Effective date: May, 16th

This Privacy Policy describes how personal information is collected, processed and protected for users of the AI Chatbot App.

We may update this Privacy Policy according to new legislative or jurisprudential requirements and/or business needs, among other reasons. The new version of this Privacy Policy will be applicable from the moment of its publication on the App. Therefore, the User is recommended to review this Privacy Policy regularly. This Privacy Policy will always be available on the App so that the data subjects can consult it at all times.

Who is the personal data controller?

GRIMLAX TRADE, S.L. (hereinafter, “the Company”, “We”, “Us” and the like) is the controller of the User’s personal data. We are firmly committed to regulatory compliance and the privacy and protection of personal data of Users. Accordingly, in the present Privacy Policy, the User (hereinafter “the User”, “you”, “your”) of the AI! (hereinafter, “the/our App”) will find all the relevant information to better understand what We do with your personal data.

What does this Policy apply to?

This Privacy Policy applies to the personal data that We collect and process from you as a User of our App as well as the services offered within it. Please bear in mind that this App is for adults in accordance with the laws and regulations of their birth or residence country.

Note:

- The Company shall not be liable if the User is not of legal age according to the laws and regulations of their country of birth or residence. In this regard, it is the sole responsibility of parents and/or legal guardians to exercise appropriate control over the online activity of their minor children and prevent their access to apps whose content is not suitable or recommended for minors.

What does personal data mean and which data do We collect and process?

For the purposes of this Policy, "personal data" refers to all data that identifies you or that could be used to identify you, such as:

- Your User ID by using RevenueCat. For further information, please consult RevenueCat’s privacy policy;

- E-mail addresses, when you contact us directly.

- Debit/credit card associated with the Apple user account and Apple gift cards.

- Information about your Apple device and how you interact with our App when you have given your consent for these platforms to communicate your data to third-party partners (such as us) who develop applications offered through the platforms.

Note:

The Company shall not be liable if the User provides personal data and/or private information from an adult without his/her consent for obtaining responses from the AI. For circumstances beyond our reasonable control such as this, the Company will be excluded from liability towards third parties and, if applicable, the Company may both delete the improperly processed information and determine the blocking of access to the User who has improperly entered information from another data subject.

What do We use your personal data for?

Please be informed that you only are required to provide personal data and information that is strictly necessary to fulfil the purposes explained below. In this regard, if you provide Us with more information than is expressly required, you consent to its processing for the purpose(s) for which it was granted.

We may use your personal data for the following purposes:

- To personalize your experience and improve the Services offered through the App. The App may use your personal information to enable you to access and use the App as well as to enhance the quality and functionality of the App. For this purpose, the App may collect information about how you navigate in the App, to improve the Users’ experience.

- For the AI to provide more accurate answers to User's questions.

- To collect the fees of the subscription plans to the Services offered through the App and process transactions;

- To manage your information queries regarding our App and/or the Service offered through it;

- To comply with our legal obligations, legal requirements, laws, and regulations and/or to respond to judicial, police or the corresponding authorities’ requirements;

To protect, investigate, and deter fraudulent, unauthorized, or illegal activity on/through our App;

When applicable, to improve our app’s functionalities and the Service offered by analyzing disaggregated data not associated with a particular User’s personal information.

- To send periodic push notifications to the User to achieve the purposes outlined in this Privacy Policy. Users must be aware that disabling push notifications may negatively affect the utility of this App.

What is the legal basis for processing your personal data?

We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why We collect and process your personal data. In almost all cases the legal basis will be:

- The consent you have provided Apple to install cookies and/or similar technologies on your device(s) to track your activity in these platforms, for example, what applications you have installed or which information you share with third-party partners about your browser or device for advertising purposes.

- To comply with our legal obligations and/or to attend administrative, judicial, police, or the corresponding authorities’ official requirements.

- Our legitimate interests in (i) offering an enhanced user experience when you access and use the app and operate it efficiently, (ii) monitoring fraudulent activity to preserve the security and integrity of our App; (iii) providing advertisements to users according to their interests; (iv) defending and addressing our rights in the event that a claim regarding our App and/or Service may arise.

Regarding cookies and/or similar technologies used by Apple to collect and store the information on your device that is later shared with the partners of the services offered by these platforms (like ourselves), we recommend that you consult the Privacy and Cookie Policies of these platforms for information on how to revoke the consent that you have given for the installation of cookies and/or similar technologies.

How long do we keep your personal data for?

We will keep your personal data only for as long as you are subscripted to the Services and, beyond that, your personal data will be retained, securely blocked, for the necessary retention period to fulfil our legal obligations and/or for our legitimate reasons (i.e to address claims in connection with the services offered through the app; to finish the investigation of detected fraudulent or illicit activity.)

Once the necessary retention period has ended, your personal data will be securely deleted from our information systems.

Who do We share the User’s personal data with?

