In order to use some of our apps or websites, we may ask you to enter your name, email, weight, height, fitness level, areas for improvement, food preferences, and ask other onboarding questions depending on the app or web products you choose from our ecosystem (for example, some mental wellness information may be required to use our mental wellness app). In some of our apps you are able to skip some of the onboarding questions by tapping on Skip or similar indication.

We also may automatically collect from your device: language settings, IP address, time zone, type and model of a device, device settings, operating system, and other technical information. We need this data to provide our services (for example, to render a certain element of the product), analyze how our customers use the app (for example, to know whether our customers use the features we release), to serve ads. Most of the time, you can influence such processing by limiting it via our privacy features available on the websites and/or apps.

Please read our Privacy Policy below to know more about what we do with data(Section 2), what data privacy rights are available to you (Section 4). Depending on the region from where you access our Services and the choice of our product, we strive to provide you with various privacy control features and rights.

Exercise other privacy rights.

When such features are available to you, this will be prominently displayed either in footers, menus, or profile sections of our products. We aim to provide most of these rights as privacy features that may be accessed by you on your own by simple UX/UI friendly interactions with our service (when you struggle to find them or they are not available as a feature, please submit a request to us).

If any questions remain unanswered or you would like to exercise your privacy rights, please contact us at support@myspicy.ai.

This Privacy Policy explains and lists the transparency information regarding what personal data is collected when you use our mobile applications, websites and the services provided through them (together “App” or “Service”), how such personal data will be processed.

By using the service, you promise us that (i) you have read, understand and agree to this privacy policy and the data processing described, and (ii) you are over 18 years of age. If you do not agree, or are unable to make this promise, you must not use the Service. In such a case, you must (a) delete your account and contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by us if you purchased it directly from our websites; and (c) delete the App from your devices.

Сontents:

1. Categories of personal data we collect

2. What are the purposes and legal bases for processing your personal data

3. With whom we share your personal data

4. How you can exercise your privacy rights

5. Age limitations

6. International data transfers

7. Changes to this Privacy Policy
8. Data retention

9. Personal data controller

10. Contact us

1. Categories of personal data we collect

We process data:

(i) directly provided by you (for example, during account creation or prompts entered to generate Content),
(ii) generated or collected automatically through your use of our services (for example, when accessing your account, interacting with AI companions, or using cookies and device information),
(iii) obtained from third-party sources (for example, payment service providers).

1.1. Data directly provided by you

1. Identifiers
This may include your name, phone number, email address. You provide us with this information

when you register for the Service, purchase our Service or contact us by any other means.

2. Onboarding and product data  
You provide us with this category of information when you register for the Service and/or go through the onboarding process and/or use the Service. This category, in particular, includes general information about you, for example, age, date of birth, gender, etc.

3. Commercial information
When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers that serve us as data and payments processors. We do not collect or store, or have access to full credit card number data, though we may receive some limited information, including credit card-related data (including a secure token reflecting your payment method), data about products or services purchased, date, time and amount of the purchase, the type of payment method used, limited digits of your card number.

4. Conversation with AI companions
We offer the opportunity to interact with AI companions. During these interactions, we process the text of your conversations with  AI companions.

5. Comments you provide with your requests
You may also provide us with some personal information using our “Contact us” forms or by sending emails on our email addresses. This information may include any comments you log in when you send your inquiry.

1.2. Data we collect automatically

1. Online activity
We record how you interact with our Service. For example, we log your interactions with certain areas of the interface, the features, and content, how often you use the App, how long you are in the app, and your subscription orders.

2. Device and Geolocation data
We collect data from your mobile device. Examples of such data include: language settings, Internet Protocol address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID. If you consent in certain of our products to share the geolocation data (for example, for you running routes), the app may receive this data as well.

3. Advertising IDs
We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

4. Cookies and similar tracking technologies

Our products employ technologies (cookies, SDKs, etc.) to process your data to enhance your user experience, optimize ads, and analyze traffic. These technologies are activated when you interact with our services, visit our website, use our apps, or enable certain features like chats. Disabling these technologies may affect the functionality of certain features, although our products will remain usable.

2. What are the purposes and legal bases for processing your personal data

We collect and utilize your data primarily to provide our services, enhance the quality of our fitness and wellness services and to continuously improve them. Furthermore, we aim to attract new customers to our products. Below, you'll find a more comprehensive breakdown of how we use your information, illustrated with clear examples.

