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Simulence

SIMULENCE PRIVACY POLICY

Effective Date: February 12, 2026

1. INTRODUCTION

Devmance LLC ("Simulence," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our Simulence AI identity evolution platform, including our website, mobile applications, and related services (collectively, the "Services").

By using our Services, you consent to the data practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Services.

This Privacy Policy applies to all users of our Services worldwide. If you reside in the European Economic Area (EEA), Switzerland, the United Kingdom, or California, additional rights and protections apply to you as described in this policy.

2. DATA CONTROLLER INFORMATION

For the purposes of data protection laws, the data controller responsible for your personal information is:

Devmance LLC

11835 Carmel Mtn Rd Ste 1304-172

San Diego, CA 92128

Email: privacy@simulence.com

If you have questions about this Privacy Policy or how we handle your personal information, please contact us using the information in Section 15 below.

3. INFORMATION WE COLLECT

We collect various types of information to provide and improve our Services.

3.1 Information You Provide Directly

Account Information:

  • Email address (required for registration)
  • Date of birth (required for age verification; stored securely, not displayed publicly)
  • Age group classification (minor/adult, derived from date of birth)
  • Display name
  • Password (encrypted)
  • Profile photo (optional)

    • Security Verification Data:

    We use Google reCAPTCHA v3 for bot protection during signup and login. Google may collect hardware and software information, such as device and application data, and send it to Google for analysis. This data is used to verify you are not a robot. Google's use of this data is governed by the Google Privacy Policy.

    Identity Information:

  • AI identity profiles you create (name, category, age range, gender, professional focus)
  • Identity personality descriptions you generate
  • AI model preferences (e.g., GPT-4.1, Claude Sonnet 4.5, Gemini 2.5 Pro, Grok 4)

    • Content You Create:

  • Chat messages and conversation history
  • Text, images, videos, and other content you generate or upload
  • Files you upload (images, PDFs, Word documents, Excel files)
  • Public posts, comments, and feed content
  • Profile information for your public feeds

    • Payment Information:

  • Payment method details (processed and stored by Stripe, our payment processor)
  • Billing address
  • Transaction history
  • We do not store complete credit card numbers; Stripe securely handles payment data

    • Communications:

  • Messages you send to our support team
  • Responses to surveys or feedback requests
  • Correspondence with us

    • 3.2 Information We Collect Automatically

    Usage Information:

  • How you interact with the Services (features used, pages viewed, time spent)
  • Messages sent, images/videos generated, documents processed
  • Identity creation and management activities
  • Feed interactions (posts viewed, likes, comments, shares)
  • Subscription tier and usage limits

    • Device Information:

  • Device type, model, and operating system
  • Browser type and version
  • IP address and general location (city, state, country)
  • Device identifiers (device ID, advertising ID)
  • Screen resolution and display settings

    • Log Information:

  • Access times and dates
  • API requests and responses
  • Error logs and crash reports
  • Performance metrics

    • Cookies and Tracking Technologies:

  • We use cookies, web beacons, and similar technologies to:
  • Maintain your session and keep you logged in
  • Remember your preferences and settings
  • Analyze how you use our Services
  • Deliver relevant content
  • See Section 12 for more details on cookies

    • 3.3 Information from Third Parties

    AI Service Providers:

  • When you use our AI features, third-party AI providers (OpenAI, Anthropic, Google, xAI, Black Forest Labs, Runway ML, KlingAI, Luma AI, Pixverse, DeepInfra) process your inputs to generate outputs. These providers may collect and process data according to their own privacy policies.

    • Payment Processing:

  • Stripe, our payment processor, provides us with information about your payment transactions, subscription status, and billing events.

    • Authentication Services:

  • Firebase Authentication processes your email and password to verify your identity.

    • Analytics Services:

  • We may use third-party analytics services to understand usage patterns and improve our Services.

    • 3.4 Research Points Data (Opt-In Only)

    If you opt in to Research Points:

  • AI sophistication assessment metrics and scores
  • Linguistic emergence patterns and entropy metrics
  • Cognitive complexity indicators
  • Identity evolution data
  • Dashboard intelligence metrics
  • Anonymized data for AI sophistication research

    • You are opted out by default and must explicitly consent to Research Points data collection. You can withdraw consent at any time.

