Privacy Policy

1. How We Collect Your Personal Data

We collect personal data you provide directly or through automated means when you:

• Visit or interact with our Services.
• Register an account or log in using sign-in links or codes (including via third-party authentication, e.g., Google, Discord, Twitter/X).
• Interact with Companions, including engaging in chats.
• Make payments or manage subscriptions.
• Contact us or report issues.
• Interact with our ads on third-party sites linking to this policy.

This policy does not cover data collected offline or by third parties (including affiliates) unless linked to this policy. Third-party links may collect data; review their privacy policies.

2. Personal Data We Collect

We collect data necessary for our purposes, based on your interaction level.

a) Browsers

• Technical Data: IP address, browser type and version, device information (e.g., model, operating system), screen resolution, and location data (e.g., country, city inferred from IP).
• Usage Data: Pages visited, session duration, time spent on features (e.g., chat interfaces), clicks, scroll depth, navigation paths, ad impressions and clicks, referral sources (e.g., search engines, social media), and communication preferences.
• Cookies: Data from cookies and similar technologies (e.g., web beacons, pixel tags) for functionality, analytics, and advertising (see Section 12).
• User-Submitted Data: Contact form submissions or issue reports.
• Consents: Permissions or preferences you provide (e.g., cookie settings, marketing opt-in).

b) Users

All Browser data, plus:

• Identity and Contact Data: Username, email, and optional profile data (e.g., bio).
• AI Interaction Data: Chat logs and interactions with Companions (e.g., text inputs, AI responses), used to operate and improve our AI services.
• Financial Data: Payment information (e.g., credit card or cryptocurrency details) provided during transactions, which we do not store.
• Marketing Data: Preferences for receiving marketing communications.
• Age Verification Data: Government-issued ID or biometric data (e.g., facial recognition) if required for age verification, processed by third parties and not stored by us (see Section 8).

We may aggregate data (e.g., usage statistics, demographic trends) for analytics or marketing. Aggregated data is not personal data unless combined with identifiable information, in which case we treat it as personal data.

3. Sensitive Data

Due to the nature of our Services, we may collect sensitive data (e.g., sexual preferences, interests) from your site behavior or chat logs. Such data is subject to strict safeguards, including encryption and access controls, and is not shared with third parties except as required by law.

4. Why We Collect Your Personal Data

We use your data for:

• Service Delivery: Provide access to the Services, manage accounts, deliver sign-in links/codes, and enable Companion interactions, including sexually explicit content for subscribers.
• AI Improvement: Use chat logs to train and enhance our AI models (no opt-out).
• Personalization: Tailor content, ads, and Companion responses based on your interests and usage patterns.
• Analytics: Monitor usage, improve functionality, and measure performance (e.g., feature engagement, ad effectiveness).
• Security: Detect fraud, prevent unauthorized access, verify age, and ensure network safety, including KYC/AML compliance.
• Legal Compliance: Comply with US laws (e.g., DMCA, CCPA), prevent fraud, and manage legal claims.
• Marketing: Send promotional materials (opt-out available for marketing emails).

Legal Bases

• Contract: To fulfill our Terms and Conditions.
• Legitimate Interests: For personalization, analytics, and security.
• Consent: For marketing (Browsers).
• Legal Obligation: For compliance with laws.

5. Who We Share Your Data With

We share data only as necessary:

• Service Providers: For payment processing (e.g., Stripe for fiat, blockchain nodes for cryptocurrency), analytics, age verification, or customer support (bound by contracts with strict data protection terms).
• Third-Party Social Media Services: For login via Google, Discord, or Twitter/X, we access limited account data (e.g., email, username, profile ID) via their APIs, as authorized by you. We do not share your chat logs or sensitive data with these services.
• Legal Authorities: To comply with US laws or respond to legal requests (e.g., DMCA notices, law enforcement).
• Business Transfers: In case of mergers or acquisitions (data use remains consistent with this policy).
• Aggregated/Anonymized Data: Shared with third parties for marketing or analytics (e.g., ad performance, user demographics), not personally identifiable.

We do not share personally identifiable data with third parties for marketing or analytics, and do not sell personal data.

6. Financial Data

We do not store financial data (e.g., credit card details or cryptocurrency wallet information). Payment information is processed securely by third-party processors (e.g., card processors for fiat, blockchain nodes for cryptocurrency) using industry-standard encryption. For cryptocurrency payments, you are responsible for sending payments to the correct wallet address and ensuring sufficient blockchain confirmations. We are not liable for user errors (e.g., incorrect addresses).

7. AI and Chat Logs

• AI Training: Chat logs and AI interactions are used to improve our AI models. There is no opt-out, as this is essential to the Services.
• Content Ownership: Chat logs and AI-generated content (e.g., Companion responses) are owned by us, as users cannot upload content (per Terms, Section 5).
• Content Removal: To request removal of chat logs, email contact@boinkai.com. Removal is subject to our 30-day retention period and may not be possible if used in AI training.

8. Biometric Data and Age Verification

To ensure users are 18+, we may require age verification through:

• Government-Issued ID: Processed by third-party verification services (e.g., Yoti, Jumio), which may involve uploading a photo ID. We do not store ID data; it is retained only by the third party per their privacy policies.
• Biometric Data: Facial recognition or other biometric analysis may be used to verify identity against the ID. Biometric data is processed by third parties, not stored by us, and deleted by the third party after verification, typically within 24 hours, per their policies.

