Privacy Policy - Blushy.ai

1. Introduction and Scope
Welcome to Blushy AI! This Privacy Policy outlines how Blushy AI, Inc. ("Blushy AI," "we," "our," or "us") collects, uses, stores, and protects your personal information when you interact with our services. By accessing or using the Blushy AI platform, which includes our website, mobile applications, and related services (collectively, the "Services"), you acknowledge and agree to the practices described in this Privacy Policy.
We are committed to safeguarding your privacy and ensuring the responsible processing of your personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) for users in the European Union and the California Consumer Privacy Act (CCPA) for users in the United States.
This Privacy Policy applies to all individuals who visit or interact with Blushy AI, including:

Visitors: Individuals who browse or access the website without creating an account.
Users: Registered individuals who interact with Blushy AI through a subscription or free trial.

Scope of this Policy
This Privacy Policy applies to:

The collection, use, and storage of personal information provided by users during account registration, interaction with our AI services, or communication with customer support.
Automatically collected data, such as usage analytics and cookies, to improve our Services.
Data shared with third parties necessary for the operation of Blushy AI or to comply with legal obligations.

Exclusions
This Privacy Policy does not apply to:

Third-party websites, applications, or services that you may access through links on the Blushy AI platform.
Data collected by third-party payment processors or marketing providers acting independently of Blushy AI.

We encourage you to carefully review the privacy policies of any third-party services before engaging with them.

2. Definitions
To provide clarity and ensure a mutual understanding of the terms used in this Privacy Policy, the following definitions apply:

1. Personal Data
Refers to any information that identifies or can be used to identify an individual directly or indirectly. Examples include your name, email address, IP address, payment information, and other details you provide during your interaction with Blushy AI.
2. Processing
Any operation or set of operations performed on Personal Data, whether by automated or manual means. This includes collection, recording, organization, structuring, storage, alteration, retrieval, use, disclosure, and deletion.
3. Controller
Blushy AI, Inc., which determines the purposes and means of processing Personal Data and ensures its compliance with applicable laws.
4. Processor
A third party that processes Personal Data on behalf of Blushy AI in accordance with its instructions and applicable privacy laws.
5. Data Subject
You, the individual whose Personal Data is being collected, stored, and processed by Blushy AI.
6. Cookies
Small files stored on your device by the website or app to enhance user experience and track behavior, preferences, and usage analytics.
7. GDPR
The General Data Protection Regulation, an EU law that governs data protection and privacy for individuals in the European Union.
8. CCPA
The California Consumer Privacy Act, a U.S. law providing privacy rights and protections to residents of California.
9. Third Parties
Entities or individuals other than Blushy AI who may process Personal Data, including service providers, advertisers, or external platforms linked through Blushy AI.
10. Consent
Freely given, informed, and unambiguous agreement by the Data Subject to the processing of their Personal Data for a specific purpose.
11. Profiling
Automated processing of Personal Data to evaluate or predict aspects of a Data Subject’s behavior, preferences, or interests, used to personalize services on Blushy AI.
12. Anonymization
The process of removing personally identifiable information from data sets so that individuals cannot be identified.

3. Purpose of Personal Data Processing
Blushy AI processes your personal data to provide, improve, and secure our services, ensuring a personalized and seamless user experience. The specific purposes for which we process your personal data include the following:

3.1 Provision of Services

To register and manage your account, including enabling access to features, subscriptions, and user preferences.
To facilitate interactions with Blushy AI’s services, such as chat-based interactions, image generation, and other features.
To process transactions, including subscription fees, in-app purchases, and refunds.

3.2 Personalization and Optimization

To tailor content, recommendations, and AI interactions to your preferences and behavior.
To analyze usage patterns to optimize the performance, design, and functionality of the Platform.

3.3 Communication

To send administrative notifications, such as account updates, subscription renewals, and security alerts.
To provide customer support and respond to your inquiries, feedback, or complaints.
To communicate marketing offers, promotions, or updates about Blushy AI services (subject to your consent, where required).

3.4 Compliance with Legal Obligations

To comply with applicable laws, regulations, and court orders.
To respond to lawful requests from public or governmental authorities.
To enforce our Terms of Use and other policies.

