SoulPartner App Privacy Policy

Last modified: 4 APRIL 2024

Effective date: 4 APRIL 2024

This Privacy and Data Protection Policy (“Policy”) is effective as of the date set forth above. VAKU APPS LTD (“Company”, “VAKU APPS LTD”, “We”, “Us”, “Our”), operating with SoulPartner application (“App”) is committed to honoring and encouraging the protection of your privacy as a user who uses the App (“you”, “your”, “User”). You may print a copy of this Policy for your records.

Our Policy is designed to provide an explanation of the information collected by us and our partners, as well as how we use and protect your information when you use our mobile applications, which are available for download on the Google Play Store or App Store, and our web applications.

Information Collected through the Services

This page serves as a means to inform visitors about the policies regarding the collection, use, and disclosure of Personal Information when using our app's Services. In this Policy, the term 'personal information' refers to any data that can be used to identify or make an individual identifiable. When you interact with or utilize our Services, we may collect the personal information outlined below. By choosing to use our Services, you agree to the collection and use of information in accordance with this policy. The Personal Information we collect is used to provide and improve the Service. The information that we and/or our partners collect is listed below.

1. Device information

To enhance your app experience, we collect device and network connection information.

The specific data we collect depends on your interactions with us, your privacy settings, and the products and features you use. It may include:

We may be able to identify the general location of your mobile device (not precise geolocation data), your mobile device’s brand, model in order to analyze usage statistics of our app.
App usage data, including, among others: frequency of use, features of our App you use, engagement.
Some of your personal data is collected by our Partners. Our Partners collect personal data related to your activity on the respective app store or distribution platform and within the App/Website by means they determine to be appropriate for that in order to provide us with analytical statistics, etc., to provide you with customized advertisement experience. Full list of our Partners you can find in a “Cross-border Transfer of Data” block.

2. Information you provide to us

Name
Age
Preferred pronouns
Materials, Records, Data, or Content: This includes any texts, visual documentation, graphics, and other forms of data that you supply, upload, transmit, generate, store, use, modify, or share via the App. It encompasses the messages you send and receive through the App, including any personal details you share about yourself or your life, as well as any photos, videos, and voice and text communications you provide.
Interests and Preferences: You have the option to set conversation preferences, such as the subjects you're interested in discussing, and communication preferences. Additionally, through your interaction with the Services, we can gather insights into your interests and preferences to tailor your conversation experiences and the functionalities of the Services to your liking.

3. Data about your use of the Services

Number pages viewed and order of those pages
Permissions status
Package name
First open time timestamp
App brand
App model
Sim card country
System language, etc.
Session duration;
Number of users and sessions;
Session duration;
Operating systems;
Device models;
Geography;
First launches;
App/Website opens;
App/Website updates;
In-app purchases
Data related to session activity;
Cookies;
Location data;
Data regarding your device;
Advertisers may store or read cookies
These data only be passed to the certified third-party statistical platform: Firebase, Google Analytics, etc.
The above information is only used to improve the product experience. We will not use this information for purposes other than improving the product experience and ad performance.

4. Monetization and Analytical Information from Other Sources

Third-party SDKs integrated into our app may access certain information, including:

Google Advertising ID
Demographic data, such as your IP address
Data to combat fraud, such as click fraud in advertising
Data associated with your device, such as device type, technological information, and country
Data for advertising, marketing, and analysis purposes
The ability for advertisers to store or read cookies

Please note that the information collected by these third-party SDKs is governed by the providers of these SDKs, and we have no control over their practices. These third parties include monetization partners like Google AdMob, Facebook Audience Network, Applovin, Mintegral etc., as well as analytical tools partners like Firebase and Facebook Analytics, etc. Links to the privacy policies of these platforms can be found in the "Cross-border Transfer of Data and Third-party Partner's Privacy Policy" section.

5. Android Advertising ID

We utilize your Android advertising identifier to deliver personalized advertising experiences. This identifier is used solely for advertising and analytics purposes. It does not contain any sensitive user information that can personally identify you or your device. Furthermore, it is not linked to personally-identifiable information or associated with any persistent device identifiers such as SSAID, MAC address, IMEI, and others.

6. Data Collected When Reporting Content

When submitting a report within the app, we may collect the following information:

The identifier of the content being reported
The reason for the report
The timestamp of the report

7. Other Information

We may gather information that you provide to us directly and voluntarily. This can include, but is not limited to, your email address, feedback content, and responses to questionnaires.

