PRIVACY POLICY

Updated: April 2024

This PRIVACY POLICY outlines how RAWSTHORN LTD handles personal data gathered from you during your use of "ChatGen", RAWSTHORN LTD data protection practices and indicates the various types of information that may be processed when you use "ChatGen". It is applicable to all individuals who access and use "ChatGen".

RAWSTHORN LTD gathers data, either individually or when combined with other information under its possession, that has the potential to identify you ("personal Information").

"Personal data" or "personal information" - any data, of any nature, concerning an individual who can be identified, either directly or indirectly, specifically through reference to that data.

RAWSTHORN LTD kindly requests that you carefully review the following Privacy Policy to understand how your personal data may be processed. By utilizing "ChatGen", you acknowledge that you have read, comprehended, and consent to be bound by these terms.

Unless stated otherwise, RAWSTHORN LTD assumes the role of data controller for the purposes of the General Data Protection Regulation (GDPR).

"ChatGen" is designed for adult use only. As a result, RAWSTHORN LTD does not knowingly or intentionally gather or request any personal information from children. The definition of "child" in the context of data processing activities may be assessed on a case-by-case basis in accordance with relevant data protection regulations. Individuals considered "children" under these laws are prohibited from directly providing any personal information to “ChatGen”.

As a general guideline, we consider individuals under the age specified by local data protection rules to be "children" until we have legal grounds to determine otherwise or until parental authorization is provided to us directly.

Parents or legal guardians are solely responsible for ensuring that their children do not provide personal information through “ChatGen” without verifiable parental consent. If RAWSTHORN LTD becomes aware that RAWSTHORN LTD have collected personal information from a child without obtaining parental consent, RAWSTHORN LTD will promptly delete that information. If you suspect that RAWSTHORN LTD may have collected information from or about a child without the proper parental consent, please contact RAWSTHORN LTD.

Safeguarding the security of your personal information is of utmost importance to RAWSTHORN LTD. RAWSTHORN LTD adheres to widely accepted industry standards to ensure the protection of personal information that is transmitted to RAWSTHORN LTD. RAWSTHORN LTD implements suitable technical and organizational measures to uphold data protection principles, such as data minimization, in an effective manner. RAWSTHORN LTD strives to encrypt your personal data using robust encryption algorithms, including hashing whenever feasible. In the event of a security breach that compromises your personal information, RAWSTHORN LTD will promptly notify you in compliance with applicable laws.

TYPES OF PROCESSED INFORMATION

1. Automatically processed data Information:

With your consent, RAWSTHORN LTD utilizes third-party technologies for automatic data processing (such as advertising or analytics tools) to analyze specific information transmitted by your device through "ChatGen". This includes Advertising ID or Android ID. Certain integrated advertising or analytics tools engage in automated processing of your personal data, which may involve profiling (any form of automated data processing utilized to assess various personal aspects concerning you to analyze or predict factors related to your personal preferences, interests, behavior, location, or movements). The automatic processing of information commences once you grant permission for "ChatGen" to track your activity. You have the option to withdraw your consent at any time; please refer to the opt-out clause below.

RAWSTHORN LTD may process certain information regarding your device and user behavior based on RAWSTHORN LTD legitimate interests. It typically does not individually identify any specific individual, and RAWSTHORN LTD only accesses it in an aggregated format. The purpose of processing - to enhance "ChatGen" and provide you with the optimal experience.

Please note that RAWSTHORN LTD does not have direct control over the information automatically provided to advertising or analytics tools. Therefore, RAWSTHORN LTD cannot assume responsibility for the processing of such information. If your user ID is linked to your Facebook account, Facebook may utilize your device information in conjunction with categorized data stored in their databases (such as age, gender, or other demographic details). RAWSTHORN LTD does not oversee, monitor, or guarantee the practices of third parties in handling your personal data, which they may collect through their own methods unrelated to "ChatGen".

- Device Information: When you utilize "ChatGen" on a mobile device, certain details regarding your device are recorded, which may include "device identifiers" (small data files or similar structures that are stored on or linked to your mobile device, allowing for the unique identification of your device (but not your personal identity): 1) connected with device: its type, operating system version, model, manufacturer, screen size etc to optimize the performance and compatibility of "ChatGen" on your device; 2) internet connection information: your mobile carrier, network provider, network type, IP address, timestamp, session duration, connection speed, and browser to deliver a seamless browsing experience and troubleshoot any connectivity issues; 3) location: your IP address, country code, region, state, city associated with your SIM card or device, language settings, time zone, and nearby points of interest to offer location-based features and tailor content to your geographical preferences; 4) other: user identifiers set up to personalize your experience and provide relevant content based on your user profile.