3.5 Fraud Prevention and Security

To protect against unauthorized access, fraud, misuse, or other illegal activities.
To monitor and safeguard the integrity of Blushy AI’s systems, networks, and user accounts.

3.6 Research and Development

To conduct internal research and develop new services, features, and technologies to enhance user experience.
To aggregate anonymized data for analytical and benchmarking purposes, ensuring no identifiable information is shared.

Blushy AI processes your personal data only for the purposes outlined above and in accordance with applicable data protection laws, such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). If we intend to process your data for a purpose not listed here, we will notify you and, where necessary, obtain your consent.
If you have any concerns about how your personal data is processed or wish to request more information, please contact us at privacy@blushy.ai.

4. Personal Data Collection
Blushy AI collects Personal Data to provide tailored services and improve your overall experience. The specific types of data collected vary depending on whether you are a visitor or a registered user.

4.1 Personal Data for Visitors
As a visitor, we may collect limited information automatically to improve our services and ensure the Platform operates efficiently:
i. Device and Browser Information. Details such as your IP address, browser type, operating system, device type, and language preferences are collected automatically when you visit the Blushy AI website or application.
ii. Usage Data. Information about your interactions with the website, including the pages you view, time spent on the site, and navigation patterns, is tracked to understand user behavior.
iii. Cookies and Tracking Technologies. We use cookies, server logs, and similar technologies to enhance your browsing experience. These technologies may collect data on user preferences and behavior. You can manage your cookie preferences through your browser settings.
Visitors remain anonymous unless they voluntarily submit Personal Data by contacting support or subscribing to updates.

4.2 Personal Data for Registered Users
When you register for an account with Blushy AI, additional data is collected to provide access to features and a personalized experience:
i. Account Information. This includes your name, email address, and password (encrypted), which are necessary for account creation and authentication.
ii. Payment Data. To process transactions such as subscriptions or in-app purchases, we collect billing information and payment details. These are managed securely by third-party payment processors, ensuring compliance with data protection standards.
iii. User Preferences and Interactions. Data related to your use of the Platform, including chat interactions, AI companion settings, and image generation requests, is stored to enhance personalization.
iv. Technical Data. Information such as login timestamps, device identifiers, and system configurations is collected to improve security and prevent fraud.
v. Support and Communication Data. When you contact customer support or submit inquiries, we collect your name, email address, and the content of your communication to provide assistance and improve our services.
Blushy AI ensures that all Personal Data is collected lawfully and transparently. If you have concerns or questions about how your data is collected, contact us at privacy@blushy.ai.

5. Marketing and Communication
Blushy AI may use your Personal Data to communicate with you about our services, promotions, and updates that we believe may be of interest to you. These communications can include newsletters, special offers, and announcements about new features or developments on the Platform. We aim to provide relevant and tailored content based on your preferences and interactions with our services.
Marketing communications are sent via email or other electronic channels only if you have provided your consent where required by applicable laws or if such communications are related to services you have already subscribed to or purchased. You may withdraw your consent or opt-out of receiving marketing messages at any time by following the unsubscribe link included in the communication or by contacting us at privacy@blushy.ai.
Blushy AI also conducts customer engagement campaigns to improve your experience on the Platform. This includes sending reminders about subscription renewals, notifications about updates to your AI companions, and suggestions for using specific features.
While we strive to make our communications relevant and beneficial, you have the right to manage your preferences or stop receiving marketing materials altogether. Please note that opting out of marketing communications will not affect service-related notifications, such as payment confirmations, security alerts, or updates to our Terms or Privacy Policy.
We respect your choices regarding communication and will ensure compliance with applicable data protection laws, including GDPR and CCPA. If you have any questions or concerns about our marketing practices, please reach out to us at privacy@blushy.ai.

6. Third-Party Marketing
Blushy AI may share limited Personal Data with trusted third-party partners for marketing purposes, ensuring compliance with applicable data protection laws. These partners may use your data to deliver advertisements, promotions, or offers that align with your interests and preferences.
We work exclusively with third parties that adhere to data privacy and security standards, such as GDPR and CCPA. Personal Data shared with these parties may include anonymized or aggregated data that cannot directly identify you, unless you have provided explicit consent for the use of identifiable data.
Blushy AI does not sell your Personal Data to third parties. However, we may allow third-party marketing services to place cookies or similar tracking technologies on your device to understand user behavior and display targeted advertisements. You can control these preferences by managing your cookie settings or using browser tools to disable tracking.
If you have consented to receive marketing communications from third parties, you may opt out at any time by contacting those parties directly or by managing your preferences through Blushy AI’s settings. If you wish to withdraw consent for third-party marketing entirely, you can contact us at privacy@blushy.ai for assistance.
Blushy AI prioritizes transparency and user control in all third-party marketing activities. If you have questions or concerns about how your Personal Data is shared for these purposes, please reach out to us.