Third-party verification services are bound by contracts ensuring data security and compliance with applicable laws. You consent to such processing when prompted for age verification. If verification fails or is refused, access to the Services may be restricted (per Terms, Section 2).

9. International Data Transfers

Some service providers (e.g., payment processors, analytics providers) may be located outside the United States, necessitating international data transfers. We ensure these transfers are secure and necessary for:

• Operating the Services (e.g., processing payments, verifying age).
• Improving functionality (e.g., analytics for performance).
• Complying with legal obligations (e.g., reporting to authorities).

We use:

• Contracts with standard data protection clauses to ensure third parties safeguard your data.
• Encryption and secure protocols for data transmission.
• Providers in jurisdictions with robust privacy laws where possible.

We minimize transfers and restrict access to the Services from the EU, UK, and South Korea to limit compliance with foreign regulations. Users in these regions are kindly requested not to access the Services.

10. Data Security

We use encryption, firewalls, and access controls to protect your data, including sensitive data. Sign-in links and codes are secured to prevent unauthorized access. However, no system is 100% secure. You are responsible for securing your email account used for sign-in links. We are not liable for breaches beyond our reasonable control (per Terms, Section 11).

11. Data Retention

We retain data only as long as necessary:

• Chat Logs: Stored and used for up to 30 days (e.g., for AI training, compliance). No guarantee of retention; likely purged sooner.
• Account Data: Retained for up to 12 months after account inactivity. No guarantee of retention; likely purged sooner.
• Backups: May persist longer for technical or legal reasons, but we strive to delete within the specified timelines.
• Age Verification Data: Not stored by us; handled by third parties and deleted post-verification (see Section 8).

Contact us at contact@boinkai.com for details.

12. Cookies and Tracking

We use cookies and similar technologies (e.g., web beacons, pixel tags) to enhance your experience. Types include:

• Essential Cookies: Enable core functionality (e.g., session management, sign-in links). Cannot be disabled.
• Performance Cookies: Collect analytics (e.g., page load times, error rates) to improve the Services.
• Functional Cookies: Support personalization (e.g., saving preferences, tailoring Companion responses).
• Advertising Cookies: Track ad impressions and clicks for targeted ads, shared as aggregated data with third parties.

Manage preferences via our Cookies Policy or browser settings. Disabling non-essential cookies may limit personalization or ad functionality but will not affect core access (see Terms, Section 9).

13. California Consumer Privacy Act (CCPA) Compliance

California residents have specific rights under the CCPA:

• Right to Know: Request details about the categories and specific pieces of personal data we collect, use, disclose, or sell (e.g., Technical Data, AI Interaction Data).
• Right to Delete: Request deletion of your personal data, subject to our 30-day chat log and 12-month account data retention periods (chat logs used for AI training may persist).
• Right to Opt-Out of Sale: Opt out of the sale of personal data. We do not sell data, but you may opt out of aggregated data sharing for analytics/marketing by emailing contact@boinkai.com.
• Right to Non-Discrimination: Exercise rights without denial of service, price changes, or reduced quality.

To exercise rights, submit a verifiable request to contact@boinkai.com or via our website's privacy portal. We respond within 45 days (extendable by 45 days for complex requests). Verification may involve confirming your email or account details. You may appoint an authorized agent with a notarized power of attorney. We may charge a reasonable fee for unfounded or excessive requests. For questions, contact contact@boinkai.com.

14. Marketing

We send transactional emails (e.g., account updates, sign-in links) and periodic marketing emails about our Services. Marketing emails include an opt-out link or can be managed by emailing contact@boinkai.com. Transactional emails are mandatory for account management.

15. Third-Party Links and Logins

• Links: Third-party websites (e.g., advertisers) have their own privacy policies. We are not responsible for their practices (per Terms, Section 9).
• Third-Party Logins: Using Google, Discord, or Twitter/X to log in allows us to access limited account data (e.g., email, username, profile ID) via their APIs. We do not access your social media posts, contacts, or private messages. Review their privacy policies before use.

16. Minors

The Services are for users 18+. We may request age verification via ID or biometric data (see Section 8). If we detect underage data, we will delete it and terminate the account. Report concerns tocontact@boinkai.com (per Terms, Section 2).

17. Complaints

Contact us at contact@boinkai.com with complaints. We will investigate and respond within a reasonable time. California residents may contact the California Department of Consumer Affairs or Attorney General for unresolved issues. Other users may contact the Wyoming Division of Banking.

18. Changes to This Policy

We may update this policy at our sole discretion. Check www.boinkai.com/privacy for the latest version. Material changes will be notified via email. Continued use constitutes acceptance (per Terms, Section 18).

19. No Error-Free Performance

We strive to comply with this policy but cannot guarantee error-free performance. We will address non-compliance promptly but are not liable for incidental damages (per Terms, Section 11).

Contact Us

For questions or support, contact:
Email: contact@boinkai.com
Address: Superscript Inc, 30 N Gould St Ste R, Sheridan, WY 82801