AI COMPANION USAGE POLICY

Effective Date: June 12, 2025
Last Modified: July 25, 2025

This AI Usage Policy for Holistic Healing Horizons FZCO ("Company," "we," "us," or "our") describes how we collect, use, process, store, and protect personal information and data in connection with the artificial intelligence companion services ("AI Companions," "AI Assistants," or "Companions") provided within the Thrive After Narcissistic Abuse membership program. This Policy governs your use of AI-powered therapeutic support tools and establishes the legal framework for data processing, privacy protection, and service limitations.

1. DEFINITIONS AND INTERPRETATION

1.1 Definitions

For the purposes of this Policy, the following terms shall have the meanings set forth below:

"AI Companions" means the artificial intelligence-powered conversational agents and therapeutic support tools developed, trained, and deployed by Holistic Healing Horizons for the purpose of providing supplemental healing support to members of the Thrive After Narcissistic Abuse program.

"Backend Model" means the underlying artificial intelligence model, algorithm, or system that powers the AI Companions, which may include but is not limited to various versions of large language models from providers such as Anthropic (Claude), OpenAI (GPT), Google (Gemini), or other AI service providers as determined by the Company in its sole discretion.

"Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to conversation transcripts, usage patterns, behavioral data, therapeutic progress indicators, and any other information that can be used to identify, contact, or locate a person, whether directly or indirectly.

"Processing" means any operation or set of operations performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction.

"Data Controller" means Holistic Healing Horizons FZCO, which determines the purposes and means of processing Personal Data.

"Data Processor" means any third-party service provider that processes Personal Data on behalf of Holistic Healing Horizons FZCO, including but not limited to AI model providers, hosting services, and platform providers.

"Therapeutic Content" means any information, guidance, exercises, or responses provided by the AI Companions that are based on the methodologies, techniques, and expertise of Danish Bashir and the Holistic Healing Horizons FZCO therapeutic framework.

1.2 Interpretation

This Policy shall be interpreted in accordance with applicable federal, state, and international privacy laws, including but not limited to the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), and other applicable privacy legislation.

2. SERVICE DESCRIPTION AND TECHNOLOGICAL FRAMEWORK

2.1 Nature of AI Companions

The AI Companions are sophisticated artificial intelligence systems specifically trained and customized by Danish Bashir, Certified Clinical Trauma Specialist and Narcissistic Abuse Recovery Professional, to provide supplemental therapeutic support through conversational interfaces. These systems are designed to:

a) Transform traditional therapeutic worksheets and exercises into interactive, conversational experiences; b) Provide 24/7 access to healing-focused guidance and support; c) Offer personalized responses based on evidence-based therapeutic methodologies; d) Facilitate deeper engagement with narcissistic abuse recovery concepts and techniques; e) Serve as an adjunctive tool to complement, but never replace, professional therapeutic intervention.

2.2 Backend Model Flexibility and Optimization

IMPORTANT NOTICE: The Company reserves the absolute right, in its sole discretion, to modify, update, change, or replace the backend AI model(s) powering the AI Companions at any time without prior notice to users. This includes but is not limited to:

a) Model Versioning: Upgrading to newer versions of existing AI models (e.g., Claude 3 Haiku to Claude 4, GPT-4 to GPT-5, etc.); b) Provider Changes: Switching between different AI service providers based on performance, cost-effectiveness, safety considerations, or technological advancement; c) Hybrid Systems: Implementing multiple AI models simultaneously or in sequence to optimize user experience and therapeutic outcomes; d) Proprietary Development: Integration of custom-developed AI systems or models specifically designed for therapeutic applications; e) Emerging Technologies: Adoption of new AI technologies, including but not limited to multimodal AI, specialized therapeutic AI, or other innovative systems as they become available.

The selection of backend models shall be based on factors including but not limited to: computational efficiency, response quality, safety protocols, privacy protection capabilities, cost optimization, regulatory compliance, and alignment with therapeutic objectives.

2.3 Training and Customization Methodology

The AI Companions have been extensively trained, customized, and fine-tuned using:

a) Danish Bashir's proprietary therapeutic methodologies and frameworks; b) Evidence-based practices for narcissistic abuse recovery; c) Trauma-informed care principles and approaches; d) Specialized knowledge of narcissistic abuse patterns, effects, and recovery processes; e) Safety protocols and crisis recognition systems; f) Ethical guidelines for AI-assisted therapeutic support.

3. COMPREHENSIVE DATA PRIVACY AND PROTECTION FRAMEWORK

3.1 Legal Basis for Processing

We process your Personal Data under the following lawful bases:

a) Legitimate Interest (Article 6(1)(f) GDPR): To provide AI Companion services, improve therapeutic outcomes, and ensure user safety; b) Contractual Necessity (Article 6(1)(b) GDPR): To fulfill our obligations under the membership agreement and provide requested services; c) Consent (Article 6(1)(a) GDPR): Where explicitly provided for specific processing activities; d) Vital Interests (Article 6(1)(d) GDPR): To protect the life or safety of users in emergency situations.