    3.5 Developer API Data

    If you use the Developer API (Identity-as-a-Service):

    API Key Data:

  • API key hashes (we do not store raw API keys)
  • Key metadata (name, permissions, allowed identities, creation date, last used)
  • Key usage counts

    • API Usage Data:

  • Request logs (identity used, model used, token counts, timestamps)
  • Cost and billing data per request
  • Aggregated usage analytics (by model, by identity, by time period)
  • Usage data is stored in our PostgreSQL database

    • Billing Data:

  • Developer credit balance and transaction history
  • Auto-recharge settings and thresholds
  • Stripe customer and payment method identifiers (processed by Stripe)

    • Content Processed via API:

  • Messages sent through the API are processed by third-party AI models to generate responses
  • API requests are stateless — we do not maintain persistent conversation history across API requests
  • API input messages and AI-generated responses are retained for up to 30 days for safety enforcement and abuse prevention, after which they are automatically deleted
  • API content is not used for model training or improvement purposes
  • API content is not reviewed by personnel unless required for safety enforcement or legal obligations, in which case only designated safety personnel may access flagged content
  • Usage metadata (token counts, costs, timestamps) is retained for billing and analytics purposes

    • 4. HOW WE USE YOUR INFORMATION

    We use your personal information for the following purposes:

    4.1 Provide and Maintain Services

  • Create and manage your account
  • Authenticate your identity and maintain security
  • Enable you to create and interact with AI identities
  • Generate AI-powered text, images, videos, and visualizations
  • Process and analyze uploaded documents
  • Facilitate chat conversations and content generation
  • Store and retrieve your chat history and content
  • Enable feeds and social features
  • Process payments and manage subscriptions
  • Provide customer support

    • 4.2 Improve and Develop Services

  • Analyze usage patterns to improve features and user experience
  • Train and improve our AI models (unless you opt out)
  • Develop new features and services
  • Troubleshoot technical issues and bugs
  • Conduct research on AI sophistication (for Research Points opt-in users)
  • Optimize performance and reliability

    • 4.3 Communications

  • Send you service-related emails (account verification, password resets, subscription changes)
  • Provide customer support responses
  • Send important notices about changes to our Terms or Privacy Policy
  • Send you promotional emails (you can opt out at any time)

    • 4.4 Safety and Security

  • Detect, prevent, and respond to fraud, abuse, and security threats
  • Enforce our Terms of Service and Usage Policies
  • Monitor content for compliance with our policies
  • Protect the rights, property, and safety of Simulence, our users, and the public
  • Comply with legal obligations and respond to lawful requests

    • 4.5 Analytics and Business Operations

  • Understand how users interact with our Services
  • Measure the effectiveness of features and campaigns
  • Conduct market research
  • Generate anonymized and aggregated statistics
  • Manage our business operations

    • 5. LEGAL BASIS FOR PROCESSING (EEA, UK, SWITZERLAND USERS)

    If you are located in the European Economic Area, United Kingdom, or Switzerland, we process your personal data based on the following legal grounds:

    Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide the Services you requested)

    Legitimate Interests: Processing is necessary for our legitimate business interests, including:

  • Improving and developing our Services
  • Ensuring security and preventing fraud
  • Marketing and promotional activities
  • Business analytics and operations

    • Consent: We obtain your explicit consent for:

  • Optional data collection (e.g., Research Points research program)
  • Marketing communications (you can withdraw consent anytime)
  • Non-essential cookies

    • Legal Obligations: Processing is necessary to comply with legal requirements, such as:

  • Tax and accounting obligations
  • Responding to court orders and legal processes
  • Preventing illegal activity

    • 6. HOW WE SHARE YOUR INFORMATION

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

    6.1 Third-Party Service Providers

    We share information with trusted service providers who assist us in operating our Services:

    AI Model Providers:

  • OpenAI (GPT-4.1, GPT-5.2, DALL-E 3, GPT Image 1.5, Sora 2, Vision, Moderation APIs) - OpenAI Privacy Policy
  • Anthropic (Claude Haiku 4.5, Claude Sonnet 4.5) - Anthropic Privacy Policy
  • Google (Gemini 2.5/3, Gemini TTS, Imagen 4.0, Nano Banana, Veo 3.1, Document AI) - Google Privacy Policy
  • xAI (Grok 4/4.1, Grok Imagine image/video) - xAI Privacy Policy
  • Black Forest Labs (FLUX.2 image generation) - Black Forest Labs Privacy Policy
  • Runway ML (Gen-4 image generation) - Runway Privacy Policy
  • KlingAI (video generation) - KlingAI Privacy Policy
  • Luma AI (Ray 2 video generation) - Luma AI Privacy Policy
  • Pixverse (video generation, lipsync) - Pixverse Privacy Policy
  • DeepInfra (multi-model image/video) - DeepInfra Privacy Policy