How Do We Use the Information

1. To improve and optimize the Services
In order to provide you with better Services, we have a legitimate interest in collecting and processing necessary data to:

Update and develop the Services
Improve your overall experience
Manage our relationship with you
Customize your service experience
Respond to your comments, questions, and provide support
Offer relevant information, updates, security alerts, and support messages
Provide offers within the Services and on other websites and platforms

2. To deliver the Services, we process data that is necessary to:

Enable your usage of the Apps and Services
Operate and maintain the Services
Provide and deliver requested products and services

3. Advertising and marketing activities

We may engage third-party advertising and marketing partners to assist us, and we may share information collected from you with these partners for advertising and marketing purposes.

Therefore, we have a legitimate interest in processing necessary data to:

Track the content you access in connection with the Services and your online behavior
Deliver, target, and improve our advertising and marketing materials
Share collected information with third-party advertising and marketing partners

By accepting this Privacy Policy and continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you for personalized advertising and marketing materials, unless you choose to opt out of this service.

We encourage you to review the privacy policies of our third-party advertising and marketing partners to understand how they collect, use, and share your information. Please note that we are not responsible for the privacy policies of any third party, whether accessed through the Services or otherwise.

4. Ensuring the Security of the Services

The security of our Services is of utmost importance to us, and we take appropriate security measures to protect your information from unauthorized access, loss, and misuse. We also require our suppliers who handle personal information on our behalf to implement suitable security measures.

To maintain the safety and integrity of the Services, prevent fraud, and ensure acceptable use, we have a legitimate interest in processing necessary data to:

Analyze and monitor the usage of the Services
Detect and prevent cheating, crime, or fraudulent activities
Take action against users engaging in fraudulent or improper behavior

While we make every effort to safeguard your personal data, we cannot guarantee its absolute security or the security of any communication channels provided by us. We advise caution when disclosing any information through the Services. It's important to note that personally identifiable information or sensitive data shared with other users in connection with the Services may be collected and used by them. Therefore, exercise care when sharing information online. Additionally, please be aware that any questions, answers, comments, or submissions posted in the forum will be publicly available.

5. Designated Countries

For all the purposes listed above, as required by the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively referred to as "Data Protection Laws"), we process the personal information of users located in the European Economic Area (EEA), United Kingdom, and Switzerland (collectively known as "Designated Countries") based on our contractual agreement with you.

6. Use of Report Data
Data collected through reports is used exclusively for analyzing, moderating content, and improving the quality of our services. This data is not shared with third parties, except as required by law.

7. Retention of Report Data
User reports and related data are stored for a period of 12 months from the date of submission. This is necessary for analysis and improving our moderation system.

What Information Do We Share

As previously stated, we may share your personal information with our trusted third-party partners. This includes disclosing your personal information to our business partners, such as advertisers, publishers, and data tracking companies. These partners may utilize your personal information to display targeted advertisements, analyze your interactions with ads and websites, and gain insights into website and app usage or user behavior to enhance their services. It's important to note that the use of information by these partners is governed by their respective privacy policies, that are listed below.

This application utilizes the OpenAI Assistant to provide specific features and services, allowing users to create an AI friend and chat with this AI friend. This feature enhances user experiences with personalized and engaging interactions. When interacting with the OpenAI Assistant, the application and assistant uses the following information you provide: name, age, preferred pronouns, texts, visual documentation, graphics, and other forms of data. This includes data that you supply, upload, transmit, generate, store, use, modify, or share via the App and in chats with your AI friend. It also encompasses the messages you send and receive through the App, any personal details you share about yourself or your life, as well as any photos, videos, and voice and text communications you provide. Additionally, your interests and preferences, including subjects you're interested in discussing and your communication preferences, are considered.

Cross-border Transfer of Data and Third-party Partner's Privacy Policy

We make every possible effort to protect entrusted data against unauthorized access, including two-factor authentication procedures, regular password changes, due diligence of privacy procedures and other appropriate and reliable measures provided by Our Partners.

Some data may be accessed and processed by the following companies:

Google LLC (Google Ads, Google Admob, Google Firebase)

Country: Ireland, USA

Purpose: Analysis of the Users' experience within the App and how Users use the Services and App

Policy link: https://policies.google.com/privacy?hl=en

Singular

Country: United States

Purpose: Analysis of the Users' experience within the App and how Users use the Services and App

Policy link: https://www.singular.net/privacy-policy/

Unity Technologies

Country: USA

Purpose: Monetization partner

Policy link: https://unity3d.com/legal/privacy-policy

The Permissions That We Request

Depending on how you engage with our app, we may request specific permissions to ensure its proper functionality. While you have the option to opt out at any time, please be aware that denying these permissions may cause our app to not work as intended. The permissions we may ask for include:

- Notification runtime permission
  - to send you and show notifications with reminders about sessions
- Alarm permission
  - to send you and show notifications with reminders about sessions
- Location
  - approximate location (network-based)
  - precise location (GPS and network-based)
- Other
  - control vibration

By granting these permissions, you enable us to deliver the full functionality of our app, enhancing your experience. We prioritize the privacy and security of your personal information and adhere to strict data protection practices. Please note that you have the option to revoke or modify these permissions at any time through your device settings.

If you use the iOS version of the app, we may also request App Tracking Transparency permission to show more relevant ads and enhance your experience.

Your Rights

We are committed to respecting your rights when you use our Services. If you would like to exercise your rights under applicable law, please contact us at help@vaku.app. We may require you to verify your identity before processing your request. However, please note that there may be limitations to your individual rights, and we may restrict them in the following circumstances:

When denial of access is required or authorized by law
When granting access would adversely affect the privacy of others
To protect our rights and properties
When the request is deemed frivolous or burdensome

1. Right to withdraw consent

If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note that this withdrawal does not affect the lawfulness of our processing prior to your withdrawal.

2. Right of access and rectification

You have the right to request a copy of your personal information held by us. We will provide you with a copy free of charge, unless we are legally permitted to charge a fee. If your access request would infringe upon the rights of others, we may limit or deny your access. You also have the right to request the correction or update of your personal information, unless you can directly do so through our Services.

3. Right to erasure (the "Right to be Forgotten")

You have the right to request the deletion of your personal information held by us if it is no longer necessary for the purposes it was collected, if you have withdrawn your consent, or if you have objected to its processing and there are no overriding legitimate grounds for us to continue processing it.

4. Right to restriction

You have the right to request the restriction of our processing of your personal information under certain circumstances. This includes situations where you believe your personal information is inaccurate, the processing is unlawful, we no longer need your personal information, or you have objected to the processing pending verification of legitimate grounds.

5. Right to object to processing

You have the right to object to the processing of your personal information based on legitimate interests, consent, or contractual necessity. However, we may continue processing your personal information if we have compelling legitimate grounds or for the establishment, exercise, or defense of legal claims.

6. Right to data portability

If we process your personal information based on a contract or your consent, and the processing is automated, you have the right to request your personal information in a structured, commonly used, and machine-readable format. You may also request that we transfer your personal information directly to another controller, where technically feasible.

7. Notification to third parties

If we share your personal information with third parties, we will notify them of any requests for rectification, erasure, or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify these third parties.

8. Automated individual decision-making, including profiling

You have the right not to be subject to decisions based solely on automated processing, including profiling, if these decisions have legal or similarly significant effects on you, unless an exception applies under applicable law.

9. Right to lodge a complaint

If you believe that we have violated your privacy rights, please contact us at help@vaku.app so that we can address your concerns. You also have the right to lodge a complaint with the relevant supervisory authority in your country of residence or where the alleged infringement occurred.

Children's Information

VAKU APPS LTD does not intentionally collect any personally identifiable information from children under the age of 13 (or the legally required age of consent for minors as defined under applicable laws) or knowingly allow such individuals to register with VAKU APPS LTD. If we discover that we have collected personal information from a child under the age of 13 (or the legally required age of consent for minors as defined under applicable laws) without parental consent, we will suspend the account and promptly delete the relevant information. If you suspect that we might have any information from a child under the age of 13 (or the legally required age of consent for minors as defined under applicable laws), please contact us at help@vaku.app.

State Authorities, Enforcement Agencies, Courts

We may be legally obliged to disclose your personal data to the competent state authority, enforcement agency or a court in case We receive a mandatory request for such disclosure from them.

We may be proactive and address the competent authority in case We suspect a violation of law to be committed in association with your use of Our App/Website.

California Residents’ Privacy Rights

We have developed this distinct Privacy Notice for California Consumers in adherence to the California Consumer Privacy Act of 2018 (“CCPA”) and other relevant California privacy regulations. This notice is formulated to supplement the data mentioned in our <Privacy Policy> and is exclusively applicable to users residing in California (“consumers” or “you”).