3.2 Categories of Personal Data Collected

3.2.1 Conversation Data

Complete transcripts of all interactions with AI Companions
Message timestamps and session duration
Response preferences and interaction patterns
Emotional indicators and sentiment analysis results
Therapeutic progress markers and milestone tracking

3.2.2 Technical Data

Device information and browser specifications
IP addresses and geographical location data
Usage analytics and feature utilization metrics
System performance data and error logs
Authentication and security credentials

3.2.3 Behavioral Data

Navigation patterns within the AI Companion interface
Feature usage frequency and duration
Response engagement levels and satisfaction indicators
Therapeutic exercise completion rates
Crisis intervention trigger events and responses

3.3 Data Security Infrastructure

3.3.1 Encryption and Technical Safeguards

End-to-End Encryption: All data transmissions utilize TLS 1.3 or higher encryption protocols
Data-at-Rest Encryption: Personal Data stored using AES-256 encryption standards
Database Security: Multi-layered database protection with role-based access controls
Network Security: Implementation of advanced firewalls, intrusion detection systems, and DDoS protection
Backup Security: Encrypted, geographically distributed backup systems with integrity verification

3.3.2 Access Controls and Authentication

Multi-Factor Authentication: Required for all administrative and system access
Principle of Least Privilege: Access granted only to the minimum extent necessary for job functions
Regular Access Reviews: Quarterly audits of user permissions and access rights
Audit Logging: Comprehensive logging of all data access and modification activities
Secure Development Practices: Implementation of security-by-design principles in all system development

3.3.3 Organizational Security Measures

Employee Training: Mandatory annual privacy and security training for all personnel
Background Checks: Comprehensive vetting of all employees with data access
Confidentiality Agreements: Legally binding privacy obligations for all staff and contractors
Incident Response Plan: Detailed procedures for data breach detection, containment, and notification
Regular Security Assessments: Third-party penetration testing and vulnerability assessments

3.4 Third-Party Data Processors and Transfers

3.4.1 Primary Service Providers

MindStudio AI: Platform provider for AI Companion deployment and management
Anthropic/Claude: AI model provider (subject to change based on optimization needs)
Alternative AI Providers: OpenAI, Google, or other providers as determined by operational requirements
Cloud Infrastructure: AWS, Google Cloud, Azure, or other certified cloud service providers
Analytics Services: Privacy-compliant analytics and monitoring services

3.4.2 Data Processing Agreements

All third-party processors are bound by:

Comprehensive Data Processing Agreements (DPAs) meeting GDPR Article 28 requirements
Standard Contractual Clauses (SCCs) for international data transfers
Binding Corporate Rules (BCRs) where applicable
Regular compliance audits and certifications
Immediate breach notification requirements

3.4.3 International Data Transfers

When Personal Data is transferred outside the European Economic Area (EEA) or United Kingdom, we ensure adequate protection through:

Adequacy Decisions: Transfers to countries recognized by the European Commission as providing adequate protection
Standard Contractual Clauses: EU-approved contractual terms ensuring GDPR-level protection
Binding Corporate Rules: Internal policies approved by data protection authorities
Certification Schemes: Adherence to approved certification mechanisms and codes of conduct

3.5 Data Retention and Deletion Policies

3.5.1 Retention Periods

Active Conversation Data: Retained for the duration of active membership plus 12 months
Analytical Data: Aggregated and anonymized data retained for up to 5 years for service improvement
Safety/Security Data: Crisis intervention and safety-related data retained for up to 7 years
Legal Compliance Data: Data retained as required by applicable laws and regulations

3.5.2 Automated Deletion Processes

Regular Purging: Automated systems delete expired data according to retention schedules
User-Requested Deletion: Processing of deletion requests within 30 days of verification
Secure Deletion: Use of cryptographic erasure and secure deletion protocols
Audit Trails: Comprehensive logging of all deletion activities for compliance verification

4. DATA SUBJECT RIGHTS AND PRIVACY CONTROLS

4.1 European Union and United Kingdom Rights (GDPR/UK GDPR)

4.1.1 Right of Access (Article 15)

You have the right to obtain:

Confirmation whether Personal Data concerning you is being processed
Access to your Personal Data and information about processing purposes
Categories of Personal Data being processed
Recipients or categories of recipients of your data
Retention periods or criteria for determining retention periods
Information about your rights and complaint procedures

4.1.2 Right to Rectification (Article 16)

You have the right to:

Obtain rectification of inaccurate Personal Data concerning you
Request completion of incomplete Personal Data through supplementary statement

4.1.3 Right to Erasure/"Right to be Forgotten" (Article 17)

You have the right to erasure when:

Personal Data is no longer necessary for the original purposes
You withdraw consent and no other lawful basis exists
Personal Data has been unlawfully processed
Erasure is required for compliance with legal obligations

4.1.4 Right to Restrict Processing (Article 18)

You may restrict processing when:

You contest the accuracy of Personal Data during verification
Processing is unlawful but you prefer restriction over erasure
Data is no longer needed by us but required for legal claims
You object to processing pending verification of legitimate grounds

4.1.5 Right to Data Portability (Article 20)

You have the right to:

Receive Personal Data in a structured, commonly used, machine-readable format
Transmit data directly to another controller where technically feasible

4.1.6 Right to Object (Article 21)

You may object to processing based on:

Legitimate interests (including profiling)
Direct marketing (absolute right)
Scientific/historical research or statistical purposes

4.2 California Rights (CCPA/CPRA)

4.2.1 Right to Know

California residents have the right to request:

Categories of Personal Information collected
Categories of sources from which information is collected
Business or commercial purposes for collection
Categories of third parties with whom information is shared
Specific pieces of Personal Information collected

4.2.2 Right to Delete

California residents may request deletion of Personal Information, subject to certain exceptions for:

Completing transactions or providing services
Detecting security incidents or protecting against fraud
Complying with legal obligations
Internal uses reasonably aligned with consumer expectations

4.2.3 Right to Correct

California residents have the right to correct inaccurate Personal Information.

