Privacy Policy

EVA AI (hereinafter “EVA AI” or “We”) values the privacy of all of our users and has established this Privacy Policy to show commitment to these rights and to safeguard your privacy. Please refer to this Privacy Policy to find out how to contact us if you have any questions about the contents herein. By using our app, website or other related services (hereinafter “Service”) you consent to the contents of this Privacy Policy.

1. PRIVACY POLICY

When you visit any website, app you are providing a range of personal data about your visit to the operators of the website, depending on the actions you take. This is also the case with EVA AI. You should always understand the privacy policies on any website when supplying personal data during your use of the Service. You should always ask for a copy of the privacy policy if the website does not make such available to you. We will only use the personal data you share with us during your use of our Services. Unless specifically mentioned, we do not use your personal data for any other reason. We will never sell your personal data to a third party, and we will never give a third party access to your personal data, except as may be provided in our Terms of Services and/or this Policy or unless required to do so by law.

2. TYPES OF PERSONAL DATA COLLECTED, USE AND SHARE OF THE COLLECTED PERSONAL DATA

We neither rent nor sell your information to anybody. Communication with your virtual friends is not shared with any other company, except for our affiliate companies or legal representatives, or service..

We collect information you intentionally provide us with, as well as some technical information from your mobile device or web browser.

The list of personal information collected and stored throughout your experience with EVA AI. Some of this information may be shared with service providers helping us to deliver your experience with EVA AI, each of such service is set forth below.

Personal information	Reason for collecting	When it is collected	Whether information is shared
First name*	To enable EVA AI to refer to you by name.	At stage of registration.	Yes, we use an external service to deliver service-related personalized emails to you that address to you by name.
Gender*	To ease your communication with virtual friend.	At stage of registration.	No
Other profile information	To ease your communication with virtual friend. This may include your birthday, work status, etc.	When you edit your profile	No
Email*	To enable you to register using your email and restore password in case you forget it. To provide marketing information and special offers, different kind of notifications about our services (you have the right to withdraw, opt-out, your consent at any time).	At stage of registration.	Yes, we use an external service to deliver automated emails to you (for example, in case you forgot your password). This service provider gets access only to the first name and email.
Facts about you and your life (including but not limited to your interests and hobbies)	To enable personalized conversation with virtual friend.	In EVA AI’s text or voice chat	No
People mentioned in the chat	To enable personalized conversation with virtual friend.	In EVA AI’s text or voice chat	No
Images you send to virtual friend	To enable recognition of object and face and appropriate reaction to images that you share with virtual friend.	When you send an image to virtual friend in chat	Yes, we use an external service for object recognition in photos.
Text and voice messages sent to virtual friend	To improve the quality of text and voice messages of virtual friend and to develop it’s AI.	In EVA AI’s text and voice chat	No
Usage data	We collect and store your usage data to track and analyze product metrics.	When you use with the EVA AI’s App or the Website	Yes, we use an external service to process usage data.

Items marked with an “asterisk” (*) are mandatory, whereas all the other items are optional and you may choose not to provide this information.

3. DEVICE INFORMATION

We collect certain information from and about the computers, phones, and other web-connected devices that you use to access EVA AI. We unify this information across different devices you use.

The device information also helps us conduct user research across our customer demographics, interests and behavior. None of this information may identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Device information	Description
Identifiers	Unique identifiers, including device ID.
Device attributes	Information regarding operating system, hardware, and software versions, browser type.
Data from device settings	Information you allow us to receive through device settings you turn on, such as access to your camera or photos.
Network and connections	Information such as the name of your mobile operator or ISP, language, time zone.
Cookie data	Data from cookies stored on your device, including cookie IDs and settings (only for the Website). Learn more about how we use cookies in the “Cookies” section.

4. COOKIES

We use analytics packages from trusted third parties in order to constantly improve your browsing experience on our website/app. Our trusted partners help us serve advertising and analytics and may place cookies on your device.

Please read their privacy policies to ensure that you are comfortable with the manner in which they use cookies.

a) Use of Google Analytics, Google DoubleClick are subject to Google Privacy Policy; b) Use of Facebook Pixel is subject to Facebook Privacy Policy; c) Use of Adroll is subject to Adroll Privacy Notice; d) Use of Criteo is subject to Criteo Privacy Policy; e) Use of Yahoo is subject to Yahoo Privacy Policy; f) Use of Microsoft Bing Ads is subject to Microsoft Privacy Statement; g) Use of MGID is subject to MGID Privacy Policy.

