Psyra Privacy Policy

1. WHAT TYPES OF INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

When you use or access our Platforms, we may collect a variety of information about you, as described below. This includes, but is not limited to, information that permits us to identify you ("personal data").

A. Personal Data About You That You Provide

When you use our Platforms, we may ask you to provide personal data such as: your name, email address, username, date of birth, gender, account preferences, and other information you choose to share in your profile or during interactions with our AI features.

B. Personal Data About You That We Collect Via Technology

We may automatically collect technical information such as: device ID, device type, IP address, browser type, operating system, usage data, interaction logs with our AI, and approximate location data.

C. Information About You That We Collect From Others

If another user refers you to Psyra, we may receive your name and email address. We will contact you to notify you of the referral. If you do not respond or request deletion, we will delete such information.

D. Information About Others That You Provide

If you use features like "refer a friend," you may provide us with another person's name and email address.

E. Information Provided to Social Networking Sites

If you connect your account to an SNS (e.g., via "Connect with Facebook"), we may receive information from that SNS per its terms and privacy policy.

F. Information Collected By Third-Party Integrated Technologies

We may integrate third-party technologies (e.g., analytics, advertising) that collect information about your use of our Platforms and other sites. Such collection is governed by the third party's privacy policy.

G. Other Information Collected Via Technology

We may collect information about your interactions with our Platforms, including page views, clicks, navigation paths, and other usage patterns. We use cookies and similar technologies as described in our Cookies Policy.

H. Information in Your Inquiries and Posts

We collect information you send to us or post on our Platforms, including messages, feedback, survey responses, reviews, and forum posts.

2. HOW DO WE USE INFORMATION COLLECTED ABOUT YOU?

A. Purposes for Which We Collect Personal Data

We use information about you to:

• Provide, personalize, and improve our Platforms and AI services
• Facilitate your use of AI-powered psychological insights and relationship simulations
• Process payments and manage your account
• Communicate with you about your account, updates, and promotions (where permitted)
• Enforce our Terms of Use and investigate violations
• Conduct research, analytics, and development of new features
• Ensure security, prevent fraud, and comply with legal obligations

We may combine information about you with data from other sources to develop a user profile. We may also anonymize or aggregate data for research, analysis, and sharing with third parties.

B. Artificial Intelligence

3. HOW LONG DO WE MAINTAIN YOUR PERSONAL DATA?

We retain your personal data only as long as necessary for the purposes described in this Policy, or as required by law. We may retain data to comply with legal obligations, resolve disputes, enforce agreements, or for technical reasons. Subject to applicable law, we will endeavor to delete your personal data upon your request.

4. TO WHOM DO WE DISCLOSE INFORMATION COLLECTED ABOUT YOU?

We may share information about you in the following situations:

• Other Users: As directed by you or as permitted by our Terms of Use.
• Affiliates: With companies under common control for group operations, service provision, and marketing (with consent where required).
• Service Providers: With vendors who perform services on our behalf (e.g., payment processing, analytics, customer support), under contractual privacy and security obligations.
• Third-Party Technologies: Information collected via integrated third-party ads or technologies is subject to those parties' privacy policies.
• Social Networking Sites: If you connect your account to an SNS, information may be shared as per the SNS's terms.
• Business Transfers: In connection with a merger, sale, or transfer of assets.
• Advisors: With professional advisors (e.g., legal, audit) under confidentiality obligations.
• Legal Requirements: When required by law, subpoena, or legal process; to protect our rights, safety, or property; or to prevent fraud or abuse.
• Aggregated/De-identified Data: We may share aggregated or de-identified data with third parties.
• With Your Consent: As otherwise disclosed at the time of collection or with your permission.

5. WHAT ARE OUR POLICIES FOR COOKIES AND SIMILAR TECHNOLOGIES?

Please see our Cookies Policy [insert link if applicable] for details on our use of cookies and similar tracking technologies.

6. HOW DO WE SECURE INFORMATION COLLECTED ABOUT YOU?

We implement technical and organizational measures to protect your personal data. However, no system is completely secure. We cannot guarantee absolute security. You are responsible for safeguarding your account credentials.

7. DO OUR PLATFORMS SUPPORT "DO NOT TRACK" SIGNALS?

Our Platforms do not currently respond to "Do Not Track" browser signals.

8. DO WE SHARE INFORMATION ABOUT YOU WITH THIRD PARTIES FOR THEIR OWN DIRECT MARKETING PURPOSES?

We do not share your personal data with unaffiliated third parties for their own direct marketing purposes without your consent.

9. WHAT ARE THE POLICIES OF LINKED WEBSITES AND OTHER THIRD PARTIES?

Our Platforms may contain links to third-party sites. This Privacy Policy does not apply to those sites. We are not responsible for their content or privacy practices.

10. WHAT IS OUR POLICY ON THE USE OF OUR PLATFORMS BY CHILDREN?

Our Platforms are not intended for users under 18. We do not knowingly collect personal data from children under 18. If you are under 18, do not use our Platforms.

11. HOW CAN YOU CORRECT, UPDATE, OR MAKE CHOICES ABOUT THE INFORMATION COLLECTED ABOUT YOU THAT WE ARE STORING?

A. General

You may access, correct, update, or delete your personal data by emailing Dev@psyra.co or through your account settings. We will respond within a reasonable time. Certain data may be retained where required by law or for legitimate business purposes.

B. Disconnecting an SNS

To disconnect an SNS from your Psyra account, adjust your settings within the SNS platform.

C. Stopping Certain Communications From Us

• Emails: Use the "unsubscribe" link in promotional emails. Transactional emails may still be sent.
• Service Communications: You may opt out of non-essential service messages via your account settings or by contacting Dev@psyra.co.
• Marketing Communications: If you consented to receive marketing communications, you may revoke consent by contacting Dev@psyra.co or following opt-out instructions.

12. ADDITIONAL DISCLOSURES FOR USERS BASED IN THE EU AND UK

A. Representative

Our representative for GDPR purposes is Psyra. Contact: Dev@psyra.co.

B. General

Your personal data may be transferred to and processed in jurisdictions outside the EU and UK. Where required, we use appropriate safeguards (e.g., standard contractual clauses) to protect your data.

We process your personal data based on: (1) your consent; (2) contract performance; (3) legal obligation; (4) vital interests; or (5) legitimate interests (e.g., service operation, improvement, security).

C. Rights Under the GDPR

If you are in the EU or UK, you may have the right to: access, correct, delete, restrict processing of, or port your personal data; object to processing; and withdraw consent. To exercise these rights, contact Dev@psyra.co. You also have the right to lodge a complaint with a supervisory authority.

D. Marketing

We will only send you direct marketing about third-party products/services with your consent. You may opt out at any time.

13. WHAT ARE THE TERMS REGARDING ANY FUTURE CHANGES TO THIS PRIVACY POLICY?

We may update this Privacy Policy periodically. The updated version will be posted with a new effective date. Your continued use after changes constitutes acceptance.

14. WHAT LAW GOVERNS ANY DISPUTES REGARDING THIS PRIVACY POLICY?

This Privacy Policy shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region, without regard to its conflict of law principles. Any dispute arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Hong Kong Special Administrative Region.

If any provision of this Privacy Policy is judged to be illegal, void or unenforceable due to applicable law or by order of a court of competent jurisdiction it shall be deemed deleted and the continuation in full force and effect of the remainder of the provisions will not be prejudiced.

If you enter into a contract with us that requires, or contemplates, collecting, using, sharing, or securing information about you in a manner that is different than that which is described in this Privacy Policy, the terms of that contract will apply.