Privacy Policy

1. Introduction

Savva Inc. ("we", "us", or "our") is committed to protecting your privacy and ensuring transparency in how your personal data is collected, used, and safeguarded. This Privacy Policy explains what information we process when you access or use the ChatLogic AI mobile application (the "App" or "Service"), how we use that information, and what rights you have in relation to it.

For the purposes of this Privacy Policy, "personal data" (or "personal information") means any information that identifies, relates to, describes, or can reasonably be linked to an individual, either directly or indirectly.

This Privacy Policy applies to all users of the App ("Users"), regardless of their location.

By accessing, downloading, or using the App, you acknowledge that you have read and understood this Privacy Policy and agree to the processing of your information as described herein.

Your Privacy Rights

Depending on your location and applicable laws, you may have certain rights regarding your personal data. These rights may include:

• the right to request access to the personal data we hold about you;
• the right to request correction of inaccurate or incomplete data;
• the right to request deletion of your personal data, subject to certain legal limitations;
• the right to restrict or object to the processing of your data in certain circumstances;
• the right to receive your personal data in a structured, commonly used format (data portability), where applicable.

To exercise any of your rights, you may contact us at: support@savva.tech

We may request additional information to verify your identity before fulfilling your request. This is a necessary security measure to prevent unauthorized access to your data.

We will respond to all valid requests within a reasonable timeframe, in accordance with applicable laws and regulations.

Data Usage and Sharing Overview

We process personal data only where it is necessary to provide the App, improve its functionality, ensure security, comply with legal obligations, or pursue legitimate business interests.

We do not sell your personal data to third parties.

We may share your information with trusted third-party service providers who perform services on our behalf, such as infrastructure hosting, analytics, payment processing, and customer support. These service providers are contractually obligated to protect your data, maintain its confidentiality, and process it only for the purposes specified by us.

We may also disclose information where required to comply with applicable laws, regulations, legal processes, or enforceable governmental requests.

Your Choices and Control

You have control over how your data is used within the App.

You may manage certain permissions directly through your device settings, including access to location data, notifications, and other device-level information.

If you no longer wish for your data to be processed in connection with the App, you may discontinue use of the Service and uninstall the App from your device. Please note that certain data is necessary for the App to function properly, and disabling or restricting such data may limit or prevent access to some features.

2. Information We Process

We process certain categories of information in order to provide, maintain, and improve the App. The type and scope of information we process depend on how you use the Service.

Functional Information

We collect and process information that is necessary for the operation of the App and the provision of its core features. Without this information, we may not be able to provide the Service or certain functionalities.

Account and Authentication Information

You may provide your email address when creating an account or purchasing a subscription. Your email address is used to:

• create and manage your account;
• authenticate your identity;
• process and manage subscription purchases;
• provide customer support and respond to inquiries;
• send important service-related communications, such as account or billing notifications.

You may also choose to sign in using third-party authentication providers such as Apple or Google. In such cases:

• authentication is performed via secure protocols (such as OAuth 2.0);
• we receive limited information required to authenticate you (such as your email address or account identifier);
• we do not access, store, or process your third-party account credentials.

If you use Google sign-in, your data is handled in accordance with Google's authentication and data protection standards. We do not independently access or use your Google account data beyond what is required for authentication.

User Content

We process the content you provide while using the App ("User Content"), including:

• text inputs, prompts, and messages;
• files or documents you upload;
• content generated by the App based on your input.

User Content is processed solely for the purpose of providing the requested functionality of the App, including generating responses and delivering AI-powered features.

You are solely responsible for the content you submit and for ensuring that such content complies with applicable laws and our Terms of Use. Any use of generated content is at your own risk.

AI Processing and Third-Party Providers

To provide AI-powered functionality, your inputs and User Content may be processed by third-party service providers, including but not limited to OpenAI, L.L.C., Anthropic, PBC, and Stability AI, Ltd.

These providers process data on our behalf and in accordance with applicable data protection requirements. Data shared with such providers is limited to what is necessary to perform the requested functionality.

Contact Information

When you contact us (for example, via email), we may collect and process the information you provide, including:

• your name;
• your email address;
• the content of your message or request.

