Privacy Notice
Last updated: August, 2024
About this Privacy Notice
This Privacy Notice is meant to give you information about what personal data we collect about you, how we use it, why we use it, and how you control the data processing.
Table of Contents
- The Basics: Who We Are, Our Role, and Definitions
- Personal Data We Collect, How We Use it, and Why
- Our Marketing Activities
- Sharing the Personal Data We Collect
- International Transfers
- Security
- Your Rights - How to Control Our Use of Your Personal Data
- Data Retention
- Cookies and Similar Technologies
- Third-Party Services
- Children
- Changes to the Privacy Notice
1. The Basics
Who We Are
OnvoLabs LTD. offers AI-generated avatars with which you may interact as a romantic partner through our platform. Our offices are located at Office 11W, 8 Georgiou Christoforou , Strovolos, Nicosia 2012, Cyprus2, and our registration number is HE 468416. If you have questions about our company or your privacy, or want to exercise your rights, you can contact us at [email protected].
Our Role: Controller and Processor
Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a "controller") and a party that processes personal data solely on the controller's behalf and according to the controller's instructions (called a "processor"). We are the controller in respect of the processing described in this Privacy Notice.
Definitions and Recommendations
- When we refer to "services", we mean any services available on our platform, including chatting with avatars either online or by phone, and/or interacting with an AI-generated image of an avatar in connection with adult content.
- When we refer to "personal data", we mean information that is defined as personal data under law. This includes information that identifies you directly or indirectly, including unique identifiers like IP addresses or cookie IDs.
- When we refer to "you", we mean visitors to our website and any user of our platform, as applicable.
- This Privacy Notice is meant to be read together with our Terms of Service, which you can find at Terms of Service In general, we recommend that you routinely review this privacy notice and your preferences on our platform.
A Note on Legal Bases
Certain jurisdictions only allow the processing of personal data where a legal basis has been established. Under the EU's General Data Protection Regulation ("GDPR"), the possible legal bases include (but are not limited): your consent, the processing is necessary to perform a contract with you, the processing is necessary to fulfill our legal obligations, or a company has a legitimate business interest to process your personal data. Where we are a controller, we only collect and process data where we have established a legal basis. Below you can find more details about specific legal bases.
2. Personal Data We Collect, How We Use It, and Why
Below is a description of the types of personal data we collect, how we use it, and the reason why we consider each use lawful. You have no legal obligation to provide us with personal data, but if you don't provide us with certain information, we may not be able to provide you with the associated services.
2.1 Website Visitors
When you visit our site, we may collect the following types of data about you. Please note that you must click a box confirming you are over 18 before accessing the website.
2.1.1 Contact Information
When you contact us, we collect any data you provide, such as your email, and the content of your message. When you sign up for our newsletters we collect your name and email address.
How We Use this Data: To respond to your message and to provide you with our newsletters and promotional materials we think may be of interest to you.
Legal Basis: We process this personal data based on the performance of a contract with you. Processing your Personal Data to share our promotional materials with you is based on our legitimate interest to promote our products and services. Processing your Personal Data to share our newsletters and promotional materials is based on your consent. You may withdraw your consent at any time by emailing us at [email protected].
2.1.2 Activity and System Data (Cookies)
When you visit our site, we automatically collect data about your computer or mobile device, including personal data such as your IP address, device ID, browsing history (e.g. the other sites you've visited before ours), and your activity on our site (e.g. what pages you visited, for how long, and what links you clicked on). For more information about the cookies we use and how to adjust your preferences, see the Cookies and Similar Technologies section below.
How We Use this Data: We mainly use this data to generate analytics data about the use of our site so we can maintain and improve the site and develop new products or services. We also use statistical data to prevent fraud and protect the security of our site. Some cookies may be used to provide you with advertising for our products and services, based on your preferences and interests. One of the tools we use to collect and analyze this data is "Google Analytics". For more information about how Google collects information and how you can control such use, see:www.google.com/policies/privacy/partners/.
