Last Updated: March 6, 2025

1. Welcome to a Journey of Heartbeats! We understand that your privacy is as precious as the whispers of your heart, and we solemnly pledge to safeguard every murmur and sigh. This Privacy Policy ("Policy") will softly unveil how we collect, use, and share your personal information, as well as your rights and choices, along with more about how we cherish your intimate desires.
2. Scope of This Policy This Policy applies to your ("you") use of our website ("Website"), including all content provided through the Website (as defined in the Terms of Use), the mobile application offered via Apple’s App Store or Google Play Store ("App"), and through accessing any related content such as email subscriptions, in-app feeds, or other services provided by us (collectively, the "Service"). Special Notice: Please carefully savor this Privacy Policy before accessing or using the Service. Accessing or using the Service signifies your full acceptance of this Privacy Policy. If you do not accept it, please refrain from using the Service. You acknowledge: (a) that you have read and understood this Policy; (b) that you accept this Policy and consent to the collection, use, and sharing of your personal information as described herein; and (c) that by agreeing to this Policy, you consent to receiving security incident notifications via the email address we have on file for you. Please note that your use of the Service is also subject to our Terms of Use and Community Guidelines. We invite you to revisit this Privacy Policy each time you use the Service. Using the Service means you agree to the most recent version of this Policy. If we make significant changes to this Policy, we will notify you via the Service (if required by law). Your continued use of the Service signifies your acknowledgment of the revised Policy.
3. How to Reach Us General Inquiries: support@yourdomain.com (mailto:support@yourdomain.com) Regional Data Rights Inquiries: support@yourdomain.com (mailto:support@yourdomain.com)
   You may also visit our contact page to whisper your thoughts to us anytime.
4. Age Restriction Though we yearn for as many souls as possible to indulge in the ultimate thrill of desire, you must be at least 18 years old to use our Service. We do not knowingly collect or market to anyone under 18 years of age. Should we discover that a person under 18 has registered or provided personal information, we will promptly terminate their account and delete such information as required by law.
5. Collection of Personal Information Personal Information We Collect To deliver a tantalizing experience, we may collect and use information defined as personal information under applicable privacy laws ("Personal Information"). Below are the categories of Personal Information we collect and use (specific examples may vary; for clarity, the type of Personal Information collected depends on the specific Service or feature you request—we do not collect all categories at once simply because you request a Service): Audio/Visual Data - Video or image files and records such as avatars, character photos, as well as voice messages or other recordings. All Audio/Visual Data we collect is willingly uploaded by you.

Contact Data - Details used to reach you, such as email address, mailing address, or phone number.

Device/Network Data - Information related to your device, browser, or app, such as device identifiers, IP address, cookie identifiers, session history, Service navigation metadata, and other data generated via apps and browsers, including through cookies and similar technologies.

Financial Data - Information like bank account details, payment card information, and related transaction data. When you purchase Services and make payments, third-party payment platforms provide us with order numbers and payment status. When withdrawing funds from us, you provide necessary recipient information.

Identity Data - Details such as your name, email address, gender, date of birth, age or age range, account login details (provided by third-party platforms with your authorization), or other account handles/usernames.

Transaction Data - Information about transactions you make on our Website, such as paid subscriptions or rewards.

User Content - Personal Information within content you provide in free-form or unstructured formats, such as AI chat sessions, character designs, "contact us" forms, or other free text fields, files, documents, or messages.

How We Collect Personal Information We gather Personal Information from various sources depending on the context of its use: Secrets You Entrust to Us - We collect Personal Information directly from you, such as when you create a user profile, design a character, chat with a character, rate a character, or contact us directly. For all content generated in chats, we use such content only in a general manner to train our models and do not link chat content to specific users.

Traces We Gently Capture - We may automatically collect certain Personal Information, such as Device/Network Data via cookies and similar technologies when you use or access our Service or open our communications.

Data from Service Providers - We receive Personal Information from service providers performing services on our behalf.

Data from Social Media Platforms - We receive Personal Information from Apple, Google, Discord, or Line when you log in via these third-party platforms. We also collect certain Personal Information from these platforms as authorized by you to use our Service.

Data Created or Inferred by Third Parties - Certain third parties (e.g., advertising platforms) may create or infer Personal Information based on observations or analysis of other Personal Information you provide.

