Privacy Policy

Effective Date: February 25, 2026 · Last Updated: February 25, 2026

1. Introduction and Scope

SLTR Digital LLC (“SLTR Digital,” “Company,” “we,” “our,” or “us”) is committed to protecting your privacy and the security of your personal information. This Privacy Policy describes how we collect, use, disclose, store, and safeguard information when you access or use any of our services.

This Policy applies to all products, services, websites, and applications operated by SLTR Digital LLC, including but not limited to:

  • Caelia — an AI video ad studio (caelia.io)
  • Nourished by Mira — an adaptive nutrition app for GLP-1 medication users (nourishedbymira.com)
  • driftLAB HQ — a personal scheduling workspace (driftlabhq.com)
  • Our corporate website at www.sltrdigitalstudio.com
  • Any future products, services, websites, or applications we may develop or operate

By accessing or using any of our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please discontinue use of our Services immediately.

2. Definitions

  • “Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an identified or identifiable natural person or household.
  • “Sensitive Personal Data” means Personal Data that reveals racial or ethnic origin, sexual orientation, health information, financial account data, precise geolocation, biometric identifiers, or other categories designated as sensitive under applicable law.
  • “Processing” means any operation performed on Personal Data, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
  • “Services” means all websites, applications, platforms, features, and related offerings operated by SLTR Digital LLC.
  • “User,” “you,” or “your” means any individual who accesses or uses our Services.
  • “Device” means any computer, mobile phone, tablet, or other electronic device used to access our Services.
  • “Service Provider” means a third party that processes Personal Data on our behalf pursuant to a written agreement.

3. Information We Collect — General

Across all of our Services, we may collect the following categories of information:

a. Information You Provide Directly

  • Account registration data (name, email address, password, phone number)
  • Profile information you choose to provide
  • Communications with us (support tickets, emails, feedback forms)
  • Survey or research participation responses
  • Payment and billing information (processed by third-party payment processors)

b. Information Collected Automatically

  • Device information (device type, operating system, unique device identifiers, browser type and version)
  • Usage data (pages visited, features used, click patterns, session duration, referring URLs)
  • Network information (IP address, Internet service provider, general geographic location derived from IP)
  • Log data (access times, error logs, diagnostic data)
  • Cookies, pixels, and similar tracking technologies (see Section 19)

c. Information from Third Parties

  • OAuth and single sign-on providers (e.g., Apple, Google)
  • Analytics providers
  • Payment processors (transaction confirmation, not full card numbers)
  • Public databases and data aggregation partners (where permitted by law)

4. Information We Collect — Nourished by Mira

Nourished by Mira is designed to keep most data on your device. The full details are in the Nourished by Mira Privacy Policy at nourishedbymira.com/privacy. In summary:

  • On-device only — body composition records, progress photographs, meal records and plans, training logs, tolerance and symptom logs, grocery lists, pantry inventory, nutrition logs, provider reports, and private journal entries are stored only on your device. We cannot access or recover this data.
  • Health platform — with your permission, the app reads body weight, lean body mass, and body fat percentage, and writes dietary calories and protein. This data is held in memory only during active use and is never stored or transmitted.
  • Optional cloud sync — only if you choose to sync: your profile (age, biological sex, current and goal weight, anonymized medication class and dosage tier, training level, dietary mode, and nutrition targets), nutrition logs, symptom logs, and pantry items.
  • Mira AI companion — your message text plus anonymized medication class, dosage tier, and derived nutrition metrics are sent to an AI service to generate a response. Your name, email, age, weight, photos, journal entries, and location are never sent. Conversations are not stored or used to train AI models.
  • Not collected — location data, advertising identifiers, contacts, payment card data, or cross-app tracking data. The app contains no third-party analytics, advertising, or tracking software.