We will not share your personal information with third parties without your consent. Nonetheless, in order to provide the Services and comply with our legal obligations, protect our legal rights, or respond to a valid legal request, we may communicate your personal data to the following third parties, including but not limited to: (i) our main service providers, such as Apple, where appropriate; (ii) other providers such as RevenueCat, Amplitude, Google Inc and Firebase, among others; (iii) service providers to perform functions and provide Services to us, such as hosting and backend infrastructure, database storage and management, email management, store marketing, credit card processing, customer service and others; (v) administrative, police or judicial authorities as long as the data is required in accordance with the applicable law and regulations; (vi) law firms to respond to claims regarding our App or services offered through it.

The third parties mentioned above may have their headquarters outside the European Economic Area (EEA), therefore, your personal data will be the object of international transfers. In any event, if a personal data international transfer is deemed appropriate, We inform you that We will only transfer personal data to recipients located in countries that ensure an adequate level of data protection or, failing that, offer the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, to ensure that your personal data is properly protected and that your individual rights and freedoms are guaranteed. In this regard, please be informed that the third parties mentioned above are committed to standard contractual clauses approved by the EU Commission certification in case of transfers to the USA.

How do We protect your personal data?

Your trust is very important to Us and for this reason, your personal data is stored confidentially and securely in our information systems. We are committed to protecting the security of your personal information and we implement the appropriate technical, organizational, administrative and security measures to safeguard and protect your information and personal data against illegal or unauthorized access, misuse or disclosure.

What rights do you have and how can you exercise them?

We inform you that the Users can withdraw their consent to processing their personal data at any time. Users may also exercise the following rights: access, verify and seek rectification, have their Personal Data deleted or otherwise removed, restrict the processing of their data, object to processing of their data, as well as the right to have the Personal Data transferred to another controller (portability), with a written request, addressed to us, via the following e-mail: info@aichatapp.app. We also inform you of your right to lodge a complaint to the Supervisory Authority.

As a general rule, We will respond to data protection rights requests within one (1) month. Occasionally, this period may be extended by two (2) further months where necessary, taking into account whether your request is particularly complex or you have made several requests. In this case, We will notify you of this event and explain the reasons for the delay to you.

Finally, We inform you that should you consider it appropriate, you have the right to lodge a complaint before the corresponding Supervisory Authority, especially if you consider that your data protection rights have not been adequately addressed.

We remain at your disposal for any doubts or questions you may have about this Policy, please contact Us by email at info@aichatapp.app.

What are cookies and what are they used for?

For the purposes of this Policy, the single term ‘cookies’ refers to cookies and/or similar technologies that track information about accessing and interacting with our App, for different purposes such as facilitating information about the user’s device, the User’s navigation through our app, remembering your browsing preferences, customizing the services offered on this App, the user’s purchase and cancellation history, to generate aggregate statistics based on user interaction, among others.

The memorized data recorded by cookies takes up a small space on a device’s memory and does not harm the device in any way.

When are cookies installed?

Interacting with our App and purchasing the paid services offered in it implies the installation of cookies, which may belong to us or be from third parties.

The use of third-party cookies is subject to the Cookies and Privacy Policies of these third parties. Therefore, We will not be responsible for the content or the veracity of the mentioned policies of said third parties. Please consult the website(s) and/or app(s) of said third parties to obtain more information or if you want to change your preferences for setting these cookies.

What type of cookies are installed?

Cookies that can be installed include the following:

Session cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and are automatically deleted when the browser on the User’s device is closed.

Persistent cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and remain installed for a certain time in the browser of the User’s device.

Owned cookies: these are sent to the User's device from our app and/or computer equipment, managed by Us, and their information is collected for our purposes.

Third-party cookies: these are sent to the User's device from computer equipment or Website or an app managed by another company (partners and/or service providers) and their information can be collected for our purposes (i.e to know the geographical location of the User) and/or to manage or improve the services that these third-party companies offer (i.e to manage the payment of the app’s services.).

Technical cookies: these allow the management and operation of this app and enable its functions and services, for example, to carry out the purchase process and manage payment, etc.

Analytical cookies: these allow Us to analyze the use of this app and recognize which functionalities interest users the most, to improve the quality and functionalities of our services (i.e. the app’s look and feel, messages’ design for usability, etc.) This information is obtained from disaggregated data which is not associated with a particular User or his/her personal information.

Preference or personalization cookies: they allow the storage of personalized information so that the User can access the service with certain characteristics such as the language, the number of results to be displayed in a search, the appearance or content of the service depending on the type of browser, etc.

To install cookies in your device's browser, We need your express consent, although other cookies are exempt from such consent. The exempt cookies are User authentication or identification cookies (session cookies only).

We have enabled adequate mechanisms to obtain your consent for the installation of cookies that require it. However, please be informed that, in accordance with the applicable laws and regulations, (i) it will be understood that your consent has been given if you modify the configuration of the browser by disabling the restrictions that prevent the installation of cookies and that, (ii) when the installation of cookies is necessary to provide you with the services that you have expressly requested, your consent will not be necessary.