Privacy Policy

1.1. The operator of personal data is the individual entrepreneur Фомичев Антон Павлович (ИНН 502103422107, ОГРНИП 324508100159404), email privacy@vluvvi.com (hereinafter referred to as the "Operator", "Service", "We").

1.2. This Policy defines the procedure for processing and protecting personal data of users of the vluvvi platform and is developed in accordance with the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" and other regulatory acts of the Russian Federation.

1.3. By using the Service, registering and/or submitting their data, the User consents to the processing of personal data under the terms of this Policy. The Service is intended for individuals over 18 years of age.

We process the following categories of data:

• Account data — email address, username, avatar, identifiers of external login services (Telegram, Google, Яндекс)
• Interaction data — messages in chats with AI companions, created characters and settings
• Messages and media in the messenger — content of correspondence with other users, transmitted files, voice and video messages, call metadata
• Voice data — audio transmitted when using voice functions and calls (processed for speech recognition and synthesis)
• Technical data — IP address, device and browser type, operating system, device identifiers (browser fingerprint) for guest access and abuse prevention
• Push tokens — when the User enables push notifications
• Analytics data — actions on the platform, page views, session duration (Yandex.Metrica)
• Payment data — transaction history (card data is processed by the payment provider, we do not store it)
• Age verification data — results of automated age assessment based on the nature of communication. The Operator does not collect or process identity documents and biometric data.

Personal data is processed for:

• ensuring the operation and personalization of the Service
• fulfilling the contract with the User (User Agreement, Public Offer)
• delivering messages between users and operating the messenger
• confirming the User's age and compliance with the Service rules
• improving the quality of AI companions and generation algorithms
• moderating content and ensuring safety
• analytics and user experience improvements
• compliance with legal requirements

Legal grounds for processing (Article 6 of Federal Law No. 152-FZ):

• consent of the personal data subject
• necessity of performing a contract to which the User is a party
• realization of the rights and legitimate interests of the Operator (security, product improvement, prevention of abuse) provided that the rights of the subject are respected
• fulfillment of obligations imposed on the Operator by law

We do not sell personal data. To provide services, we entrust processing to certain individuals to the extent necessary for the relevant operation: analytical services (for example, Yandex.Metrica), payment platforms (card data is processed by the payment provider, we do not store it), infrastructure and storage providers, push notification delivery services. For generating AI responses and media content, as well as speech recognition and synthesis, only the content of messages and requests is used without information that allows identifying the User (without email address, name, account identifier); identifying personal data is not transferred to such services.

We can automatically process data, including using automated systems (including automatic age assessment and fraud prevention systems), to ensure the security of the Service.

4.1. The Service is intended solely for adults (18+). To prevent access by minors, the Operator applies automated age assessment based on the nature of the User's communication.

4.2. The Operator does not request or process identity documents, photographs (selfies), or biometric personal data.

4.3. Upon detecting signs of minority, the User's account is blocked., and the associated personal data is deleted within a reasonable time frame.

Messages in chats with AI companions are stored on our servers until the User deletes the chat or account, for:

• ensuring the history of correspondence and the context of the dialogue
• moderation and detection of violations
• improving the quality of AI models (in anonymized form)

Messages in the messenger between users are stored for delivery and displaying the history of correspondence to all its participants. Media files may be checked by automated means to detect prohibited content. Individual chats may use end-to-end encryption — their content is not accessible to the Operator in this case.

The User understands that they may voluntarily transmit sensitive data in messages, including personal, financial, medical, or other information, and does so at their own risk. We recommend not to disclose data in chats that should not be revealed.

When deleting an account, messages in chats with AI companions are deleted within 30 days. Messages sent to other users in the messenger may remain accessible to their recipients as part of the conversation history.

The chat with the AI companion deleted by the user is irretrievably deleted within 30 days, including generated photos, videos, and voice messages. If there is an ongoing violation check for the account, deletion is postponed until its completion. General facts of the character's 'common memory' about you may be retained in your other chats with them.

6.1. The initial recording, systematization, accumulation, storage, clarification, extraction, and other processing of personal data of citizens of the Russian Federation is carried out using databases located on the territory of the Russian Federation (Article 18, Part 5 of Federal Law No. 152-FZ).

6.2. Cross-border transfer of personal data by the Operator is not carried out.

6.3. Certain technological operations (AI response generation, speech recognition and synthesis, image generation) may be performed with the involvement of third-party services. For these operations, only the content of messages and requests is used without information that allows identifying the User; personal data (email address, name, account identifier, etc.) is not transferred to such services.

6.4. Involved parties process the received data solely at the request of the Operator and to the extent necessary to provide services.

All data is stored in secure repositories using encryption during transmission and storage. We apply organizational and technical measures to protect information.

The retention period for personal data is determined by the purposes of processing and the activity period of the account. Inactive accounts and associated data may be deleted after 12 months of inactivity. Technical and analytical data may be stored separately for a reasonable period.

Despite the measures taken, data transmission over the internet cannot be completely secure, and we cannot guarantee absolute data protection.

The platform uses cookies, similar local storage technologies (localStorage — for example, for message drafts), and analytical services:

• Necessary cookies — authorization and operation of the platform
• Analytical (Yandex.Metrica) — user behavior analytics, heat maps, webvisor

Some analytical tools (for example, Yandex.Metrica's webvisor) may record user actions on the site, including mouse movements, clicks, and interaction with the interface, except for fields protected from recording.

The user can refuse analytical cookies by selecting 'Only necessary' in the cookies banner, as well as manage cookies in the browser settings. More details — in our Cookies Policy.

In accordance with Federal Law No. 152-FZ, you have the right to:

• Receive information about the processing of your personal data and access to it
• Request clarification of data in case of their inaccuracy
• Request blocking or deletion of data if they are processed in violation of the law or are no longer needed
• Withdraw consent for the processing of personal data
• Challenge the actions of the Operator in the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court

If you are in a jurisdiction where GDPR applies, you may also have rights to access, rectification, erasure, data portability, restriction of processing, and objection to processing.

To exercise your rights, please contact us at privacy@vluvvi.com. We will consider the request within the time frame established by law (usually within 30 days).

The user has the right to withdraw consent to the processing of personal data at any time by sending a request to privacy@vluvvi.com, or by deleting the account.

After the withdrawal of consent, the Operator ceases processing, except in cases where processing may continue on other legal grounds (for example, to comply with legal requirements). Withdrawal of consent may make it impossible to further use certain features of the Service.

The vluvvi service is intended exclusively for individuals who are 18 years of age or older. We do not knowingly collect personal data from individuals under the age of 18.

If we become aware that a user is under 18 years of age, their account will be blocked, and the associated personal data will be deleted within a reasonable time frame.

If you are a parent or legal representative and believe that a minor has provided us with personal data without your consent, please contact us at privacy@vluvvi.com — we will delete such data as soon as possible.