5. MODE AND PLACE OF PROCESSING THE PERSONAL DATA

The Data controller processes the personal data of users of EVA AI in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the personal data.

The personal data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data controller, in some cases, the personal data may be accessible to certain types of persons in charge, involved with the operation of the website (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Data controller.

The Data controller has secure certificates from VeriSign and McAfee that show the app and website are approved, fully tested, and certified by these two expert security systems. This means that you are safe from any viruses, identity theft, spyware, fraudulent credit card activity, spam, and internet scams.

The Personal data is processed at the Data controller’s operating offices and in any other place where the parties involved with the processing are located.

6. RETENTION TIME AND DELETION OF PERSONAL DATA

You have the right, at any time, to change or delete your Personal data by deleting your profile at App or website.

You may also send a request to our Support Team and they will guide you through the process.

The Personal data is kept for the time necessary to provide the services to you and you can always request that the Data controller suspend or delete your personal data. If You wish to delete personal data we have collected during your use of Website / app, you should send a request to our Support Team. Processing of your request will take some time to take effect. Thank you for your patience. Please note that changing or deleting your personal data will only change or delete the data in our database for purposes of future activities and for managing future communications. These changes and deletions will not change or delete emails or personal data website / app may have already forwarded to other users or credit card companies or any other third parties, all as provided above in this Privacy Policy. Further, if you delete your personal data from the Website / app, but continue to use other our services, you may receive emails from us regarding those services. However, we may elect to keep your personal data, subject to the requirements of the law and legitimate interests of the Data controller.

Please note that, even after termination of membership and deletion of any personal data, termination of any license granted hereunder, some content may continue to exist because of cached internet pages beyond the control of EVA AI.

7. CHANGES TO THIS PRIVACY POLICY

We reserve the right to replace, modify or amend this Privacy Policy at its own discretion. It is your responsibility to review this page and check for any Privacy Policy updates. Please note the latest modification date on the top of the Privacy Policy.

8. CONTACT US

The Data controller of the website is NOVI LIMITED, reg. number HE 407352, address Aglantzias, 62, EKATERINI NICOSIA BUSINESS, Flat/Office 213 CENTER, Aglantzia, 2108, Nicosia, Cyprus.

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy, including YOUR LEGAL RIGHTS section. You can address your requests to DPO through our support team.

Please send all the requests, including exercise of rights for EU, US and other users regarding personal data, as well as communications, inquiries, clarifications and provision of information to our support team at [email protected]

9. YOUR LEGAL RIGHTS

RIGHTS OF EU USERS

If you are located in the European Union, as data subject (a person whose personal information is collected, stored and processed) you have several rights under General Data Protection Regulation (“GDPR”):

• You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information:
  • the purposes of the processing;
  • the categories of personal information;
  • to whom the personal information have been or will be disclosed;
  • the envisaged period for which the personal information will be stored, or the criteria used to determine that period.

If you would like to have a copy of your personal information from us, we will provide it only in case: (1) you will prove your identity, (2) it will not adversely affect the rights and freedoms of others.

• You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies:
  • this personal information is no longer necessary in relation to the purposes for which they were processed;
  • you withdraw consent if the processing was based on your consent, and where there is no other legal ground for the processing;
  • you object to the processing and there are no overriding legitimate grounds;
  • your personal information has been unlawfully processed;
  • your personal information has to be erased for compliance with a legal obligation.
• You have the right to receive your personal information which you provided us with in a structured,commonly used and machine-readable format and have the right to transmit those data to another company, where: (a) the processing is based on your consent or on a contract; and (b) the processing is carried out by automated means.
• You have the right to withdraw your consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
• You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal information infringes GDPR.

You can exercise the above rights by contacting our support team via the CONTACT US section of this Privacy Policy

RIGHTS OF CALIFORNIA USERS

If you are located in California, USA, the California Consumer Privacy Act (CCPA) gives you the right to exercise the following rights:

• Right to know and access. You may submit a verifiable request for information regarding the:
  • categories of personal information we collect, use or share;
  • purposes for which categories of personal information are collected or used by us;
  • categories of sources from which we collect personal Information; and
  • specific pieces of personal information we have collected about you.
• Right to equal service. We will not discriminate against you if you exercise your privacy rights.
• Right to delete. You may submit a verifiable request to close your account and we will delete personal information about you that we have collected.