- Application Information: name, API key (identifier for the application), version, and properties of "ChatGen" to improve the services and understanding user behavior within "ChatGen".

- Cookies and etc: cookies and similar technologies such as pixels, web beacons, and scripts. These technologies help to enhance the functionality and effectiveness of "ChatGen". For instance, to track the number of users accessing specific areas or features of "ChatGen" and determine which links or advertisements are clicked on.

- Log File Information: whenever you make a request to access "ChatGen" or install it on your device, log file information is automatically generated and recorded: the start and end times of your "ChatGen" usage and your interactions within "ChatGen".

- Ad-related information: the date and time an ad is displayed, the content and nature of the ad offer, the ad format (text, image, or video), the specific placement of the ad within "ChatGen", and your interaction with the ad.

- In-App events: tutorial progress, level advancements, payments, in-app purchases, custom events, progression milestones, and user data processing preferences.

2. Functional Information:

When you use "ChatGen", RAWSTHORN LTD requests and processes specific information. It would be impossible to deliver the full functionality of "ChatGen".

- Contact Information (such as your name, email address, and any additional content provided in the email) that you voluntarily provide when reaching out to RAWSTHORN LTD via email or support form. RAWSTHORN LTD collects, stores, and processes this information using its cloud storage provider (Amazon.com, Inc.) to ensure efficient response to your inquiry, fulfill your requests, deliver the requested services, and send you the communications you specifically request.

- User Content (which includes the text and images you input into the message field and send through "ChatGen", as well as any text or other content produced by AI through "ChatGen"). Provided that you adhere to the rules and restrictions outlined in RAWSTHORN LTD Terms of Use, you have the freedom to manage, utilize, share, or otherwise exploit your User Content for personal purposes. However, it is important to note that it is your sole responsibility to ensure compliance with applicable laws when utilizing User Content. RAWSTHORN LTD would like to highlight that RAWSTHORN LTD collaborates with a third-party service provider, OpenAI, LLC, for the processing and creation of AI-generated User Content.

3. Payment Information:

The billing, processing, and charging for in-app purchases are handled by RAWSTHORN LTD e-commerce provider (Google). They are responsible for safeguarding and ensuring the security of your personal information. This information is processed to fulfill the contractual obligations between you and RAWSTHORN LTD. Please note that RAWSTHORN LTD does not have access to or utilize your credit or debit card details.

THE PURPOSES OF PROCESSING

  1. Enabling Service Availability: RAWSTHORN LTD utilizes functional information and automatically processed information to ensure the provision of all requested services to you.
  2. Enhancing, Testing, and Monitoring "ChatGen" Effectiveness: RAWSTHORN LTD analyzes automatically processed information to gain insights into your behavior and trends, identify potential outages and technical issues, and effectively operate, safeguard, enhance, and optimize "ChatGen".
  3. Communication Purposes: RAWSTHORN LTD uses the contact information you provide to communicate with you through newsletters. This includes sending marketing notifications, receiving feedback regarding your "ChatGen" experience, and informing you about RAWSTHORN LTD policies and terms. Additionally, RAWSTHORN LTD uses your information to respond to any inquiries or messages you send to RAWSTHORN LTD.
  4. Delivering Interest-based Advertising and Targeted Content: By utilizing automatically processed information, RAWSTHORN LTD may offer marketing content tailored to your preferences, such as displaying ads that align with your interests. This enables RAWSTHORN LTD to provide personalized content and information, including online advertisements and other marketing initiatives.
  5. Fraud Prevention and Law Enforcement: Ensuring a spam-free and secure environment is important to RAWSTHORN LTD. RAWSTHORN LTD employs your information to prevent, detect, and investigate instances of fraud, security breaches, potentially prohibited or illegal activities.

Please note that If any new purposes arise for processing your personal data, RAWSTHORN LTD will inform you accordingly and make appropriate changes to this PRIVACY POLICY.

