Privacy Policy
Privacy Policy
Last updated: June 12, 2023
Welcome to Veby!
Veby ( “we”, “us”, and/or “our”) operates the Veby mobile and web applications, and other related services (collectively, the “Services”).
We are committed to protecting your privacy. This Privacy Policy describes how we collect, store, use, and share information through our Services.
We care about the protection and confidentiality of your information. When you use the Apps, you may provide information during your conversations with your care companion. We process this information only as described in this Privacy Policy, such as to allow you to have individualized and safe conversations and interactions with your care companion and to allow your companion to learn from your interactions to improve your conversations. We may also use information about your visit to our Website to promote our Services, but we will never use or disclose the content of your conversations for marketing or advertising purposes.
Any terms we use in this Policy without defining them have the definitions given to them in our Term of Services. If you have any questions, please contact us at [email protected]
1. What information we collect
A. Information you provide
Through your use of the Services, you may provide us with the following information:
Account information. This includes your name, email address, and password. If you choose to log in using another service, such as Google or Apple, we receive information about the service you used to log in and — depending on your chosen account settings with Google and Apple — details about you, including your name, email address, or unique user identifiers.
Profile information. We ask you to provide your birth date, pronouns, and work status when you register for the Apps.
Messages and content. This includes the messages you send and receive through the Apps, such as facts you may provide about you or your life, and any photos, videos, and voice and text messages you provide.
Interests and preferences. You may select conversation preferences, such as topics you would like to discuss, and communication preferences, such as the times of day you like to use the Apps. We also learn about your interests and your preferences over time through your use of the Services to personalize your conversations and the features of the Services.
Payments, transactions, and rewards. When you make purchases through the Services, our third-party payment processor, Stripe, collects your payment information. We maintain a record of your purchases, the features you select, and the rewards you earn and use.
B. Information we collect automatically
We automatically log the following information about you, your computer or mobile device, your network, and your interactions over time with our Services and our communications:
Device and network data. This includes your computer’s or mobile device’s operating system, manufacturer and model, browser, IP address, device and cookie identifiers, language settings, mobile device carrier, and general location information such as city, state, or geographic area.
Usage data. This includes information about how you use the Services, such as your interactions with the Services, the links and buttons you click, and page visits.
We use cookies, web beacons (e.g., pixel tags), and local storage technologies (e.g., HTML5) to collect some of this information.
2. How we use your information
A. Use of your information
We use your information for the following purposes:
Operating and administering the Services
Providing and maintaining the content and functionality of the Services. Creating your account and profile. Facilitating payments and transactions, including for the purchase of premium features, and managing your rewards. Responding to your inquiries, comments, feedback or questions, and troubleshooting. Managing our relationship with you, which includes sending administrative information to you relating to our Services.
Service necessity
Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.
Providing the core functionality of the Apps
Providing you a personalized AI companion and allowing you to personalize your profile, interests, and AI companion. Enabling you to have individualized and safe conversations and interactions with your AI companion, and allowing your AI companion to learn from your interactions to improve your conversations. Syncing your Replika history across the devices you use to access the Services.
Service necessity
Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.
Monitoring and protecting the Services
Preventing fraud, criminal activity, and misuse of our Services, and ensuring the security of our IT systems, architecture and networks (including testing, system maintenance, support, and hosting of data).
Legitimate interests
Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.
Analyzing trends in the use of the Services
Aggregating, anonymizing, and deidentifying personal information. Analyzing the use and effectiveness of our Services. Improving and adding features to our Services. Developing our business and marketing strategies.
Legitimate interests
Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.
Marketing and advertising the Services
Sending you information by email that we believe will be of interest to you, such as information about our Services, features, and surveys. Displaying and targeting advertisements about our Services on the internet.
Legitimate interests. Consent, where required by applicable laws
Account information. Device and network data. Usage data
Enforcing our agreements, complying with legal obligations, and defending against legal claims and disputes
Enforcing and complying with our terms and policies. Protect our and others’ rights, privacy, safety, or property. Ensuring the integrity of our Services. Verifying the age of registered users. Defending against legal claims and disputes. Recovering payments due to us. Keeping records of transactions, and complying with legal process.
Legitimate interests. Legal obligation
Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.
B. Sensitive information.
The Services allow you to input information that may be sensitive and subject to special protections under applicable laws. This section explains how we use and protect sensitive information.
Sensitive information you provide in your messages and content. In your conversations with your AI companion, you may choose to provide information about your health status, religious views, sexual orientation, political views, racial or ethnic origin, philosophical beliefs, or trade union membership. By providing sensitive information, you consent to our use of it for the purposes set out in this Privacy Policy.
3. How we share your information
A. Service providers
We do not share the content of your conversations. Under your permission, we may share your information with companies and individuals such as your doctors who already have service agreement with you. It is to help us operate the Services or our business so that we can provide the best services to you.
B. Authorities and others
We may share information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the legal compliance and protection purposes described above in Section 2.A.
C. Business transferees
We may share information with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests (including, in connection with a bankruptcy or similar proceedings).
4. How we secure your information
We use a variety of industry-standard security technologies and procedures to help protect your data from unauthorized access, use, or disclosure.
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
All transmitted data are encrypted during transmission. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All stored data are maintained on secure servers. Access to stored data is protected by multi-layered security controls, including firewalls, role-based access controls, and passwords.
While we use reasonable commercial efforts to protect the data, no technology, data transmission, or system can be guaranteed to be 100% secure. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your data, we will notify you as soon as we spot the issue.
5. Where we store your information
Our Services are operated from the United States of America. If you are located in another jurisdiction, please be aware that the information you provide to us may be transferred to, stored, and processed in the U.S.A., a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.
6. Data retention
We will retain your personal information for only as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
7. Your rights and choices
A. Opt-out of marketing communications
You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “Contact us” section below. You may continue to receive Services-related and other non-marketing emails from us.
B. Limit our use of sensitive personal information
If you choose to provide sensitive personal information in your messages and content, we will use that information only to facilitate your conversation with your AI companion and as described in the “Sensitive information” section above. If you do not want us to process your sensitive information for these purposes, please do not provide it. You may request that we delete information you have provided as set out in the “Personal information requests” section below.
C. Personal information requests
We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:
Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
Correction of personal information that is inaccurate or out of date.
Deletion of personal information that we no longer need to provide the Services or for other lawful purposes. You can delete your account in your account settings.
Withdrawal of consent, where we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Additional rights, such as to object to and request that we restrict our use of personal information.
To make a request, please contact us as provided in the “Contact us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
D. Right to erasure (‘right to be forgotten’)
You can request the deletion of your personal data. We are guided by principe of integrity and confidentiality measures.
8. Changes to this Privacy Policy
The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was last updated on the date indicated above.
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