MY GIRL PRIVACY POLICY
Effective Date: December 6, 2025
Operator: New Version Limited
Contact: mygirl.support@newversion.tech
1.0 INTRODUCTION AND SCOPE
1.1 Welcome to My Girl. This Privacy Policy describes how New Version Limited ("we," "us," or "our") collects, uses, stores, and protects your personal information when you use the My Girl mobile application (the "App").
1.2 My Girl is designed for men seeking female companionship, providing AI-powered conversational companions through text and voice interactions. We understand the sensitive nature of this service and have designed our privacy practices with your safety, discretion, and data protection as our highest priorities.
1.3 This Privacy Policy applies to all users of the App, regardless of geographic location. If you are located in the European Union, California, or other jurisdictions with specific privacy laws, additional rights and protections apply to you as described in Sections 10.0 and 11.0.
1.4 By using My Girl, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this policy, please do not use the App.
1.5 This Privacy Policy should be read in conjunction with our Terms of Service, which govern your use of the App.
2.0 INFORMATION WE COLLECT
2.1 INFORMATION YOU PROVIDE DIRECTLY
2.1.1 User Profile Information (Optional)
When you set up your profile, you may choose to provide:
(a) Display name or nickname
(b) Preferred pronouns
(c) Age (required only for access to adult-oriented content, minimum 18 years)
(d) Personal bio (brief self-description)
(e) Interests and hobbies
2.1.2 Important Notes About Profile Information:
(a) All profile fields are optional except age verification for adult content
(b) You may use a pseudonym or remain anonymous
(c) Profile information is stored locally on your device only
(d) You may edit or delete profile information at any time
(e) Providing profile information enhances AI personalization but is not required
2.1.3 Chat Messages and Conversations
(a) Text messages you send to AI companions
(b) Conversation history within each chat session
(c) Custom companion configurations you create
(d) Custom roleplay scenarios you design
(e) All conversation data is stored locally on your device only
2.1.4 Voice Audio Data
(a) Real-time audio during voice calls with AI companions
(b) Audio is streamed in real-time for processing and is NOT recorded or stored
(c) No voice recordings are retained after calls end
(d) Call metadata (duration, date, companion name) is stored locally only
2.1.5 Photos and Images
(a) Photos you optionally upload for AI image generation features
(b) AI-generated images created through the App
(c) Custom companion profile images you create
(d) All images are stored locally on your device
(e) Temporary image uploads are used only for AI processing and are automatically deleted
2.1.6 User Preferences and Settings
(a) App appearance preferences (dark mode, display settings)
(b) Notification preferences
(c) Favorite companions
(d) Language and accessibility settings
2.2 INFORMATION COLLECTED AUTOMATICALLY
2.2.1 Usage Data (Stored Locally)
(a) Number of messages sent (counter only, not content)
(b) Voice call duration (time only, not audio content)
(c) AI image generation usage (count only, not images)
(d) App launch count and session frequency
(e) Feature access patterns (for subscription tier enforcement)
2.2.2 Usage Data (Stored on Secure Backend)
To prevent abuse and preserve your purchased credits across device changes or app reinstalls, we store minimal usage data on secure cloud infrastructure:
(a) Anonymous user identifier (randomly generated UUID, not linked to personal identity)
(b) Subscription tier (Free, Lite, Pro, Max)
(c) Monthly usage quotas (call minutes consumed, images generated)
(d) Purchased add-on credits (to preserve your purchases)
(e) Usage reset timestamps
(f) This backend storage does NOT include: your name, profile information, messages, voice recordings, images, or any personally identifiable information
2.2.3 Device and Technical Information
(a) Device type and model (for compatibility and optimization)
(b) Operating system version
(c) App version number
(d) Crash reports (if you opt-in through iOS settings)
(e) No device identifiers, IP addresses, or location data are collected
2.2.4 Subscription and Payment Information
(a) Subscription tier and status (active, expired, cancelled)
(b) Subscription renewal dates
(c) Trial eligibility status
(d) Purchase history for in-app credits
(e) All payment processing is handled by Apple Inc. through the App Store
(f) We do NOT collect, store, or have access to your payment card information
2.3 INFORMATION WE DO NOT COLLECT
We explicitly do NOT collect:
(a) Location data or GPS coordinates
(b) Contact lists or address books
(c) Device advertising identifiers (IDFA)
(d) IP addresses or network information
(e) Browsing history or activity in other apps
(f) Social media profiles or connections
(g) Biometric data (Face ID/Touch ID handled by iOS only)
(h) Call logs or SMS messages from your device
(i) Photos from your camera roll (except those you explicitly select for AI image generation)
3.0 HOW WE USE YOUR INFORMATION