5. Information We Collect — Caelia

Caelia works with photos of faces and the videos made from them. The full details are in the Caelia Privacy Policy at caelia.io/privacy. In summary:

  • Inputs and outputs — photos, audio, and text you provide to create videos, and the videos generated from them. Location metadata is removed from uploaded images before storage.
  • Facial data — temporary measurements of facial features computed only to animate a face, processed only after your express consent and destroyed as soon as the video is generated, and in every case within 24 hours (see Section 17).
  • Consent records — records of your biometric consent, your confirmation that you have permission to use the people in your photos, and your age confirmation.
  • Purchases — credit pack, transaction identifier, date, country, and refund status from Apple, RevenueCat, or Stripe. We never receive your full card number.
  • Usage, device, and safety data — features used, generation requests, errors, device and app version, IP address, and results of automated checks for prohibited content. Caelia does not access your advertising identifier or track you across other apps or websites.
  • No training — your photos, audio, text, videos, and facial data are never used to train or improve any AI model, and are never used for marketing or made public.

6. Information We Collect — driftLAB HQ

The full details are in the driftLAB HQ Privacy Policy at driftlabhq.com/privacy. In summary:

  • Account and content — your email address and the tasks, notes, dates, tags, and “Who” labels you create. Sign-in uses one-time email codes; no passwords are stored.
  • Drift AI — your messages, recent conversation history, and the task and calendar details needed to answer are sent to Amazon Bedrock, which does not use them to train any model. Conversations are stored until you delete your account.
  • Google connector — if you connect Google, OAuth tokens for calendar access and send-only Gmail access are stored server-side. driftLAB HQ cannot read your Gmail. Use of Google data follows the Google API Services User Data Policy, including Limited Use.
  • Connected mailboxes — if you connect a non-Google mailbox, its app-specific password is stored encrypted, and your inbox is read live to display it and answer Drift AI requests. Email contents are not stored.
  • Analytics — cookieless site analytics (Plausible) and, where configured, product analytics (PostHog) tied to your account identifier and email, never to your content.

7. How We Use Your Information

We use the information we collect for the following purposes:

  • To provide, operate, maintain, and improve our Services
  • To personalize your experience and deliver relevant content and recommendations
  • To process transactions and send related information (receipts, confirmations)
  • To communicate with you about updates, security alerts, support, and administrative messages
  • To verify your identity and prevent fraud, abuse, and unauthorized access
  • To monitor and analyze usage trends to improve functionality and user experience
  • To enforce our Terms of Service and other legal agreements
  • To comply with applicable laws, regulations, legal processes, or governmental requests
  • To protect the rights, property, and safety of SLTR Digital, our users, and the public
  • For Caelia: to generate, store, and deliver your videos, manage your credit balance, and detect and prevent prohibited content, fraud, and misuse of likeness
  • For Nourished by Mira: to calculate personalized nutrition targets, generate meal plans and grocery lists, power the Mira AI companion, and back up data you choose to sync
  • For driftLAB HQ: to store and sync your workspace, run Drift AI requests, and operate the calendar and email connections you choose to enable

9. Sharing and Disclosure

We do not sell your Personal Data. We do not sell or share your data for cross-context behavioral advertising.

We may share your information in the following circumstances:

  • Service Providers — third parties who perform services on our behalf (cloud hosting, analytics, payment processing, customer support), bound by contractual obligations to protect your data and use it only for specified purposes
  • At Your Direction — when you explicitly instruct us to share data (e.g., Nourished by Mira provider reports shared with your healthcare provider)
  • Legal Requirements — when required by law, subpoena, court order, or governmental regulation, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others
  • Business Transfers — in connection with a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction. You will be notified of any such transfer and any choices you may have regarding your data.
  • Aggregated or De-Identified Data — we may share data that has been aggregated or de-identified so that it can no longer reasonably identify you, for research, analytics, or business purposes

10. Third-Party Services

Our Services integrate with or rely on the following categories of third-party services. Each third party operates under its own privacy policy:

  • Cloud Infrastructure — Amazon Web Services (AWS) for hosting, storage, and compute
  • Payment Processing — Stripe, Apple Pay, Google Pay, or similar processors for subscription and in-app purchases
  • Analytics — Google Analytics for website usage analysis
  • Authentication — OAuth providers (Apple, Google) for single sign-on
  • App Distribution — Apple App Store and Google Play Store

We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing them with your information.

