Privacy Policy
Last updated
Introduction
Sunsay Inc. and its affiliates (collectively, “Sunsay”, "Company", "we", “us” or “our”) are committed to protecting your privacy. We are dedicated to protecting your privacy rights and making our practices transparent and fair. This privacy policy (“Policy”) explains how we collect, use and process Personal Data (as defined below) when you use our websites, including any sub-domains and affiliated sites (“Website(s)”), or our mobile applications (“App(s)”, collectively, “Services”). It also outlines your rights regarding your Personal Data and how to contact us with questions.
This Policy applies whenever you visit, install, or interact with our Services. Please note that parts of this Policy may not be applicable to you, depending on the jurisdiction in which you reside and the applicable laws. This Policy forms part of our Terms of Use (“Terms”). If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time, pursuant to this Policy and our Terms. You are not legally required to provide us with any Personal Data (as defined below) but without it we will not be able to provide you with certain parts of our Services.
1. What types of data we collect?
We collect Personal Data from you, meaning any information which potentially allows your identification with reasonable means (for example, email address or name, collectively "Personal Data"). This section sets out how and when we collect and process Personal Data about you.
1.1. Account information:
If you choose to register an account with our Services, we collect your full name, email address, password, phone number, birthdate and username, as well as any optional details you choose to provide. In some cases, we may ask for proof of identity or age verification by requesting a government-issued ID or similar documentation. If you choose to log in, access or otherwise connect to the Services through a social networking service (such as Facebook, Twitter, Instagram, Apple, or Google), we collect your user ID and username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access.
In certain cases, we may request additional information about your parent or legal guardian to verify their identity and obtain their explicit consent, including copies of identification documents as required by law.
1.2. Payment and subscription information:
When you make a purchase on our Services, you will be asked to provide certain billing and shipping details (such as your name, billing address, shipping address and chosen payment method). Payment card details are collected and processed directly by our third-party payment service provider; we do not store full credit card numbers or CVV codes. When you subscribe to our Services, we collect information about your subscription plan, subscription status, renewal dates, billing cycle, and subscription history. This information is used to manage your subscription, provide you with the appropriate level of access to our Services, and process renewals and cancellations.
1.3. Usage information:
When you use our Services, we collect technical information about your interaction with our Services. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) as well as other information which relates to your activity in the Services. In addition, we may collect information about your preferences, interests, and goals related to you to help personalize your experience. This includes your selected topics of interest, personalization settings, language preferences, and how you customize your use of our Services.
1.4. Location information:
We may provide certain location-based services that rely on your device’s geolocation data. You can disable location sharing through your device settings. We collect this information to provide relevant location-based content and offers.
1.5. User content information:
When you interact with our AI companion or any other Services, we collect the content of your conversations and interactions, including the questions you ask, the topics you discuss, and your feedback. This information is used to provide you with personalized responses, improve the quality of our Service, and enhance your overall experience. Your conversations will be analyzed to better understand our users’ needs and improve our Services. We implement appropriate technical and organizational measures to protect this information.
1.6. Sensory information:
When you use our dice, we collect information necessary to connect and synchronize the dice with our Services, such as dice identifiers, firmware version, connection and synchronization information, battery status (where applicable), and information relating to your use of the Dice, including dice roll outcomes. We use this information to enable the dice's functionality, maintain and troubleshoot the connection, prevent misuse or fraud, and improve our Services.
1.7. Sensitive information:
Our Services are not intended to collect any special categories of Personal Data or sensitive data. We do not actively request or require you to provide any sensitive information, and you are asked not to do so. Any sensitive data will only be processed if you voluntarily choose to submit it in the content you enter into the Services, and in such cases, it will be processed solely as part of your interaction with the Services and in accordance with this Policy and applicable laws. If you believe that the foregoing has been processed through our Services, please contact us via the details provided below.
1.8. Communication information:
When you send us an email or contact us via the support/contact us within our Services, we collect the Personal Data you provide us. This includes your name, email address and any other information you choose to provide.
2. Tracking Technologies
When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These Tracking Technologies allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve the performance of our Services, perform analytics, customize your experience, and offer you, for example, tailored content and advertisements that better correspond with your interests. For more information, see the following section of this Policy.