This information is processed and stored using trusted cloud service providers, including Amazon.com, Inc., and is used solely to respond to your inquiries, provide customer support, fulfill your requests, and communicate with you as needed.

Information Processed Automatically

With your permission, we may use third-party technologies (such as analytics and advertising tools) that automatically collect and process certain information from your device.

This may include automated processing and, in some cases, profiling, which refers to analyzing data to understand usage patterns, preferences, and behavior in order to improve the App and user experience.

You can withdraw your consent for such processing at any time through your device settings.

In addition, we may process certain limited data based on our legitimate interest, such as improving performance, stability, and functionality of the App. This data is typically aggregated and does not directly identify you.

Device and Usage Information

When you use the App, we may collect technical information about your device and usage, including:

Device Information

• device type, model, and manufacturer;
• operating system and version;
• screen size, resolution, and orientation;
• device performance metrics (such as memory usage, battery status, and performance data).

Connection Information

• mobile carrier and network provider;
• network type and connection details;
• IP address;
• session duration and timestamps.

Location Information

• approximate location based on IP address or device settings;
• country, region, and language preferences;
• time zone.

Application Information

• App version and configuration;
• internal identifiers (such as API keys or app instance identifiers);
• interactions with App features.

Device Identifiers

We may use device identifiers (such as advertising identifiers) to support analytics and, where applicable, advertising functionalities. These identifiers help us understand usage patterns and improve the Service.

Cookies and Similar Technologies

When you use the App, we may use cookies and similar technologies (such as pixels, web beacons, and scripts). These technologies allow us to:

• operate and improve the App;
• understand how users interact with features and content;
• analyze usage patterns and performance;
• support marketing and advertising activities.

Information collected through these technologies may be aggregated and used to optimize the App experience and deliver relevant content and features.

We may also allow third-party advertising partners to use such technologies within the App to provide services or display advertisements.

Log File Information

When you access or use the App, certain information is automatically recorded in log files. This may include:

• date and time of access;
• duration of sessions;
• interactions with App features;
• technical events and usage patterns.

This information helps us analyze performance, troubleshoot issues, and improve the functionality of the App.

Advertising and Analytics Data

We may collect and process information related to advertising and analytics, including:

• when and how advertisements are displayed;
• whether an ad was viewed, clicked, or resulted in a conversion;
• the type and placement of advertisements within the App;
• user interactions with advertising content.

Analytics tools may also track in-App events, such as:

• onboarding steps and feature usage;
• subscription actions and purchases;
• user progression and engagement events.

Some third-party services may use this information to perform profiling, which involves analyzing user behavior, preferences, and interests to provide more relevant content or advertising.

Please note that certain data collected by third-party tools may be processed independently by those providers in accordance with their own privacy policies. We do not control how such third parties process data collected through their own technologies.

Third-Party Data Processing

Some third-party providers (for example, analytics or advertising partners) may collect and process data independently, including through their own technologies integrated into the App. In such cases:

• we do not control or supervise their data processing practices;
• they may combine collected data with other information available to them;
• any requests regarding such data should be directed to the respective third-party provider.

Payment Information

All in-app purchases are processed by Apple Inc. through your Apple ID account. We do not collect, access, or store your payment card details. Payment processing, billing, and transaction security are handled entirely by Apple in accordance with its own policies.

You can review applicable purchase terms and manage your subscriptions through your Apple ID account settings.

Email Communications

If you provide your email address, we may use it to send you service-related communications, as well as updates about new features, offers, and other information related to the App.

These communications may be based on our legitimate interest in improving the Service and keeping users informed.

Where applicable, we may use limited data (such as usage patterns or general location) to personalize communications and make them more relevant to you.

You can opt out of receiving marketing communications at any time by using the unsubscribe link included in each email. Your request will be processed within a reasonable timeframe.

3. Purposes of Processing Your Personal Data

We process your personal data to operate, improve, and develop the App, as well as to ensure a safe and efficient user experience. In particular, we may use your information for the following purposes:

Providing and Maintaining the Service

We use functional and automatically collected information to deliver the core functionality of the App, including processing your requests, generating AI-powered responses, managing your account, and enabling access to features and services.

Improving and Optimizing the App

We use automatically collected data to analyze user behavior, understand trends, monitor performance, detect technical issues, and improve the reliability, functionality, and overall user experience of the App.