11. Data Retention

We retain your Personal Data for as long as your account is active or as needed to provide you with our Services. Additionally:

  • Caelia — facial data is destroyed within 24 hours and never backed up. Photos, audio, and videos are kept until you delete them or your account, then removed from active systems within 30 days and from backups within 90 days. Purchase records are kept for 7 years for tax and accounting purposes.
  • Nourished by Mira — on-device data stays until you delete it, delete the app, or reset your device. Cloud-synced data is retained while your account exists and permanently deleted when you delete your account. Mira conversations are not stored; operational logs are purged after seven (7) days.
  • driftLAB HQ — workspace content, connector tokens, and Drift AI conversations are retained until you delete them or your account, at which point they are deleted immediately. Provider backups age out on the database provider's rotation schedule.

Anonymized or aggregated data that cannot identify you may be retained indefinitely for research and analytics purposes. When data is no longer needed, we securely delete or anonymize it.

12. Data Security

We implement administrative, technical, and physical safeguards designed to protect your Personal Data, including:

  • Encryption in transit using TLS 1.2 or higher
  • Encryption at rest using AES-256 or equivalent industry-standard encryption
  • Role-based access controls limiting employee access to Personal Data on a need-to-know basis
  • Regular security assessments, vulnerability scanning, and penetration testing
  • Incident response procedures for prompt detection, containment, and notification of data breaches

Despite these measures, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security but are committed to protecting your data using commercially reasonable measures.

13. Your Rights — General

Depending on your jurisdiction, you may have the following rights regarding your Personal Data:

  • Access — the right to request a copy of the Personal Data we hold about you
  • Rectification — the right to correct inaccurate or incomplete Personal Data
  • Erasure — the right to request deletion of your Personal Data, subject to legal retention requirements
  • Portability — the right to receive your Personal Data in a structured, machine-readable format
  • Restriction — the right to restrict processing of your Personal Data under certain circumstances
  • Objection — the right to object to processing based on legitimate interests
  • Withdraw Consent — the right to withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact us at privacy@sltrdigitalstudio.com. We will respond within thirty (30) days or as required by applicable law. We will not discriminate against you for exercising your privacy rights.

14. Your Rights — GDPR (EEA/UK Residents)

If you are located in the European Economic Area or the United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR), including:

  • All rights listed in Section 13, enforceable under Articles 15–22 of the GDPR
  • The right not to be subject to automated decision-making, including profiling, that produces legal effects or similarly significant effects
  • The right to lodge a complaint with your local data protection supervisory authority

For GDPR-related inquiries, contact us at privacy@sltrdigitalstudio.com. International data transfers from the EEA/UK are protected through Standard Contractual Clauses (SCCs) approved by the European Commission (see Section 21).

15. Your Rights — CCPA/CPRA (California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with the following rights:

  • Right to Know — the right to request the categories and specific pieces of Personal Data we have collected about you in the preceding 12 months
  • Right to Delete — the right to request deletion of your Personal Data, subject to certain exceptions
  • Right to Correct — the right to request correction of inaccurate Personal Data
  • Right to Opt-Out of Sale or Sharing — we do not sell your Personal Data and do not share it for cross-context behavioral advertising
  • Right to Limit Use of Sensitive Personal Information — you may direct us to limit the use and disclosure of your Sensitive Personal Information to purposes necessary to provide the Services
  • Right to Non-Discrimination — we will not discriminate against you for exercising any of your CCPA/CPRA rights

To exercise these rights, email privacy@sltrdigitalstudio.com with the subject line “California Privacy Request.” We will verify your identity before processing your request and respond within forty-five (45) days as required by law.

16. Children's Privacy

Our Services are generally not directed to children under the age of 13. Specific age requirements apply to each Service:

  • Caelia — limited to users aged 18 and older.
  • Nourished by Mira — not intended for children under 13. Users between 13 and 17 should use the app with the consent and supervision of a parent or guardian.
  • driftLAB HQ — intended for general adult use and not directed to children under 13.