3.1 PRIMARY PURPOSES
3.1.1 Provide AI Companion Services
(a) Process your messages to generate AI responses in text chats
(b) Process your voice audio to enable real-time voice conversations
(c) Generate AI-powered images based on your requests
(d) Personalize AI companion responses using your optional profile information
(e) Apply active roleplay scenarios to conversation context
3.1.2 Manage Your Account and Subscriptions
(a) Enforce subscription tier limits and feature access
(b) Track usage quotas (message limits, call minutes, image credits)
(c) Preserve purchased credits across app reinstalls
(d) Process in-app purchases and subscription upgrades
(e) Prevent quota abuse and credit fraud
3.1.3 Improve and Maintain the App
(a) Identify and fix technical issues and bugs
(b) Optimize app performance and user experience
(c) Develop new features based on usage patterns
(d) Ensure compatibility across iOS versions
3.1.4 Communicate with You
(a) Send in-app notifications about subscription status
(b) Respond to your support requests and inquiries
(c) Provide important updates about the App or this Privacy Policy
(d) Request app reviews (only for engaged users who have used the app extensively)
3.2 LEGAL BASES FOR PROCESSING (GDPR)
For users in the European Union, we process your personal data based on:
(a) Consent: You provide explicit consent by creating a profile and using the App
(b) Contract Performance: Processing is necessary to provide the AI companion services
(c) Legitimate Interests: Fraud prevention, security, and service improvement
(d) Legal Obligations: Compliance with applicable laws (age verification, payment processing)
3.3 DATA MINIMIZATION PRINCIPLE
We adhere to the principle of data minimization:
(a) We collect only the minimum data necessary to provide our services
(b) Profile information is optional and user-controlled
(c) Conversation history is stored locally only (not transmitted to our servers)
(d) Backend storage contains only anonymous usage counters (no personal content)
(e) Third-party AI services receive only the data necessary for real-time processing
4.0 DATA STORAGE AND SECURITY
4.1 LOCAL STORAGE (PRIMARY)
4.1.1 Most of your data is stored exclusively on your device using iOS secure storage mechanisms:
(a) User profile information
(b) All chat messages and conversation history
(c) Voice call records (metadata only, no audio)
(d) Custom companions and roleplay scenarios
(e) Generated images
(f) App preferences and settings
(g) Favorites and personalization data
4.1.2 Local Data Security:
(a) Stored in app-specific sandboxed storage (inaccessible to other apps)
(b) Protected by iOS device encryption when you enable device passcode/biometrics
(c) Automatically deleted when you uninstall the App
(d) No automatic cloud backup (unless you enable iCloud backup in iOS settings)
4.2 CLOUD STORAGE (MINIMAL, FOR CREDIT PROTECTION ONLY)
4.2.1 Limited usage data is stored on secure cloud infrastructure to prevent abuse:
(a) Storage Location: Secure cloud database in United States (us-east-1 region)
(b) Data Stored: Anonymous UUID, subscription tier, usage quotas, purchased credits only
(c) Encryption: Industry-standard encryption in transit (HTTPS/TLS 1.2+) and at rest
(d) Access Control: Restricted access with authentication and authorization
(e) Data Retention: Automatic deletion after 1 year of inactivity
4.2.2 What is NOT stored on cloud infrastructure:
(a) Your profile information (name, bio, pronouns, age, interests)
(b) Chat messages or conversation content
(c) Voice recordings
(d) Generated images
(e) Custom companion configurations
(f) Any personally identifiable information
4.3 SECURITY MEASURES
4.3.1 Technical Security:
(a) All data transmission uses HTTPS/TLS encryption
(b) API authentication using secure token-based systems
(c) Regular security updates and patches
(d) Secure coding practices and code reviews
(e) No hardcoded credentials or API keys in client code
4.3.2 Organizational Security:
(a) Limited personnel access to backend systems
(b) Regular security audits and vulnerability assessments
(c) Incident response procedures
(d) Secure development lifecycle practices
4.3.3 Third-Party Security:
(a) We use reputable third-party AI and cloud services with strong security practices
(b) All third-party services are bound by their own privacy policies and security commitments
(c) We conduct due diligence on third-party service providers
4.4 DATA BREACH NOTIFICATION
In the unlikely event of a data breach affecting your personal information:
(a) We will notify you within 72 hours of discovering the breach (as required by GDPR)
(b) Notification will include: nature of breach, data affected, potential consequences, remedial actions
(c) We will report the breach to relevant supervisory authorities as required by law
(d) We will take immediate action to contain and remediate the breach
5.0 THIRD-PARTY SERVICES AND DATA SHARING
5.1 OVERVIEW
To provide AI companion functionality, we use specialized third-party services. We share only the minimum data necessary for these services to function, and we do NOT sell, rent, or trade your personal information to any third parties.