4.2.4 Right to Opt-Out

California residents may opt-out of:

Sale of Personal Information (Note: We do not sell Personal Information)
Sharing for cross-context behavioral advertising
Targeted advertising based on sensitive Personal Information

4.3 Virginia Rights (VCDPA)

Virginia residents have rights similar to California residents, including:

Access to Personal Data
Correction of inaccuracies
Deletion of Personal Data
Data portability
Opt-out of profiling and targeted advertising

4.4 Exercising Your Rights

4.4.1 Request Methods

To exercise your privacy rights, you may:

Email: Submit requests to [privacy contact email]
Written Request: Mail requests to [physical address]
Online Portal: Use the privacy request form in your membership dashboard
Phone: Call [privacy phone number] during business hours

4.4.2 Verification Requirements

To protect your privacy, we require verification of identity through:

Account credentials and security questions
Government-issued identification (for sensitive requests)
Multi-factor authentication where available
Notarized affidavits for certain deletion requests

4.4.3 Response Timeframes

Initial Response: Acknowledgment within 72 hours
Complete Response: Within 30 days (GDPR) or 45 days (CCPA)
Complex Requests: May require additional 30 days with notification
Appeals Process: Available for denied requests with independent review

5. PROFESSIONAL DISCLAIMERS AND LIMITATIONS OF SERVICE

5.1 No Professional Therapeutic Relationship

5.1.1 Explicit Disclaimer

IMPORTANT LEGAL NOTICE: The AI Companions provided by Holistic Healing Horizons do NOT constitute, establish, or create a professional therapeutic, counseling, medical, psychiatric, or healthcare relationship between you and Danish Bashir, Holistic Healing Horizons, or any associated professionals. The AI Services are strictly educational, informational, and supportive tools designed to supplement, not replace, professional mental health care.

5.1.2 Scope of AI Companion Services

The AI Companions are designed exclusively to:

Provide educational information about narcissistic abuse recovery
Offer structured exercises and therapeutic techniques in conversational format
Support implementation of evidence-based coping strategies
Facilitate self-reflection and personal growth activities
Provide 24/7 access to healing-focused content and guidance

5.1.3 What AI Companions Cannot Provide

The AI Companions explicitly CANNOT and DO NOT provide:

Professional psychotherapy, counseling, or psychiatric services
Medical advice, diagnosis, or treatment recommendations
Crisis intervention or emergency mental health services
Suicide prevention or self-harm intervention
Substance abuse treatment or addiction counseling
Medication management or psychiatric consultation
Legal advice or guidance on legal matters
Relationship counseling involving multiple parties
Assessment or diagnosis of mental health conditions
Treatment planning for complex psychological disorders

5.2 Limitations of Artificial Intelligence Technology

5.2.1 AI System Limitations

Users must understand and acknowledge that AI Companions:

Are algorithmic systems that generate responses based on training data and cannot replicate human judgment, intuition, or professional expertise
May occasionally provide responses that are inaccurate, inappropriate, or not suitable for specific individual circumstances
Cannot assess complex psychological states, recognize subtle warning signs, or provide nuanced clinical judgment
Lack the ability to form genuine therapeutic alliances or provide the full spectrum of human empathy and understanding
May not recognize cultural, linguistic, or contextual nuances that affect therapeutic approaches

5.2.2 Response Accuracy Disclaimer

While we strive to provide accurate and helpful information through our AI Companions, we cannot guarantee:

The accuracy, completeness, or reliability of any AI-generated response
That AI recommendations are appropriate for your specific situation
That following AI guidance will result in therapeutic progress or positive outcomes
That AI responses are free from errors, omissions, or potentially harmful suggestions

5.3 Professional Care Requirements

5.3.1 Mandatory Professional Consultation

You MUST seek immediate professional help from a licensed mental health professional if you experience:

Suicidal Ideation: Any thoughts of ending your life or self-harm
Psychotic Symptoms: Hallucinations, delusions, or severe disconnection from reality
Severe Depression: Persistent hopelessness, inability to function, or major life impairment
Substance Abuse: Dependence on alcohol, drugs, or other substances
Eating Disorders: Dangerous restriction, binging, purging, or distorted body image
Domestic Violence: Current physical, emotional, or sexual abuse situations
PTSD/Trauma Response: Severe flashbacks, dissociation, or trauma reactions
Bipolar Episodes: Manic or hypomanic episodes requiring medical intervention
Anxiety Disorders: Panic attacks, agoraphobia, or severe social anxiety
Relationship Crises: Situations requiring professional mediation or intervention

5.3.2 Ongoing Professional Care

The AI Companions are designed to supplement, not replace:

Regular therapy sessions with licensed professionals
Psychiatric medication management
Medical treatment for co-occurring conditions
Support groups and peer counseling
Crisis intervention services
Specialized trauma treatment programs

6. EMERGENCY PROTOCOLS AND CRISIS INTERVENTION

6.1 Emergency Contact Information

🚨 CRITICAL EMERGENCY NOTICE 🚨

IF YOU ARE EXPERIENCING A MENTAL HEALTH EMERGENCY, THOUGHTS OF SELF-HARM, OR ARE IN IMMEDIATE DANGER:

DO NOT rely on AI Companions for crisis support. IMMEDIATELY contact:

6.1.1 United States Emergency Services

Emergency Services: 911
National Suicide Prevention Lifeline: 988
Crisis Text Line: Text HOME to 741741
National Domestic Violence Hotline: 1-800-799-7233
SAMHSA National Helpline: 1-800-662-4357
Veterans Crisis Line: 1-800-273-8255, Press 1

6.1.2 International Emergency Contacts

United Arab Emirates: 999 (Police), 998 (Ambulance), 997 (Fire)
Dubai Emergency: 999 (General Emergency)
United Kingdom: 999 (Emergency), 116 123 (Samaritans)
Canada: 911 (Emergency), 1-833-456-4566 (Talk Suicide Canada)
Australia: 000 (Emergency), 13 11 14 (Lifeline)
European Union: 112 (Emergency)
International Association for Suicide Prevention: [Website with country-specific numbers]

6.1.3 Additional Crisis Resources

Your local emergency room or urgent care facility
Your primary care physician or psychiatrist
Local community mental health crisis teams
Mobile crisis intervention units
Psychiatric emergency services

6.2 Crisis Recognition and Response Protocols

6.2.1 AI System Limitations in Crisis Situations

LEGAL DISCLAIMER: AI Companions are NOT equipped to:

Provide real-time crisis intervention
Assess immediate danger or suicide risk
Contact emergency services on your behalf
Provide the level of support required during mental health emergencies
Replace human judgment in crisis situations

6.2.2 Crisis Content Detection

While our AI systems include safety protocols to recognize concerning content, users must NOT rely on these systems for:

Accurate risk assessment
Crisis intervention
Emergency response coordination
Professional clinical judgment in emergency situations

6.2.3 Immediate Action Requirements

If you experience thoughts of self-harm, suicide, or are in crisis:

STOP using the AI Companion immediately
CONTACT emergency services using the numbers provided above
GO to your nearest emergency room if safe to do so
CALL a trusted friend, family member, or mental health professional
REMOVE any means of self-harm from your immediate environment

7. QUALITY ASSURANCE, MONITORING, AND CONTENT REVIEW

7.1 Conversation Monitoring and Review

7.1.1 Legal Basis for Monitoring

We reserve the right to monitor, review, and analyze AI Companion conversations for the following legally justified purposes:

Safety Monitoring: Detection of crisis situations, self-harm indicators, or safety concerns requiring intervention
Quality Assurance: Evaluation of AI response accuracy, appropriateness, and therapeutic value
Service Improvement: Analysis of user interactions to enhance AI training and system performance
Compliance Monitoring: Ensuring adherence to therapeutic standards, ethical guidelines, and legal requirements
Risk Management: Identification and mitigation of potential harms or misuse of services

7.1.2 Scope of Review Activities

Authorized personnel may review:

Conversation transcripts and interaction patterns
User feedback and satisfaction indicators
Safety alerts and crisis-related content
Technical performance metrics and error reports
Therapeutic progress indicators and outcome measures

7.1.3 Personnel Authorized for Review

Conversation review is restricted to:

Danish Bashir: Primary therapeutic supervisor and AI training specialist
Clinical Team Members: Licensed mental health professionals authorized by Danish Bashir
Technical Team: Platform engineers and data scientists with signed confidentiality agreements
Quality Assurance Staff: Trained reviewers operating under strict privacy protocols
Safety Monitors: Specialized personnel trained in crisis recognition and intervention protocols

7.2 Confidentiality and Professional Standards

7.2.1 Professional Confidentiality Obligations

All personnel with access to conversation data are bound by:

Professional Ethics Codes: Adherence to relevant mental health professional standards
Confidentiality Agreements: Legally binding privacy and non-disclosure obligations
HIPAA Compliance: Where applicable, strict adherence to healthcare privacy standards
Training Requirements: Mandatory training on privacy, ethics, and appropriate data handling
Audit Procedures: Regular compliance monitoring and violation reporting mechanisms

7.2.2 Use Limitations for Reviewed Content

Information obtained through conversation review may ONLY be used for:

Immediate safety interventions when required
Aggregate analysis for service improvement (with identifying information removed)
Quality assurance feedback to improve AI responses
Compliance monitoring and regulatory reporting
Research and development activities (with proper anonymization)

7.3 User Rights Regarding Review Activities

7.3.1 Notification Rights

Users have the right to:

Receive general information about review practices and purposes
Request specific information about any review of their conversations
Object to certain types of review activities (subject to safety and legal requirements)
Access records of who has reviewed their conversations and when

7.3.2 Opt-Out Limitations

While we respect user privacy preferences, certain monitoring activities cannot be disabled due to:

Legal Obligations: Requirements to monitor for safety and compliance purposes
Safety Imperatives: Need to detect and respond to crisis situations
Service Functionality: Technical requirements for AI system operation and improvement
Therapeutic Standards: Professional obligations to maintain quality and safety standards

8. TECHNICAL SPECIFICATIONS AND SERVICE AVAILABILITY

8.1 System Architecture and Performance

8.1.1 Service Availability Standards

Uptime Target: 99.5% availability on a monthly basis
Planned Maintenance: Scheduled during low-usage periods with advance notice
Emergency Maintenance: May be performed without notice for security or safety reasons
Backup Systems: Redundant infrastructure to minimize service interruptions
Performance Monitoring: Continuous monitoring of response times and system performance

8.1.2 Technical Requirements for Users

Internet Connection: Stable broadband connection recommended for optimal performance
Browser Compatibility: Modern web browsers with JavaScript enabled
Device Specifications: Desktop, tablet, or mobile device with current operating system
Security Settings: Ability to accept secure cookies and encrypted connections
Accessibility Features: Screen reader compatibility and keyboard navigation support

8.2 AI Model Evolution and Updates

8.2.1 Continuous Improvement Process

Our AI systems undergo regular updates including:

Model Retraining: Periodic retraining on updated therapeutic content and methodologies
Safety Enhancements: Implementation of improved safety detection and response mechanisms
Performance Optimization: Updates to improve response quality, speed, and relevance
Feature Additions: Introduction of new capabilities and therapeutic tools
Bug Fixes: Resolution of identified issues and system improvements

8.2.2 Backend Model Transition Procedures

When changing or updating backend AI models:

Gradual Rollout: Phased implementation to ensure service continuity
Performance Testing: Comprehensive testing of new models before full deployment
User Impact Assessment: Analysis of potential changes to user experience
Rollback Capabilities: Ability to revert to previous models if issues arise
Communication: Notification of significant changes that may affect user experience

8.3 Data Backup and Recovery

8.3.1 Backup Procedures

Real-Time Backup: Continuous backup of conversation data and user information
Geographic Distribution: Multiple backup locations for disaster recovery
Encryption Standards: All backups encrypted using industry-standard protocols
Integrity Verification: Regular testing of backup systems and data recovery procedures
Retention Compliance: Backup retention aligned with data retention policies

8.3.2 Disaster Recovery Plan

Recovery Time Objective (RTO): Service restoration within 4 hours of major incidents
Recovery Point Objective (RPO): Maximum data loss limited to 15 minutes
Business Continuity: Procedures to maintain critical functions during system outages
Communication Plan: User notification procedures during service disruptions
Testing Schedule: Quarterly disaster recovery testing and plan updates

9. INTELLECTUAL PROPERTY AND PROPRIETARY RIGHTS

9.1 Ownership of AI Training Content

9.1.1 Proprietary Methodologies

The therapeutic content, methodologies, and techniques embedded in the AI Companions are the exclusive intellectual property of Danish Bashir and Holistic Healing Horizons FZCO, including:

Therapeutic Frameworks: Proprietary approaches to narcissistic abuse recovery
Treatment Protocols: Specialized intervention strategies and healing techniques
Educational Content: Training materials, exercises, and therapeutic tools
Assessment Tools: Proprietary evaluation and progress measurement instruments
Research Data: Clinical insights and evidence-based practice developments

9.1.2 AI Model Customizations

All customizations, fine-tuning, and specialized training applied to create the AI Companions constitute proprietary intellectual property, including:

Training Datasets: Curated therapeutic content and conversation examples
Model Parameters: Specific configurations and optimization settings
Response Templates: Structured therapeutic response frameworks
Safety Protocols: Crisis detection and response algorithms
Integration Code: Custom software and platform integrations

9.2 User-Generated Content and Conversations

9.2.1 Ownership of Personal Conversations

Users retain ownership rights to their personal conversations and content shared with AI Companions, subject to the limited rights granted to us for service provision, safety monitoring, and improvement purposes.

9.2.2 Limited License for Service Provision

By using the AI Companions, you grant us a limited, non-exclusive license to:

Process your conversations to provide AI responses
Analyze interaction patterns for service improvement
Use aggregated, anonymized data for research and development
Monitor content for safety and compliance purposes
Backup and store conversations according to retention policies

9.3 Third-Party Intellectual Property

9.3.1 AI Model Licensing

We utilize third-party AI models under appropriate commercial licenses, including:

Anthropic Claude: Licensed for commercial use in therapeutic applications
Alternative Providers: OpenAI, Google, or other providers as operationally required
Platform Services: MindStudio AI and other platforms under commercial agreements
Supporting Technologies: Various software and services supporting AI operations

9.3.2 Compliance with Licensing Terms

All use of third-party intellectual property complies with:

Commercial License Terms: Adherence to provider-specific usage requirements
Attribution Requirements: Proper crediting of third-party technologies where required
Usage Limitations: Compliance with any restrictions on data use or model deployment
Indemnification Provisions: Protection for users against intellectual property claims

10. REGULATORY COMPLIANCE AND LEGAL FRAMEWORK

10.1 Healthcare and Mental Health Regulations

10.1.1 HIPAA Compliance Considerations

While AI Companions do not establish covered healthcare relationships under HIPAA, we implement HIPAA-level privacy protections including:

Administrative Safeguards: Assigned security responsibility and workforce training
Physical Safeguards: Workstation use restrictions and device controls
Technical Safeguards: Access control, audit controls, and transmission security
Business Associate Agreements: Where applicable, appropriate contractual protections

10.1.2 State Mental Health Regulations

We monitor and comply with applicable state regulations regarding:

Scope of Practice: Ensuring AI services do not constitute unlicensed practice
Mandatory Reporting: Understanding obligations for reporting suspected abuse or neglect
Privacy Requirements: State-specific privacy protections for mental health information
Professional Standards: Adherence to applicable therapeutic and ethical guidelines

10.2 International Privacy Law Compliance

10.2.1 European Union Regulations

GDPR Compliance: Full adherence to EU General Data Protection Regulation
Data Protection Officer: Appointed DPO for EU-related privacy matters
Privacy Impact Assessments: Regular evaluation of high-risk processing activities
Cross-Border Transfer Mechanisms: Appropriate safeguards for international data transfers
Supervisory Authority Cooperation: Collaboration with EU data protection authorities

10.2.2 Other International Frameworks

UAE Data Protection Law: Compliance with Federal Law No. 45 of 2021 on the Protection of Personal Data
UAE Cybersecurity Law: Adherence to Federal Law No. 5 of 2012 on Combating Cybercrimes
UK GDPR: Compliance with United Kingdom data protection requirements
Canadian PIPEDA: Adherence to Personal Information Protection and Electronic Documents Act
Australian Privacy Act: Compliance with Australian privacy principles
Other Jurisdictions: Monitoring of privacy laws in countries where users are located

10.3 Consumer Protection and Accessibility

10.3.1 Americans with Disabilities Act (ADA) Compliance

Our AI Companions are designed to be accessible to users with disabilities through:

Screen Reader Compatibility: Support for assistive technologies
Keyboard Navigation: Full functionality without mouse interaction
Alternative Text: Descriptive text for visual elements
Color Contrast: Adequate contrast ratios for visual accessibility
Font Size Options: Adjustable text sizing for visual impairment accommodation

10.3.2 Consumer Protection Compliance

Transparent Pricing: Clear disclosure of all costs and subscription terms
Fair Billing Practices: Accurate billing and easy cancellation procedures
Truth in Advertising: Honest representation of service capabilities and limitations
Dispute Resolution: Fair procedures for addressing user complaints and disputes

11. LIABILITY LIMITATIONS AND LEGAL DISCLAIMERS

11.1 Comprehensive Limitation of Liability

11.1.1 General Disclaimer

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, HOLISTIC HEALING HORIZONS, DANISH BASHIR, AND ALL ASSOCIATED PARTIES EXPRESSLY DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, AND ACCURACY OF INFORMATION PROVIDED THROUGH AI COMPANIONS.

11.1.2 Service Limitations

WE MAKE NO REPRESENTATIONS OR WARRANTIES THAT:

AI Companion responses will be accurate, complete, or appropriate for your specific situation
Use of AI services will result in therapeutic progress or positive mental health outcomes
AI systems will detect all crisis situations or safety concerns
Services will be available without interruption or technical difficulties
AI responses will be free from errors, omissions, or potentially harmful content

11.2 Exclusion of Consequential Damages

11.2.1 Damage Limitations

IN NO EVENT SHALL HOLISTIC HEALING HORIZONS FZCO, DANISH BASHIR, OR ASSOCIATED PARTIES BE LIABLE FOR:

Indirect Damages: Including lost profits, business interruption, or consequential losses
Emotional Distress: Psychological harm or emotional suffering resulting from AI interactions
Medical Consequences: Any adverse health outcomes or therapeutic setbacks
Reliance Damages: Losses resulting from reliance on AI-generated advice or recommendations
Third-Party Claims: Damages arising from third-party actions or decisions

11.2.2 Maximum Liability Cap

OUR TOTAL LIABILITY FOR ANY CLAIMS ARISING FROM OR RELATED TO AI COMPANION SERVICES SHALL NOT EXCEED THE AMOUNT PAID BY YOU FOR SERVICES DURING THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM.

11.3 Indemnification

11.3.1 User Indemnification Obligations

You agree to indemnify, defend, and hold harmless Holistic Healing Horizons FZCO, Danish Bashir, and all associated parties, employees, agents, contractors, and service providers from and against any and all claims, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising from or related to:

a) Misuse of Services: Your use of AI Companions in violation of this Policy or applicable laws b) Reliance on AI Content: Any decisions made or actions taken based on AI-generated responses c) Third-Party Claims: Claims by third parties arising from your use of the services d) Violation of Rights: Any violation of intellectual property, privacy, or other rights of third parties e) False Information: Provision of false, misleading, or fraudulent information to AI systems f) Unauthorized Access: Any unauthorized access to or use of AI services through your account

11.3.2 Scope of Indemnification

The indemnification obligation includes but is not limited to:

Legal fees and court costs
Settlement amounts and judgments
Expert witness fees and litigation expenses
Regulatory fines and penalties
Administrative costs and investigation expenses

11.3.3 Indemnification Procedures

In the event of a claim subject to indemnification:

We will provide prompt written notice of the claim
You will assume control of the defense with counsel of your choice
We reserve the right to participate in defense at our own expense
No settlement may be made without our written consent
You will cooperate fully in the defense of any claim

12. FORCE MAJEURE AND SERVICE INTERRUPTIONS

12.1 Force Majeure Events

12.1.1 Definition of Force Majeure

Neither party shall be liable for any failure or delay in performance of obligations under this Policy due to causes beyond their reasonable control, including but not limited to:

a) Natural Disasters: Earthquakes, floods, hurricanes, fires, or other acts of nature b) Government Actions: Laws, regulations, orders, or governmental restrictions c) Cyber Attacks: Malicious attacks on systems, data breaches, or security incidents d) Infrastructure Failures: Internet outages, power failures, or telecommunications disruptions e) Pandemic Events: Public health emergencies affecting normal business operations f) Labor Disputes: Strikes, lockouts, or other labor-related disruptions g) Supplier Failures: Failures by third-party service providers or vendors

12.1.2 Notice and Mitigation Obligations

Upon occurrence of a Force Majeure event:

Prompt written notice will be provided to affected users
Reasonable efforts will be made to minimize service disruption
Alternative service options will be explored where feasible
Regular updates will be provided regarding restoration timeline
Service credits or compensation may be provided as appropriate

12.2 Planned Maintenance and Updates

12.2.1 Scheduled Maintenance Windows

Advance Notice: Minimum 48 hours notice for planned maintenance
Timing: Scheduled during periods of lowest user activity
Duration: Limited to the minimum time necessary for completion
Backup Plans: Contingency procedures for extended maintenance periods
User Communication: Clear information about expected impact and duration

12.2.2 Emergency Maintenance

Immediate Implementation: May be performed without advance notice for security or safety reasons
Prompt Notification: Users informed as soon as reasonably possible
Expedited Resolution: Priority given to restoring normal service operations
Post-Incident Review: Analysis and reporting of causes and preventive measures

13. DISPUTE RESOLUTION AND GOVERNING LAW

13.1 Governing Law and Jurisdiction

13.1.1 Applicable Law

This Policy and all related disputes shall be governed by and construed in accordance with the laws of the United Arab Emirates and the Emirate of Dubai, without regard to conflict of law principles. The application of the United Nations Convention on Contracts for the International Sale of Goods is expressly excluded.

13.1.2 Jurisdiction and Venue

Any legal action or proceeding arising under this Policy shall be brought exclusively in the courts of Dubai, United Arab Emirates, and the parties hereby consent to the personal jurisdiction and venue of such courts.

13.2 Alternative Dispute Resolution

13.2.1 Mandatory Mediation

Before initiating any formal legal proceedings, the parties agree to attempt resolution through:

Good Faith Negotiation: Direct discussion between the parties for 30 days
Professional Mediation: Binding mediation through an agreed-upon neutral mediator
Mediation Rules: Conducted under the Commercial Mediation Rules of the American Arbitration Association
Cost Allocation: Mediation costs shared equally between the parties
Confidentiality: All mediation proceedings remain strictly confidential

13.2.2 Binding Arbitration

If mediation fails to resolve the dispute within 60 days:

Arbitration Requirement: All disputes must be resolved through binding arbitration
Arbitration Rules: Conducted under the Commercial Arbitration Rules of the American Arbitration Association
Arbitrator Selection: Single arbitrator with expertise in technology and mental health law
Location: Arbitration conducted in Dubai, United Arab Emirates or virtually as agreed
Award Finality: Arbitration awards are final and binding with limited appeal rights

13.2.3 Class Action Waiver

YOU AGREE THAT ANY DISPUTE RESOLUTION PROCEEDINGS WILL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION. YOU EXPRESSLY WAIVE YOUR RIGHT TO PARTICIPATE IN CLASS ACTION LAWSUITS OR CLASS-WIDE ARBITRATION.

13.3 Equitable Relief

Notwithstanding the arbitration requirement, either party may seek equitable relief (including injunctive relief) in court for:

Intellectual Property Violations: Unauthorized use of proprietary information or trade secrets
Privacy Breaches: Violations of confidentiality or data protection obligations
Security Incidents: Urgent matters requiring immediate judicial intervention
Regulatory Compliance: Actions necessary to comply with legal or regulatory requirements

14. POLICY MODIFICATIONS AND UPDATES

14.1 Amendment Procedures

14.1.1 Right to Modify

Holistic Healing Horizons FZCO reserves the right to modify, update, or revise this Policy at any time, in its sole discretion, to reflect:

Changes in applicable laws or regulations
Evolution of AI technology and capabilities
Updates to privacy and security practices
Modifications to service offerings or features
Feedback from users and regulatory guidance

14.1.2 Notice Requirements

Material changes to this Policy will be communicated through:

Email Notification: Direct email to registered users at least 30 days before effective date
Website Posting: Prominent notice on the Holistic Healing Horizons FZCO website
In-App Notifications: Alerts within the AI Companion interface
Version Dating: Clear indication of effective date and version number
Summary of Changes: Highlight of material modifications for user review

14.1.3 Acceptance of Changes

Continued use of AI Companion services after the effective date of Policy modifications constitutes acceptance of the updated terms. Users who do not agree to modifications may:

