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.
3.4 Session recordings
We record how visitors use the website (Session Replay) to find usability problems and errors. We use the open-source software Sentry, which we operate ourselves on our own servers; no data is passed to the software vendor or other third parties.
- Recorded: pages visited, clicks, scrolling, mouse and touch movements, the visible page layout, technical errors, browser and device type
- Not recorded: chat messages and chat previews are blocked, everything you type into input fields and your email address are masked in the browser before anything is sent; IP addresses are not stored
- Linking: if you are logged in, the recording is linked to your internal user ID (not your name or email)
- Retention: recordings are deleted automatically after 30 days
- Legal basis: our legitimate interest in a functional, error-free and user-friendly Service (Art. 6(1)(f) GDPR). You can object to this processing at any time (Art. 21 GDPR, see section 8).
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