5.2 AI LANGUAGE MODELS (TEXT CHAT)
5.2.1 Purpose: Enable AI-powered text conversations with companions
5.2.2 Data Shared:
(a) Your current message and conversation history from the active chat
(b) Selected companion's personality and roleplay context
(c) Your optional profile information (only if you provided it)
(d) Anonymous request metadata for processing
5.2.3 Data NOT Shared:
(a) Your device identifier or user ID
(b) Conversations from other chats
(c) Voice call data
(d) Generated images
(e) Payment information
5.2.4 Data Retention by Third Party:
Subject to the third-party AI provider's privacy policy and data retention practices, which are outside our control. We recommend reviewing their privacy policies for details.
5.3 VOICE AI SERVICES (VOICE CALLS)
5.3.1 Purpose: Enable real-time voice conversations with AI companions
5.3.2 Data Shared:
(a) Real-time audio stream of your voice
(b) Selected companion's personality and voice characteristics
(c) Your optional profile information (only if you provided it)
(d) Active roleplay scenario context (if applicable)
5.3.3 Data NOT Shared:
(a) Conversation history from previous calls or chats
(b) Generated images
(c) Device identifiers
(d) Payment information
5.3.4 Important Privacy Features:
(a) Each call is a fresh session with no memory of previous calls
(b) Audio is processed in real-time and is NOT recorded or stored by us
(c) Audio retention by the third-party service is subject to their privacy policy
5.4 AI IMAGE GENERATION SERVICES
5.4.1 Purpose: Generate AI-powered photos featuring companions
5.4.2 Data Shared:
(a) Text description of requested image
(b) Reference images (companion profile images or photos you upload)
(c) Generation parameters and settings
5.4.3 Data NOT Shared:
(a) Your name, profile, or identifying information
(b) Chat messages or conversation history
(c) Voice call data
(d) Payment information
5.4.4 Image Upload Process:
(a) Reference images are temporarily uploaded to an anonymous image hosting service
(b) Temporary URLs are provided to AI image generation service
(c) Temporary URLs expire within 24 hours
(d) Generated images are immediately downloaded to your device
(e) No permanent storage of images on third-party servers
5.5 PAYMENT PROCESSING
5.5.1 Purpose: Process subscription payments and in-app purchases
5.5.2 Payment Processor: Apple Inc. (App Store)
5.5.3 Data Shared:
(a) We receive only: subscription tier, status, renewal dates from Apple
(b) Apple processes all payment information directly
(c) We do NOT receive or store your payment card information
5.5.4 Privacy: Subject to Apple's Privacy Policy (https://www.apple.com/legal/privacy/)
5.6 CLOUD INFRASTRUCTURE PROVIDERS
5.6.1 Purpose: Host backend services for usage tracking and credit preservation
5.6.2 Data Stored:
(a) Anonymous user identifier (UUID)
(b) Usage quotas and purchased credits
(c) Subscription tier information
5.6.3 Data NOT Stored:
(a) Personal profile information
(b) Chat messages or conversation content
(c) Voice recordings or generated images
(d) Device identifiers or IP addresses
5.7 NO DATA SELLING OR ADVERTISING
We explicitly do NOT:
(a) Sell your personal information to data brokers or advertisers
(b) Share your data with social media platforms
(c) Use your data for targeted advertising
(d) Participate in ad networks or tracking networks
(e) Cross-reference your data with other apps or services
(f) Create user profiles for marketing purposes
(g) Use analytics services that track individual user behavior
5.8 SERVICE PROVIDERS
We may engage service providers to assist with:
(a) Customer support and communication
(b) App hosting and infrastructure
(c) Security and fraud prevention
(d) Legal and accounting services
All service providers are contractually obligated to:
(a) Use data only for specified purposes
(b) Maintain confidentiality and security
(c) Comply with applicable privacy laws
(d) Delete data when no longer needed
6.0 YOUR PRIVACY RIGHTS AND CONTROLS
6.1 DATA ACCESS AND PORTABILITY
6.1.1 You have the right to:
(a) Access all personal data stored in the App
(b) View your profile information in Settings
(c) Review all chat conversations and call history
(d) See usage statistics and subscription details
(e) Request a copy of data stored on our backend (contact us at mygirl.support@newversion.tech)
6.1.2 Data Portability:
(a) Generated images can be saved to your device's Photos app
