from inside the app, with your photos, videos and audio embedded so the backup stands on its own.
Full Deletion: You can delete your account from inside the app. Your memories, media, profile and shared space content are permanently removed from our servers, and the process completes within 30 days.
Sixteen or over: You need to be at least 16 to hold a Pholu account, and we ask you to confirm it when you sign up. Sixteen is the highest age any country in the EU sets for agreeing to a service like this on your own behalf, so we ask once, for the strictest of them, rather than a different question in every country.
Children in your memories are a different matter: Photographs and recordings of your family, including your children, are yours to keep here. This is about who holds the account, not who appears in it.
If you believe someone under 16 holds an account, write to support@pholu.app. We will close it and delete what it holds.
Where the money goes: Paid plans are bought inside the app and billed by the App Store or Google Play, not by Pholu. We never see your card.
Automatic renewal: A subscription renews automatically at the price shown when you bought it, and the next payment is taken on the renewal date, until you cancel. A monthly plan renews every month, a yearly plan every year.
Cancelling: Cancel in the App Store or Google Play, at least 24 hours before the renewal date. Cancelling stops the next payment; the period you have already paid for runs to its end, and nothing changes until it does.
Free trials: Where a free trial is offered, it becomes a paid subscription when it ends, unless you cancel before then.
Price changes: If the price of a plan changes, the App Store or Google Play tells you before it applies to your subscription, and asks you to agree where the store requires it. A change never applies to a period you have already paid for.
Refunds: Refunds are issued by the App Store or Google Play, because they took the payment — ask them rather than us. Your statutory rights as a consumer are unaffected.
When a subscription ends: Your memories are not deleted. The archive on your device stays exactly as it is, and the parts of Pholu that need a paid plan — cloud backup, inviting people into a shared space, the larger AI allowance — stop until you take one again. Export works on any plan, including the free one.
What you upload stays yours: You keep ownership of everything you put into Pholu. By uploading it you confirm you have the right to store it, and to share it with whoever you share it with.
Reporting an infringement: If you believe something held in a Pholu shared space infringes your copyright, write to our copyright agent at support@pholu.app with "Copyright" in the subject line. Tell us which work is yours, where in Pholu the material is, how to reach you, that you believe in good faith the use was not authorised by you or by law, and that what you have told us is accurate and that you are the owner or are authorised to act for them.
What we do with it: We remove or disable access to material that is the subject of a valid notice, and we tell whoever uploaded it. If they believe the removal was a mistake they can send a counter-notice to the same address, and we will pass it on to the person who complained.
Repeat infringers: An account that repeatedly infringes somebody else’s copyright is closed.
Our designated agent: Ricardo Vanildo Lourenço Da Costa, Pholu, 56 Broom Terrace, Leeds LS10 3JT, United Kingdom. Telephone +44 7459 787257. Email support@pholu.app. Notices should be addressed there. The designation is on file with the United States Copyright Office under registration number DMCA-1081599, effective 1 October 2026.
Where this comes from: This is the notice-and-takedown procedure set out in section 512 of the US Copyright Act, and it is also how we handle notices under the equivalent hosting provisions of UK and EU law.
Fair Resolution: Disputes are handled transparently under UK law. We aim to resolve issues directly and honestly, and where we cannot, standard UK consumer protection applies.