Transparency, Protection, and Your Data

This policy explains how Cerafyna collects, processes, stores, and safeguards your personal data, and the rights you have under applicable data protection laws.

For Ethical AI Companion Services

Effective Date:: February 11, 2026

Service Provider:: Cerafyna Technologies (to be established in the United Kingdom)

"The Service" refers to the AI companion service and any associated website or app.

Current Operational Host & Developer:

Total Solution Concepts Company, LTD / 讀樂樂行銷貿易有限公司 (Taiwan)

Address:: 新北市林口區文化二路一段20巷25弄4號1樓之2

Website:: www.totalsolutions.tw

Privacy Contact Email:: privacy@totalsolutions.tw

(UK legal entity details will be updated once Cerafyna Technologies is registered.)

1. Introduction

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our AI companion services ("Service").

We are committed to transparency, user safety, and compliance with:

UK GDPR
EU GDPR
EU ePrivacy Directive (Cookie Law)
US state privacy laws (where applicable)

By using the Service, you agree to the data-processing practices described in this Policy.

Where required by law (e.g., marketing or non-essential cookies), we obtain your separate consent.

2. Data Controller

For UK/EU users, the Data Controller will be:

Cerafyna Technologies (to be established in the United Kingdom).

During setup, certain technical and operational functions are performed by our Taiwan partner:

Total Solution Concepts Company, LTD, including:

Website development
Hosting and infrastructure support

They operate under GDPR-style safeguards.

This Policy will be updated once Cerafyna Technologies is formally registered.

3. Data We Collect

3.1 Account Information

Email address
Username
Password (hashed and salted)

3.2 Chat & Usage Data

Messages you send to the AI
AI-generated responses
Conversation history
Interaction patterns (features used, timestamps)

Conversations may include sensitive-feeling information.
Avoid sharing highly sensitive data (e.g., identity documents, passwords).

3.3 Technical Data

IP address (pseudonymized/anonymized where possible)
Device type
Browser type
Operating system
Log files
Approximate location (city-level)

3.4 Payment Information

Handled by third-party processors (Stripe, PayPal).

We do not store full credit card numbers.

3.5 Optional Data

Profile details
Preferences
Feedback or support messages

4. How We Use Your Data

4.1 To Provide the Service

Generate AI responses
Maintain conversation context
Manage accounts and subscriptions

4.2 To Improve the Service

Debugging and performance optimization
Safety and moderation improvements
Feature development

We use aggregated or anonymized data wherever possible.

4.3 Security & Fraud Prevention

Detect abuse or harmful behavior
Protect the platform
Enforce Terms of Service

4.4 Customer Support

Respond to inquiries
Resolve technical issues

4.5 Legal Compliance

Profile details
Preferences
Feedback or support messages

5. AI Training & Human Review

5.1 AI Training

By default, your conversations are not used to train general-purpose or public AI models.

We may use anonymized or aggregated data for:

Safety improvements
Abuse detection
Reliability and quality assurance

If we ever wish to use identifiable conversation data for training, we will request explicit, informed consent.

5.2 Human Review

Limited human review may occur:

To investigate abuse or safety concerns
To provide customer support
To comply with legal obligations
Reviewers follow strict confidentiality rules.

Optional UX studies require separate consent.

8. International Data Transfers

Because some backend services are managed from Taiwan, your data may be processed outside the UK/EU.

We rely on:

SCCs for EU data
IDTA for UK data
Additional technical and organizational safeguards

We will update mechanisms as new frameworks become available.

International transfers (including Taiwan) use:

EU Standard Contractual Clauses (SCCs)
UK International Data Transfer Addendum (IDTA)
Additional safeguards (encryption, access controls)

9. Data Retention

We retain data only as long as necessary for:

Providing the Service
Legal obligations
Security and fraud prevention

Typical retention periods:

Account data: until account deletion
Chat history: until deleted or account closure
Logs: 30–180 days
Backups: limited retention with automatic expiry

Anonymized data may be retained for analytics.

11. Children's Privacy

The Service is not intended for children under 13.

Users aged 13–17 may use the Service only with parental/guardian consent where required.

If we learn we collected data from a child without proper consent, we will delete it promptly.

12. Cookies & Tracking

We use cookies for:

Essential site functions
Preferences
Analytics (anonymized where possible)

See our Cookies Policy for full details.

13. Security Measures

We implement:

Encryption in transit and at rest
Access controls
Secure authentication
Monitoring and logging
Regular security reviews

No system is 100% secure, but we take reasonable steps to protect your data.

14. Changes to This Policy

We may update this Policy to reflect:

Service changes
Legal requirements
Technical updates

Material changes will be communicated via website notices, email, or in-app messages.

Continued use of the Service indicates acceptance of updated terms.

1. Introduction

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our AI companion services ("Service").

We are committed to transparency, user safety, and compliance with:

UK GDPR
EU GDPR
EU ePrivacy Directive (Cookie Law)
US state privacy laws (where applicable)

By using the Service, you agree to the data-processing practices described in this Policy.

Where required by law (e.g., marketing or non-essential cookies), we obtain your separate consent.

