Privacy Policy — Misenpai

1. Introduction

Misenpai ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service, in accordance with the General Data Protection Regulation (GDPR) and applicable German data protection laws.

2. Data Controller

The data controller responsible for your personal data is:

[Operator Name]
[Address]
[City, Postal Code]
Germany
Email: privacy@misenpai.com

3. Data We Collect

3.1 Information You Provide

• Account data: name, email address, password, date of birth
• Profile data: avatar, bio, preferences (gender preference, character types, interest tags)
• User content: comments, messages, and interactions with AI characters

3.2 Automatically Collected Data

• Technical data: IP address, browser type, operating system, device information
• Usage data: pages visited, features used, session duration
• Cookies: session cookies, preference cookies (see our Cookie Policy)

3.3 Third-Party Data

If you register via social login (Google, etc.), we receive your name, email, and profile picture from the provider.

4. Legal Basis for Processing

We process your data based on:

• Contract performance (Art. 6(1)(b) GDPR) — to provide the Service
• Legitimate interests (Art. 6(1)(f) GDPR) — for security, analytics, and service improvement
• Consent (Art. 6(1)(a) GDPR) — for optional features and marketing

5. How We Use Your Data

• Providing and personalizing the Service
• Processing AI character interactions
• Account management and authentication
• Communicating with you about the Service
• Analyzing usage to improve the Service
• Ensuring security and preventing fraud

6. Data Sharing

We do not sell your personal data. We may share data with:

• Service providers: hosting, analytics, AI processing (under data processing agreements)
• Legal requirements: when required by law, court order, or government request

7. Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Service. After account deletion, we may retain certain data for up to 30 days for backup purposes, and longer where required by law.

8. Your Rights (GDPR)

You have the right to:

• Access your personal data (Art. 15 GDPR)
• Rectification of inaccurate data (Art. 16 GDPR)
• Erasure ("right to be forgotten") (Art. 17 GDPR)
• Restrict processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Object to processing (Art. 21 GDPR)
• Withdraw consent at any time (Art. 7(3) GDPR)

To exercise these rights, contact us at privacy@misenpai.com.

9. International Transfers

Your data may be processed by service providers outside the EU/EEA. In such cases, we ensure appropriate safeguards (e.g., Standard Contractual Clauses) are in place.

10. Data Security

We implement appropriate technical and organizational measures to protect your data, including encryption, access controls, and regular security assessments.

11. Children's Privacy

The Service is not intended for persons under 18. We do not knowingly collect data from minors. If we discover that a minor has created an account, we will promptly delete it.

12. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or in-app notification.

14. Contact

For privacy-related inquiries: privacy@misenpai.com