Text in 【】 in this Policy is a placeholder and must be completed or removed by legal counsel before launch. The list of third parties in the tables must match the service providers actually integrated.
1. Overview
- This Privacy Policy explains how 【Company name】 ("we", "us" or "our") collects, uses, stores, shares and protects your personal information when you use the Puffie app and related services (the "Service"), and the rights you have.
- This Policy applies to all features of the Service. The Service is intended only for users aged 17 or older.
- If there is any inconsistency between this Policy and the Terms of Use, this Policy prevails with respect to the processing of personal information.
2. Information We Collect
1. Information You Provide
- Account information: The user identifier obtained when you sign in with Apple or Google, together with the email address you choose to share (which may be an Apple-provided relay email address if you use Sign in with Apple) and your name; or, if you sign in with an email verification code, the email address you enter.
- Profile information: Nickname, avatar, user profile (a description of yourself that you want characters to know) and time zone.
- Conversation content: The messages you send to characters and the messages characters send back to you.
- User-created characters: Character name, avatar, bio, persona, greeting, example dialogues, tags and visibility settings.
- Reports and feedback: Reasons for reports and your email correspondence with us.
2. Information Collected Automatically
- Device and app information: Device model, operating system version, app version, language, time zone and push token.
- Usage information: How features are used, the number and timing of conversations and messages, and crash and performance diagnostic data.
- Network information: IP address and the approximate region inferred from it, used for security, rate limiting and compliance.
3. Subscription Information
- When you purchase a subscription through In-App Purchase, we receive the transaction identifier, product identifier, subscription status, expiration time and environment information from Apple and our subscription management provider. We do not receive your bank card or payment account information.
3. How We Use Information
| Purpose | Information involved |
|---|---|
| Providing the chat feature: generating character replies and maintaining conversation context and memory | Conversation content, character information, user profile, time zone |
| Accounts and sign-in | Account information, device information |
| Push notifications: alerting you to new messages when you are away from the app | Push token, unread status |
| Subscriptions and allowances: determining entitlements, enforcing quotas and preventing abuse | Subscription information, usage information, device information, IP address |
| Content safety: automated moderation, report handling and human review | Conversation content, character information, report information |
| Improving the Service: statistical analysis, performance and crash diagnostics | Usage information, device information |
| Legal compliance and dispute handling | Any of the above categories of information (as needed) |
We do not use your conversation content to serve you advertising.
4. Third-Party Processors
To provide the Service, we engage the following categories of third parties to process certain information on our behalf. Each provider processes data in accordance with its agreement with us and may not use it for any other purpose.
| Category | Purpose | Information involved | Provider |
|---|---|---|---|
| AI model services | Generating character replies, summaries and moderation classification | Conversation content, character information, user profile (excluding account identifiers) | 【Model provider name】 |
| Subscription management | Verifying and syncing In-App Purchase status | User identifier, transaction and subscription information | RevenueCat |
| App distribution and payments | App downloads, In-App Purchases | Processed by Apple in accordance with its privacy policy | Apple |
| Push services | Sending notifications | Push token, notification content summary | Apple Push Notification service (APNs) |
| Analytics and crash reporting | Measuring feature usage, diagnosing crashes | Device information, usage information (anonymized or pseudonymized) | 【Analytics provider name】 |
| Cloud infrastructure | Storage and computing | All of the above information (stored encrypted) | 【Cloud provider name】 |
| Speech synthesis (if enabled) | Generating character voices | Character reply text | 【Speech provider name】 |
Except as described above, with your consent or as required by law, we do not share your personal information with third parties.
5. Handling of Conversation Content and Human Review
- To generate replies, your messages are sent to the model service provider together with the conversation history and character settings for processing. We strive to complete each request with the minimum information necessary and do not pass your account identifier to the model service provider.
- Our staff do not routinely view your conversations. Staff may view relevant conversation excerpts only in the following cases: you submit a report that includes the relevant content; the content triggers automated safety moderation and requires review; or to respond to legal requirements.
- We do not use your conversation content to train our own models. How model service providers process data is governed by their agreements with us, and we choose providers that commit not to use customer data for model training. 【Confirm and complete accurately before launch】
6. Data Retention
| Data | Retention period |
|---|---|
| Account and profile information | Deleted within 【30】 days after account deletion |
| Conversation content | Retained until you delete the conversation or your account; removed from production systems within 【30】 days after deletion, and purged from backups on rotation within 【90】 days |
| User-created characters | Retained until you delete the character or your account; information about public characters that others have used may be retained after anonymization |
| Long-term memory | Retained until you delete the relevant memory or your account |
| Subscription and transaction records | Retained for 【N】 years as required by financial and tax regulations |
| Logs and diagnostic data | 【90】 days |
| Moderation and report records | 【1】 year, for handling appeals and preventing repeat violations |
Where laws or regulations require a longer retention period, that requirement applies.
7. Your Rights
- Access and correction: You can view and edit your profile information and user profile in the app.
- Deletion: You can delete an individual conversation, an individual user-created character or an individual memory; you can also delete your account to delete all of your data.
- Export: You can request a copy of your data using the contact details in Section 12. 【Confirm before launch whether in-app export will be offered】
- Withdrawing consent and turning off push notifications: You can turn off notification permissions in your device's system settings, or turn off the push notification toggle in the app.
- Deleting your account: In the app via "Me → Settings → Delete Account", or by requesting it by email.
We will respond within 【15】 business days after receiving your request and verifying your identity.
8. Age and Minors
The Service is intended only for users aged 17 or older. We do not knowingly collect personal information from anyone under the age of 17. If you become aware that we have collected information from a minor without permission, please contact us and we will delete it as soon as possible.
9. Data Security
- We protect your information with measures such as encryption in transit (TLS), encryption at rest, access controls and audit logs.
- No system can guarantee absolute security. If a security incident occurs that may affect your rights and interests, we will notify you promptly in accordance with the law.
10. Data Storage Location and Cross-Border Transfers
Your data is stored in 【Server location】. To provide the Service, some information (such as conversation content) may be transferred to service providers located in other countries or regions for processing. We will take the measures required by applicable law to safeguard the security of such transfers. 【To be completed by legal counsel based on data center location and compliance requirements】
11. Changes to This Policy
We may revise this Policy from time to time. The revised Policy will be published in the app and on this page, and the version number and effective date at the top will be updated. For material revisions, we will ask you to confirm again.
12. Contact Us
- Email: [email protected]
- Operator: 【Company name】
- Address: 【Registered address】