Applicable Law We are dedicated to protecting your Personal Information, and the rights outlined in this Policy reflect those granted by applicable laws. For this Policy, applicable laws include: (a) the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2013; (b) the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") until it ceases to apply in the UK; and (c) where applicable, any UK legislation ratifying or adopting the GDPR, along with associated or supplementary data protection laws or regulations. We recognize that as an international business, some users may reside outside England and Wales. In certain cases, local laws in these jurisdictions may grant additional rights regarding the personal data you provide us. We anticipate that the rights in this Policy also offer such protections for your Personal Information. For further questions, please whisper to our Data Protection Officer at support@yourdomain.com (mailto:support@yourdomain.com). 6. Use of Personal Information Website General Use When you visit our Website, we may use Device/Network Data, Audio/Visual Data (including Contact Data, Identity Data, Financial Data, Transaction Data, User Content, and General Location Data). The specific data used depends on the Service or feature you engage with—we do not collect all data types at once simply because you visit. You may also create an account, design and chat with characters, contact us, read our blog or other materials, or complete transactions via our Service. We use this Personal Information to maintain the Service’s operations, such as keeping you logged in, age screening, delivering pages, enabling AI chats with characters, and content screening, for our Business Purposes and other legitimate interests, including: Ensuring the security of our Website and other technological systems;

Analyzing Service usage, such as navigation patterns and clicks, to understand and enhance the Service.

We may use this Personal Information for Commercial Purposes. Cookies and Similar Tracking Technologies When using cookies and similar technologies on our Service, we may involve Device/Network Data, Identity Data, Transaction Data, and User Content. Such data may be collected automatically. We and authorized third parties may use cookies and similar technologies for the following purposes: "Essential" purposes to maintain Service operations (e.g., sustaining user sessions, content delivery);

"Functional" purposes, such as enabling certain Service features (e.g., maintaining a logged-in session);

"Analytics" purposes and Service improvement, such as analyzing traffic to and within our Service (e.g., counting page views, observing user navigation, distinguishing unique visits/visitors, understanding user behaviors, and enhancing design and functionality);

"Retargeting," Online Advertising, or other marketing purposes, using certain data to deliver, purchase, or target ads more likely to captivate you.

We may use this Personal Information for Business Purposes. We use Google Analytics and Google Tag Manager to better understand who uses the Service, how they engage with it, and for remarketing and behavioral targeting. Google Analytics uses cookies to collect and store information like visited Service pages, click locations, time spent per page, IP address, device and OS type, language preferences, location data, device ID, search traffic, gender, and age. Google and other third parties may use cookies, pixels, web beacons, and other storage technologies to collect information from the Service and other websites, using it for ad targeting and measurement services. Google may track your activity across sites and over time. For details on Google Analytics, visit the Google Analytics Privacy Disclosure Policy. If logged into Google, you can opt out of certain ad-related data collection via the "Data & Personalization" section of your account settings. Google Tag Manager, a tag management system, allows the Service to update measurement codes and related fragments (tags) on our Website or app. We use this information to enhance the Service, as described herein. Google Tag Manager may collect data related to tag firing, standard HTTP request logs, and online identifiers like cookie IDs and IP addresses. See Google Analytics Opt-Out for details on the Google Analytics Opt-out Browser Add-on. We may also collaborate with third-party marketing firms to deliver online marketing to you. See "Your Rights and Choices" for information on opting out of cookies, similar technologies, and Online Advertising. Mobile App If you use our mobile app, we may use Device/Network Data, Audio/Visual Data (including Contact Data, Identity Data, Financial Data, Transaction Data, User Content, and General Location Data). We use this Personal Information to provide the mobile app, for Business Purposes, and other legitimate interests, such as: Optimizing the app’s display and functionality on your device;

Facilitating communication with AI characters;

Enabling character creation, interaction, and experiences;

Providing access to your account.

