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Privacy Policy

1. Introduction

ElenaCall ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our Service.

2. Information We Collect

2.1 IP Address

We collect your IP address for the following purposes:

• Fraud prevention and abuse detection
• Enforcing free trial limits (one trial per IP per 24-hour period)
• Geographic compliance (ensuring the Service is legal in your jurisdiction)
• Aggregate analytics to improve Service performance

IP addresses are stored in encrypted form and automatically deleted after 24 hours unless fraud indicators require longer retention (maximum 90 days).

2.2 Payment Token

When you make a payment and consent to saving your card, we store a payment token — a randomized reference provided by our payment processor. This token:

• Contains no card number, CVV, or expiry date
• Cannot be used to reconstruct your card details
• Is used solely to enable one-tap recharges without re-entering card details
• Is stored in association with an anonymous session identifier, not your name or email
• Is deleted upon your request or after 12 months of inactivity

Full card data is processed exclusively by our PCI DSS-compliant payment processor and never touches our servers.

2.3 Conversation Memory

To provide a personalized experience, we may store a conversation summary linked to your anonymous session identifier (derived from your payment token). This includes:

• Preferences you have expressed during sessions (e.g., name you've given, topics discussed)
• Session duration and frequency (for billing and personalization)

We do not store full voice recordings or transcripts. Summaries are generated automatically and contain no sensitive personal identifiers. You may request deletion of your conversation memory at any time.

2.4 Technical Data

• Browser type and version
• Device type (mobile/desktop)
• Session timestamps

This data is used solely for technical performance monitoring and is retained for 30 days.

3. How We Use Your Information

• To process payments and manage billing
• To provide and personalize the Service
• To enforce fair use policies (one free trial per IP per 24h)
• To detect and prevent fraud or unauthorized access
• To comply with legal obligations
• For aggregate, anonymized analytics to improve the Service

4. Advertising and Retargeting

We may use anonymized and aggregated technical data (including hashed IP addresses) to create custom audiences on advertising platforms such as Meta and Google for the purpose of retargeting users who have previously visited the Service. This data is:

• Hashed before transmission to advertising platforms
• Never linked to payment data or conversation memory
• Subject to the privacy policies of the respective advertising platforms

You may opt out of interest-based advertising by visiting your platform preferences on Meta or Google, or by using a VPN.

5. Data Sharing

We do not sell, rent, or share your personal information with third parties, except:

• Payment processors (Segpay or equivalent) — to process transactions. They operate under their own PCI DSS compliance.
• AI voice providers (ElevenLabs) — for real-time audio processing only. No personal data is transmitted, only audio streams processed in real-time and discarded immediately.
• Advertising platforms — hashed, anonymized identifiers only, as described in Section 4.
• Law enforcement — when required by applicable law or valid legal process.

6. Data Retention

• IP addresses: 24 hours (standard) / up to 90 days (fraud investigation)
• User accounts (username, password, credits): Automatically deleted after 6 months of inactivity. Activity is defined as signing in or initiating a voice session. No prior notice is sent. Upon deletion, all associated credits and conversation memory are permanently lost and cannot be recovered.
• Payment tokens: Deleted upon account deletion, deletion request, or 6 months of inactivity — whichever comes first
• Conversation memory: Deleted upon account deletion or 6 months of inactivity
• Billing records: 7 years (legal requirement)
• Technical logs: 30 days

7. Your Rights (GDPR)

If you are located in the European Economic Area, you have the following rights:

• Access: Request a copy of the data we hold about you
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your payment token, conversation memory, and associated data
• Portability: Request your data in a machine-readable format
• Objection: Object to processing for advertising purposes
• Restriction: Request that we limit processing of your data

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

Note that accounts are automatically deleted after 6 months of inactivity — no request is necessary in this case.

8. Cookies

We use session cookies solely to remember your age verification status during your visit. We do not use tracking cookies, advertising cookies, or third-party analytics cookies on the Service itself.

9. Security

We implement industry-standard security measures including:

• TLS encryption for all data in transit
• Tokenization of payment data (no raw card data stored)
• Encrypted storage for IP addresses and session identifiers
• Strict access controls and audit logging

10. Children's Privacy

Our Service is strictly for adults aged 18 and over. We do not knowingly collect any information from individuals under 18. If we become aware that a minor has used our Service, we will immediately terminate access and delete any associated data.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the date at the top of this page.

12. Contact

For privacy-related inquiries: [email protected]