BlackShift LLC
—
Privacy Policy
CATALYST
PRIVACY POLICY
Effective date: July 13, 2026 • Last updated: July 13, 2026
This Privacy Policy explains how BlackShift LLC (“Catalyst”, “we”, “us” or “our”) collects, uses,
shares and protects personal data when you use the Catalyst service, including our mobile
applications and the website at catalyst.life (together, the “Servic
e”). It should be read together
with our Terms of Service.
Catalyst is the controller of the personal data described in this Policy. If you have any question
about this Policy or about how we handle your data, you can contact us at
privacy@catalyst.life.
1. Who We Are and About This Policy
1.1
BlackShift LLC, a Wyoming limited liability company with entity ID 2025
-
001734421,
whose registered office is at 30 N Gould St, Ste R, Sheridan, WY 82801, United States,
is the controller responsible for your personal data.
1.2
This Policy applies to personal data we process about users of, and visitors to, the Service.
It does not apply to third
-
party services that we do not operate or control, even where
we link to them or integrate with them.
1.3 Where we collect data in a particular context, we may give you further privacy information
at the time, in addition to this Policy.
2. Information We Collect
2.1 We collect the following categories of personal data:
2.2
Account information.
information you provide when you create and manage your
account, which may include your email address, name or username, a password
(which we store only in hashed form), your confirmation that you are at least eighteen
(18) years of age, and, where you sig
n in using a third party such as Apple or Google,
the basic identifiers that provider shares with us.
2.3
Profile information.
information you add to your public profile, such as a display
name, a photograph, and any biographical details you choose to provide.
2.4
Content and onboarding information.
the goals, tasks, commitment statements and
questionnaire answers you provide during onboarding and while using the Service,
and the Daily Reflections, posts, comments and messages you create through the
Service, including in Mastermind Groups. Goals and t
he tasks within them have
visibility settings, as described in Clause 5. Your Reflections and other content are
written by you and may, depending on what you choose to write, reveal sensitive
information about you (see Clauses 3 and 5).
2.5
Cycle and activity data.
information about your participation in Cycles, including your
Cycle status, Lives, completion, the timing of your Daily Reflections, and your activity
and interactions within the Service.
2.6
Payment information.
we use third
-
party payment processors to take payments (see
Clause 6). We do not collect or store full payment card numbers. We receive limited
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transaction information from our processors, such as a payment token, the status, date
and amount of a payment, and a partial card reference, which we use to operate
subscriptions and Cycles, to provide bonuses, and to manage refunds and disputes.
2.7
Device and technical information.
information about the device and software you
use, including device model, operating system, app version, language settings, device
identifiers, and the push notification token used to deliver notifications. We process
your IP address transiently when you
connect, as described in Clause 2.8.
2.8
Approximate location.
when you connect, we derive your country from your IP
address and store only that derived country; we do not retain the IP address itself
beyond short
-
lived technical logs. We use this to operate the Service, including for
security and fraud prevention. Th
e Service is not offered in the United Arab Emirates,
as described in our Terms of Service.
2.9
Usage and analytics data.
information about how you use the Service. Within our
mobile and web applications, this is collected through our own self
-
hosted analytics
systems only
—
we do not use third
-
party analytics SDKs in the applications. On our
public website (landing pages), w
e use third
-
party analytics and attribution tools
—
currently AppsFlyer, Meta Pixel and Google Analytics
—
to understand traffic and
measure our marketing, as described in Clause 11. Analytics data may include events
relating to your use of features, subsc
riptions, payments and Cycles.
2.10
Cookies and similar technologies.
on our website, we and our providers use cookies
and similar technologies as described in Clause 11.
2.11
Communications.
the content of any messages you send us, including support
requests.
2.12
Special category data.
We do not ask you to provide special category data (such as
data about your health, mental health, religious or philosophical beliefs, sexual
orientation, or political opinions). However, because you write your Reflections and
other content freely, that co
ntent may contain such information. Where it does, we rely
on the basis described in Clause 3.7, and the visibility rules in Clause 5 apply.
3. How We Use Your Information
3.1
We use your personal data for the purposes set out below. Where the law requires a legal
basis for processing, the relevant basis is stated.
3.2
To provide the Service.
to create and operate your account, provide the Service,
operate Cycles and Mastermind Groups, deliver Completion Bonuses, and otherwise
perform our agreement with you. Legal basis: performance of our contract with you.
