Privacy Policy

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ℹ️

Legal Notice

In case of discrepancies, the English version prevails

1. Introduction and Controller Information

This Privacy Policy explains how CLARINA YOUR COMPANION IN LIFE LIMITED ("we," "our," or "us") collects, uses, and protects your personal information when you use our AI companion services. We are committed to protecting your privacy and ensuring transparent processing of your personal data in accordance with the General Data Protection Regulation (GDPR), Austrian Data Protection Act (DSG), German Federal Data Protection Act (BDSG), and Swiss Federal Act on Data Protection (FADP).

Data Controller:

CLARINA YOUR COMPANION IN LIFE LIMITED 59 Downsight Heights, Skerries, CO. Dublin K34 HY88 Email: info@clarina.ai Tax Reference Number: 4430663NH

EU Representative: [If outside EU, provide EU representative details as required by GDPR Article 27]

2. Personal Data We Collect

2.1 Account and Registration Data

Email address and password
Name and profile information (optional)
Authentication data from third-party providers (Google, etc.)
Account preferences and settings

2.2 Conversation and Interaction Data

Chat messages and conversations with your AI companion
Voice recordings (if voice features are used)
User feedback and ratings
Session duration and frequency of use

2.3 Technical and Usage Data

IP address and device identifiers
Browser type, version, and language settings
Operating system and device information
Usage patterns and app performance data
Log files and error reports

2.4 Payment and Billing Data

Billing address and payment method information
Transaction history and invoices
Subscription and plan details

3. Legal Basis and Purposes of Processing

Purpose	Legal Basis (GDPR)	Data Categories
Providing AI companion services	Art. 6(1)(b) - Contract performance	Account, conversation, technical data
Improving AI responses and personalization	Art. 6(1)(a) - Consent	Conversation data, usage patterns
Security and fraud prevention	Art. 6(1)(f) - Legitimate interest	Technical data, usage logs
Payment processing	Art. 6(1)(b) - Contract performance	Payment and billing data
Legal compliance	Art. 6(1)(c) - Legal obligation	All relevant data as required

4. AI Processing and EU AI Act Compliance

🤖 AI System Information

CLARINA YOUR COMPANION IN LIFE LIMITED uses artificial intelligence systems to provide personalized companion services. Our AI processes your conversations to understand context and provide meaningful responses.

4.1 AI Processing Transparency

You are always interacting with an AI system, not a human
Our AI learns from conversations to improve responses (with your consent)
Human oversight is maintained for quality and safety
No automated decision-making affects your legal rights without human review

4.2 AI Model Training and Development

With your explicit consent, we may use anonymized and aggregated conversation data to improve our AI models. This includes:

Training data optimization
Response quality improvement
Safety and bias mitigation
New feature development

Your Control: You can withdraw consent for AI training at any time in your account settings. This will not affect the functionality of your companion services.

5. Data Sharing and Third Parties

5.1 Service Providers

We work with carefully selected service providers who process data on our behalf:

Cloud Infrastructure: [Specify providers like AWS, Google Cloud, etc.]
Payment Processing: Stripe, PayPal, and other payment processors
Email Services: Resend.com for transactional emails
Analytics: [Specify analytics providers if any]
Customer Support: [Specify support tools if any]

5.2 International Data Transfers

Some of our service providers are located outside the European Economic Area (EEA). We ensure adequate protection through:

EU Commission adequacy decisions
Standard Contractual Clauses (SCCs)
Data Processing Agreements with appropriate safeguards
Binding Corporate Rules where applicable

EU Data Residency: Core conversation data is primarily stored within the EU to ensure maximum protection under GDPR.

6. Data Retention

Data Type	Retention Period	Reason
Account data	Until account deletion + 30 days	Service provision
Conversation history	Until deletion request or account closure	Service continuity
Payment records	7 years after last transaction	Legal compliance
Technical logs	90 days	Security and debugging

7. Your Privacy Rights

Under GDPR and applicable privacy laws, you have the following rights:

🔍 Right of Access

Request copies of your personal data

✏️ Right to Rectification

Correct inaccurate personal data

🗑️ Right to Erasure

Request deletion of your personal data

⏸️ Right to Restrict Processing

Limit how we process your data

📦 Right to Data Portability

Receive your data in a portable format

🚫 Right to Object

Object to processing based on legitimate interests

How to Exercise Your Rights

To exercise any of these rights, please contact us at info@clarina.ai or use the data management tools in your account settings. We will respond within 30 days.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

Technical Measures

End-to-end encryption for conversations
TLS encryption for data in transit
AES-256 encryption for data at rest
Regular security audits and penetration testing
Multi-factor authentication

Organizational Measures

Privacy by design and default
Regular staff training on data protection
Data minimization principles
Incident response procedures
Access controls and audit logs

9. Cookies and Tracking Technologies

We use cookies and similar technologies to improve your experience. For detailed information about our cookie usage, please see our Cookie Policy.

Cookie Categories:

Strictly Necessary: Essential for website functionality
Functional: Remember your preferences and settings
Analytics: Help us understand how you use our service (with consent)
Marketing: Personalize content and advertisements (with consent)

You can manage your cookie preferences through our cookie banner or in your browser settings.

10. Children's Privacy

Age Restriction

Our services are not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.

If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

11. Contact Information and Complaints

Data Protection Contact

Email: info@clarina.ai

Mail: 59 Downsight Heights, Skerries, CO. Dublin K34 HY88

Tax Reference Number: 4430663NH

Supervisory Authorities

Austria: Datenschutzbehörde (DSB)

Germany: Your local Landesdatenschutzbehörde

Switzerland: Federal Data Protection and Information Commissioner (FDPIC)

Right to Lodge a Complaint

You have the right to lodge a complaint with your local supervisory authority if you believe we have not handled your personal data in accordance with applicable law.

12. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service features. We will notify you of any material changes by:

Email notification to registered users
Prominent notice on our website
In-app notification for significant changes

Your continued use of our services after we publish or send a notice about changes to this Privacy Policy means you consent to the updated policy.

Last Updated: 12. Juli 2025

Effective Date: 12. Juli 2025

Version: 1.0