In order to verify your identity when you make a request, you will be required to log in to your password-protected account or respond to an email verification request.

You have a right to tell us that you do not want us to share your personal information with third parties, apart from the permitted share under this Privacy Policy and CCPA. We hereby inform you that we do not sell the personal Information of our users or share it in exchange for any value to any parties. We only share your personal information in manners and for purposes described above, which include solely business purposes.

Under CCPA, you can appoint an authorized agent to make the requests for exercising the rights above on your behalf. In order to do this, we will ask you to verify the request directly via email.

Under CCPA we are bound to disclose to you what categories of personal information we collect, how and when we share it. You can find this information in section TYPES OF PERSONAL DATA COLLECTED, USE AND SHARE OF THE COLLECTED PERSONAL DATA of this Privacy Policy.

The CCPA also requires us to disclose certain metrics about the various requests we get, such as how many specific requests we received from California residents in the last calendar year. You can request for us to provide the said metrics via the CONTACT US section of this Privacy Policy.

RIGHTS OF VIRGINIA USERS

If you are located in Virginia, USA, the Virginia Consumer Data Protection Act (VCDPA) gives you the right to exercise the following rights:

• To confirm whether or not the Data Controller is processing your personal data and to access such personal data;
• To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data;
• To delete personal data provided by or obtained about your;
• To obtain a copy of your personal data that you previously provided to the Data Controller in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
• To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

In order to verify your identity when you make a request, you will be required to log in to your password-protected account or respond to an email verification request.

We hereby inform you that we do not sell the personal Information of our users or share it in exchange for any value to any parties. We only share your personal information in manners and for purposes described above, which include solely business purposes.

You can find what categories of personal information we collect, how and when we share it in section TYPES OF PERSONAL DATA COLLECTED, USE AND SHARE OF THE COLLECTED PERSONAL DATA of this Privacy Policy.

RIGHTS OF JAPAN USERS

If you are located in Japan, as data subject (a person whose personal information is collected, stored and processed) you have certain rights under the Act on the Protection of Personal Information (“APPI”):

• you shall have the right to object at any time to the processing of personal data for direct marketing purposes.
• You have the right to submit a complaint with our support team via CONTACT US section of this Privacy Policy if you consider that the processing of your personal information infringes the APPI, the relevant laws and this Privacy Policy.
• When You have requested notification or disclosure of the purpose of use of their personal information to the contact address set forth in CONTACT US link of this Privacy Policy, we shall disclose to you the personal data held by us after confirmation of your identity; provided, however, that this shall not apply if we are not obligated to disclose such personal data under the APPI or other applicable laws. In some cases, we may charge a separate fee for the disclosure of such personal data.
• If, as a result of the disclosure of personal data as described above, the content of the personal data is found to be inaccurate, and we receive a request for correction, addition, or deletion of the personal data from the person concerned, addressed to our support team via CONTACT US section of this Privacy Policy, in accordance with the procedures prescribed by us, we shall, after confirming the identity of you, conduct an investigation to the extent necessary without delay and, based on the results of the investigation, correct, add, or delete the content of the relevant personal data.
• If we receive a request from you to suspend the use of or delete their personal data in accordance with the provisions of the APPI, addressed to our support team specified in CONTACT US section of this Privacy Policy, we shall, after confirming the identity of you, suspend the use or delete the relevant personal data to the extent necessary without delay; provided, however, that this shall not apply if it is found that there is no reason for the request.

10. ACCEPTANCE OF THIS PRIVACY POLICY

Our website, app and your use of it, including any issue concerning privacy, is subject to this Privacy Policy and the related Terms of Use. When you use our EVA AI, you accept the conditions set out in this Privacy Policy and the related Terms of Use. You signify and guarantee that you will never generate any databases, websites, software, legal entities and services that compete with EVA AI. Such behavior will be fully investigated, and necessary legal action will be carried out, including, without limitation, civil, criminal, and injunctive redress. The acceptance of this Privacy Policy and applicable Terms of Use are considered as a pre-condition for the use of EVA AI and our services.