We may use this Personal Information for Commercial Purposes. Account Registration When you register and create an account, we use Identity Data, Contact Data, and User Content. If you upload a profile avatar, we use Audio/Visual Data. If you link payment information, we collect Financial Data. We use this Personal Information to create and maintain your account, deliver requested products and services, and for Business Purposes. We may use Identity Data and Contact Data for Commercial Purposes. We do not sell or "share" Financial Data or use it for Business Purposes prohibited by law. Characters Creation When you create a character via the Service, we use Audio/Visual Data, User Content, and any Personal Information within it. We use this Personal Information to create and maintain your character, train it to generate content, and allow others to discover it (if desired). We may use User Content to train AI models and for Business Purposes. Chats When you chat with a character via the Service, we use Device/Network Data, User Content, and any Personal Information within it. We use this Personal Information to enhance your chat experience, monitor chats for safety and appropriateness, and for Business Purposes. We may use User Content from chats to train AI models. For more on appropriate chat content, see our Community Guidelines. Purchases and Transactions When you purchase a membership, redeem virtual currency, buy chat credits, or complete other transactions, we use Transaction Data, Identity Data, Financial Data, and Contact Data. We do not store your Financial Data. We use this Personal Information to execute or initiate transactions with you, process orders, payments, or refunds, fulfill delivery, and document transactions. Blog When you access our blog, we use Device/Network Data. When you open or interact with marketing emails, push notifications, or similar communications, we use Contact Data, Identity Data, and Device/Network Data. You may receive marketing communications as per applicable laws. Contact Us When you reach out via a "contact us" form, phone, or email through the Service, we use Contact Data, Device/Network Data, User Content, and any Personal Information within it. We use Contact Data and User Content to respond to your inquiry and related matters. Posts and Social Media When you log in using a third-party social media account, we use Identity Data. Such platforms include Apple, Google, Line, and Discord. Your posts may be public or reposted on our Service. We use content you post or interact with (e.g., comments, social media posts) on social media platforms. Content you share publicly on our Service may be visible to others if you choose to make it so. 7. Purpose of Use Business Purposes Beyond the uses above, we generally use Personal Information for common purposes tied to our business ("Business Purposes"): Operating the Service and Fulfilling Obligations - We use any necessary Personal Information to provide the Service or fulfill obligations to you, such as delivering requested information, features, and services.

Internal Processes and Service Improvement - We may use any Personal Information processed through the Service to train models, understand usage or functionality, provide customer service, create and analyze usage logs and metadata, and ensure Service security and stability. We may also use it to identify which parts of the Service matter most to users, how users engage with it, its performance or issues, or to detect potential information security risks.

Analytics - We use necessary Personal Information to create analytics on Service usage, viewed pages and content, and reports on usage and performance metrics. Our analysis focuses on aggregated insights about user groups (e.g., how many use a specific feature), not individual behaviors.

Compliance, Safety, and Public Interest - Without your consent or further notice, and as permitted by law, we may use any Personal Information covered by this Policy for public interest or legal requirements, such as fulfilling legal obligations, protecting vital interests, or as required by public authorities. See the Data Sharing section for details on disclosures in exceptional cases.

Corporate Events - Your Personal Information may be used or shared during routine operations, reorganizations, or business transitions like mergers, acquisitions, liquidations, or sales of substantially all assets.

Other Uses - If we use Personal Information in ways not described here, this Policy generally applies (e.g., regarding your rights and choices) unless stated otherwise when you provide it.

Commercial Purposes We and certain third parties use Personal Information to advance our commercial or economic interests ("Commercial Purposes") based on collection context and your rights and choices. Online Marketing - Third-party ad platforms may collect your Personal Information via third-party SDKs in mobile apps and engage in Online Advertising on our Service to boost engagement and help more people discover the ultimate thrill. This involves various parties and providers, including third-party data controllers, using Personal Information to deliver and tailor ads. In mobile apps only, third parties may collect data like unique IDs, IP addresses, device info, OS type, and ad interaction data to build and assess profiles for relevant ads and offers, gauge ad effectiveness, and enable ads across sites. These parties may enhance profiles with demographic or preference data and track ad views, interactions, frequency, or purchases. They may identify you across sites, devices, and over time. You can control their use of your data and the ads you see using tools in the "Your Rights and Choices" section below. Contact us to learn about specific providers we use for these services.

Marketing Communications - We may send marketing and promotional communications as per applicable laws, personalized based on your user profile.

8. Data Sharing Collected information may be shared with various parties based on its purpose and context. We generally transfer data to the following recipient categories or for Business Purposes: Vendors and Service Providers - For general operations, service improvements, feature enablement, and lawful interests, we may share Personal Information with vendors, service providers, and subprocessors providing services or processing data on our behalf, such as third-party hosting providers for our Service or content, or embedded third-party ad platform SDKs. We may engage third parties as subprocessors, like tech support or AI model operators.

Corporate Events - Your Personal Information may be disclosed to third parties during business transitions like mergers, acquisitions, liquidations, or sales of substantially all assets, either as part of transferred assets or during due diligence (under confidentiality restrictions).

Affiliates - As needed to streamline operations and develop services better suited to customer interests, we may share your Personal Information with current or future affiliated entities, subsidiaries, or parent companies.

Legal Disclosures - In limited cases, without notice or consent, we may access and disclose your Personal Information, correspondence, or other data if we believe it’s legally required, to prevent or respond to crimes, investigate violations of our Terms of Use or Community Guidelines, or protect our or others’ interests. We may, at our discretion (but without obligation), object to such disclosures.

9. Your Rights and Choices Your Rights Applicable laws may grant rights over your Personal Information, varying by location and residence, and potentially limited by our own rights. You may submit requests to exercise these rights via support@yourdomain.com (mailto:support@yourdomain.com). Note: We can only fulfill rights requests for Personal Information we control or use. We may lack access to or control over third-party-controlled data. Contact third parties directly to exercise rights over their data. Verification Requirements All direct rights requests must be verified to ensure the requester’s authority, reduce fraud, and protect your Personal Information. For example, we may require email verification to confirm identity. For agent-submitted requests, we reserve the right to validate the agent’s authority. Your Choices Under applicable law, you may have the following choices regarding Personal Information we use: Change Information - To update your information, contact us at support@yourdomain.com (mailto:support@yourdomain.com).

Close Account - If the email linked to your account becomes inactive, we may remove it without notice. To close your account, email support@yourdomain.com (mailto:support@yourdomain.com).

Consent - If you consent to our use of Personal Information, you may withdraw it anytime. Withdrawal may require account closure if consent is essential for core Service functions.

Email Marketing - You may opt out of or withdraw consent for email marketing communications via links in our messages.

Cookies & Similar Technologies - To avoid data collection via cookies or similar technologies, manage/deny them in your browser settings. Opt out of some third-party services directly via the third party, e.g., Google’s analytics/marketing services at Google Analytics Terms of Use, Google Privacy Policy, or Google Analytics Opt-out.

Do-Not-Track - Your browser/device may offer a "Do Not Track" option to signal operators not to track certain online activities over time or across sites/apps. Our Service does not currently support Do Not Track requests, meaning we or our analytics providers/third parties may collect data about your online activity during and after Service use.

10. Security We implement and maintain commercially reasonable security measures to protect your Personal Information from unauthorized use. While we strive to shield our Service and your data from unauthorized access, use, modification, or disclosure, we cannot guarantee absolute safety from intrusions during transmission or storage.
11. Data Retention We retain Personal Information as long as reasonably necessary for the purposes in this Policy or as required by law. Necessity varies by context and purpose. We consider factors like: Retention periods under applicable law;

Industry best practices;

Whether the purpose justifies continued use;

Privacy risks of continued use;

Applicable data protection impact assessments;

IT system design considerations/limitations;

Costs of continued use, retention, and deletion.

We periodically review retention periods and may pseudonymize or anonymize data held longer. 12. Links to Third-Party Websites or Applications This Policy applies only to the Service. The Service may link to or redirect users to other websites or apps we don’t own or operate, where this Policy doesn’t apply. Links from our Service don’t imply endorsement or review of those sites/apps. Our described policies and procedures don’t apply there. We neither control nor are responsible for their privacy practices or content. Contact those providers directly for their privacy policies. Still, we aim to protect our Service’s integrity and welcome feedback on linked sites/apps. 13. International Transfers We operate in the United States. If you’re outside the U.S., your Personal Information may be used there, where legal protections may differ from other countries. Our services are supported by vendors in other jurisdictions, and your data may transfer there. We cannot guarantee equivalent or stronger protections than in your location. 14. Changes to This Policy We may update this Policy from time to time. Visit this page regularly for the latest updates. Using the Service after changes signifies acceptance. Unless stated otherwise, new features enhancing the Service are subject to this Policy. 15. Regional Data Rights Your Nevada Privacy Rights Nevada Revised Statutes (NRS 603A.300 et seq.) allow Nevada consumers to direct an online operator not to sell collected covered information. If you’re a Nevada consumer, submit a request via support@yourdomain.com (mailto:support@yourdomain.com). We’ll provide details on verifying the request and your identity. Your California Privacy Rights California Civil Code Section 1798.83 permits California residents to request information from businesses they have a relationship with about Personal Information shared with third parties for direct marketing, including types and recipients in the prior year. California residents may make one annual request via support@yourdomain.com (mailto:support@yourdomain.com).