We do not knowingly collect Personal Data from children under 13 without verified parental consent. If we become aware that we have collected data from a child under 13 without appropriate consent, we will promptly delete it. If you believe a child has provided us with Personal Data, contact us at privacy@sltrdigitalstudio.com.

17. Biometric Data

Caelia processes facial data to animate faces in the photos you upload. The following disclosures apply, including under the Illinois Biometric Information Privacy Act (BIPA), the Texas and Washington biometric identifier laws, and similar state laws:

  • Consent: Facial data is not processed until you give express written (electronic) consent in the app. You may withdraw consent at any time.
  • Purpose: Facial data is used solely to generate the video you requested. It is never used to identify or verify anyone, recognize faces across photos, infer sensitive characteristics, build a face database, or train any model.
  • Retention: Facial data is held only in temporary processing storage and is permanently destroyed as soon as the video is generated or the request ends, and in every case within 24 hours. It is never backed up.
  • No Sale or Profit: Facial data is never sold, leased, traded, or otherwise used for profit, and is disclosed only to the computing providers that process it on our behalf or where required by law.

No other Service collects biometric data. Where a Service uses Face ID or Touch ID (for example, to unlock the private journal in Nourished by Mira), authentication is handled entirely by your device's operating system and we never have access to it.

18. Health and Wellness Data

Nourished by Mira collects health data such as body composition, nutrition, symptom, and anonymized medication information. Please note:

  • Nourished by Mira is not a medical device and does not provide medical advice. Mira is not a licensed healthcare provider or registered dietitian. Consult a qualified healthcare provider before changing your diet, exercise, or medication.
  • We treat all health-adjacent data with enhanced security measures, including encryption and restricted access.
  • We do not share health-adjacent data with employers, insurers, or data brokers.

19. Cookies and Tracking Technologies

We use the following categories of cookies and similar technologies:

  • Strictly Necessary — required for the operation of our Services (authentication, security, load balancing). These cannot be disabled.
  • Functional — enable enhanced features and personalization (language preferences, remembering your choices).
  • Analytics — help us understand how visitors interact with our Services (Google Analytics). These collect aggregated, anonymized data.

We do not use advertising or behavioral targeting cookies. You can control cookies through your browser settings. Blocking certain cookies may affect the functionality of our Services.

20. On-Device Processing

Certain features in our Services process data exclusively on your device:

  • Nourished by Mira health data — body composition records, progress photographs, meal plans, journal entries, and provider reports never leave your device. Medication details are anonymized on-device before any transmission.

21. International Data Transfers

SLTR Digital is based in the United States. If you access our Services from outside the United States, your Personal Data may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction. For transfers from the EEA or UK, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission and/or UK Information Commissioner's Office to ensure adequate protection of your data. By using our Services, you consent to the transfer of your data to the United States subject to these safeguards.

22. Do Not Track Signals

Some browsers transmit “Do Not Track” (DNT) signals. There is currently no uniform standard for interpreting DNT signals. Our Services do not currently respond to DNT signals. However, we do not engage in cross-site tracking or sell your Personal Data, and you may control analytics cookies through your browser settings as described in Section 19.

23. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the “Last Updated” date at the top of this page, sending an email to the address associated with your account, or providing an in-app notification. We encourage you to review this Policy periodically. For material changes that affect how we process Sensitive Personal Data, we will provide at least thirty (30) days' notice before the changes take effect. Your continued use of our Services after the effective date of any changes constitutes your acceptance of the updated Policy.

24. Future Products

This Privacy Policy applies to all current and future products, services, websites, and applications developed or operated by SLTR Digital LLC. When we launch new products, this Policy will be updated to include any additional data practices specific to those products. We will notify users of significant additions through the channels described in Section 23.

25. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

For GDPR-related inquiries from the EEA or UK, please email privacy@sltrdigitalstudio.com with the subject line “GDPR Request.” For CCPA requests from California residents, please email with the subject line “California Privacy Request.”