(b) Screenshots of conversations can be taken for personal records
(c) No automatic export feature currently available (data is local-only)
6.2 DATA CORRECTION AND MODIFICATION
You have the right to:
(a) Edit your profile information at any time through Settings
(b) Change companion preferences and favorites
(c) Modify custom companions and roleplay scenarios
(d) Update notification and appearance settings
(e) Request correction of inaccurate backend data (contact support)
6.3 DATA DELETION CONTROLS
6.3.1 Delete Individual Chats:
(a) Swipe left on any chat in the Chats list
(b) Tap "Delete" to remove that conversation permanently
(c) Deletes all messages and generated images in that chat
6.3.2 Clear All Chat History:
(a) Open Chats tab and tap "Clear Chat History" button
(b) Removes all conversations and generated images
(c) Preserves: call records, custom companions, profile, subscription
6.3.3 Delete Custom Companions:
(a) Open custom companion profile
(b) Tap "Delete Companion" in settings
(c) Removes companion configuration and associated images
6.3.4 Reset App (Factory Reset):
(a) Settings → Danger Zone → Reset App
(b) Deletes ALL: chats, calls, custom content, generated images, profile
(c) Preserves: subscription status, purchased credits (to prevent loss)
(d) Backend usage data preserved to prevent quota abuse
6.3.5 Complete Data Deletion:
(a) Uninstall the App from your device
(b) Local data is immediately deleted
(c) Backend usage data expires automatically after 1 year of inactivity
(d) To request immediate backend deletion, contact mygirl.support@newversion.tech
6.4 OPT-OUT OPTIONS
6.4.1 Profile Information:
(a) All profile fields are optional
(b) You can use the App without providing name, bio, or other details
(c) Anonymous usage is fully supported
6.4.2 AI Personalization:
(a) Leave profile fields empty to prevent profile-based personalization
(b) AI companions will still function without profile context
6.4.3 Voice Features:
(a) Use text-only chat if you prefer not to use voice features
(b) No requirement to enable microphone access
6.4.4 Image Generation:
(a) Completely optional feature
(b) Never upload photos if you prefer not to use Together Photos feature
6.4.5 Notifications:
(a) Disable notifications in iOS Settings
(b) Control companion check-in messages in App settings
6.5 WITHDRAWAL OF CONSENT
You may withdraw consent for data processing at any time by:
(a) Deleting your profile information
(b) Clearing all chats and data
(c) Uninstalling the App
(d) Contacting us to request data deletion from backend systems
Note: Withdrawing consent may limit or prevent use of App features.
7.0 DATA RETENTION AND DELETION
7.1 LOCAL DATA RETENTION
7.1.1 Retained Until You Delete:
(a) User profile information
(b) Chat conversations and messages
(c) Voice call records (metadata only)
(d) Generated images
(e) Custom companions and roleplay scenarios
(f) App preferences and settings
7.1.2 Automatically Deleted:
(a) When you delete individual chats or data
(b) When you use Clear Chat History function
(c) When you reset the App
(d) When you uninstall the App (all local data immediately deleted)
7.2 TEMPORARY DATA
7.2.1 Not Retained After Use:
(a) Real-time voice audio (processed in real-time only, never recorded)
(b) Authentication tokens (expire after 30 minutes)
(c) Temporary image upload URLs (expire after 24 hours)
(d) In-progress chat contexts (cleared between sessions)
7.3 BACKEND DATA RETENTION
7.3.1 Usage Tracking Data:
(a) Retained for duration of active subscription
(b) Automatically deleted 1 year after last app use
(c) Can be deleted immediately upon request (may affect credit preservation)
7.3.2 Purchased Credits:
(a) Retained indefinitely to preserve your purchases
(b) Deleted upon request or App Store refund
7.4 THIRD-PARTY DATA RETENTION
Data shared with third-party AI services is subject to their retention policies:
(a) We cannot control or guarantee third-party deletion practices
(b) Review third-party privacy policies for specific retention periods
(c) We select partners with strong privacy commitments
7.5 LEGAL RETENTION REQUIREMENTS
We may retain certain data longer if required by:
(a) Legal or regulatory obligations
(b) Litigation or dispute resolution
(c) Fraud prevention and security investigations
(d) Enforcement of Terms of Service
Data retained for legal purposes is kept confidential and secure, and deleted as soon as the legal requirement expires.