SHARING OF THE DATA

RAWSTHORN LTD carefully selects third-party providers who are committed to implementing the necessary technical and organizational measures to safeguard user personal data. However, RAWSTHORN LTD cannot guarantee the security of information transmitted to such third parties. RAWSTHORN LTD are not liable for any accidental loss or unauthorized access to your personal data resulting from the actions of third parties.

RAWSTHORN LTD may share information collected through tools like cookies, log files, device identifiers, and location data with third-party organizations that provide automatic data processing technologies for "ChatGen", provided that RAWSTHORN LTD does not sell your personal data to third parties.

To support the delivery and enhancement of our services, RAWSTHORN LTD may engage the following third-party service providers to provide RAWSTHORN LTD with the necessary infrastructure:

  1. Amplitude Inc. (analytics), location: U.S.A., https://amplitude.com/privacy;
  2. AppsFlyer Inc. (analytics), location: U.S.A., https://www.appsflyer.com/legal/services-privacy-policy/;
  3. Firebase (Google LLC) (user authentication, analytics and marketing services, location: U.S.A., https://policies.google.com/privacy https://firebase.google.com/support/privacy?hl=en;
  4. Facebook (Meta Platforms, Inc.) (analytics, ad management), location: U.S.A., https://www.facebook.com/privacy/explanation;
  5. OpenAI, L.L.C. (AI-generated content), location: U.S.A., https://openai.com/privacy/, https://openai.com/terms/;
  6. Tableau Software LLC (analytics), location: U.S.A., https://www.salesforce.com/company/privacy/;
  7. Qonversion Inc. (In-App subscription implementation and revenue analytics), location: U.S.A., https://qonversion.io/privacy-policy.

You can obtain more information about the services and privacy options available, including opt-out choices, at the respective websites and privacy policies associated with those services.

There may be circumstances where RAWSTHORN LTD need to disclose your personal information for legitimate reasons, public interest, or unforeseen situations, such as: compliance with legal obligations; protection of RAWSTHORN LTD rights, your safety, or the safety of others; investigation of fraud or responding to government requests.

In the event of a merger, acquisition, or sale of all or a portion of RAWSTHORN LTD assets, RAWSTHORN LTD will notify you through a prominent notice within "ChatGen" regarding any change in ownership or the usage of your personal information.

RETENTION OF YOUR PERSONAL DATA

RAWSTHORN LTD typically retains your personal data for the duration necessary to fulfill the functional purpose of "ChatGen" and to meet RAWSTHORN LTD legal obligations. If you wish to discontinue RAWSTHORN LTD use of your personally accessible and stored information, you can request the erasure of your personal data and the closure of your account.

Nevertheless, certain data may be retained for a limited period (not exceeding the necessary storage duration) if it is required to comply with legal obligations such as taxation, accounting, or auditing, or to maintain data backup and security measures, prevent fraud, or address other malicious activities.

INTERNATIONAL DATA TRANSFERS

RAWSTHORN LTD operates globally and provides "ChatGen" to users worldwide.

Please be aware that RAWSTHORN LTD may transfer information, including personal information, to a country or jurisdiction that does not have the same level of data protection laws as your jurisdiction. In this case, your personal information may be transferred to a third country, a specific territory within that country, or an international organization where data protection and confidentiality regulations may not offer the same level of protection as in your country.

RAWSTHORN LTD strives to ensure that any recipient of personal data provides adequate protection for the received information, in accordance with applicable data protection laws. By using "ChatGen", you consent to the transfer of your personal data to any third country, specific territory, or international organization. Whenever possible, RAWSTHORN LTD encrypts your personal data before transmitting it to the hosting organizations for storage.

YOUR RIGHTS

You have the following options available for the personal information collected:

  1. Data Access and Portability: You can request copies of your personal information.
  2. Data Modification or Correction: If you are unable to update your data through your account, you have the right to request the correction, amendment, or updating of your data.
  3. Data Retention and Deletion: User data is typically retained as long as your user profile exists or as required to provide the relevant services. However, specific retention periods may vary depending on the processing context. You have the right to request the deletion of some or all of the personal data held about you.
  4. The Right to Know about Data Sharing: You have the right to inquire about the sharing of your data with third parties. For detailed information on this matter, please refer to the Section “SHARING OF THE DATA” of our Privacy Policy above. Should you have additional questions regarding data sharing, feel free to contact us at any time.
  5. Restriction of Processing: Under certain circumstances, you may have the right to limit how your personal information is used.

