Privacy Policy

1. Information We Collect

Information You Provide

When you use Avatarmy services, we collect information that you voluntarily provide:

• Contact information (name, email, phone number)
• Business information (company name, real estate license details)
• WhatsApp conversation data with our AI avatars
• Property and client information you share with our avatars
• Payment and billing information

Automatically Collected Information

We automatically collect certain information when you use our services:

• Usage data (features used, time spent, interaction patterns)
• Device information (device type, operating system, browser)
• WhatsApp metadata (message timestamps, delivery status)
• IP address and general location data

2. How We Use Your Information

We use your information for the following purposes:

• Service Delivery: To provide and operate our AI avatar services via WhatsApp
• Personalization: To customize AI responses and recommendations based on your needs
• Improvement: To analyze usage patterns and improve our AI models and services
• Communication: To send service updates, notifications, and respond to your inquiries
• Security: To detect, prevent, and address fraud and security issues
• Compliance: To comply with legal obligations and enforce our terms
• Billing: To process payments and manage subscriptions

3. AI and Machine Learning

Our AI avatars (LUCA, ARIA, LEXIS, and BRAVO) use machine learning to provide intelligent assistance. Here's how we handle your data in this context:

• Conversations are processed to generate contextual responses
• Anonymized data may be used to improve AI model accuracy
• Personal identifiers are removed from training datasets
• You can opt out of having your data used for AI training

Our AI systems are designed with privacy by design principles, ensuring data minimization and purpose limitation.

4. Data Sharing and Disclosure

We do not sell your personal information. We may share your data only in the following circumstances:

Service Providers

We work with trusted third-party service providers who help us operate our services:

• WhatsApp Business API (Meta) for message delivery
• Cloud hosting providers for data storage
• Payment processors for billing
• Analytics providers for service improvement

Legal Requirements

We may disclose your information if required by law, court order, or to:

• Comply with legal processes
• Protect our rights, property, or safety
• Prevent fraud or illegal activities
• Protect the safety of our users or the public

5. Data Security

We implement robust security measures to protect your data:

• End-to-end encryption for WhatsApp communications
• Encrypted data storage and transmission
• Regular security audits and vulnerability assessments
• Access controls and authentication mechanisms
• Employee training on data protection and security

While we use industry-standard security measures, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but are committed to protecting your data to the best of our ability.

6. Your Rights (GDPR Compliance)

As an Estonian company operating within the EU, we comply with the General Data Protection Regulation (GDPR). You have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restriction: Limit how we process your data
• Right to Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to certain types of data processing
• Right to Withdraw Consent: Withdraw previously given consent at any time

To exercise any of these rights, contact us at privacy@leonandvera.com or via WhatsApp.

7. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

• Active account data is retained while your subscription is active
• Conversation history is retained for 24 months for service improvement
• Billing records are retained for 7 years to comply with tax regulations
• After account deletion, most data is removed within 30 days

Some data may be retained longer if required by law or for legitimate business purposes (e.g., fraud prevention, dispute resolution).

8. International Data Transfers

Avatarmy is based in Estonia (EU). If you access our services from outside the EU, your data may be transferred to and processed in the EU or other countries where our service providers operate.

We ensure that international data transfers comply with GDPR requirements through appropriate safeguards such as Standard Contractual Clauses (SCCs) or adequacy decisions.

9. Cookies and Tracking

Our website uses cookies and similar tracking technologies to:

• Remember your preferences and settings
• Analyze website traffic and usage patterns
• Improve website performance and user experience
• Provide personalized content

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

10. Children's Privacy

Avatarmy services are designed for business professionals aged 18 and older. We do not knowingly collect personal information from children under 18. If we become aware that we have collected data from a child, we will take steps to delete it immediately.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes via:

• WhatsApp notification
• Email to your registered address
• Prominent notice on our website

Changes will be effective 30 days after notification, unless otherwise stated. Your continued use of our services constitutes acceptance of the updated policy.