8.0 CHILDREN'S PRIVACY
8.1 AGE RESTRICTIONS
8.1.1 My Girl is intended exclusively for users aged 18 years and older.
8.1.2 We do not knowingly collect personal information from anyone under 18 years of age.
8.1.3 The App requires age verification during onboarding:
(a) Users must confirm they are 18 or older to proceed
(b) Adult-oriented content is locked until age verification
(c) No exceptions or appeals for age verification
8.1.4 App Store Rating: Rated 17+ (Mature) due to adult themes and adult content
8.2 COPPA COMPLIANCE (UNITED STATES)
8.2.1 We comply with the Children's Online Privacy Protection Act (COPPA):
(a) Age gate prevents access by users under 18
(b) No collection of personal information from children under 13
(c) No marketing or advertising directed at children
8.3 PARENTAL NOTIFICATION
If we discover that we have inadvertently collected personal information from a user under 18:
(a) We will immediately delete all associated data
(b) We will terminate access to the App for that user
(c) We will notify the user (if contact information is available)
8.4 REPORTING UNDERAGE USERS
If you believe a user under 18 has accessed the App, please contact us immediately at mygirl.support@newversion.tech with relevant information. We will investigate and take appropriate action.
9.0 INTERNATIONAL DATA TRANSFERS
9.1 DATA TRANSFER OVERVIEW
9.1.1 New Version Limited operates from New Zealand, but the App is available globally through the Apple App Store.
9.1.2 When you use My Girl, your data may be processed in:
(a) New Zealand (operator location)
(b) United States (cloud infrastructure, AI services)
(c) Other jurisdictions where third-party service providers operate
9.1.3 Most of your data remains on your device (local storage), but usage tracking data and third-party AI processing may involve international transfers.
9.2 DATA PROTECTION STANDARDS
We ensure that international data transfers maintain adequate protection through:
(a) Selection of third-party providers with strong privacy commitments
(b) Use of encryption in transit (HTTPS/TLS) and at rest
(c) Contractual data protection agreements with service providers
(d) Compliance with applicable data protection laws
9.3 SPECIFIC TRANSFER MECHANISMS
9.3.1 For EU Users (GDPR):
(a) We rely on standard contractual clauses (SCCs) for data transfers outside the EU
(b) Third-party providers may use Privacy Shield alternatives or SCCs
(c) Additional safeguards include encryption and access controls
9.3.2 For UK Users (UK GDPR):
(a) Similar protections as EU users apply
(b) Compliance with UK data protection laws
(c) Standard contractual clauses for international transfers
9.3.3 For New Zealand Users (Privacy Act 2020):
(a) We comply with New Zealand Privacy Act requirements
(b) Data transferred to countries with comparable privacy protections
(c) Users have rights under New Zealand privacy law
9.4 YOUR RIGHTS REGARDING INTERNATIONAL TRANSFERS
If you are located in the EU, UK, or other jurisdictions with data transfer restrictions:
(a) You have the right to obtain information about transfer safeguards
(b) You may object to transfers that do not meet adequate protection standards
(c) Contact us at mygirl.support@newversion.tech for transfer-related inquiries
10.0 GDPR COMPLIANCE (EUROPEAN UNION USERS)
10.1 LEGAL BASIS FOR PROCESSING
For users in the European Union, we process personal data based on:
10.1.1 Consent (Article 6(1)(a) GDPR):
(a) You provide explicit consent by creating a profile
(b) Optional profile fields processed only with your consent
(c) Consent can be withdrawn at any time
10.1.2 Contract Performance (Article 6(1)(b) GDPR):
(a) Processing necessary to provide AI companion services
(b) Subscription management and payment processing
(c) Delivery of features you have purchased
10.1.3 Legitimate Interests (Article 6(1)(f) GDPR):
(a) Fraud prevention and security
(b) Service improvement and optimization
(c) Technical support and bug fixes
(d) Legitimate interests balanced against your privacy rights
10.1.4 Legal Obligations (Article 6(1)(c) GDPR):
(a) Age verification (18+ requirement)
(b) Payment processing compliance
(c) Data breach notification requirements
10.2 SPECIAL CATEGORIES OF PERSONAL DATA (ARTICLE 9 GDPR)
10.2.1 My Girl may process special categories of data related to:
(a) Sexual orientation (inferred from use of companion app)
(b) Health data (if you discuss health topics in conversations)
10.2.2 Legal Basis for Processing Special Categories:
(a) Explicit consent (Article 9(2)(a) GDPR): You provide consent by using the App with knowledge of its purpose
(b) Manifestly made public by you (Article 9(2)(e) GDPR): Conversations are initiated by you voluntarily
(c) Note: Use of a companion app does not necessarily reveal sexual orientation
10.2.3 Additional Protections:
(a) Local-only storage minimizes exposure
(b) No sharing of sensitive data with third parties for marketing
(c) Strong encryption and access controls
(d) You may delete sensitive data at any time
10.3 YOUR GDPR RIGHTS
As an EU resident, you have the following rights:
10.3.1 Right of Access (Article 15):