2.1. What types of Tracking Technologies do we use?
Selecting Manage cookie preferences below opens a panel listing every cookie set on this site, grouped into Necessary, Preferences, Statistics and Marketing categories, together with each cookie's provider, purpose and storage duration. You can review or change your consent from that panel at any time.
When you use or access our Services, we use the following categories of Tracking Technologies:
a. ++Strictly necessary++: These Tracking Technologies are automatically placed on your device when you access our Services or take certain actions on our Services. These Tracking Technologies are essential to enable you to navigate and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies. b. ++Tracking and advertising Tracking Technologies++: These Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. Tracking Technologies remember the websites you visit, and such information is shared with other parties such as advertisers and/or publishers. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy policies/cookies policies and principles, which we do not control. c. ++Functionality Tracking Technologies++: These Tracking Technologies allow our Services to remember choices you make when you visit our Services (such as language options) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged in) and support other features of our Services. d. ++Performance Tracking Technologies++: These Tracking Technologies collect information about your online activity (for example, the duration of your visit to our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics and research and to perform statistics (based on aggregated information). e. ++Social media and similar++: these Tracking Technologies include social media features, such as the Facebook "Like" or "Share" buttons, or third-party log-in services. These features are either hosted by a third party or hosted directly on our Services on the Brand Websites. Your interactions with these features are governed by the privacy statement of the company providing these features.
2.2. How and by whom Tracking Technologies are stored on your device?
We store Tracking Technologies on your device when you visit or access our Services (for example, when you visit our Website). Such Tracking Technologies are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on our Services. Such Tracking Technologies are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit to our Services or for repeated visits.
There are various ways in which you can manage and control your Tracking Technologies settings. You can change your Tracking Technology preferences by changing your browser settings to send a “Do-Not-Track” signal. In such a case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Services may not work properly or effectively if you delete or disable cookies.
To learn more about how you can manage your cookies, below is a list of useful links that can provide you with more information:
a. Google Chrome b. Internet Explorer c. Mozilla Firefox d. Safari (Desktop) e. Safari (Mobile) f. Android Browser g. Microsoft Edge h. Opera i. Opera Mobile
You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:
j. The Interactive Advertising Bureau (US) k. The Interactive Advertising Bureau (EU) l. European Interactive Digital Advertising Alliance (EU) m. Digital Advertising Alliance n. Network Advertising Initiative o. “Your Online Choices” (UK)
If you are accessing our services through a mobile device app, you can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:
a. On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version). b. On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).
"Do Not Track" Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
3. Database
The Personal Data which will be processed will be stored in a database of the Company (which is the controller of the database and whose contact details are provided below). The Database is managed in accordance with applicable law and under the responsibility of the Company ("Database").
The use of the Services offered by the Company constitutes your consent to this Policy and that the Personal Data about you will be stored and managed in the aforesaid Database, where required under applicable laws. The use of the Personal Data in the Database will be made in accordance with the terms of this Policy or the provisions of the applicable law, for the purposes outlined below. It is hereby clarified that consent to this Policy constitutes consent for the purposes of the provisions of applicable laws.
4. Why do we process your Personal Data?
This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.
| Purpose | Legal basis |
|---|---|
| Provision of our Services; support. We use your Personal Data, such as your name and email address, as well as any Personal Data you submit through your interactions with our AI features (including conversations with our AI companion), to provide you with our Services and provide customer support. This includes, for example, allowing you to log-in, personalizing your experience, or responding to your inquiries. | The legal bases for processing this data are the performance of our contractual obligations towards you; your consent (for example, when you provide Personal Data); and our legitimate interests. Our legitimate interests in this case are provision of our Services and supporting our customers. |
| Payments and subscription. When you make a purchase through the Services, your payment details are collected and processed by our third-party payment processors. We receive from them limited information about your payment method (such as card type, last four digits and billing details) for the purposes of fulfilling orders and transactions, linking your payment method to your account on the Services, billing and issuing invoices. | The legal bases for processing this data are the performance of our contractual obligations; we may also rely on our legitimate interest to comply with any legal obligation which applies to us and the exercise and defence from legal claims. |
| Improve our Services and AI features. We collect and analyse information about you and your usage of our Services, including your interactions with our AI features, for the purposes of improving the quality, relevance and effectiveness of our Services, including debugging to identify and repair errors, enhancing our AI capabilities, and undertaking internal research for technological development and demonstration. ¶ We may use aggregated and de-identified data from your interactions with our AI features to improve and train our AI models, enhance the quality of AI-generated responses, and develop new features | The legal basis for processing this data is our legitimate interest. Our legitimate interests in this case are providing and improving our Services. ¶ . |
| Marketing and advertising. We may use your contact details (such as your email address and/or phone number) to send you direct marketing communications about our products and services, including newsletters, updates, offers and other promotional messages that we believe may be of interest to you, subject to your explicit consent, when required under applicable law. You can opt out of receiving direct marketing at any time by following the unsubscribe link in our emails or by contacting us directly. | The legal bases for processing this data are your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing you with information and offers that are relevant to your interest. |
| Integrity and security. We process certain information about you and your usage of our Services in order to keep the integrity and security of our Services, prevent fraud, verify your identity and enforce our policies. | The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services; detection of fraudulent activities; and the safety of our end-users. |
| Compliance with applicable laws; assistance to law enforcement agencies. We process your Personal Data in order to comply with our legal obligation under applicable laws. | The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are compliance with our legal obligations and assisting law enforcement agencies. |
