Privacy Policy — SoulCue AI

Effective date: 29-11-25

This Privacy Policy describes how Individual Entrepreneur Dmitrii Kotelnikov (“we”, “us”) processes information when you use the SoulCue AI mobile application (“App”).

Controller: Individual Entrepreneur Dmitrii Kotelnikov
Address: Building 5, Ponichala 3 Settlement, Krtsanisi District, Tbilisi 0190, Georgia
Contact: insane.products.studio@gmail.com

1. What We Collect

• Chat content: your messages and saved insights to generate responses. Your inputs may be transmitted to [LLM_PROVIDER] via our backend for inference and safety checks. We do not use chat data for advertising or profiling.
• Device & usage data: device model, OS version, app version, language, time zone, approximate region, IP address (transient), timestamps, and in-app events necessary to operate and improve the App.
• Analytics & diagnostics: aggregated analytics events (Firebase Analytics) and crash logs (Crashlytics). These do not include your chat messages.
• Purchases: subscription status and receipts via Apple and Adapty. We never receive your full payment card details.

2. Data We Do NOT Collect

We do not collect or access:

• contacts or address book
• photos, videos, or media files
• precise location (GPS)
• health or medical information
• financial data outside subscription status
• advertising identifiers for personalized ads

3. How We Use Data

We use data to:

• operate and improve the App,
• generate AI responses,
• ensure security and prevent abuse,
• provide customer support,
• comply with legal obligations,
• personalize your experience (if applicable).

We do not use your data for targeted advertising.

4. Legal Bases (EEA/UK)

• Contract performance: providing the App and its features.
• Legitimate interests: security, diagnostics, service improvement.
• Consent: where required by law (e.g., optional analytics toggles).

5. Sharing and Processors

We share personal data only with processors necessary for the App’s functionality:

• OpenAI ChatGPT — AI processing of your inputs (may not store data depending on configuration).
• Google Firebase — analytics (aggregated), crash diagnostics.
• Adapty — subscription status, receipts, entitlements.
• Apple — payment processing.

We may share de-identified or aggregated statistics. We do not sell personal data.

6. International Transfers

Data may be processed in countries outside your own. Where required, we use safeguards such as Standard Contractual Clauses or equivalent protections.

7. Storage & Retention

• Chat history: stored locally on your device. If cloud sync becomes available and you enable it, chat data may be stored on our servers.
• Analytics & logs: retained for up to 24 months, then deleted or anonymized.
• Abuse prevention logs: retained only as long as necessary.

8. Your Rights

Depending on your location, you may have rights to access, correct, delete, restrict, or port your data, and object to certain processing.

To exercise rights, contact insane.products.studio@gmail.com. Some analytics can be disabled via device or App settings where available.

9. Children

The App is intended for users aged 16+. We do not knowingly collect personal data from children under this age.

10. Security

We use reasonable safeguards such as TLS encryption, limited access controls, and secure infrastructure. However, no method of storage or transmission is completely secure.

11. California / US State Privacy Notices

We do not sell personal information. California and other US state residents may request access or deletion by contacting us at the email above. We will not discriminate against users who exercise privacy rights.

12. Changes

We may update this Policy by posting a new version here. Material changes will be communicated in the App when feasible.

13. Contact

Individual Entrepreneur Dmitrii Kotelnikov
Building 5, Ponichala 3 Settlement, Krtsanisi District, Tbilisi 0190, Georgia
Email: insane.products.studio@gmail.com