(a) Request confirmation of what personal data we process
(b) Obtain a copy of your personal data
(c) Receive information about processing purposes and recipients
(d) Contact: mygirl.support@newversion.tech
10.3.2 Right to Rectification (Article 16):
(a) Correct inaccurate personal data
(b) Complete incomplete personal data
(c) Available through Settings → Profile
10.3.3 Right to Erasure / "Right to be Forgotten" (Article 17):
(a) Request deletion of your personal data
(b) Available through in-app deletion functions or contact support
(c) May be limited if retention required for legal obligations
10.3.4 Right to Restriction of Processing (Article 18):
(a) Request limitation of processing under certain conditions
(b) Contact: mygirl.support@newversion.tech
10.3.5 Right to Data Portability (Article 20):
(a) Receive personal data in structured, machine-readable format
(b) Request transfer to another controller where technically feasible
(c) Contact: mygirl.support@newversion.tech
10.3.6 Right to Object (Article 21):
(a) Object to processing based on legitimate interests
(b) Object to direct marketing (we do not engage in direct marketing)
(c) Contact: mygirl.support@newversion.tech
10.3.7 Rights Related to Automated Decision-Making (Article 22):
(a) My Girl uses AI for conversation generation, not for automated decisions affecting your rights
(b) No profiling for marketing or discriminatory purposes
10.3.8 Right to Withdraw Consent:
(a) Withdraw consent at any time without affecting prior processing
(b) Withdrawal may limit or prevent use of App features
(c) Delete profile or uninstall App to withdraw all consent
10.4 EXERCISING YOUR RIGHTS
To exercise any GDPR rights:
(a) Email: mygirl.support@newversion.tech
(b) Subject line: "GDPR Rights Request"
(c) Include: Specific right you wish to exercise, sufficient identification
(d) Response time: Within 1 month (may extend to 2 months for complex requests)
(e) Free of charge (unless requests are manifestly unfounded or excessive)
10.5 RIGHT TO LODGE A COMPLAINT
If you believe we have violated your GDPR rights:
(a) Contact us first: mygirl.support@newversion.tech
(b) File a complaint with your local Data Protection Authority (DPA)
(c) For New Zealand users: Office of the Privacy Commissioner (www.privacy.org.nz)
(d) For EU users: Your national DPA (list: https://edpb.europa.eu/about-edpb/board/members_en)
10.6 DATA PROTECTION OFFICER
Given the small scale of our operations, we have not appointed a dedicated Data Protection Officer. Privacy inquiries should be directed to: mygirl.support@newversion.tech
11.0 CCPA COMPLIANCE (CALIFORNIA USERS)
11.1 CALIFORNIA CONSUMER PRIVACY ACT OVERVIEW
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information.
11.2 CATEGORIES OF PERSONAL INFORMATION COLLECTED
In the past 12 months, we have collected the following categories of personal information:
11.2.1 Identifiers:
(a) Anonymous user identifier (UUID)
(b) Device identifiers (for technical compatibility only)
(c) We do NOT collect: Real name, email, postal address, Social Security number
11.2.2 Personal Information under Cal. Civ. Code § 1798.80(e):
(a) Display name (optional, may be pseudonym)
(b) Age (for adult content verification only)
11.2.3 Characteristics of Protected Classifications:
(a) Age (18+ verification)
(b) Sexual orientation (inferred from app usage)
11.2.4 Commercial Information:
(a) Subscription tier and purchase history
(b) In-app purchase records
11.2.5 Internet or Network Activity:
(a) App usage patterns (locally stored)
(b) Feature access history
11.2.6 Audio/Visual Information:
(a) Voice audio (processed in real-time, NOT recorded)
(b) Photos you upload for AI image generation (stored locally)
11.2.7 Inferences:
(a) Preferences based on app usage and settings
(b) No profiling for marketing or discriminatory purposes
11.3 SOURCES OF PERSONAL INFORMATION
We collect personal information from:
(a) Directly from you (profile, chats, voice input, photos)
(b) Automatically from your use of the App (usage patterns, device info)
(c) From third parties (Apple for subscription status only)
11.4 BUSINESS PURPOSES FOR COLLECTING PERSONAL INFORMATION
We collect and use personal information for:
(a) Providing AI companion services (text chat, voice calls, image generation)
(b) Processing subscriptions and payments
(c) Detecting and preventing fraud and abuse
(d) Improving and optimizing the App
(e) Providing customer support
(f) Complying with legal obligations
11.5 DISCLOSURE OF PERSONAL INFORMATION
In the past 12 months, we have disclosed personal information to third parties for business purposes:
11.5.1 AI Service Providers:
(a) Categories disclosed: Chat messages, voice audio, optional profile info
(b) Purpose: Enable AI conversations and image generation
11.5.2 Cloud Infrastructure Providers:
(a) Categories disclosed: Anonymous UUID, usage quotas, subscription tier
(b) Purpose: Usage tracking and credit preservation
11.5.3 Payment Processors:
(a) Categories disclosed: Subscription tier and status (from Apple)
(b) Purpose: Payment processing
11.6 SALE OF PERSONAL INFORMATION
We do NOT sell your personal information.