*We rely, in particular, on the following legitimate interests:

• To communicate with you regarding your use of our Service
  These may include reminders to respond to a message, password resets or account updates.
• To communicate with you regarding possible cooperation
  To communicate with you regarding possible cooperation. The legitimate interest we rely on for this processing is our interest to establish and maintain business relationships with potential partners, clients or collaborators allowing you to benefit from our programs and offers.
• To research and analyze your use of the Service
  Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).
• To send you marketing communications (unless you provide consent to that)
  The legitimate interest for this processing is our interest to promote our Service in a measured and appropriate way. We may rely on it, for example, when we have an established business relationship with you, which may cover purchasing some products within the Service.
• To personalize our ads
  We rely on our interest to promote our Service in a reasonably targeted way.
• To audit ad performances
  The legitimate interest for this processing is our interest in ensuring the accuracy and quality of our advertising services and complying with industry standards.
• To defend our legal rights and interests
  The legitimate interest refers to our need to protect ourselves from legal disputes, claims, or other actions that could threaten our operations, reputation, or financial stability. This interest is considered legitimate because it enables us to effectively manage risks and maintain compliance with applicable laws and regulations. This could involve using the data to support the organization's position in a dispute, respond to legal requests, or provide evidence in litigation.
• To enforce our Terms and Conditions of Use and to prevent and combat fraud
  Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Service, and non-compliance with our Terms and Conditions of Use.
• To prevent and combat fraud
  Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Service.

3. With whom we share your personal data

We engage partners to carry out specific services or business functions on our behalf using their technologies and resources, based on our instructions. This cooperation may involve, in particular, processing your data using their software development kits (SDKs), APIs, cookies, and other technologies. Consequently, your information is transferred and processed on their servers (usually without a partner's direct access to the specific pieces of information) on our behalf for our purposes.

Such type of processing of personal data may be regarded as sharing of information with third parties. We strive to conclude specific data processing agreements with all such parties to establish the rules for processing of your data specifically on our behalf and limited to it. Our partners help us operate, provide, improve, integrate, customize, support, and market our Service.

The types of third parties we share information with include, in particular:

1. Third-party services providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We process your personal information using the following types of service providers (and in certain cases, their subprocessors):

a. Cloud storage providers

To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon. You may read more on Amazon’s security practices on its website.

b. Product monitoring service providers

To monitor infrastructure and the App’s performance, we use Crashlytics, which is a monitoring service provided by Google. Here’s its Data Collection Policy.

We use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. To learn more, please visit Google’s Privacy policy and Privacy and Security in Firebase.

d. Data analytics providers

Ad performance measurement systems

To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service.Appsflyer allows you to Opt Out of having data from my device sent to AppsFlyer's servers for apps usage collection. You can read more about Appsflyer’s  privacy practices in its Privacy Policy.

General analytics tools

To analyze how visitors use the Service and to measure the effectiveness of some ads we use Google Analytics, a web analysis program of Google. On Google Analytics we get, in particular, information on the data you enter on our website and users’ interactions within the website. Google allows you to influence the collection and processing of the information generated by Google, in particular, by installing a browser plug-in, available here. You can read more about how Google uses the information here.

To track and analyze behavior of our App’s users (in particular, how they react to changes of the App structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users).You can read more about Firebase’s  privacy practices in its Privacy Policy and Privacy and Security in Firebase.

e. Gateway service providers and payment processing partners

We use various payment processing and payment gateway providers that help us connect with different banks and payment systems around the world. These providers allow us to offer our customers a wide range of payment options and ensure fast and smooth transactions. Due to the large number of payment processing providers we work with, we cannot list them all here. Each payment processing provider has its own terms and conditions and privacy policy that may apply to the transactions they process.

f. Communication services providers

Zendesk provides us with customer service software, which enables us to handle your inquiries and requests via email, chat, phone and other channels. Thus, when you contact us via any of these channels, some of your information is automatically transferred to Zendesk. The transfer is required to provide you with timely and effective support. Read more about Zendesk’s approach to privacy on their website.

g. Marketing service providers

Meta. We use Meta Ads Manager together with MetaMeta Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through MetaMeta Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the App (for example, installed it). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.

Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our App (for example, show our ads to users who have purchased a subscription). Some other examples of events that may be used for tailoring ads include, in particular, installing our App, finishing a workout program. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

Ad networks, ad agencies and direct publishers are third-party services that provide us with advertising solutions for displaying our ads on various websites and apps. In particular, these services allow us to target our ads based on your interests and activities on our App and other websites. Some examples of events that may be used for targeting ads include, in particular, installing our App, finishing a workout program or purchasing a subscription. These services may also collect some information about you such as your device ID or IP address for delivering relevant ads. You can opt out of interest-based advertising by visiting the Digital Advertising Alliance’s consumer choice page or the Network Advertising Initiative’s consumer opt-out page.

2. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

3. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

4. Affiliates

We may share your personal information with our partner organizations that are part of our corporate group – these are companies that are owned by, own, or are jointly-owned with us. These partner organizations will use the information in ways that align with this Privacy Policy, ensuring that your privacy is respected and protected across all our affiliated services.

4. How you can exercise your privacy rights

A. General privacy rights

To be in control of your personal data, you have the following rights:

• Accessing / reviewing / updating / correcting your personal data. You have the right to review, edit, or change the personal data that you had previously provided to us. If you would like to receive a copy of data we process, please send us a data access request or depending on the product you use, look for a data access privacy feature that is usually available in the profile section.
• Deleting your personal data. You can request erasure of your personal data, as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time (for example, information about your payments and your requests to us); in such event, we will fulfill your request in relation to portion of the data within the timeframes required for exercising data deletion requests and to another portion of the data after we have complied with our retention obligations (for example, after the end of data retention period obligation for payment data).
• Getting to know the details of the processing.You have the right to be informed about the collection and use of your personal data. This means that you have the right to understand what personal data is being processed, why it's being processed, who it's being shared with, how long it's being stored. We strive to follow the transparency requirements and provide most of the information in this Privacy Policy. However, if you have any questions about our data processing practices or if you would like more details about how we use your personal data, please contact us.
• Objecting to or restricting the use of your personal data. You can ask us to stop using your personal data or limit our use. For example:

• Email marketing: we provide you with the ability to unsubscribe from email marketing communication by following the unsubscribe link in every email or by contacting our support team.
• Additional means to influence personalized advertising

• iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.
• Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads).

To learn even more about how to affect advertising choices on various devices, please look at the information available here.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

Network Advertising Initiative – http://optout.networkadvertising.org/

Digital Advertising Alliance – http://optout.aboutads.info/

Digital Advertising Alliance (Canada) –  http://youradchoices.ca/choices

Digital Advertising Alliance (EU) –  http://www.youronlinechoices.com/

DAA AppChoices page –  http://www.aboutads.info/appchoices

We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.

• The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns as customer satisfaction is our top priority, thus we strive to appoint sufficient resources and efforts to provide you with top of the market customer support and most likely will be able to satisfy your request directly. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority.
• The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above. The data will be made available to you in the .json file or another file format.

Exercising your rights

To exercise any of the available privacy rights, please send a request to support@myspicy.ai or use the privacy features available in our products.

Verification. To ensure that we properly handle the requests you make regarding your rights, we are required to verify those requests. Depending on the type of request and the product used by you, this may include your name, age, email, date of subscription purchase, date of last activity, date of account creation or some other Service use data that will reasonably identify you as an owner of the account, etc. We may also ask you for additional proof of identity, if necessary, but we strive to use as little as possible (for example, for some requests we will send you a verification code or link).

An authorized agent. You may also designate an authorized agent to exercise your rights on your behalf. If you have provided an authorized agent with a power of attorney, we will work directly with your authorized agent to complete your request. Where you have not provided an authorized agent with a proper power of attorney or similar authorization, we will reach out to you directly to confirm the authorized agent’s authority and collect the verification Information. The authorized agent shall verify the identity of both himself and the consumer.

5. Age limitations

We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at support@myspicy.ai.

6. International data transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Useand for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy appropriate safeguards, such as standard data protection clauses adopted by the EDPB.

7. Changes to this Privacy Policy

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

8. Data retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy and our the Terms and Conditions of Use (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the Service.

We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For example, under certain accounting and tax laws we are required to store Commercial Information for long periods of time to comply with laws we are subject to. Therefore, even if you submit a data deletion request, a small portion of the data that relates to our compliance obligations will be stored even after the request is satisfied.

9. Personal data controller

Zeframin Limited  (reg. No. HE 418324 with registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus) will be the controller of your personal data.

10. Contact us

You may contact us at any time for details regarding this Privacy Policy, its previous versions, or our information practices. For any questions concerning your account or your personal data please contact us at support@myspicy.ai.