Privacy Policy

1. Who we are

Subsly publishes Penpal AI. This policy explains what we collect, why we collect it, and the choices available to you.

2. Information we collect

• Account information: sign-in identifiers, authentication state, and account settings.
• Profile and relationship context: details you choose to provide, such as names, birthday, gender, relationship preferences, assistant name, and custom instructions.
• Conversation content: messages, imported chat history, memory summaries, feedback, attached images, generated images, voice-note metadata, and audio submitted for voice features.
• Purchase information: StoreKit product IDs, transaction IDs, entitlement state, subscription status, boost balances, and voice-credit balances. We do not receive your full payment card details.
• Usage and diagnostics: token usage, model/provider choices, feature events, device model, OS version, app version, language, timezone, and error logs.

3. How we use information

• Provide chat, memory, image, voice note, live call, import, and personalization features.
• Route requests to our backend and supported AI providers to generate responses, images, audio, and summaries.
• Verify purchases, apply subscriptions and consumable boosts, prevent abuse, and enforce fair-use limits.
• Debug, secure, maintain, and improve the App.
• Respond to support, privacy, and deletion requests.

4. Third parties and processors

• Apple: App Store, StoreKit purchases, subscription management, and device permissions.
• Firebase/Google Cloud: authentication, database, storage, cloud functions, and diagnostics.
• AI providers: supported model providers may process submitted content and related context to generate requested outputs.
• No sale of personal data: we do not sell personal data and do not use third-party advertising SDKs.

5. AI processing

When you send a message, image, audio clip, or import, the relevant content and context may be sent to our backend and AI providers. This is necessary to generate responses, create images, create audio, transcribe speech, recall memory, or summarize imported history.

6. Data retention

• Conversation and profile data may remain in your account until you delete it or request deletion.
• Generated media and uploaded media may be stored to make chat history and playback work.
• Purchase and entitlement records are retained as needed for accounting, fraud prevention, and legal compliance.
• Logs and diagnostics are retained for a limited period needed for reliability and security.
• Backups may persist for a limited period after deletion.

7. Your choices and rights

• Use iOS Settings to control camera, microphone, speech, photo, and notification permissions.
• Use in-app controls to update custom instructions, manage settings, clear relevant state, or delete your account.
• Contact us to request access, correction, export, restriction, objection, or deletion where applicable by law.
• Manage or cancel subscriptions in Settings > Apple ID > Subscriptions.

8. Children

Penpal AI is not directed to children under 16, and we do not knowingly collect personal data from children under 16.

9. Security

We use TLS in transit, access controls, and provider security controls. No system is perfectly secure, but we work to protect your information.

10. International transfers

Your information may be processed in the United Kingdom, United States, European Economic Area, or other countries where our providers operate. Where required, we use appropriate safeguards.

11. Changes

We may update this Privacy Policy. Updates will be posted here and material changes may be announced in-app.

12. Contact

Email privacy requests to privacy@subsly.ai or support requests to support@subsly.ai.