Legal Basis: We process this personal data based our legitimate interests to develop and improve our products and services, and to prevent fraud. When we collect your activity data to advertise to you, we do so on the basis of our legitimate interest to market our own products and services. Additional information regarding Our Marketing Activities is provided below.
2.2 Users
If you are a user of our platform, we collect the following information from and about you.
2.2.1 Registration Data
In order to access our platform, you must first create an account. When creating an account, you will be asked to provide your name and email address. If you access our platform using a third-party login service, we also receive personal data about you from that service.
How We Use this Data: We use your registration information to allow you to access to our platform, save your preferences, protect the security of our platform, prevent fraud, and address any issues that arise. We use your contact details to communicate with you about our platform. We also use your contact details to send you promotional materials relating to our products and services. For more information about our marketing activities and how you can control your preferences, see the section on Our Marketing Activities below.
Legal Basis: When we process your registration data to provide you with our services, we do so to perform a contract with you, in this case our Terms of Service. When we process your registration data to maintain our platform, including to prevent fraud, protect the security of and/or address issues with our platform, we do so on the basis of our legitimate interest to maintain our assets. When we use your contact details to send you promotional materials, we do so based on our legitimate interest to market our products and services. When we use your Personal Data to send you promotional materials relating to our services, we do so based on your consent. You may withdraw your consent at any time by emailing us at [email protected].
2.2.2 Account Information and Platform Preferences
We collect all the data that is saved to your account. This includes your avatars, chats, the images you generate, your preferences, and any other account-related data.
How We Use this Data: To provide you with our services. We use the avatars you create to improve our AI models and create new AI based models and services.
Legal Basis: When we process this personal data to provide you with our services, we do so to perform a contract with you. When we use your avatars to improve our services, we do so based on our legitimate interest to improve our services.
2.2.3 Payment Data
If you make a purchase through the platform, your payment is processed by a third-party payment processor. We receive information related to such purchase that constitutes personal data.
How We Use this Data: To process your purchase and to prevent fraud.
Legal Basis: We process your payment data to perform a contract with you, specifically our Terms of Service. When we process your payment data to prevent fraud, we do so based on our legitimate interest to protect ourselves and our customers.
2.2.4 Personal Data You Provide
We collect any personal data that you submit to our platform while using the services, such as any personal data you include in any chats, prompts, and/or phone conversations. We advise caution when interacting with our avatars and discourage you from sharing personal and/or sensitive data in chats, prompts, or conversations.
How We Use this Data: To provide you with our services, to improve our Servies and AI models, to develop new services and products and to solve (technical) issues relating to the Services.
Legal Basis: When we process the personal data you provide to provide you with our services, we do so in order to perform our contract with you, specifically, the Terms of Service. When we process your personal data to maintain and improve our services, we do so based on our legitimate interest to improve our services.
2.2.5 Special Categories of Data
In the course of providing our services to you, we collect data relating to your sex life (in connection with the services) and sexual orientation, which is subject to special protections under the law. We will collect such data subject to your consent.
How We Use this Data: To provide you with our services and to create analytics about our users in order that we can better understand our users' needs and maintain and improve our services accordingly.
Legal Basis: We process this Personal Data based on your explicit consent. You may withdraw your consent by contacting us at[email protected]. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
2.2.6 Activity and System Data (Cookies)
We collect data about your device and your activity, as described more fully above in section 2.1.2, when you use our platform.
2.3 Visitors to Our Social Media Pages
When you engage with our social media outlets, such as when you post on our social media pages, such as on Facebook, Instagram, X, and Reddit, like or share our posts, answer surveys, or similar activities, we collect the personal data you provide, such as the content of your post and the information available to us through your profile or account. The social media companies we use may also provide us with aggregate and analytical information about activity relating to us.
How we use this data: We may use this information to engage with you or respond to your posts and comments and to analyze the effectiveness of our social media efforts and to improve how we manage them, and for marketing purposes.
Legal Basis: When we process your personal data to engage with you or respond to your posts and comments and to, we do so on the basis of our legitimate interest to engage with and serve our audiences in an effective manner. When we process your personal data to improve our social media outlets or for marketing purposes, we do so based on our legitimate interest to effectively market our products and services, improve our services, and develop new ones.
3. Our Marketing Activities
As described above, we may use personal data we collect for advertising and marketing purposes. We try to limit the marketing material we send to a reasonable and proportionate level. Below we describe how you can control the marketing material you receive from us.
3.1 Email Marketing and Services Communications
- We use your contact details to send you marketing material about our products and services if you have provided your consent. You may withdraw your consent at any time by emailing us at [email protected].
- You can stop the delivery of all marketing emails by following the "unsubscribe" link in any messages we send you. Alternatively, you can contact us at [email protected] to request to unsubscribe.
- Note that if you are a registered user, we may need to contact you about administrative or service-related issues as part of the services we provide to you. This is not marketing communication and you will continue to receive these messages even if you opt-out of marketing emails.
3.2 Web Ads
- We serve online ads based on the activity data we collect using cookies. You can change the way your browser manages cookies by adjusting the settings on your browser as explained below in the How to Adjust Your Preferences section.
- We may also use social media plugins which will allow social media platforms to link personal data collected through our platform with personal data in your social media profile. This combined data may be used to serve you with advertising or customized content on the applicable social media platform. We recommend that you routinely review the privacy notices and preference settings that are available to you on social media platforms you use.
4. Sharing the Personal Data We Collect
We share your personal data as follows:
4.1 Affiliates
We share your personal data, with our affiliated companies, OnvoLabs LTD, where this is necessary to provide you with our products and services and so that we can manage our business, such as to keep updated records of our users.
4.2 Service Providers
Below is a list of the types of service providers we use, the service each provides, and the types of data shared with each. All service providers have agreed to confidentiality restrictions and have undertaken to use your personal data solely as we direct.
| Type of Service | Description | Personal Data Shared |
|---|---|---|
| Cloud Computing | We use service providers that offer cloud computing services. They offer us space on their servers for us to store our files and programs, including your personal data. | All personal data that we collect from you is stored on third party servers. |
| Email Marketing | We use an independent vendor to send out marketing emails on our behalf. | Your name and email address. |
| Payment Processors | When you make a payment through our services, the transaction is processed by an independent vendor. | The details of your purchase and your credit card number. |
| Analytics Providers | We use various service providers to assist us with analytics services. | Data collected automatically through our site, including IP addresses and cookie information. |
4.3 Generative AI Service Providers
We use various generative AI service providers in order to provide you with the services, specifically to generate the avatars, images, chats, and phone conversations and will share data with them for that purpose. Such service providers may also use the provided data for the improvement of their own services and models.
4.4 Data Controllers
We also share your personal data with Vercel, Inc. and Supabase, Inc., which act as independent, separate controllers of your personal data and process your personal data in accordance with their own respective policies.
4.5 Change of Ownership
If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your personal data shall continue to be subject to the provisions of this Privacy Notice.
4.6 Law Enforcement Related Disclosure
We may share your personal data with government agencies or other relevant parties, such as a law office or independent auditor: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms of Service and this Privacy Notice) or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations, such as audit requirements.
5. International Transfers
Some of our service providers are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.
- If you are located in the EU, when we share your personal data with third parties based outside of the European Economic Area ("EEA"), we will ensure that they sign on agreements that require them to comply with applicable law, and make sure that your data protection rights are protected. We will also implement the following safeguards:
- When we transfer your personal data to Israel, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection.
- Where we transfer your personal data to other countries, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses, to give your personal data the same protection it has in the EEA.
- Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
6. Security
The security of your personal data is our highest priority. We work hard to make sure that your personal data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords. The measures we take include:
- Technical Measures. The electronic safeguards we employ to protect your personal data include secure servers and firewalls. We encrypt authentication data in transit and at rest.
- Access Control. We limit access to your personal data only to authorized personnel who have a need to know, including customer support staff and software developers. We review these permissions regularly and revoke an employee's access immediately after his/her termination.
- Internal Policies. We maintain and regularly review and update our privacy related and information security policies.
- Personnel. We require employees to sign non-disclosure agreements according to applicable law and industry customary practice.
- Database Backup. Our databases are backed up and verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity.
7. Your Rights - How to Control Our Use of Your Personal Data
Depending on which laws apply, you have certain legal rights over your data. Below is some general information about rights that may apply to you but we recommend checking the law or consulting with a lawyer to understand what applies in your specific case. To exercise your rights, please contact us at [email protected]. We may ask for reasonable evidence to verify your identity before we can comply with any request.
- Right of Access. You may have a right to know what personal data we collect about you. We may charge you with a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15 of the GDPR for more details, if your personal data is subject to GDPR.
- Right to Correct Personal Data. You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. See Article 16 of the GDPR for more details, if your personal data is subject to GDPR.
- Deletion of Personal Data ("Right to Be Forgotten"). If you are located in the EU, you may have the right to request that we delete your personal data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your personal data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17 of the GDPR for more details, if your personal data is subject to GDPR.
- Right to Restrict Processing. If you are located in the EU, you may have the right to ask us to stop processing your personal data. See Article 18 of the GDPR for more details, if your personal data is subject to GDPR.
- Right to Data Portability. If you are located in the EU, you you may have the right to request that we provide you with a copy of the personal data you provided to us in a structured, commonly-used, and machine-readable format. See Article 20 of the GDPR for more details, if your personal data is subject to GDPR.
- Right to Object. If you are located in the EU, you may have the right to object to the processing of your personal data. See Article 21 of the GDPR for more details, if your personal data is subject to GDPR.
- Withdrawal of Consent. If we are processing your data based on your consent, you are always free to withdraw your consent, however, this won't affect processing we have done from before you withdrew your consent.
- Right to Lodge a Complaint with Your Local Data Protection Authority. If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your personal data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
Data Retention
We retain your personal data as long as necessary to fulfill each of the purposes we described above. The data will be automatically deleted after 12 months.
When deciding how long to store personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized access, the purposes for which the personal data was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business's retention policy.
In some circumstances, we may store your personal data for an extended period if required to do so by law (e.g. to fulfill tax or audit requirements), or to keep accurate records of our interactions in case there is a prospect of litigation relating to your personal data. In such cases, we will maintain the same security measures as described above.
Cookies and Similar Technologies
A cookie is a small piece of text that is sent to your browser by a website you visit. This piece of text acts as a tag, letting the website know that it's you (or your device) that's visiting. There are other technologies that act similarly, like web beacons, pixel tags, and Device IDs for apps, but for simplicity's sake, we'll refer to them all as "cookies."
Below is a list of cookie types and their functions:
| Cookie Type | Function |
|---|---|
| Necessary | These cookies allow the platform to work correctly. They enable your access to the platform, movement around the site, and access to different services and tools. These cookies cannot be disabled. |
| Functionality | These cookies remember your settings, preferences, and other choices you make (like placing an item in a shopping cart) in order to help personalize and streamline your experience. |
| Security | These cookies help us identify and prevent security risks. They may be used to store your session information to prevent unauthorized access to your account. |
| Performance/Analytics | These cookies collect analytical information to help us understand how you use our platform, including tracking page views, clicks, and how long you spent on each page. This helps us improve our platform to better suit your needs. |
| Advertising | These cookies help advertisers show you relevant ads. They may track your browsing habits and activity on both our platform and other sites, helping us serve you ads tailored to your interests. |
You can adjust your cookie preferences through your browser. Note that if you disable cookies, some features of the services may not function properly.
Third-Party Services
Our platform may provide access to third-party services. Please note that these services are governed by their own privacy policies, and we do not take responsibility for their actions or data handling practices.
Children
We do not knowingly collect personal data from children under the age of 18. If you become aware that a child under 18 has provided us with personal information, please contact us immediately.
Changes to the Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our practices, legal requirements, or technology. We encourage you to check this page periodically to stay informed of any updates.