2. Data Controller

For UK/EU users, the Data Controller will be:

Cerafyna Technologies (to be established in the United Kingdom).

During setup, certain technical and operational functions are performed by our Taiwan partner:

Total Solution Concepts Company, LTD, including:

Website development
Hosting and infrastructure support

They operate under GDPR-style safeguards.

This Policy will be updated once Cerafyna Technologies is formally registered.

3. Data We Collect

3.1 Account Information

Email address
Username
Password (hashed and salted)

3.2 Chat & Usage Data

Messages you send to the AI
AI-generated responses
Conversation history
Interaction patterns (features used, timestamps)

Conversations may include sensitive-feeling information.
Avoid sharing highly sensitive data (e.g., identity documents, passwords).

3.3 Technical Data

IP address (pseudonymized/anonymized where possible)
Device type
Browser type
Operating system
Log files
Approximate location (city-level)

3.4 Payment Information

Handled by third-party processors (Stripe, PayPal).

We do not store full credit card numbers.

3.5 Optional Data

Profile details
Preferences
Feedback or support messages

4. How We Use Your Data

4.1 To Provide the Service

Generate AI responses
Maintain conversation context
Manage accounts and subscriptions

4.2 To Improve the Service

Debugging and performance optimization
Safety and moderation improvements
Feature development

We use aggregated or anonymized data wherever possible.

4.3 Security & Fraud Prevention

Detect abuse or harmful behavior
Protect the platform
Enforce Terms of Service

4.4 Customer Support

Respond to inquiries
Resolve technical issues

4.5 Legal Compliance

Profile details
Preferences
Feedback or support messages

5. AI Training & Human Review

5.1 AI Training

By default, your conversations are not used to train general-purpose or public AI models.

We may use anonymized or aggregated data for:

Safety improvements
Abuse detection
Reliability and quality assurance

If we ever wish to use identifiable conversation data for training, we will request explicit, informed consent.

5.2 Human Review

Limited human review may occur:

To investigate abuse or safety concerns
To provide customer support
To comply with legal obligations
Reviewers follow strict confidentiality rules.

Optional UX studies require separate consent.

8. International Data Transfers

Because some backend services are managed from Taiwan, your data may be processed outside the UK/EU.

We rely on:

SCCs for EU data
IDTA for UK data
Additional technical and organizational safeguards

We will update mechanisms as new frameworks become available.

International transfers (including Taiwan) use:

EU Standard Contractual Clauses (SCCs)
UK International Data Transfer Addendum (IDTA)
Additional safeguards (encryption, access controls)

9. Data Retention

We retain data only as long as necessary for:

Providing the Service
Legal obligations
Security and fraud prevention

Typical retention periods:

Account data: until account deletion
Chat history: until deleted or account closure
Logs: 30–180 days
Backups: limited retention with automatic expiry

Anonymized data may be retained for analytics.

Transparency, Protection, and Your Data

1. Introduction

We are committed to transparency, user safety, and compliance with:

2. Data Controller

Cerafyna Technologies (to be established in the United Kingdom).

Total Solution Concepts Company, LTD, including:

3. Data We Collect

3.1 Account Information

3.2 Chat & Usage Data

3.3 Technical Data

3.4 Payment Information

3.5 Optional Data

4. How We Use Your Data

4.1 To Provide the Service

4.2 To Improve the Service

4.3 Security & Fraud Prevention

4.4 Customer Support

4.5 Legal Compliance

5. AI Training & Human Review

5.1 AI Training

5.2 Human Review

6. Legal Bases for Processing (GDPR)

We process data under:

7. Data Sharing

We may share data with:

International transfers (including Taiwan) use:

8. International Data Transfers

We rely on:

International transfers (including Taiwan) use:

9. Data Retention

We retain data only as long as necessary for:

Typical retention periods:

10. Your Rights (UK/EU GDPR)

You have the right to:

You may also contact:

11. Children's Privacy

12. Cookies & Tracking

We use cookies for:

13. Security Measures

We implement:

14. Changes to This Policy

We may update this Policy to reflect:

Transparency, Protection, and Your Data

1. Introduction

We are committed to transparency, user safety, and compliance with:

2. Data Controller

Cerafyna Technologies (to be established in the United Kingdom).

Total Solution Concepts Company, LTD, including:

3. Data We Collect

3.1 Account Information

3.2 Chat & Usage Data

3.3 Technical Data

3.4 Payment Information

3.5 Optional Data

4. How We Use Your Data

4.1 To Provide the Service

4.2 To Improve the Service

4.3 Security & Fraud Prevention

4.4 Customer Support

4.5 Legal Compliance

5. AI Training & Human Review

5.1 AI Training

5.2 Human Review

6. Legal Bases for Processing (GDPR)

We process data under:

7. Data Sharing

We may share data with:

International transfers (including Taiwan) use:

8. International Data Transfers

We rely on:

International transfers (including Taiwan) use:

9. Data Retention

We retain data only as long as necessary for:

Typical retention periods:

10. Your Rights (UK/EU GDPR)

You have the right to:

You may also contact:

11. Children's Privacy

12. Cookies & Tracking

We use cookies for: