Privacy Policy
This Privacy Policy explains what personal data the Companion AI service processes, for what purposes, for how long, and what rights you have. It is written with Regulation (EU) 2016/679 (GDPR) in mind and applies to users outside the Russian Federation.
1. Data Controller
1.1. The data controller is Individual Entrepreneur Dmitry Mikhailovich Kuzmin, OGRNIP 324632700015672, Samara Region, Russian Federation (the "Operator", "we").
1.2. This Policy covers the Companion AI service, the Telegram bot @CompanionVoiceBot (the "Service"), and all personal data we receive from its users ("User", "you").
1.3. Contact for any data protection question: support@amourvoice.com or @HelpCompanionVoiceBot. Your consent to processing is set out in a separate document, the Consent to Personal Data Processing.
1.4. The Service is intended only for persons aged 18 or over. We do not knowingly collect data of anyone under 18. If we learn that a person under 18 uses the Service, their access is blocked and their data is deleted, except for information we must keep by law or to prevent repeated registration.
1.5. The website amourvoice.com is informational only. It does not collect visitors' personal data and does not use cookies for tracking or web analytics.
2. Purposes, Data, Legal Bases and Retention
2.1. We process personal data only for the purposes listed below. Each purpose shows the data involved, the legal basis under Art. 6 GDPR and how long the data is kept.
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| 1. Registration and access to the Service | Telegram ID, Telegram name and username, interface language, gender (if you chose it in the Service or mentioned it in the conversation; optional, can be changed or removed in settings), date and time of consent to the Service documents, status of subscription to the Service's channel | Performance of contract (Art. 6(1)(b)) | While you use the Service and until deletion at your request |
| 2. Providing the Service: conversation with an AI companion and replies in text and voice to your text messages, voice messages and images, including, on request, searching publicly available information on the internet | Text messages, voice messages and their transcripts, images, message timestamps, search queries | Performance of contract (Art. 6(1)(b)) | Voice messages and images are not stored in the conversation history and are deleted once the reply is produced (technical storage no longer than 24 hours). Transcripts are kept in a technical cache for up to 24 hours (and afterwards as part of the conversation history, see purpose 3). Synthesized voice replies are kept in a technical cache for up to 12 hours for resending |
| 3. Personalising the conversation | Conversation history with each Personality, information you have shared about yourself in the conversation ("memory") | Performance of contract (Art. 6(1)(b)) | Until you delete it (the /clear command) or automatically after 90 days of inactivity |
| 4. Payments: accepting payment, keeping your balance and purchased Personalities, refunds | Telegram ID, amount in Telegram Stars, transaction date, items purchased, payment ID, balance, purchased Personalities, refund records | Performance of contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) | While you use the Service; payment and refund records for the periods required by tax and accounting law (at least 5 years) |
| 5. Support and handling requests | Telegram ID, name, username, email address (if you wrote to us by email), content of the request and of the correspondence with support | Performance of contract (Art. 6(1)(b)); legitimate interest (Art. 6(1)(f)) | While the request is handled and up to 3 years after it is closed |
| 6. Security and enforcement of the rules: preventing abuse, protecting minors, responding to signs of a crisis | Telegram ID, Service request logs (time, request type, technical details of processing; stored encrypted together with a short excerpt of the message and the reply), automatic violation and safety flags (stored encrypted together with the excerpt of the message they refer to), blocking records | Legitimate interest (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) | Request logs: 90 days; violation and safety flags: 180 days; blocking records: until the block is lifted or the data is deleted |
| 7. Analysing the performance of the Service and advertising channels in aggregate | Source of the referral link through which you came to the Service; usage metadata: dates of registration and activity, registration steps, buttons pressed and sections opened (never message content), number and type of messages, purchases made and their amount | Legitimate interest (Art. 6(1)(f)) | While you use the Service and until deleted at your request; results are used in aggregate, and one User's records are used only to handle their requests or investigate Service errors |
| 8. Compliance with legal obligations | Data we are required to keep or disclose by law or upon a lawful request of competent authorities | Legal obligation (Art. 6(1)(c)) | For the periods required by law |
2.2. We do not process biometric data: your voice is used only to recognise the text of your message and is never used to identify you.
2.3. We do not ask for special categories of personal data (Art. 9 GDPR). If you choose to share information about your health, sex life or other special categories in the conversation, it is processed only to carry on the conversation and to keep you safe, is not used for any other purpose and is deleted together with the conversation history; within request logs and safety flags (purpose 6) it is kept no longer than the periods stated there. By sharing such information you explicitly consent to this processing (Art. 9(2)(a) GDPR). You are free not to share it.
3. Automated Processing
3.1. Replies of the AI companion are generated automatically. We do not make decisions producing legal effects concerning you or similarly significantly affecting you based solely on automated processing (Art. 22 GDPR). Automatic safety flags do not by themselves restrict your access.
4. Recipients of Personal Data
4.1. To provide the Service we engage processors (Art. 28 GDPR) and share data with them only as needed for the relevant purpose. Categories of recipients:
- AI technology providers (USA): receive your messages, conversation history, memory and images to generate replies. Instead of your Telegram ID they receive a pseudonymous identifier from which your Telegram ID cannot be derived;
- speech recognition and synthesis providers (USA, EU countries): receive your voice messages for transcription and the reply text for voicing;
- public information search provider (USA): receives a search query when a reply needs up-to-date information from the internet;
- hosting providers and traffic delivery and protection networks (EU countries, global): run the servers, store data and protect the Service from attacks;
- Telegram: as the platform the Service runs on and as the operator of payments in Telegram Stars.
4.2. We do not sell personal data and do not share it for advertising or marketing. We may disclose personal data to competent authorities only upon a lawful request.
4.3. Details of specific processors are available on request.
5. International Transfers
5.1. Your personal data is processed and stored in several countries, including the United States, countries of the European Union and the Russian Federation, where the Operator is established.
5.2. Where a transfer goes to a country without an adequacy decision, it relies on the safeguards available under applicable law, such as standard contractual clauses (Art. 46(2)(c) GDPR) offered by our providers, or on your explicit consent (Art. 49(1)(a) GDPR). You may request information about these safeguards by contacting us.
6. Data Protection
6.1. We implement appropriate technical and organizational measures to protect your Personal Data from unauthorized access, loss, misuse, alteration, or disclosure (Art. 32 GDPR).
6.2. Measures include: encryption of data at rest and in transit, access controls, secure communication protocols, security monitoring, and regular backups.
6.3. No method of transmission over the Internet or electronic storage is entirely secure. We cannot guarantee absolute security but take all reasonable steps to protect your data.
7. Deleting Your Data
7.1. The /clear command in the Service deletes the conversation history and memory with the selected Personality.
7.2. Full deletion of your data (profile, history, memory, logs) is available on request to support. Records we must keep by law (for example, payment records) are deleted when the statutory period expires.
7.3. When the retention periods in Section 2 expire or the purposes are achieved, data is deleted or anonymized.
8. Your Rights
8.1. Under the GDPR you have the right to:
- access your personal data (Art. 15);
- have inaccurate or incomplete data rectified (Art. 16);
- have your data erased (Art. 17);
- restrict processing in certain cases (Art. 18);
- receive your data in a structured, machine-readable format (Art. 20);
- object to processing based on legitimate interest (Art. 21);
- withdraw your consent at any time without affecting the lawfulness of processing before the withdrawal (Art. 7(3));
- lodge a complaint with a supervisory authority, in particular in the country where you live or work (Art. 77).
8.2. To exercise your rights, contact @HelpCompanionVoiceBot or support@amourvoice.com, stating your Telegram ID (or username) and your request. We may ask you to confirm that you own the account.
8.3. We respond within one month of receiving the request. Where necessary, taking into account the complexity and number of requests, this period may be extended by two further months; we will inform you of the extension and the reasons within the first month (Art. 12(3) GDPR).
8.4. After you withdraw consent or your data is deleted, the Service cannot be used without registering again.
9. Relationship with Telegram
9.1. The Service runs on the Telegram platform. Telegram's own processing of platform data is governed by the Telegram Privacy Policy. This Policy applies only to processing by the Operator.
9.2. We comply with the Telegram Bot Terms and the Telegram Privacy Policy for Third-Party Bots.
10. Changes and Contact
10.1. We may update this Policy. The current version is always available at amourvoice.com/privacy/international/. We notify you of material changes in the Service.
10.2. Contact: @HelpCompanionVoiceBot, support@amourvoice.com.