Policy version: 18th of December, 2021 (for previous versions of this policy see https://euphoria-ai.com/privacy-policy/)
This app is supplied by Euphoria Ltd ("Anima", "we", "us", and "our"). We build virtual companion apps.
Our company number is 1254867.
Our registered office and our place of business is C/O Pollock Accounting 4-5 Sentinel Square, Hendon, London, United Kingdom, NW4 2EL. However, please direct all correspondence related to the App to [email protected].
"App" means the Euphoria: Virtual AI Love Story with AI app that you download and install onto your device, and includes all updates to such app that we make available or provide to you from time to time.
The app provides virtual companion and virtual chat functionality.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use, and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint.
We are the controller of personal data obtained via the app, meaning we are the organization legally responsible for deciding how and for what purposes it is used.
If you are aged under 17 (or under 18 if you are in the UK) you must not use the app as it is not designed for you. We do not intend to collect the personal data of anyone under 17. If you are aware that any personal data of anyone under 17 has been shared with the app, please let us know so that we can delete that data.
This privacy policy relates to your use of the app only.
The app may link to other apps, websites, or services owned and operated by us or by certain trusted third parties to make additional products, information, and services available to you. These other apps, websites, or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites, or services, please consult their privacy policies as appropriate.
The personal data that we may collect about you broadly falls into the following categories:
When you download and access our app, we may collect certain information automatically from your device. In some countries, including the UK, this information may be considered personal data under applicable data protection laws.
Specifically, the information we collect automatically may include details such as your unique device identification numbers, other internal identifiers (integers), and other technical information. We may also collect information about how your device has interacted with our app.
Collecting this information enables us to better understand the users of our app, where they come from, and what content or functionality in our app is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our app to our users.
From time to time, we may receive personal data about you from third-party sources (including Apple, Google, and Facebook), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal data to us.
The types of information we collect from third parties include name, email address, external tokens/ids, and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you.
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).
Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us (see ‘How to contact us’ below).
We may use your personal data to send you updates (by email, push notification, and text message) about our services, including exclusive offers, promotions, or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘Legal basis for processing personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the app, including:
We only allow our group companies and service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to share your personal data with countries outside the UK. In those cases, we will comply with applicable UK laws designed to ensure the privacy of your personal data.
We will transfer your personal data from the UK to:
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) legally-approved standard data protection clauses recognized or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
For further information about such transfers and the safeguards we employ, including to obtain a copy of the standard data protection clauses, please contact us (see ‘How to contact us’ below).
You generally have the following rights, which you can usually exercise free of charge:
When contacting us please:
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example via the app or by other means, such as email.
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law, or to make a complaint.
Our contact details are shown below:
Our contact details: [email protected]