Privacy Policy

1. Introduction

This Privacy Policy explains how GIRLS IN SYNC LTD ("we", "us", "our"), Company Number 15920644, registered at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, also operating through Motosurfing s.r.o. (IČO: 53680375, Bratislava, Slovak Republic), collects, uses, and protects your personal data when you use the Girls in Sync platform.

We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data Controller

The data controller for your personal data is:
GIRLS IN SYNC LTD
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Also operating through:
Motosurfing s.r.o. — IČO: 53680375
M. Schneidra Trnavského 3606/2E, 841 01 Bratislava, Slovak Republic

Email: [email protected]

3. Data We Collect

We collect the following categories of personal data:

Account Data

• Telegram user ID and display name (when logging in via Telegram)
• Email address (when logging in via email OTP)
• Age confirmation status

Usage Data

• Chat messages sent to AI companions
• AI-generated content viewed and purchased
• Platform activity (pages visited, features used)
• Session data (last active date, session count)

Payment Data

• Transaction records (amount, currency, payment method, date)
• We do not store credit card numbers — payments are processed by third-party providers

Analytics Data

• Device type, browser type, operating system
• General location (country level, derived from language/currency settings)
• Platform interaction events (anonymized)

4. How We Use Your Data

We use your personal data for the following purposes:

• Provide the Service: Authenticate your account, enable chat with AI companions, deliver purchased content
• Process Payments: Handle credit purchases, subscriptions, and transaction records
• Improve the Platform: Analyze usage patterns to improve features and user experience
• Safety & Moderation: Monitor for prohibited content and enforce our Terms of Use
• Communication: Send service notifications, updates, and re-engagement messages via Telegram

5. Legal Basis for Processing

We process your data based on:

• Contract: Processing necessary to provide the Service you have requested
• Legitimate Interest: Analytics and platform improvement, fraud prevention, safety moderation
• Consent: Marketing communications and non-essential cookies (where applicable)
• Legal Obligation: Compliance with applicable laws, responding to legal requests

6. Data Sharing

We may share your data with:

• Payment Processors: To process your transactions (they receive only the data necessary for payment)
• AI Service Providers: Chat prompts are sent to AI providers for response generation — no personal identifying information is shared with AI providers
• Analytics Providers: Anonymized usage data for platform analytics (PostHog)
• Law Enforcement: When required by law or to protect the safety of our users

We do not sell your personal data to third parties.

7. Data Retention

We retain your data for the following periods:

• Account Data: For the duration of your account, plus 30 days after deletion
• Chat History: For the duration of your account, plus 30 days after deletion
• Payment Records: 7 years (as required by UK financial regulations)
• Content Reports: 2 years for compliance and audit purposes
• Analytics Data: 24 months (anonymized/aggregated)

8. Your Rights (GDPR)

Under the UK GDPR, you have the following rights:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate personal data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing: Request limitation of how we process your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time

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

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including encryption in transit (TLS/SSL), access controls, and secure data storage. However, no method of transmission over the Internet is 100% secure.

10. International Transfers

Your data may be processed by AI service providers located outside the UK/EEA. Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs), to protect your data in accordance with UK GDPR requirements.

11. Cookies

We use essential cookies for authentication and session management. We use analytics cookies (PostHog) to understand how users interact with the Platform. You can manage cookie preferences through your browser settings.

12. Children's Privacy

Girls in Sync is intended for users aged 18 and above. We do not knowingly collect personal data from individuals under 18. If we become aware that we have collected data from a minor, we will promptly delete the account and associated data.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via the Platform. The "Last updated" date at the top of this page indicates when the policy was last revised.

14. Complaints

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office
Website: ico.org.uk
Phone: 0303 123 1113

15. Contact

GIRLS IN SYNC LTD — Company No. 15920644
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

Also operating through:
Motosurfing s.r.o. — IČO: 53680375
M. Schneidra Trnavského 3606/2E, 841 01 Bratislava, Slovak Republic

Email: [email protected]
General support: [email protected]