3.3
To handle payments.
to take payments and manage subscriptions, Participation
Fees, bonuses, refunds, chargebacks and related records. Legal basis: performance
of our contract with you, and compliance with our legal obligations.
3.4
To provide planning and voice features.
to generate personalised planning
suggestions, voice features and related materials, as described in Clause 4. Legal
basis: performance of our contract with you.
3.5
To keep the Service safe.
to operate the community feed and profiles, to keep the
Service safe, to moderate content, to investigate misuse, and to prevent and address
fraud and payment disputes. Legal basis: our legitimate interests in operating a safe
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and trustworthy service and protecting it from abuse, and compliance with our legal
obligations.
3.6
To improve the Service and communicate with you.
to understand how the Service
is used, to improve and develop it, to send you service
-
related communications and
notifications, and, where you have agreed or where the law otherwise permits, to send
you marketing and to measure our marketing. Legal basis:
our legitimate interests, and
your consent where required. You can opt out of non
-
essential communications at any
time using the unsubscribe link in the email; essential service communications (such
as receipts, security notices and legal notices) continue
for as long as you hold an
account.
3.7
Where content contains sensitive information.
where your Reflections or other
content contain special category data, or where you choose to publish such content
under Clause 5, we process it on the basis of your explicit consent. You can withdraw
that consent at any time by ceasing to provide such con
tent, by marking content
private, or by deleting it, although this will not affect processing carried out before
withdrawal.
3.8
To meet legal obligations.
to comply with applicable law and lawful requests, and to
establish, exercise or defend legal claims. Legal basis: compliance with our legal
obligations, and our legitimate interests.
4. Automated Planning and Voice Features
4.1
Some features of the Service generate planning suggestions, voice output and related
materials automatically. To provide these features, we share the relevant content you
provide, such as your goals and Reflections, with third
-
party providers that operate
the
underlying AI models
—
currently Anthropic and OpenAI for planning suggestions, and
Eleven Labs for voice features
—
which process that content on our behalf in order to
provide those features to you.
4.2
These providers act as our processors for this purpose and are bound by contractual
obligations that restrict their use of your content to providing the relevant services to
us. Under the applicable terms and settings for the services we use, your content
is
not used to train these providers’ models.
4.3
These features are provided for general informational and organisational purposes only,
do not constitute professional advice, and are subject to the disclaimers in our Terms
of Service. The suggestions are generated automatically and may not always be
acc
urate or suitable.
5. Public Reflections, Profiles and the Community Feed
5.1
The Service includes profiles and a community feed through which Users can see one
another’s content. Where you are not participating in a Cycle, your Daily Reflections
may be shown on your profile; where you are participating in a Cycle, your Daily
Reflec
tions may be published to the community feed.
5.2
In either case, you may mark a Daily Reflection as private, in which case it is not shown
on your profile or in the community feed and is not made available to other Users,
including the members of your Mastermind Group.
5.3
Goals.
When you create a goal, you choose its visibility. A public goal is shown on
your profile, and your posts show both the goal and the tasks you completed or did not
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complete towards it. A semi
-
public goal is shown on your profile and in your posts, but
the tasks within it are not shown. A private goal is not shown to other Users at all
—
not on your profile, not in your posts, and not in the copies of your posts share
d with
your Mastermind Group
—
although you remain free to mention it in the text of your
own Reflections. You can change a goal’s visibility at any time; the change applies to
how the goal is displayed going forward.
5.4 Content that you make visible to other Users can be seen, and may be stored or shared,
by those Users. You should not include in any content you make visible any information
you do not wish to be seen by others, including sensitive information about yo
urself or
others.
5.5 Removing or marking content private stops it being displayed going forward, but we cannot
control content that other Users have already seen, copied or stored.
6. How We Share Your Information
6.1
We share personal data with service providers who process it on our behalf to operate
the Service. These currently include providers of payment processing (Whop,
RevenueCat and Network AE), AI features (Anthropic, OpenAI and Eleven Labs),
cloud hosting and
infrastructure (Google Cloud), chat and feed infrastructure (Stream),
notifications (Firebase), and website analytics and attribution (AppsFlyer, Meta and
Google). These providers may only use the data to provide services to us.
6.2
We share content you choose to make visible with other Users, as described in Clause 5.
6.3 We may disclose personal data where required to comply with applicable law, regulation
or a lawful request, to enforce our Terms of Service, or to protect the rights, safety or
property of Catalyst, our Users or others.