Personalization and Advertising

We may use certain information to personalize content, recommendations, and, where applicable, advertising. This may include showing content or advertisements that are more relevant to your preferences and interests.

Communication with You

We use your contact information to:

• respond to your inquiries and provide customer support;
• send important service-related communications (such as updates, changes to policies, or account-related notifications);
• send marketing communications, including newsletters and promotional offers, where permitted by applicable law.

You may opt out of receiving marketing communications at any time.

Security, Fraud Prevention, and Legal Compliance

We use your information to detect, prevent, and investigate fraud, unauthorized access, security incidents, and other harmful or illegal activities. This includes enforcing our Terms of Use, protecting our rights and intellectual property, and complying with applicable legal obligations.

If we intend to process your personal data for purposes other than those described in this Privacy Policy, we will notify you by updating this Policy or through other appropriate means, as required by applicable law.

4. Sharing of Your Information

We share your information only in the ways described in this Privacy Policy and only where necessary to provide, maintain, and improve the App.

We do not sell or rent your personal data to third parties.

We may share certain categories of information (such as device data, usage data, cookies, and identifiers) with third-party service providers that support the functionality of the App, including analytics, infrastructure, authentication, advertising, and AI processing.

While we carefully select service providers that implement appropriate technical and organizational measures to protect your data, we do not control their independent data processing practices and cannot guarantee absolute security of data transmitted to such third parties.

Third-Party Service Providers

We may engage the following third-party providers:

These providers may process data on our behalf or, in some cases, independently under their own privacy policies.

Advertising and Opt-Out

You may opt out of certain types of interest-based advertising through your device settings. Please note that even if you opt out, you may still receive contextual (non-personalized) advertisements.

Location Data Control

If you do not want third-party service providers to access your location data, you can disable location services in your device settings:

iOS: Settings → Privacy & Security → Location Services → Select the App → Choose "Never"

Disabling location access may affect certain features of the App.

If you would like to learn more about third-party services used in connection with the App, including their privacy practices and available opt-out options, we encourage you to review their respective privacy policies.

The App may contain links to third-party websites or services, or you may access the App through third-party platforms. We are not responsible for the privacy practices, policies, or content of such third-party services. We recommend reviewing their privacy policies before interacting with them.

We may disclose your personal data where necessary and in accordance with applicable law, including in the following circumstances:

• Legal obligations: where disclosure is required by law, regulation, or legal process;
• Protection of rights: where we believe in good faith that disclosure is necessary to protect our rights, enforce our Terms, prevent fraud, or ensure the safety of users or others;
• Business transfers: in connection with a merger, acquisition, financing, or sale of all or part of our business or assets. In such cases, your information may be transferred as part of the transaction. We will provide notice of any such change in ownership or use of your personal data, where required by law.

5. International Data Transfers

We operate globally and may transfer, store, and process your personal data in countries outside of your country of residence, including the United States and other jurisdictions.

These transfers may occur when we use third-party service providers or infrastructure located in different regions to support the functionality of the App, including hosting, analytics, advertising, and AI processing.

If you are located in the European Economic Area (EEA), United Kingdom, or other regions with data protection laws that differ from those of the United States, please note that your personal data may be transferred to countries that may not provide the same level of data protection as your jurisdiction.

In such cases, we take appropriate measures to ensure that your personal data remains protected in accordance with applicable laws. These measures may include:

• entering into data processing agreements with recipients;
• implementing standard contractual clauses or similar safeguards, where required;
• transferring data only to organizations that provide adequate levels of data protection.

By using the App, you acknowledge and consent to the transfer of your personal data to such jurisdictions, as described in this Privacy Policy.

For data storage purposes, we rely on trusted hosting providers. Where possible, we apply encryption and other security measures before transferring and storing your data. We work only with providers that meet appropriate security and reliability standards.

6. Data Retention

We retain your personal data only for as long as necessary to provide the App, fulfill the purposes described in this Privacy Policy, and comply with our legal obligations.

The specific retention period may vary depending on the type of data and the purpose for which it is processed. In general, we keep personal data:

• for the duration of your use of the App;
• as needed to provide services and support;
• as required to comply with legal, tax, accounting, or regulatory obligations.