5. To whom we disclose your Personal Data?
We share and disclose Personal Data as permitted by law, as described below:
5.1. Affiliated companies:
We may share Personal Data internally within our parent company, affiliated companies and subsidiaries, for the purposes described in this Policy.
5.2. Payment processors:
We share your payment information with third party payment processors, for the purpose of facilitating your payments when using our Services. These third parties have access to your Personal Data so that they perform these tasks on our behalf.
5.3. Service providers:
Our service providers work on our behalf and need access to certain Personal Data in order to provide their services to us. These companies include, but are not limited to, cloud storage providers, AI service providers, analytics services, fraud prevention, identity verification providers etc.
5.4. Third party advertisers:
Third parties may use Tracking Technologies to collect information for advertising based on your browsing interests.
5.5. Third party integrations:
You may integrate third-party services (Apple, Google, Facebook, etc.). You are bound by their privacy notices and terms. We do not receive or store your passwords.
5.6. AI and machine learning providers:
We use third-party AI service providers, including providers of large language models (LLMs), to power our AI features such as our AI chatbot and AI companion. These providers include, without limitation: (i) Anthropic - the company behind the Claude model that powers your AI conversations, used to process your chat messages and generate personalized AI responses; (ii) OpenAI - whose models are integrated into our backend infrastructure for natural language processing and content generation capabilities; and (iii) Google AI Models - integrated into our backend infrastructure for AI-driven analysis and response optimization. The list of providers may be updated from time to time. Not all providers may be active for you at any given time. When you interact with our AI features, we send the active providers the content of your chat messages and the profile details you share with us – including, without limitation, your name, gender, birth date, birth time and birth location - for the purpose of generating AI-powered responses and providing the conversational functionality of our Services. We share data with these providers solely for the purposes described above and under contractual terms that require them to protect your data, maintain confidentiality, and limit their use of your data to providing services to us.
5.7. Compliance with laws and protection of rights:
We disclose some data about you to government authorities, law enforcement agencies or officials, regulatory bodies, courts, advisors, private or other third parties. The disclosure will be made in our sole discretion, as we believe it necessary or appropriate to comply with applicable laws, regulations, legal process (including but not limited to subpoenas), requests from competent authorities, to respond to claims, to protect our or a third party’s property or rights, to protect the safety of the public or any person, or to prevent, investigate or stop any activity we consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We may also disclose Personal Data where otherwise permitted or required by applicable law.
5.8. Auditors and advisers:
We share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards, auditing, managing disputes etc.
5.9. Mergers and acquisitions:
We will transfer, sell or otherwise share your data in case of entering into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.
6. Marketing and advertising
We may use your Personal Data ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, ads, products, services, websites and applications which relate to our affiliated companies or our business partners (“Marketing Affiliates”), which we believe may interest you, subject to your consent when required by applicable law.
You can unsubscribe at any time using the unsubscribe link at the bottom of any marketing email you receive from us. You can also decline receiving further marketing offers from us or from our business partners and Marketing Affiliates at any time, by contacting us at: contact@sunsay.com.
Please note that even if you unsubscribe from our marketing-mailing list, we can continue to send you service-related updates and notifications.
