Privacy Policy

The controller of your personal data is [Company name, address, email]. [Data protection officer or privacy contact, if appointed.] This policy explains what we collect, why, for how long, and your rights under the GDPR.

What we collect

• Account: name, email, password (hashed), sign-in records.
• Age: your date of birth, and the yes/no result of any independent age check (never the ID document or selfie, which stay with the age-check provider).
• Chats: your messages, the characters' replies, a summary of each relationship, and short facts characters remember about you.
• Purchases: what you bought and when. Card details go directly to our payment provider; we never see them.
• Usage and cost records: which AI calls served your chats and what they cost (no message text).
• With your consent only: product analytics events (for example, a match or a message sent).
• Device: a random device identifier used only to enforce age blocks, and push-notification tokens if you turn notifications on.

Why, and on what legal basis

• To provide the service you signed up for (contract): accounts, chats, memory, gems, VIP, notifications you ask for.
• To keep minors out and users safe (legal obligation and legitimate interest): age checks, moderation of messages for crisis language and abuse, reports.
• To keep accounting and tax records (legal obligation).
• To improve Linger (consent): analytics, which you can turn off at any time.

AI processing

To write a reply, we send the character's persona, a short summary, the few remembered facts that matter for the message and your recent messages to our AI provider [provider name], which processes them on our behalf under a data processing agreement. [Confirm with the provider's terms: API data not used for model training; retention period.] We do not use your chats to train AI models.

Who we share data with

Processors acting for us: hosting and database [provider], AI provider [provider], payments [Stripe or merchant of record], age assurance [provider], push delivery (your browser's push service). We do not sell your data.

International transfers

[Where a processor is outside the EEA: EU-US Data Privacy Framework or Standard Contractual Clauses. Counsel to complete per provider.]

How long we keep it

• Chats, memories and profile: until you delete them or your account.
• Purchase and ledger records: [10 years] as required by Italian tax law, without your name or email after account deletion.
• Under-18 blocks: a one-way hash of the email and device, for the block period only.

Your rights

You can access, download (Profile → Download my data), correct and delete your data (Profile → Delete my account), object to processing, withdraw consent, and complain to the Garante per la protezione dei dati personali or your local authority.

Children

Linger is for adults only. If we learn that a user is under 18, we close the account and delete its data except what the law requires us to keep.