Privacy Policy
Effective from: [DATE]. This is a translation of the Polish Polityka prywatności. If the two differ, the Polish version prevails.
1. Data controller
The controller is [NAME OF PERSON / COMPANY, ADDRESS], e-mail: [E-MAIL] (the "Controller").
2. What data we process
Chat content and moderation. Messages are passed between partners in real time. An authorized administrator may review recent messages in an active conversation to respond to abuse. The live view is held only in server memory and deleted when the conversation ends. Ordinary conversations are not archived. When a conversation is reported using the "Report" button, up to 80 recent messages are saved for moderation for at most 90 days. The administrator may end a conversation or impose a temporary block, tied to a hashed IP identifier, for up to 30 days. Access to conversations and moderation actions are recorded for 30 days; the audit log does not contain ordinary chat messages.
IP address and connection logs. For safety, the Service logs your IP address and the start and end time of each connection, and which IP addresses were matched in one chat. Chat content is not saved in these logs. Logs are kept in a database on the Controller's server, accessible only to the Controller, for 30 days, then deleted automatically. They are used to protect against abuse, to identify violators, and to disclose data to authorized authorities (e.g. police or prosecutors) only on their request and under applicable law. We also use a hashed IP identifier kept only in memory to limit connections. Logs of an intermediary server (e.g. nginx, CDN) are kept for [PERIOD, e.g. 14 days].
Captcha. If you disconnect quickly many times in a row, we ask you to type a code from an image. The counter of quick disconnects is tied to the hashed IP identifier, kept only in server memory, and removed after an hour of inactivity or after you solve the captcha. The captcha runs on our own server, with no external services.
Browser data (localStorage). We remember your theme, language and your confirmation of age and acceptance of the Terms. This is technical data necessary for the Service to work. It is not used for tracking and needs no cookie banner. You can delete it in your browser settings. We use no advertising or analytics cookies [remove this sentence if you add analytics].
Access to logs. Connection logs also include random connection and conversation identifiers, pairing events and chat endings, without ordinary chat content. Full IP addresses are available only in a protected administrator section after additional password verification. Every log view and export is recorded in the administrator audit log for 30 days. An export covers the selected time and data range and includes a manifest identifying the purpose, recipient and case or request reference.
3. Purposes and legal bases (GDPR)
Providing the chat: Art. 6(1)(b) GDPR. Security, abuse prevention, moderation of reports, defence of claims: Art. 6(1)(f) GDPR (legitimate interest). Disclosure of data to public authorities on request: Art. 6(1)(c) GDPR (legal obligation). Reported chats are kept for up to 90 days from the report, and longer if proceedings are pending, until they end.
4. Recipients and AI
When you chat with a virtual partner, your messages are sent to the AI model provider, Anthropic, PBC (USA), to generate replies. The transfer relies on appropriate safeguards, e.g. standard contractual clauses. Messages are not linked to your identity, because we do not send your IP or other identifiers. Data may also be entrusted to the hosting provider [HOSTING PROVIDER] and disclosed to public authorities where required by law.
5. Your rights
You have the right of access, rectification, erasure, restriction of processing, portability, and to object to processing based on legitimate interest. You can lodge a complaint with the President of the Polish Personal Data Protection Office (UODO, ul. Stawki 2, 00-193 Warsaw) or with your local supervisory authority. Because the Service is anonymous and does not store chats, we may be able to identify your data only for reported chats and connection logs. Send requests to [E-MAIL].
6. Age and security
The Service is for people aged 18 and over only. If we learn that a minor uses the Service, we will block access. We use encrypted connections (HTTPS/WSS), security headers and abuse limits. Data is not sold and not used for profiling.
7. Changes
We will announce changes to this Policy on this page.