7. Cookies and Tracking Technologies
Blushy AI uses cookies and similar tracking technologies to enhance your experience on our Platform, analyze user behavior, and deliver personalized content. Cookies are small data files stored on your device when you visit our website or application. They enable Blushy AI to recognize your device and remember your preferences.
We use different types of cookies, including:

Essential Cookies: Necessary for the operation of the Platform and enabling secure access to your account.
Performance Cookies: Help us understand how users interact with the Platform and improve its functionality.
Personalization Cookies: Enable us to tailor content and features to your preferences and behavior.
Advertising Cookies: Used by Blushy AI or third-party partners to deliver relevant ads based on your activity.

You can manage your cookie preferences through your browser settings or the cookie management tool provided on our website. Disabling certain cookies may affect the functionality or performance of the Platform. For further details about cookies and how we use them, contact us at privacy@blushy.ai.

8. Change of Purpose for Data Usage
Blushy AI processes your Personal Data only for the purposes outlined in this Privacy Policy. If we need to use your data for a new purpose not originally specified, we will notify you and provide an explanation for the change. Where required by applicable laws, we will seek your consent before processing your Personal Data for the new purpose.
Exceptions to this include cases where the new purpose is compatible with the original purpose of data collection, such as for compliance with legal obligations or safeguarding the integrity of the Platform. In these instances, Blushy AI ensures that the new processing activity aligns with your rights and expectations under GDPR, CCPA, and other applicable data protection laws.
For inquiries regarding changes to data usage purposes, please reach out to privacy@blushy.ai.

9. Sharing Your Personal Information
Blushy AI shares your Personal Data only when necessary to deliver our services, comply with legal obligations, or fulfill other purposes outlined in this Privacy Policy. We do not sell your Personal Data to third parties.
Your data may be shared with the following entities:

Service Providers: Third-party vendors, such as payment processors, analytics providers, and hosting services, who assist in operating the Platform. These providers are contractually obligated to protect your data and use it solely for the purposes specified by Blushy AI.
Business Partners: Entities we collaborate with to provide integrated features or co-branded services.
Legal and Regulatory Authorities: Government bodies, law enforcement agencies, or courts, if required by applicable laws or to protect the rights, safety, or property of Blushy AI and its users.
Mergers or Acquisitions: In the event of a business reorganization, merger, acquisition, or sale, your Personal Data may be transferred to the acquiring entity or successor organization.

Whenever your data is shared, we ensure that appropriate safeguards are in place to protect your privacy. If you have questions about data sharing or want to limit how your Personal Data is shared, please contact us at privacy@blushy.ai.

10. Retention Period of Personal Data
Blushy AI retains your Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. The retention period varies depending on the type of data and its intended use:

Account Information: Retained for the duration of your account’s active status and for a reasonable period thereafter to comply with legal or regulatory requirements.
Transaction Data: Retained as required by financial and tax laws, typically for at least seven years.
Usage Data: Anonymized or aggregated data may be retained indefinitely for analytical and research purposes.

Once the retention period expires, your Personal Data will be securely deleted, anonymized, or otherwise disposed of in compliance with applicable data protection laws. For specific questions about data retention, contact privacy@blushy.ai.

11. Data Security Measures
Blushy AI is committed to protecting your Personal Data through the implementation of robust security measures. These measures include:

Encryption: All sensitive data, such as passwords and payment information, is encrypted both in transit and at rest to prevent unauthorized access.
Access Controls: Restricted access to Personal Data is granted only to authorized personnel who require it to perform their job functions.
Regular Monitoring: Our systems are continuously monitored for potential vulnerabilities and threats to ensure the security of your information.
Secure Payment Processing: Payment data is handled exclusively by third-party processors that comply with industry standards, such as PCI DSS.

