Privacy Policy - Sara's AI Twin Friends

1. Introduction

At Sara's AI Twin Friends ("we," "our," or "us"), your privacy is paramount. This Privacy Policy explains how we collect, use, protect, and share your information when you use our AI Twin platform and video call services.

Privacy First: We use end-to-end encryption, secure storage, and never share your personal data with third parties for marketing purposes.

2. Information We Collect

Account Information

For All Users:

• Email address and username
• Encrypted password
• Profile preferences and settings
• Platform usage analytics

For Creators (Additional KYC Data):

• Government-issued photo ID
• Face verification photos
• Legal name and date of birth
• Residential address (verification only)
• Phone number for security

AI Training Data

Creator Content (Voluntarily Provided):

• Profile photos for AI Twin generation
• Personality descriptions and communication style
• Sample conversations for AI training
• Voice samples (if provided)

Communication Data

• Chat messages between users and AI Twins (encrypted)
• AI-generated photo requests and descriptions
• Video call scheduling and metadata
• Customer support communications

Technical Information

• IP address and device information
• Browser type and operating system
• MetaMask wallet address (creators only)
• Platform usage patterns and preferences
• Cookies and similar tracking technologies

Payment Information

Cryptocurrency Only: We never store credit card or banking information. All payments processed through blockchain via MetaMask. We only record transaction hashes for verification.

3. How We Use Your Information

Primary Platform Functions

AI Twin Operations:

• Generate AI responses in creator's style
• Create personalized AI photos
• Maintain conversation context
• Improve AI accuracy over time

Security and Compliance:

• Verify creator identities (KYC compliance)
• Prevent fraud and unauthorized access
• Monitor for prohibited content
• Comply with legal and regulatory requirements

Platform Improvement:

• Analyse usage patterns to improve experience
• Develop new features and services
• Optimize platform performance and reliability

4. Data Security and Protection

Encryption and Storage

• End-to-end encryption for all chat messages
• AES-256 encryption for stored data
• Secure document storage via Cloudflare R2
• Encrypted video call recordings
• Regular security audits and updates

KYC Document Security

• Government IDs encrypted immediately upon upload
• Face verification photos processed and then deleted
• KYC data stored separately from platform data
• Access limited to authorized verification personnel

5. Information Sharing and Disclosure

We Do NOT Share Your Data With:

✗ Advertisers or marketing companies
✗ Data brokers or analytics firms
✗ Social media platforms
✗ Other users (beyond intended functions)
✗ Anyone for commercial gain

Required Legal Disclosures

We may disclose information when required by law:

• Valid court orders or subpoenas
• Law enforcement investigations
• Preventing harm to users or the public
• Enforcing our Terms of Service

6. Data Retention and Deletion

Account Deletion: You can request full account deletion anytime.

• Data deleted within 30 days (unless legal retention applies)
• AI Twins deactivated immediately
• Chat history and AI content removed

7. Your Privacy Rights

Your Rights Include:

✓ Access, correction, and deletion of data
✓ Data export (portability)
✓ Restrict or object to processing
✓ Withdraw consent at any time
✓ Opt-out of non-essential communications

Exercise Your Rights:

• Use account settings for basic changes
• Email privacy@blpagency.org for formal requests
• Response within 30 days guaranteed

Complaints Contact:

UK Information Commissioner's Office (ICO)

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

www.ico.org.uk

8. Cookies and Tracking Technologies

We use a Cookie Preference Center compliant with EU ePrivacy Directive.

We do NOT use: Advertising cookies, social media cookies, or fingerprinting technologies.

9. Third-Party Services and Integrations

MetaMask Wallet

• Cryptocurrency payments only
• No access to private keys
• Subject to MetaMask's privacy policy

Other Services

• Jitsi: End-to-end encrypted video calls, no storage
• Cloudflare R2: Secure EU-based encrypted storage
• External links: Have separate privacy policies

10. Children's Privacy (COPPA & Online Safety)

Adults Only (18+)

• Age verification required during registration
• KYC verification for creators ensures age compliance
• Immediate removal if underage use detected

11. International Data Transfers

We store data primarily within the European Economic Area (EEA). Some technical processing may occur in the US or other regions under EU Standard Contractual Clauses (SCCs).

Encryption: Applied in transit and at rest for all data.

12. Policy Updates and Changes

We may update this Privacy Policy periodically.

• Users notified by email for material changes
• Banner notice on login
• 30-day review period before enforcement
• Continued use means acceptance of updates

13. Contact Information and Complaints

General Privacy:

privacy@blpagency.org

Data Protection Officer:

dpo@blpagency.org

Emergency:

Security: security@blpagency.org

KYC: verification@blpagency.org

Legal: legal@blpagency.org

J.P. CONSULTING & REMEDIATION SERVICES LTD | 64 DRAKE STREET, ROCHDALE, ENGLAND, OL16 1PA

14. AI Data Governance and Transparency (EU AI Act)

We maintain AI documentation consistent with the EU Artificial Intelligence Act Articles 9–15.

• All AI Twins clearly identified as artificial entities
• Training data from consenting creators only
• Internal AI Risk and Impact Assessments before release
• Bias and data-quality tests conducted regularly
• Anonymized audit logs monitor AI activity
• Users can request human review via support@blpagency.org

15. Risk and Safety Commitment

We are committed to safe, fair, and transparent AI development:

• Continuous monitoring for algorithmic bias and misuse
• Yearly AI and Online Safety Risk Assessments
• Dedicated AI Compliance Officer overseeing audits
• Rapid response protocol for harmful AI behavior

16. User Rights Under EU AI Act and GDPR

You have the right to:

✓ Know when interacting with AI
✓ Request human intervention for AI communications
✓ Obtain explanations about AI system behavior
✓ Access, correct, delete, or port your data
✓ Object to automated processing or withdraw consent
✓ File complaints with data protection or AI authorities

Contact: privacy@blpagency.org or compliance@blpagency.org

17. Compliance and Audit Contact

AI Compliance & Data Protection Officer

Email: compliance@blpagency.org

64 DRAKE STREET, ROCHDALE, ENGLAND, OL16 1PA

We cooperate fully with EU supervisory and AI authorities during audits.

18. DSA Notice & Action Policy

In accordance with the EU Digital Services Act, users can report illegal content to legal@blpagency.org.

• Each report reviewed by human moderators
• Actions: removal, restriction, or law enforcement referral
• Transparent records of outcomes maintained

19. Legal Bases for Processing (GDPR Article 6)

We process your data based on:

• Contractual necessity (providing our services)
• Legal compliance (KYC, regulatory requirements)
• Legitimate interests (security, fraud prevention)
• Your explicit consent (where applicable)

Important: We do not use data for automated decisions with legal or significant effects.