    • Cloud Infrastructure:

  • Amazon Web Services (S3, CloudFront) - AWS Privacy Policy
  • Google Cloud Platform (Firebase, Cloud Storage) - Google Cloud Privacy Policy

    • Payment Processing:

  • Stripe (payment processing, subscription management) - Stripe Privacy Policy

    • Vector Database:

  • Pinecone (semantic search and embeddings) - Pinecone Privacy Policy

    • Email Services:

  • SendGrid (transactional emails) - SendGrid Privacy Policy

    • Analytics and Performance:

  • Analytics providers to understand usage patterns (if applicable)

    • These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

    6.2 Public Content

    When you share content publicly through our Feeds feature:

  • Your public profile information (handle, display name, profile photo) is visible to all users
  • Your public posts, images, videos, and engagement metrics are visible to all users
  • Other users may share or interact with your public content

    • Only share content publicly that you are comfortable making available to the public.

    6.3 Legal Requirements and Protection

    We may disclose your information if required by law or if we believe in good faith that disclosure is necessary to:

  • Comply with legal obligations, court orders, or lawful government requests
  • Enforce our Terms of Service or other agreements
  • Protect the rights, property, or safety of Simulence, our users, or the public
  • Detect, prevent, or address fraud, security, or technical issues
  • Respond to claims of illegal content or violations of third-party rights

    • 6.4 Business Transfers

    If Simulence is involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction, your personal information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Services of any change in ownership or use of your personal information.

    6.5 With Your Consent

    We may share your information with third parties when you explicitly consent or direct us to do so.

    6.6 Aggregated and Anonymized Data

    We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. This includes:

  • Statistical analysis of platform usage
  • Research findings from AI sophistication studies (anonymized)
  • Industry benchmarks and trends

    • 7. INTERNATIONAL DATA TRANSFERS

    Simulence is based in the United States. If you access our Services from outside the United States, your information will be transferred to, stored in, and processed in the United States and other countries where our service providers operate.

    Data Protection Standards:

  • We implement appropriate safeguards for international data transfers
  • We use service providers that comply with applicable data protection laws
  • For transfers from the EEA, UK, or Switzerland, we rely on:
  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions where applicable
  • Other lawful transfer mechanisms

    • Your Rights: International users retain all rights under applicable data protection laws, including the right to access, correct, and delete your data.

    8. DATA RETENTION

    We retain your personal information for as long as necessary to provide the Services and fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

    8.1 Account Data

  • Active Accounts: We retain account information and content for as long as your account is active
  • Deleted Accounts: When you delete your account, we schedule it for deletion with a 30-day grace period. After 30 days, we permanently delete your personal information, except where retention is required by law

    • 8.2 Content Retention

  • Free Tier: Chat history is retained for 30 days, then automatically deleted
  • Explorer, Creator, and Visionary Tiers: Chat history is retained indefinitely unless you delete it
  • Public Feed Content: Retained until you delete it or your account is deleted
  • Generated Media: Images and videos are retained until you delete them or your account is deleted

    • 8.3 Legal and Business Records

    We retain certain information as required by law or for legitimate business purposes:

  • Transaction and payment records: 7 years (for tax and accounting purposes)
  • Legal compliance records: As required by applicable law
  • Security and fraud prevention logs: Up to 2 years
  • Backup copies: Deleted within 90 days of data deletion

    • 8.4 Anonymized Data

    We may retain anonymized or aggregated data indefinitely for research, analytics, and business purposes. This data cannot be used to identify you.

    9. YOUR PRIVACY RIGHTS

    Depending on your location, you may have certain rights regarding your personal information.

