Privacy Policy
Effective date: [EFFECTIVE DATE]
This policy explains how AI Flirt Chat handles your personal data. It is written for the EU General Data Protection Regulation (GDPR) and the Italian privacy code, and it applies to everyone who uses the Service.
1. Who is responsible for your data
- Controller: [COMPANY LEGAL NAME], [REGISTERED ADDRESS], VAT number [VAT NUMBER].
- Contact for privacy requests: [CONTACT EMAIL].
- Data protection officer: [DPO EMAIL]. [CONFIRM WHETHER A DPO IS REQUIRED OR APPOINTED.]
2. What we collect
| Category | What it includes | Where it comes from |
|---|---|---|
| Account | Email address. If you sign in with Google, the name and account identifier Google shares with us. | You, or Google |
| Date of birth | Entered once at sign-up. Used for the 18+ check. Cannot be edited. | You |
| Age-check records | A salted hash of your email address and a salted hash of your device identifier, with the end date of any block. Stored so that a blocked person cannot register again straight away. We never store plain email or device values here. | Generated by us |
| Device identifier | A random cookie (the did cookie) used for the age check and abuse prevention. See the Cookie Policy. | Generated by us |
| Preferences | Interests you pick, the star sign we show during onboarding (worked out from your birthday), and notification settings with quiet hours and time zone. | You, or derived from your birthday |
| Consents | Which version of the Terms and Privacy Policy you accepted, and when. | You, recorded by us |
| Matching and relationships | Likes, passes, Super Likes, matches, and each character's mood and warmth score for you, with the times these changed. | You and the characters' replies |
| Chats and memories | The messages you send and the characters' replies, a short running summary of each conversation, and short notes (facts) about you that each character keeps. Chat content may include sensitive information if you choose to share it. | You, and the AI service |
| Push subscriptions | The push endpoint and keys your browser gives us, so we can send notifications you have allowed. | Your browser |
| Waitlist (before launch) | Your email address, the page you signed up from, any campaign tags (utm_source, utm_campaign), the host of the site that referred you, the referral code you were given, and the version of the consent wording you agreed to. | You, and the link you came from |
| Payments | Purchases, the gem ledger, VIP status, and the reference IDs a payment provider gives us for each purchase or subscription. We never see or store card numbers or wallet keys. | You, and the payment provider |
| AI usage | Which character and purpose a request was for, token counts, cost, and response timing, linked to your account. Used for spending limits and service quality. | Generated by us |
| Safety | Messages flagged by our automatic checks (for example, crisis language or unsafe replies), reports you file, and moderator notes and decisions. | Automatic checks, you, and our moderators |
| Technical data | IP address and request logs held by our hosting provider for security and troubleshooting. [LOG RETENTION: confirm]. | Your browser, through our hosting provider |
We do not ask for, and do not store, identity documents or photographs of you. If you use an optional third-party age check, that provider handles the documents. We only receive the result. [CONFIRM WITH THE CHOSEN PROVIDER.]
3. Why we use it and our legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Running your account, matches, chats and memories | Contract (6(1)(b)) |
| Age check and blocking under-18 users | Legal obligation (6(1)(c)) and legitimate interest in protecting minors (6(1)(f)) |
| Safety: crisis detection, reply checks, reports and moderation | Legitimate interest (6(1)(f)); protection of life where crisis help is shown (6(1)(d)) |
| Sending push notifications and character check-ins | Consent (6(1)(a)), given by allowing notifications in your browser |
| Payments, VIP billing, tax and accounting records | Contract (6(1)(b)) and legal obligation (6(1)(c)) |
| Keeping records of consents | Legal obligation (6(1)(c)) |
| Security, fraud and abuse prevention, and AI spending limits | Legitimate interest (6(1)(f)) |
| Answering your privacy requests | Legal obligation (6(1)(c)) |
Chats can contain special category data, such as health information, if you share it. We process it only to run the chat and to keep you safe. We ask you to share no more than you need. [CONFIRM THE ART. 9 BASIS, e.g. explicit consent given by the user when sharing.]
4. Automated decisions and AI
- The characters' replies are produced by an AI model. They are generated automatically each time you send a message.
- The AI does not make decisions that have a legal or similarly significant effect on you, with one exception: the age check. A date of birth under 18 blocks sign-up automatically. If you think the result is wrong, email [CONTACT EMAIL] and a person will review it. [CONFIRM ART. 22 BASIS.]
- Automatic checks may flag a message. A flagged reply is hidden and reviewed by a person, and you can report content yourself at any time.