Terminate their use of AI services before the effective date
Request deletion of their data in accordance with data subject rights
Contact support to discuss concerns about specific changes
Exercise applicable legal rights regarding data processing

14.2 Version Control and Record Keeping

14.2.1 Historical Versions

Archive Maintenance: All previous versions of this Policy archived for reference
Access Availability: Previous versions accessible upon request for legal or compliance purposes
Change Tracking: Detailed records of all modifications and effective dates
Legal Compliance: Retention of policy versions as required by applicable laws

14.2.2 Implementation Timeline

Staging Period: New policies implemented in stages to ensure smooth transition
User Adaptation: Reasonable time provided for users to understand and adapt to changes
Support Availability: Enhanced customer support during transition periods
Feedback Collection: Mechanisms for user feedback on policy changes and implementation

15. CONTACT INFORMATION AND SUPPORT

15.1 Privacy and Data Protection Contacts

15.1.1 Data Protection Officer

Privacy Inquiries and Data Subject Rights:

Email: [email protected]
Mail: Data Protection Officer, Holistic Healing Horizons FZCO, IFZA, Dubai Digital Park, Silicon Oasis, Dubai, United Arab Emirates
Response Time: Initial response within 72 hours, complete response within 30 days

15.1.2 Security Incident Reporting

Data Breach or Security Concerns:

Email: [email protected]
Incident Response: Immediate acknowledgment, investigation within 24 hours

15.2 Customer Support and Technical Issues

15.2.1 General Support

Technical Issues and Account Questions:

Support Portal: Available through membership dashboard
Email: [email protected]
Business Hours: Monday-Friday, 9 AM - 5 PM [Dubai, Asia]
Response Time: Email responses within 24-48 hours

15.2.2 AI Companion Specific Support

AI Service Issues and Feedback:

Email: [email protected]
Feedback Form: Available within AI Companion interface
Bug Reports: Dedicated portal for technical issue reporting
Feature Requests: Mechanism for suggesting service improvements

16. ACKNOWLEDGMENT AND AGREEMENT

16.1 User Acknowledgment

By accessing or using the AI Companion services provided by Holistic Healing Horizons FZCO, you explicitly acknowledge and agree that you have:

16.1.1 Policy Review and Understanding

Complete Reading: Read this entire AI Usage Policy in its entirety
Legal Understanding: Understood the legal implications and obligations contained herein
Risk Awareness: Been informed of the limitations and risks associated with AI-assisted therapeutic tools
Professional Disclaimer: Understood that AI Companions do not constitute professional therapy or medical advice
Emergency Protocols: Been clearly informed of appropriate emergency procedures and contacts

16.1.2 Consent to Data Processing

Data Collection Consent: Agreed to the collection and processing of personal data as described
International Transfers: Consented to international data transfers with appropriate safeguards
Monitoring Activities: Understood and accepted conversation monitoring for safety and quality purposes
Third-Party Processing: Agreed to data processing by authorized third-party service providers

16.1.3 Acceptance of Terms

Legal Binding: Agreed to be legally bound by all terms and conditions in this Policy
Dispute Resolution: Accepted the mandatory arbitration and dispute resolution procedures
Liability Limitations: Understood and accepted all liability limitations and disclaimers
Indemnification: Agreed to indemnification obligations as specified

16.2 Certification of Capacity

By using AI Companion services, you certify that you:

Are at least 18 years of age or have parental/guardian consent
Have the legal capacity to enter into binding agreements
Are not prohibited by law from accessing or using these services
Understand the English language sufficiently to comprehend this Policy
Are accessing services voluntarily and without coercion

16.3 Electronic Signature and Agreement

Your continued use of AI Companion services constitutes your electronic signature and binding agreement to this Policy. This electronic agreement is equivalent to a written signature and is legally enforceable.

Electronic Record: This Policy and your agreement are stored electronically and are accessible through your membership portal.

17. SEVERABILITY AND ENFORCEABILITY

17.1 Severability Clause

If any provision of this Policy is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be deemed severed from this Policy, and the remaining provisions shall remain in full force and effect. The invalid provision shall be replaced with a valid provision that most closely approximates the intent and economic effect of the invalid provision.

17.2 Survival of Provisions

The following provisions shall survive termination of your use of AI Companion services:

Data retention and deletion obligations
Intellectual property rights and restrictions
Liability limitations and disclaimers
Indemnification obligations
Dispute resolution procedures
Governing law and jurisdiction clauses

18. EFFECTIVE DATE AND SUPERSEDING PROVISIONS

18.1 Effective Date

This AI Usage Policy becomes effective on June 12, 2025 and supersedes all previous versions, agreements, or understandings related to the use of AI Companion services provided by Holistic Healing Horizons FZCO.

18.2 Policy Precedence

In the event of any conflict between this AI Usage Policy and other agreements or policies related to your Holistic Healing Horizons FZCO membership, this Policy shall control specifically regarding AI Companion services, data processing, and related privacy matters.

DOCUMENT VERSION: 1.0
EFFECTIVE DATE: June 12, 2025
LAST MODIFIED: July 25, 2025

This comprehensive AI Usage Policy has been prepared with the assistance of legal and technical experts to ensure maximum protection for both users and service providers while maintaining transparency and compliance with applicable laws and regulations.