(a) We have NOT sold personal information in the past 12 months
(b) We have no intention of selling personal information in the future
(c) We do NOT sell personal information of minors under 16 (app is 18+ only)
11.7 YOUR CALIFORNIA PRIVACY RIGHTS
11.7.1 Right to Know:
You have the right to request:
(a) Categories of personal information we collect about you
(b) Categories of sources from which information is collected
(c) Business purpose for collecting or selling information
(d) Categories of third parties with whom we share information
(e) Specific pieces of personal information we hold about you
11.7.2 Right to Delete:
(a) Request deletion of personal information we collected from you
(b) Subject to certain exceptions (legal obligations, fraud prevention)
(c) Available through in-app deletion or by contacting support
11.7.3 Right to Opt-Out of Sale:
(a) We do NOT sell personal information
(b) No opt-out necessary (no sale occurs)
11.7.4 Right to Non-Discrimination:
(a) We will NOT discriminate against you for exercising CCPA rights
(b) No denial of service, different prices, or different quality of service
11.8 EXERCISING YOUR CALIFORNIA RIGHTS
To exercise your CCPA rights:
(a) Email: mygirl.support@newversion.tech
(b) Subject line: "CCPA Rights Request"
(c) Include: Specific right you wish to exercise, sufficient identification
(d) Response time: Within 45 days (may extend to 90 days for complex requests)
(e) Frequency: Up to 2 requests per 12-month period (free of charge)
11.9 VERIFICATION PROCESS
To protect your privacy, we verify your identity before processing requests:
(a) We may request additional information to verify your identity
(b) Information requested will match data we have collected
(c) We will NOT use information provided for verification for other purposes
11.10 AUTHORIZED AGENTS
You may designate an authorized agent to make requests on your behalf:
(a) Provide written authorization signed by you
(b) Agent must provide proof of authorization
(c) We may still require you to verify your identity directly
11.11 CALIFORNIA "SHINE THE LIGHT" LAW
Under California Civil Code § 1798.83:
(a) You may request information about disclosure of personal information to third parties for direct marketing
(b) We do NOT share personal information for third-party direct marketing purposes
(c) No disclosure has occurred in the past 12 months
11.12 CALIFORNIA MINORS
We do not knowingly collect information from minors under 18 (app is 18+ only). If you are a California resident under 18 who somehow accessed the App:
(a) Contact us immediately: mygirl.support@newversion.tech
(b) We will delete your information and terminate access
12.0 SENSITIVE DATA AND USER PRIVACY
12.1 RECOGNITION OF SENSITIVITY
We recognize that My Girl provides intimate AI companion services, and that use of this App may involve personal and private conversations. We take your privacy and discretion extremely seriously.