5. Who we share data with
We share data only with the providers below, and only as needed for the purpose listed.
| Recipient | Role | Data | Location |
|---|---|---|---|
| [HOSTING PROVIDER] | Hosting of the app and logs | All app data in transit and at rest on servers | [REGION] |
| [DATABASE PROVIDER] | Database | All stored app data | [REGION] |
| Anthropic, PBC | AI replies, memory summaries and safety checks | Message text, conversation summaries and facts, and character details needed for the reply | United States |
| [PAYMENT PROVIDER] (not yet live) | Crypto and Telegram Stars payments, when they open | Purchase and subscription data, and any billing details you give the provider | [REGION] |
| Resend, Inc. | Sending sign-in emails | Your email address and the sign-in link | United States [CONFIRM] |
| Browser push services (for example Google, Apple, Mozilla) | Delivering notifications you allowed | Push endpoint, encrypted notification content | Varies by browser |
| [AGE VERIFICATION PROVIDER] (optional) | Optional third-party age check | Whatever the provider needs for the check; it returns only the result to us | [REGION] |
We do not sell your personal data, and we do not share it with advertisers. [CLIENT TO CONFIRM.]
6. International transfers
Some providers are based outside the European Economic Area, including in the United States. Where we transfer data there, we rely on the EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) or on an adequacy decision, together with additional safeguards where needed. You can ask us for a copy of the safeguards at [CONTACT EMAIL]. [CONFIRM THE SAFEGUARD FOR EACH PROVIDER.]
7. How long we keep data
| Data | How long |
|---|---|
| Account, profile, chats, memories and relationship state | Until you delete your account (see section 8) |
| Deleted accounts | Removed from live systems within 7 days after the deletion window closes. Backups are overwritten within 30 days. [CONFIRM] |
| Age-check records (hashed) | For the length of the block plus [PERIOD, e.g. 12 months], so that an under-18 user cannot re-register straight away. [CONFIRM] |
| Payment and invoice records | 10 years, as Italian tax and accounting rules require. [CONFIRM] |
| AI usage logs | [PERIOD, e.g. 12 months], then aggregated or deleted. [CONFIRM] |
| Safety flags and reports | [PERIOD, e.g. 12 months] after the case is closed, longer only where the law requires. [CONFIRM] |
| Push subscriptions | Until you turn notifications off, or until the browser says the subscription is gone |
| Waitlist entries | Until launch plus 12 months. Removed at once when you unsubscribe, or when an account with the same email is deleted. [CONFIRM] |
| Request and server logs | [PERIOD]. [CONFIRM] |
8. Your rights and how to use them
Under the GDPR you have the right to access your data, correct it, have it erased, restrict or object to its use, receive it in a portable format, and withdraw consent at any time (this does not affect what we did before you withdrew it).
- Download a copy of your data: Settings > Privacy > Download my data. You get a file with your profile, consents, matches, chats, memories, gem history, payment records (without card data) and reports you filed.
- Delete your account: Settings > Privacy > Delete my account. Your sessions end, push subscriptions are removed, and any VIP subscription is cancelled at the end of its period. We erase your data after 7 days. Signing in again during those 7 days cancels the deletion. Payment records are kept in anonymised form as section 7 explains.
- Anything else: email [CONTACT EMAIL]. We reply within one month, and we may ask you to confirm who you are first.
- Complaints: you can complain to the Italian data protection authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or to the authority in the country where you live.
Waitlist before launch
Before AI Flirt Chat opens, you can join a waitlist with your email address. We use it only to send launch emails and to count people who joined through your referral link. You agree to this with a box that you tick yourself, and you must be 18 or over. Every launch email includes an unsubscribe link that removes your entry. Your entry is also deleted when an account with the same email is deleted. [CONFIRM THE EMAIL PROVIDER AND UNSUBSCRIBE FLOW.]
9. Under-18s
The Service is for adults only. If we learn that someone under 18 has an account, we will suspend it and delete the data. If you believe a minor is using the Service, email [CONTACT EMAIL].
10. Security
Connections use HTTPS. Email addresses and device identifiers used for the age check are stored only as salted hashes. Staff access is limited to what each role needs, and admin actions are logged. No system is perfectly secure, so if we have a breach that puts your rights at risk we will tell you and the authority as the law requires.
12. Changes to this policy
We will update this policy when the Service or the law changes. For significant changes we will tell you before they take effect. The effective date at the top shows the current version.