IF YOU DO NOT RESIDE IN CALIFORNIA, THIS POLICY IS NOT RELEVANT TO YOU. PLEASE REFER TO OUR PRIMARY PRIVACY NOTICE HERE.

1. Right to Demand Information

As per CCPA, you (or your authorized representative) can demand us to reveal details about our collection, usage, and sharing of your personal information over the previous 12 months. This includes: the types of personal information we have gathered; the sources of such personal information; the purpose of gathering that personal information; and the types of third parties with whom we share this information.

2. Right to Erase Information

Under the CCPA, You (or your authorized representative) have the right to decline your information being sold or shared. You (or your representative) can demand us to erase specific personal information that we have gathered from you and retained, except in certain cases. These cases include situations where we need your data to detect security incidents or to protect against harmful or illicit activity, to identify and rectify application errors, to exercise free speech rights, to fulfill internal uses aligned with your expectations based on your relationship with us, and other cases outlined by CCPA and other California laws.

3. How to Exercise Your Rights

To exercise the rights detailed above, please send a verifiable consumer request to us at help@vaku.app. Only you or your authorized representative can make a verifiable consumer request regarding your personal information. Such a request can be made twice within a 12-month period. A verifiable consumer request must provide enough information to allow us to reasonably verify your identity and confirm that we have collected personal information about you. It should also describe your request with sufficient detail to allow us to understand and respond to it. We cannot accurately respond to your request if we cannot verify your identity.

4. Our Response to Your Request

We strive to respond to a verifiable consumer request within 45 days of receipt. If we need more time (up to 90 days), we will notify you of the reason and the extension period via email, telephone, or other electronic means. We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or clearly unfounded. If we determine that a fee is justified, we will explain our decision and provide a cost estimate before proceeding with your request.

5. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. This includes actions like: denying you our services; charging you different prices or rates for our services; providing you with a different level or quality of our services; suggesting that you may receive different prices, rates, levels, or quality of services.

6. Data Collection Guidelines for Minors

Our Services are not designed for anyone under the age of 13. We do not intentionally gather personally identifiable information from children under 13. If we discover that such information has been provided by a child under 13, we will immediately remove it from our servers. If you are a parent or guardian and discover that your child has provided us with personal information, please contact us to initiate necessary action. Users aged 13 to 16 have the right to opt in, and parents or guardians of users aged 13 to 16 can also reach out to us.

Data Controller

VAKU APPS LTD ("VAKU APPS", "VAKU", "we", "us", or "our"), holds the privacy of your personal information in high regard and is devoted to safeguarding it. To provide you with the most effective and up-to-date security tools, we may need to gather your personal data. VAKU APPS LTD understands the importance of your trust and does not consider it automatically given. Therefore, in our Privacy Policy, we delineate what we do, how we do it, your choices, and how we may require your collaboration to ensure your safety.

By accepting this Privacy Policy and downloading or continuing to use the Services, you provide your consent for us and our partners to collect and use the information about you that is listed on this page.

The VAKU APPS LTD Privacy Policy applies to VAKU APPS LTD and, unless otherwise stated, its subsidiaries, including any contractors, representatives, agents, and resellers acting on our behalf (collectively referred to as "we," "us", or "our").

Questions, comments and complaints about the data practices related to the App can be submitted to the following email: help@vaku.app.

Complaint Lodgement

In case you are convinced We are somehow infringing your personal data rights granted by the GDPR, you may lodge a complaint with the supervisory authority. Our lead authority is:

Name: Office of the Commissioner for Personal Data Protection

Address: Iasonos 1, 1082 Nicosia, Cyprus

Telephone: +357 22818456

E-mail: http://commissionerdataprotection.gov.cy/.

We kindly invite you to share your concerns with Us first regarding any issue related to processing of your personal data. You may use the following channels to address your inquiries:

Email address: help@vaku.app

Updates to the Policy

In order to improve the quality of Services and to comply with legal requirements, the Company may may update or amend this Privacy Policy at our sole discretion and at any time without providing direct notice to you. It is your responsibility to review this Privacy Policy periodically for any updates or changes. By continuing to use our Service after any such amendments are made, you acknowledge and agree to such amendments and to be bound by the updated Privacy Policy. Please check the following URL for the latest version of our Privacy Policy: https://sites.google.com/view/soul-partner-privacy-policy

Continued use of the app after any amendments to the Privacy Policy constitutes your acceptance of the new Privacy Policy. If you do not agree to the Privacy Policy, you may not access or use the Services and should therefore immediately cease any use of the Services.

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