If you no longer wish for us to process your personal data, you may request deletion of your data and closure of your account by contacting us at: support@savva.tech

Please note that we may retain certain information for a limited period where necessary to:

• comply with legal obligations;
• resolve disputes and enforce our agreements;
• maintain security, backup, and fraud prevention systems.

Such data will be retained only for as long as required for these purposes and will be securely deleted thereafter.

7. Exercising Your Rights

Depending on your location and applicable data protection laws, you may have certain rights regarding your personal data. These rights may include:

Access and Portability

You have the right to request access to the personal data we hold about you and, where applicable, receive a copy of such data in a structured and commonly used format.

Correction of Data

If your personal data is inaccurate or incomplete, you have the right to request that we correct or update it.

Deletion of Data

You have the right to request the deletion of your personal data, subject to certain legal limitations. Please note that some data may be retained where required to comply with legal obligations or for legitimate business purposes.

Restriction of Processing

In certain circumstances, you may request that we limit the processing of your personal data.

Right to Know About Data Sharing

You have the right to request information about whether and how your personal data is shared with third parties. Additional details are provided in this Privacy Policy.

Objection to Processing

Where your personal data is processed based on legitimate interests or for direct marketing purposes, you may have the right to object to such processing.

To exercise any of your rights, please contact us at: support@savva.tech

We may request additional information to verify your identity before fulfilling your request. This is a necessary security measure to prevent unauthorized access to personal data.

Right to Lodge a Complaint

If you believe that your data protection rights have been violated, you have the right to file a complaint with your local data protection authority or supervisory authority, in accordance with applicable laws.

8. How to Opt Out

You have control over how your data is used, including options to limit tracking, advertising, and location data processing.

Opt-Out of Marketing Tracking

You can manage activity tracking and personalized advertising directly through your device settings.

On iOS devices:

• Go to Settings → Privacy & Security → Tracking
• Turn off tracking for specific apps, or disable "Allow Apps to Request to Track" entirely

If tracking is disabled, apps will not be able to access your device's advertising identifier or track your activity across other apps and websites.

To limit Apple's personalized advertising:

• Go to Settings → Privacy & Security → Apple Advertising
• Turn off "Personalized Ads"

Please note that even if you opt out of personalized advertising, you may still receive contextual (non-personalized) ads based on general information, such as the content you are viewing.

Opt-Out of Location Data Processing

If you do not want the App or third-party providers to access your location data, you can disable location services:

On iOS devices:

• Go to Settings → Privacy & Security → Location Services
• Select the App
• Set location access to "Never"

Disabling location access may affect certain features of the App.

9. Data Security

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it from unauthorized access, loss, misuse, alteration, or disclosure.

Our security practices are based on generally accepted industry standards and may include:

• encryption of data in transit and, where applicable, at rest;
• secure authentication and access controls;
• data minimization and restricted access to personal data;
• monitoring systems to detect and prevent unauthorized access or security incidents.

We regularly review and improve our security measures to ensure an appropriate level of protection, taking into account the nature of the data and the risks associated with its processing.

However, please note that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your personal data, we cannot guarantee its absolute security.

In the event of a data breach affecting your personal data, we will notify you and/or the relevant authorities in accordance with applicable laws.

If you have any questions regarding data security, please contact us at: support@savva.tech

10. Children's Privacy

The App is not intended for use by children, and we do not knowingly collect personal data from individuals who are considered children under applicable data protection laws.

For the purposes of this Privacy Policy, a "child" generally refers to an individual under the age of 16, unless a different age threshold applies under the laws of your jurisdiction.

If you are a parent or legal guardian, you are responsible for supervising your child's use of digital services and ensuring that personal data is not provided without your consent.

If we become aware that we have collected personal data from a child without a valid legal basis or appropriate parental consent, we will take reasonable steps to delete such information as soon as possible.

If you believe that a child may have provided us with personal data, please contact us at: support@savva.tech

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons.

When we make changes, we will update the "Last updated" date at the top of this Privacy Policy. Where appropriate, we may also provide additional notice, such as through the App or other communication channels.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, you may contact us at: support@savva.tech

We will make reasonable efforts to respond to your inquiries in a timely manner.