Privacy Policy for Soul AI Applications

Effective Date: June 27, 2024

1. Introduction

Welcome! This Privacy Policy explains how Soul AI LLC ("we," "us," or "our") collects, uses, and shares information when you use our iOS applications (the "App" or "Apps").

Your privacy is important to us. This policy outlines our practices and your rights concerning your information. By using the App, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

We collect very limited information, focusing only on what's necessary to provide and improve the App:

Information You Provide Directly:

• Email Address: When you register for an account (if applicable for the specific App), we collect your email address. This is used solely for account creation, login, password recovery, and essential service-related communications.

Information Processed via Third Parties:

• Payment Information (via Apple): If you make any purchases within the App (e.g., subscriptions, one-time purchases), these are processed directly by Apple through their secure In-App Purchase system. We do not collect, receive, or store your credit card details or other sensitive payment information. Apple's processing of your payment information is governed by Apple's own Privacy Policy. We may receive transaction confirmation data from Apple (like a transaction ID and purchase status) but not your underlying financial details.
• Large Language Model (LLM) API Interactions (OpenAI): To provide the core functionality of the App, your inputs (e.g., text prompts you enter) are sent to our third-party Large Language Model API provider, OpenAI.
  • Important: We send your input to the OpenAI API solely to generate the response you requested within the App.
  • According to OpenAI's current usage policies (https://openai.com/policies/usage-policies/), data submitted via their API is not used to train their models unless explicitly opted into. *Note: OpenAI's policies can change; refer to their linked policy for the most current information.*
  • We do not intentionally send personal information (like your email address) within these prompts unless you explicitly type it into the input field.
  • Please review the privacy policy and data usage terms of OpenAI for details on how they handle the data processed through their API.

Information Collected Automatically (Minimal Technical Data):

• Like most mobile applications, we may automatically collect limited technical information necessary for the App to function correctly and securely. This might include:
  • Device type (e.g., "iPhone 14")
  • Operating system version (e.g., "iOS 17")
  • IP address (primarily for security, geographic region estimation, and diagnostics)
  • Crash reports (anonymized or pseudonymized data about app crashes, potentially via Apple's reporting or a service like [e.g., Firebase, AWS, etc.], solely for identifying and fixing bugs).
  • Basic usage statistics (e.g., frequency of app launch, feature interaction – often aggregated and anonymized) to help us understand usage patterns and improve the App.

3. How We Use Your Information

We use the information we collect for the following specific purposes:

• To Provide and Maintain the App: Using your email for login/account management (if applicable), using technical data for compatibility and functionality.
• To Enable Core Features: Sending your inputs to the OpenAI API to generate responses.
• To Communicate With You: Using your email for essential service updates, security notices, or password resets (if applicable). We will not use your email for marketing purposes unless you explicitly opt-in.
• To Improve the App: Analyzing anonymized or aggregated usage data and crash reports to identify bugs, understand user needs, and enhance performance.
• For Security and Fraud Prevention: Using IP addresses or device information to monitor for suspicious activity.
• To Comply with Legal Obligations: If required by law or valid legal process.

Legal Basis for Processing (GDPR):

• Processing your email for account management (if applicable) is based on the Performance of a Contract (our agreement to provide you the App service).
• Processing your inputs via the OpenAI API is based on the Performance of a Contract (providing the core feature you are using).
• Processing technical data for functionality, security, and basic improvement is based on our Legitimate Interest in operating and securing the App effectively, provided your rights do not override these interests.

4. How We Share Your Information

We do not sell your personal information. We only share information under the following limited circumstances:

• LLM API Provider (OpenAI): As described above, your inputs are sent to their API to generate responses. Their handling of this data is governed by their policies.
• Apple: For processing In-App Purchases as described above.
• Service Providers (Minimal): We may use third-party companies for hosting our backend (if applicable) or basic crash reporting (e.g., Firebase, AWS etc.). These providers are only given access to the information necessary to perform their tasks and are obligated not to disclose or use it for other purposes.
• Legal Requirements: We may disclose your information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• Business Transfers: If we are involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction, subject to notice and choices provided to you under applicable law.

5. Data Retention

• We retain your email address (if collected) for as long as your account remains active. If you delete your account, we will delete your email address from our active systems within a reasonable timeframe, subject to backup retention cycles or legal requirements.
• Technical logs (like IP addresses or crash data) are typically retained for a shorter period (e.g., 30-90 days) necessary for security, diagnostics, and troubleshooting.
• Data processed by third parties (Apple, OpenAI) is subject to their respective retention policies.

6. Data Security

We implement reasonable administrative, technical, and physical security measures designed to protect the information we collect from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. However, please be aware that no security system is impenetrable, and we cannot guarantee the absolute security of your information.

7. Your Privacy Rights

Depending on your location (e.g., EEA/UK under GDPR, California under CCPA/CPRA), you may have certain rights regarding your personal information:

• Right to Access: You may request access to the personal information we hold about you (primarily your email address, if collected).
• Right to Rectification: You can request correction of your email address (if collected and inaccurate) by contacting us.
• Right to Erasure (Deletion): You can request the deletion of your account and associated email address (if applicable) by contacting us. Note that deleting your account may result in the loss of access to the App's registered features.
• Right to Object (GDPR): You may object to processing based on legitimate interests under certain circumstances.
• Right to Restrict Processing (GDPR): You may request that we restrict the processing of your information under certain conditions.
• Right to Opt-Out of Sale/Sharing (CCPA/CPRA): We do not "sell" your personal information as traditionally defined. If our use of technical data with service providers constitutes "sharing" under CCPA's broad definition, you can contact us regarding your rights.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, please contact us at support@soul-ai.xyz. We will respond to your request in accordance with applicable laws. We may need to verify your identity before processing your request.

8. Children's Privacy (COPPA Compliance)

Our Apps are not intended for use by children under the age of 13 (or 16 in some jurisdictions like the EEA). We do not knowingly collect personal information from children under these ages. If you are a parent or guardian and believe we have inadvertently collected information from your child, please contact us immediately at support@soul-ai.xyz so we can take steps to remove that information.

9. International Data Transfers

Your information, including your email address (if collected) and any data processed via the OpenAI API or technical logs, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ. For example, OpenAI API servers or our hosting infrastructure may be located in the United States. We rely on the data processing agreements and safeguards provided by our third-party providers (like OpenAI, Apple, hosting services) for such transfers where required by law (e.g., Standard Contractual Clauses for transfers out of the EEA/UK).

10. Apple App Store Requirements Alignment

This Privacy Policy aligns with the information provided in the App Privacy section of our App Store listings. Payments are handled securely via Apple's In-App Purchase system. Any permissions requested by the app (e.g., notifications) will use the standard iOS permission prompts, which you can manage in your device Settings.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy within our Apps or by other means (like updating the "Effective Date" at the top). You are advised to review this Privacy Policy periodically for any changes. Your continued use of the App after changes constitutes your acceptance of the revised policy.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

By email: support@soul-ai.xyz