While we take all reasonable precautions to secure your data, no method of electronic transmission or storage is completely secure. Blushy AI cannot guarantee absolute data security. If you suspect a security breach, contact us immediately at privacy@blushy.ai.

12. Personal Information of Minors
Blushy AI is intended exclusively for individuals aged 18 and older. We do not knowingly collect, process, or store Personal Data from minors under the age of 18. If we become aware that a user under 18 has provided Personal Data, we will take immediate steps to delete the information and, if necessary, terminate the associated account.
If you are a parent or guardian and believe that your child has submitted Personal Data to Blushy AI, please contact us at privacy@blushy.ai. We will promptly investigate and take appropriate action to ensure compliance with applicable child privacy laws, such as the Children’s Online Privacy Protection Act (COPPA).
Blushy AI encourages parents and guardians to monitor their children’s online activities and educate them about responsible internet usage.

13. Third-Party Links and External Services
Blushy AI may include links to third-party websites, applications, or services on our Platform. These links are provided for user convenience or additional functionality but are not governed by this Privacy Policy. Interacting with these external services may involve the collection and use of your Personal Data by third parties.
Blushy AI does not control or monitor the content, privacy practices, or policies of third-party services. When you access these links, you do so at your own risk. We strongly encourage you to review the privacy policies and terms of use of any third-party websites or services before providing your Personal Data or engaging with their content.
If you have questions or concerns about third-party links on our Platform, you may contact us at privacy@blushy.ai.

14. Mergers, Acquisitions, and Asset Transfers
In the event of a merger, acquisition, restructuring, sale of assets, or similar business transaction, Blushy AI may transfer your Personal Data to the acquiring entity or successor organization. Such transfers are necessary to ensure the continuity of services and may be subject to the acquiring entity’s privacy policies.
Blushy AI will notify you of any significant changes in data handling practices resulting from such transactions, where required by applicable laws. If you do not agree with the new policies or data practices, you may request the deletion of your Personal Data or terminate your account.
For more information about how your data may be handled in these situations, please reach out to us at privacy@blushy.ai.

15. GDPR and Your Rights
If you are located in the European Union (EU) or the European Economic Area (EEA), you have specific rights under the General Data Protection Regulation (GDPR). Blushy AI respects your rights and ensures that you can exercise them in accordance with applicable laws. Below is an overview of these rights:

15.1 Right to Access
You have the right to request access to the Personal Data Blushy AI holds about you. This includes:

Confirmation of whether your data is being processed.
A copy of your Personal Data, along with details about the purposes of processing and the recipients with whom the data has been shared.

To exercise this right, contact us at privacy@blushy.ai.

15.2 Right to Rectification
You have the right to request that Blushy AI corrects any inaccurate or incomplete Personal Data we hold about you. We will ensure your data is accurate and up to date. Submit rectification requests to privacy@blushy.ai.

15.3 Right to Erasure ("Right to Be Forgotten")
You may request the deletion of your Personal Data where:

The data is no longer necessary for the purpose it was collected.
You withdraw your consent, and no other legal basis for processing exists.
You object to processing, and no overriding legitimate grounds exist.
The data has been unlawfully processed.

Blushy AI will comply with your request unless retention is required for legal, regulatory, or legitimate business purposes. Submit deletion requests to privacy@blushy.ai.

15.4 Right to Restriction of Processing
You have the right to request that Blushy AI limits the processing of your Personal Data if:

You contest the accuracy of the data.
The processing is unlawful, but you prefer restriction over deletion.
The data is no longer needed by Blushy AI, but you require it for legal claims.

During the restriction period, Blushy AI will only process your data with your consent or for specific legal purposes.

15.5 Right to Data Portability
You may request a copy of your Personal Data in a structured, commonly used, and machine-readable format. Where feasible, you can also request that Blushy AI transfers your data directly to another service provider. This right applies only to data you provided directly to Blushy AI, processed with your consent or under a contractual obligation.