To exercise any of the rights mentioned above, please contact RAWSTHORN LTD through the provided contact form. Kindly note that these rights apply specifically to the information RAWSTHORN LTD has physical access to and store.

You also have the right to file a complaint with your local data protection or supervisory authority if you have reasonable grounds to believe that your rights under relevant data protection laws have been violated. Please be aware that when filing a complaint with these authorities, you may need to furnish additional information and substantiate your complaint with adequate objective evidence. By initiating a complaint, you consent to providing a clear explanation of the circumstances you believe have infringed upon your rights. Furthermore, in certain instances, prior to lodging a complaint with your local data protection or supervisory authority, you may be required to first communicate your concerns directly to us and seek clarifications if necessary.

In cases where your personal information is processed automatically, you may have the right to object to such processing under certain circumstances. If your personal information is processed for direct marketing purposes, you can request that your data be ceased for these purposes. To exercise this right, please contact the third-party services listed above to learn how you can object to the processing of your data.

If you are located in the European Union, you can reach out to Konrad Gutowski, via email at [email protected] if you have any privacy-related questions.

OPT-OUT

  1. If you prefer that third-party service providers do not use personalized ads based on your interests, please follow the instructions provided below:
    Choose option “Opt out of Ad Personalization” on your Android device in Settings/ Google/ Ads

Please note that opting out of certain interest-based advertising does not guarantee that you will no longer receive contextual ads based on non-personal information, such as ads related to the content of other digital products you use.

  1. If you do not want third-party service providers to utilize your precise location data or street-level location information, please follow the instructions below:
    Turn Location off for the applicable Product via the menu “Settings > Apps > "ChatGen" > Permissions > Location”. Then turn off the “Location” button.

ATTENTION CALIFORNIA RESIDENTS

Please review the following important information in accordance with the California Consumer Privacy Act of 2018 (CCPA). As a California resident, you have the right to request the following:

  • Information about the categories of personal information that RAWSTHORN LTD processes.
  • Details about the sources from which RAWSTHORN LTD obtains your personal information.
  • The purpose for which RAWSTHORN LTD processes your personal data.
  • Information about the categories of third parties with whom RAWSTHORN LTD may share your personal information.
  • Access to specific pieces of personal information that RAWSTHORN LTD may have collected about you, provided that the information provided in the request is sufficiently reliable to identify you as the user.

Please be aware that under the CCPA, personal information excludes de-identified or aggregated consumer information. To submit a verifiable consumer request for accessing, transferring, or deleting personal data, please use the provided contact form. In the body of your request, please include the phrase "Your rights to maintain confidentiality in the state of California".

When submitting a verifiable request, please be prepared to:

  • Provide adequate information that enables us to reasonably verify your identity or the authority of your representative. This may include your name, address, city, state, zip code, and email address.
  • Describe your request in sufficient detail to understand, evaluate, and respond appropriately.

Please note that if RAWSTHORN LTD is unable to verify your identity or confirm that the personal information pertains to you, RAWSTHORN LTD will be unable to fulfill your request or provide you with personal information. As a precautionary measure against fraudulent or false requests, RAWSTHORN LTD may also conduct checks, including using third-party identity verification services.

Any personal information provided in a verifiable consumer request will be used solely for the purpose of verifying the requester's identity or authority and not for any other purpose.

RAWSTHORN LTD strives to respond to verifiable consumer requests within forty-five (45) days of receipt. If more time is required, RAWSTHORN LTD will notify you in writing of the reason and the extended timeframe. Please note that RAWSTHORN LTD is only obligated to respond to two requests per customer per year. In certain circumstances, if you choose to delete your personal information from RAWSTHORN LTD records, RAWSTHORN LTD may be unable to provide certain services.

RAWSTHORN LTD does not sell any of your personal data to third parties.

MISCELLANEOUS

RAWSTHORN LTD maintains a regular practice of updating this PRIVACY POLICY. Any changes made to this PRIVACY POLICY will be posted here and in other suitable locations.

If you have any inquiries or concerns regarding this PRIVACY POLICY, please don't hesitate to reach out using the support form. RAWSTHORN LTD is here to assist you.

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