6.4
If we are involved in a merger, acquisition, financing, reorganisation or sale of assets,
personal data may be transferred as part of that transaction, subject to this Policy or a
successor policy.
6.5 We do not sell your personal data.
7. International Data Transfers
7.1
We and our service providers may process your personal data in countries other than the
one in which you live, including the United States and the European Union, where our
cloud infrastructure and the providers listed in Clause 6 are located.
7.2
Where we transfer personal data from the European Economic Area, the United Kingdom
or other regions with similar restrictions to a country that has not been recognised as
providing an adequate level of protection, we rely on appropriate safeguards, such a
s
standard contractual clauses, to protect that data. You can ask us for more information
about these safeguards using the contact details in Clause 14.
8. How Long We Keep Your Information
8.1
We keep personal data for as long as necessary for the purposes described in this Policy,
including for as long as you maintain an account, and thereafter as needed to comply
with our legal obligations, resolve disputes and enforce our agreements.
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8.2 Some data is kept for specific minimum periods. In particular, we retain records relating to
payments and transactions for up to seven (7) years to meet legal, accounting, tax and
payment
-
dispute requirements, even after you delete your account.
8.3
When you delete your account, we delete or anonymise your personal data within thirty
(30) days, except for data we are required or permitted to retain as described above.
Your profile, Reflections, posts and comments are deleted. Messages you have sent
in
direct messages and Mastermind chats are not deleted: they are anonymised and
remain visible to the other participants, attributed to a deleted user. Content you
previously made visible to other Users may persist as described in Clause 5.4.
9. How We Protect Your Information
9.1 We use technical and organisational measures designed to protect personal data,
including encryption of data in transit and at rest, access controls, and restrictions on
who can access data. No method of transmission or storage is completely secure, an
d
we cannot guarantee absolute security.
9.2 You are responsible for keeping your account credentials confidential and for the security
of the devices you use to access the Service.
10. Your Rights
10.1
Depending on where you live, you may have some or all of the following rights in relation
to your personal data: to access it; to have it corrected; to have it deleted; to restrict or
object to its processing; to receive it in a portable format; and, where
processing is
based on consent, to withdraw that consent at any time.
10.2
You can exercise these rights, and can access and delete much of your data, through
the Service, or by contacting us at privacy@catalyst.life. We may need to verify your
identity before acting on a request.
10.3
You also have the right to lodge a complaint with a supervisory authority, such as the
data protection authority in your country of residence or another competent supervisory
authority applicable to you. We would, however, appreciate the chance to address
your
concerns before you do so.
10.4
Where we rely on our legitimate interests, you may object to that processing, and we will
stop unless we have compelling legitimate grounds to continue or need to continue for
legal reasons.
11. Cookies and Similar Technologies
11.1
On our website, we and our providers use cookies and similar technologies to operate
the site, remember your preferences, keep you signed in, and
—
on our public website
—
understand traffic and measure our marketing through third
-
party tools, currently
Ap
psFlyer, Meta Pixel and Google Analytics.
11.2
Some of these are necessary for the site to function. For others, where required by law,
we ask for your consent and you can manage your choices through the cookie controls
provided on the site or through your browser settings.
12. Children
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12.1
The Service is intended only for persons aged eighteen (18) or over. We do not knowingly
collect personal data from anyone under eighteen. If we learn that we have collected
such data, we will delete it. If you believe a person under eighteen has provided
us
with personal data, please contact us.
13. Changes to This Policy
13.1
We may update this Policy from time to time. If we make a material change, we will notify
you by email or through the Service before the change takes effect. The date at the
top of this Policy shows when it was last updated. Your continued use of the Servi
ce
after a change takes effect indicates your acceptance of the updated Policy, except
where we are required to obtain your consent.
14. How to Contact Us and Complain
14.1
The Service is operated by BlackShift LLC, a Wyoming limited liability company with
entity ID 2025
-
001734421, whose registered office is at 30 N Gould St, Ste R,
Sheridan, WY 82801, United States. For any privacy question or request, contact us
at privacy@
catalyst.life. Legal notices may be sent to legal@catalyst.life.
14.2
European Union representative: [To be appointed before the Service is offered in the
European Union where appointment is required by applicable law. Contact details will be
published here.]
14.3
United Kingdom representative: [To be appointed before the Service is offered in the
United Kingdom where appointment is required by applicable law. Contact details will be
published here.]