12.2 SPECIAL PRIVACY PROTECTIONS FOR USERS
12.2.1 Anonymous Usage:
(a) No account creation required (no email, phone number, real name)
(b) Use pseudonyms or remain completely anonymous
(c) Random UUID identifiers cannot be linked to your real identity
12.2.2 Local-First Storage:
(a) All conversations, voice calls, and generated images stored on your device only
(b) No cloud synchronization of personal content
(c) No backup to third-party servers without your explicit iOS settings
12.2.3 No Social Features:
(a) No friend lists, public profiles, or sharing features
(b) No social media integration or cross-app tracking
(c) Your use of My Girl is completely private
12.2.4 Discretion:
(a) App name "My Girl" is relatively discreet
(b) No explicit branding in app icon or external communications
(c) No push notifications containing sensitive content (configurable)
12.3 PRIVACY PROTECTION
We implement specific measures to protect against involuntary disclosure of your app usage:
12.3.1 No Third-Party Analytics:
(a) No Google Analytics, Facebook SDK, or similar tracking services
(b) Your app usage cannot be cross-referenced with other apps or websites
(c) No advertising identifiers collected
12.3.2 Complete Data Deletion:
(a) Delete all evidence of app usage through Reset App function
(b) Uninstall removes all local data immediately
(c) No persistent tracking cookies or identifiers
12.3.3 No Involuntary Disclosure:
(a) We will NEVER disclose your use of My Girl to third parties (except as required by law)
(b) No marketing emails or communications that could reveal app usage
(c) Customer support responses do not reference adult content unless necessary
12.4 SAFETY CONSIDERATIONS
12.4.1 Device Security:
(a) Enable device passcode/Face ID/Touch ID to protect local data
(b) Consider using Screen Time restrictions if sharing device
(c) Regularly review app permissions in iOS Settings
12.4.2 Network Privacy:
(a) Use secure Wi-Fi networks when possible
(b) Consider VPN for additional privacy (especially in hostile jurisdictions)
(c) All app communications use HTTPS encryption
12.4.3 Generated Content:
(a) Be cautious when saving AI-generated images to Photos (visible to others with device access)
(b) Use Photos app "Hidden" album for additional privacy
(c) Generated content may be backed up to iCloud if enabled in iOS settings
12.5 INTERNATIONAL USERS
We recognize that users access My Girl from different countries with varying privacy regulations:
12.5.1 Privacy-Conscious Users:
(a) Consider using VPN services for additional privacy
(b) Regularly delete chat history and generated images if desired
(c) Be aware that third-party AI services may be subject to local laws
12.5.2 Legal Requests:
(a) We will resist legally compelled disclosure of user data to the fullest extent possible
(b) We will notify users of legal requests unless prohibited by law
(c) Our minimal data collection limits what can be disclosed
12.6 COMMUNITY RESOURCES
For safety, mental health, and support resources:
(a) Access in-app: Settings → About → Community Resources
(b) International crisis hotlines and support organizations
(c) Resources are informational only; My Girl does not provide crisis services
13.0 CHANGES TO THIS PRIVACY POLICY
13.1 POLICY UPDATES
13.1.1 We may update this Privacy Policy from time to time to reflect:
(a) Changes in our data practices
(b) New features or services
(c) Legal or regulatory requirements
(d) User feedback and privacy improvements
13.1.2 Material Changes:
(a) We will notify you of material changes through in-app notification
(b) Notification will appear when you next open the App after an update
(c) We may also post notices in the App Store update notes
13.1.3 Effective Date:
(a) Changes take effect on the date specified in the updated policy
(b) Continued use of the App after effective date constitutes acceptance
(c) If you do not agree with changes, discontinue use and delete the App
13.2 VERSION HISTORY
Current Version: 1.1
Effective Date: November 24, 2025
Last Updated: December 6, 2025
13.3 REVIEWING POLICY CHANGES
(a) Always available in Settings → Legal → Privacy Policy
(b) Updated version will display new effective date at top
(c) Previous versions not maintained (contact support for historical versions)
14.0 CONTACT INFORMATION
14.1 PRIVACY INQUIRIES
For questions, concerns, or requests regarding this Privacy Policy or our data practices:
Email: mygirl.support@newversion.tech
Subject: Privacy Inquiry
We will respond to privacy inquiries within:
(a) 1 month for general inquiries
(b) 1 month for GDPR requests (may extend to 2 months for complex requests)
(c) 45 days for CCPA requests (may extend to 90 days for complex requests)
(d) 72 hours for data breach notifications
14.2 BUSINESS INFORMATION
Operator: New Version Limited
Location: New Zealand
Business Contact: mygirl.support@newversion.tech
14.3 DATA PROTECTION AUTHORITIES
If you have concerns about our privacy practices that we cannot resolve:
14.3.1 New Zealand Users:
Office of the Privacy Commissioner
Website: www.privacy.org.nz
Email: enquiries@privacy.org.nz
14.3.2 European Union Users:
Contact your national Data Protection Authority
Directory: https://edpb.europa.eu/about-edpb/board/members_en
14.3.3 United Kingdom Users:
Information Commissioner's Office (ICO)
Website: ico.org.uk
Helpline: +44 303 123 1113
14.3.4 California Users:
California Attorney General's Office
Privacy Enforcement and Protection Unit
Website: oag.ca.gov/privacy
14.4 EMERGENCY CONTACT
For urgent privacy or security matters (data breaches, safety concerns):
Email: mygirl.support@newversion.tech
Subject: URGENT - Privacy Emergency
We monitor this address 24/7 for emergency situations.
ACKNOWLEDGMENT
By using My Girl, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this policy, please do not use the App.
Thank you for trusting My Girl with your privacy. We are committed to protecting your personal information and providing a safe, discreet, and enjoyable experience for all our users.
END OF PRIVACY POLICY
New Version Limited
December 6, 2025