15.6 Right to Withdraw Consent
If Blushy AI relies on your consent for the processing of your Personal Data, you have the right to withdraw that consent at any time. Once consent is withdrawn, we will cease processing your data unless another legal basis applies. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

15.7 Right to Object to Processing
You have the right to object to the processing of your Personal Data if the processing is based on Blushy AI’s legitimate interests. If you object, we will stop processing your data unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

15.8 Right to Object to Direct Marketing
You can object to the use of your Personal Data for direct marketing purposes. Once you object, Blushy AI will no longer use your data for such purposes. To opt-out of marketing communications, you can use the unsubscribe link provided in the emails or contact us at privacy@blushy.ai.

16. International Transfers and Safeguards
Blushy AI operates globally, and your Personal Data may be transferred to and stored in countries outside of your country of residence, including the United States. These countries may not have data protection laws equivalent to those in your jurisdiction. However, Blushy AI ensures that such transfers are conducted in compliance with applicable data protection laws, including GDPR and CCPA.
To safeguard your data during international transfers, we implement the following measures:

Standard Contractual Clauses (SCCs): For data transfers from the EU/EEA, we rely on European Commission-approved Standard Contractual Clauses.
Adequacy Decisions: If applicable, we transfer data only to countries deemed to provide an adequate level of protection under GDPR.
Binding Agreements: Third-party service providers and partners involved in processing your data are contractually required to maintain data security and confidentiality.

If you have questions about international data transfers or would like a copy of the safeguards in place, please contact privacy@blushy.ai.

17. Procedures for Exercising Your Rights
Blushy AI is committed to enabling you to exercise your data protection rights under applicable laws, including GDPR and CCPA. To make a request, follow these steps:

Submission: Submit your request via email to privacy@blushy.ai, specifying the right(s) you wish to exercise (e.g., access, rectification, erasure). Include enough detail to help us locate your data, such as your name, email address, and account details.
Verification: To protect your data, we may require proof of identity before processing your request. This could include a government-issued ID or other identifying information.
Processing: Once verified, we will process your request within the timeframes specified by applicable laws (e.g., 30 days under GDPR). If an extension is necessary, we will inform you promptly.
Response: We will provide you with a confirmation of action taken, or an explanation if your request cannot be fulfilled due to legal or operational constraints.

If you require assistance or encounter difficulties in exercising your rights, please reach out to us at privacy@blushy.ai.

18. Complaints and Supervisory Authorities
If you believe that Blushy AI has violated your data protection rights or failed to comply with applicable privacy laws, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

EU/EEA Users: Contact your national data protection authority. A list of EU supervisory authorities is available here.
UK Users: You can file a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk.
US Users: For CCPA-related issues, you can contact the California Attorney General’s office.

Blushy AI encourages you to first contact us at privacy@blushy.ai to resolve any issues or concerns directly. We are committed to addressing your concerns promptly and transparently.

19. Time Limits for Responding to Requests
Blushy AI is committed to responding to your data-related requests within the timeframes specified by applicable data protection laws. These time limits include:

GDPR Requests: For users in the EU/EEA, we will respond to your requests (e.g., access, rectification, erasure, or restriction of processing) within 30 days of receiving a valid and verified request. If additional time is required due to the complexity of the request, we will notify you within the initial 30-day period and provide an explanation for the delay.
CCPA Requests: For California residents, we will respond to verifiable consumer requests within 45 days. If an extension is necessary, we will inform you and explain the reasons for the extension, which will not exceed an additional 45 days.
Other Jurisdictions: For users outside the EU/EEA and California, we aim to respond within a reasonable timeframe, which will generally not exceed 30 days.

If your request is incomplete or requires clarification, we may contact you to request additional information. Failure to provide the necessary details may result in delays or the inability to process your request.
To make a request or inquire about the status of a submitted request, please contact us at privacy@blushy.ai.

20. Changes to the Privacy Policy
Blushy AI may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or operational requirements. Any updates will be published on our website and application, and the "Last Updated" date at the top of the Privacy Policy will indicate the most recent revision.
In the event of significant changes to how we collect, use, or share your Personal Data, we will notify you by email (if applicable) or through a prominent notice on the Platform.
You are responsible for regularly reviewing this Privacy Policy to stay informed about how we protect your Personal Data. Continued use of the Blushy AI Platform after updates have been made constitutes your acceptance of the revised Privacy Policy.
If you disagree with the updated Privacy Policy, you may choose to stop using the Platform and contact us to request the deletion of your account and Personal Data.
For questions or concerns about changes to this Privacy Policy, contact us at privacy@blushy.ai.