7. Your rights
Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights:
7.1. Rights of access to your Personal Data:
You have the right to receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information;
7.2. Rights of data portability:
You have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability;
7.3. Right of rectification:
You have the right to request rectification of your Personal Data in our control in the event that you believe the Personal Data held by the Company is inaccurate, incomplete or outdated;
7.4. Right of deletion/erasure:
You have the right to request that the Company erase or delete Personal Data held about you at any time;
7.5. Right to restriction or objection to processing:
You have the right to request that the Company restrict or cease to conduct certain Personal Data processes at any time;
7.6. Right to withdraw your consent:
To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time;
7.7. Right not to be subject to automated decision making:
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significant effects to you; and
7.8. Right to lodge a complaint and appeal our decisions:
All requests, complaints or queries may be addressed to the Company to the following email address: contact@sunsay.com. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
For US residents:
Depending on your state of residence in the US, you may have certain additional rights under relevant applicable states laws regarding the collection and processing of your Personal Data, in addition to the rights described above.
7.9. Right to opt-out of sale or share of Personal Data:
In the event that we sell or share your Personal Data for behavioural advertising purposes, you have the right to submit a request to opt-out. After you opt-out, we may continue disclosing some Personal Data to our partners to help us perform business-related functions such as providing the Services, ensuring security, producing aggregate statistics and preventing fraud;
7.10. Right to limit the use and disclosure of sensitive Personal Data:
You may request that we limit the collection and disclosure of your sensitive Personal Data only to what is necessary to perform our Services, or as otherwise permitted by applicable US data protection laws;
7.11. Right to non-discrimination:
You have the right to be free from discrimination for exercising your rights, including different pricing, products or quality of services, based solely upon your request;
7.12. Right to content removal:
If you are a California resident under the age of eighteen (18) and over the age of sixteen (16), you may request removal of content you submitted to the Services by emailing us; and
7.13. California “Shine the Light”:
California residents may request information about our disclosure of Personal Data to third parties for direct marketing. We will respond to one such request per calendar year, as required by applicable law.
7.14. Authorized agent:
Depending on your residence state, you may designate an authorized agent to submit privacy requests on your behalf, subject to identity and authorization verification.
You may also have the right to be deleted from the Database in case your data is used for direct marketing. The applicant is entitled to appeal any rejection on account of the Company, in accordance with applicable regulations. Any request as aforesaid should be addressed to: contact@sunsay.com. Prior to responding to your requests, we may verify your identity by matching any identifying information you provide against the information we have about you.
Please note that these rights are not absolute, and may be subject to the relevant applicable laws, our own legitimate interests and regulatory requirements.
8. Transfer of Personal Data
Please note that we, as well as our trusted partners and service providers, may be located around the world. Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Policy, including in countries that may not provide the same level of data protection as the country where you reside. In such cases, we will ensure that applicable safeguards and legal mechanisms are used to ensure that the transfer is aligned with the applicable data protection laws.
9. Minors
Our Services are intended solely for users who are at least sixteen (16) years of age, where permitted by applicable law. If you are under eighteen (18), you must have your parent or legal guardian’s permission to use the Services. In specific jurisdictions, we may, at our sole discretion, require parental or legal guardian consent or implement other measures or requirements to ensure compliance with applicable laws and regulations regarding consent or age restrictions.
Under no circumstances are users under the age of sixteen (16) permitted to use the Services. Any registration, use, or access to the Services by anyone under the age of sixteen (16) is unauthorized and constitutes a violation of our Terms of Use. We reserve the right to request proof of age or parental/legal guardian consent at any time. We may suspend or block access to the Services if we suspect that a user does not meet the applicable age requirements.
If we learn that we have inadvertently collected Personal Data from a person under sixteen (16), we will deactivate the account and delete that information as quickly as possible. If you believe that we might have any such information, please contact us.
10. Retention
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
11. Third parties
Our Services may be provided, in whole or in part, in conjunction with third-party services, technologies, or platforms that are not operated or controlled by us. Such third parties may collect and process Personal Data in accordance with their own privacy policies and practices. We do not control, and are not responsible for, the privacy practices of such third parties, and we encourage you to review the applicable privacy policies of any third-party services with which you interact.
12. Updates to this Policy
We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the "Last Modified" heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
13. Controlling version
This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.
14. Contact us
If you have any further questions, please contact us by email at: contact@sunsay.com.
Address: 850 New Burton Road, Suite 201, Dover, Kent County, Delaware 19904, United States.