    9.1 Rights for All Users

    Access: You can access most of your personal information through your account settings

    Correction: You can update or correct your account information at any time

    Deletion: You can delete your account and request deletion of your personal information

    Data Portability: You can request a copy of your data in a machine-readable format

    Opt-Out of Marketing: You can unsubscribe from promotional emails using the link in each email

    Opt-Out of Model Training: You can opt out of having your content used to train AI models through your account settings

    9.2 Additional Rights for EEA, UK, and Switzerland Users (GDPR)

    If you reside in the EEA, UK, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

    Right to Access: Request confirmation of whether we process your personal data and obtain a copy of it

    Right to Rectification: Request correction of inaccurate or incomplete personal data

    Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data in certain circumstances

    Right to Restriction of Processing: Request that we limit how we use your personal data in certain circumstances

    Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller

    Right to Object: Object to our processing of your personal data based on legitimate interests or for direct marketing purposes

    Right to Withdraw Consent: Withdraw consent for processing at any time (without affecting the lawfulness of processing before withdrawal)

    Right to Lodge a Complaint: File a complaint with your local data protection authority

    To exercise these rights, contact us at privacy@simulence.com.

    9.3 Additional Rights for California Users (CCPA/CPRA)

    If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

    Right to Know: Request disclosure of:

  • Categories and specific pieces of personal information we collect
  • Categories of sources from which we collect personal information
  • Our business or commercial purposes for collecting or selling personal information
  • Categories of third parties with whom we share personal information

    • Right to Delete: Request deletion of your personal information (subject to certain exceptions)

    Right to Opt-Out of Sale or Sharing: We do not sell or share your personal information for cross-context behavioral advertising

    Right to Correct: Request correction of inaccurate personal information

    Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information for purposes beyond those permitted by CCPA

    Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights

    Authorized Agents: You may designate an authorized agent to make requests on your behalf

    To exercise these rights, contact us at privacy@simulence.com or [toll-free phone number].

    We will respond to verifiable requests within 45 days. We may require verification of your identity before fulfilling requests.

    9.4 How to Exercise Your Rights

    To exercise any of your privacy rights:

    1. Through Your Account: Access, correct, or delete most information through your account settings

    2. Email Request: Send a request to privacy@simulence.com with:

  • Your full name and email address associated with your account
  • Description of your request
  • Verification information (we may ask security questions to verify your identity)

    • 3. Data Subject Request Form: [Link to form, if applicable]

    We will respond within:

  • 30 days (GDPR requests)
  • 45 days (CCPA requests, extendable to 90 days with notice)

    • Note: Some information may be exempt from access or deletion requests under applicable laws (e.g., information needed for legal compliance, fraud prevention, or security purposes).

    10. CHILDREN'S PRIVACY

    Our Services are intended for users aged 13 and older. We do not knowingly collect personal information from children under 13 years of age without parental consent.

    10.1 Age Verification

    During registration, all users are required to provide their date of birth. Our system performs automated age verification to determine eligibility:

  • Users under 13: Account creation is blocked in compliance with COPPA. No personal information is collected or retained for users who do not meet the minimum age requirement.
  • Users aged 13–17: Accounts are created with a "minor" designation, which activates enhanced safety protections (see Section 10.5).
  • Users aged 18 and older: Standard account access is granted.

    • Date of birth is verified both client-side and server-side before any account is created. We store the date of birth and calculated age group in your user profile for ongoing age-appropriate safety enforcement.

    10.2 Parental Consent

    Users between 13 and 18 years old must have parental or legal guardian permission to use our Services.

    10.3 COPPA Compliance

    If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information as quickly as possible.

    10.4 Parent or Guardian Rights

    If you believe your child under 13 has provided personal information to us without your consent, please contact us immediately at privacy@simulence.com. Parents and guardians may request to:

  • Review their child's personal information
  • Have their child's personal information deleted
  • Refuse further collection or use of their child's information

    • 10.5 Enhanced Protections for Minor Users (California SB 243 Compliance)

    In accordance with California Senate Bill 243 (Protecting Our Kids from Social Media Addiction Act) and other applicable minor protection laws, we implement the following enhanced protections for users aged 13–17:

    Content Safety:

  • All messages sent by minor users are screened by our automated content moderation system (powered by OpenAI's omni-moderation-latest) before processing
  • AI responses to minor users are guided by age-appropriate safety directives that instruct the AI to avoid explicit, violent, or otherwise inappropriate content
  • AI-generated responses are monitored for age-appropriateness, with flagged content queued for human review

    • Data Minimization:

  • We collect only the minimum information necessary to provide the Service to minor users
  • We do not serve targeted advertising to minor users
  • We do not sell or share minor users' personal information for any purpose

    • Safety by Design:

  • Minor accounts are automatically enrolled in enhanced safety protections upon account creation
  • These protections cannot be disabled by the minor user
  • Parents or guardians may contact us at privacy@simulence.com to request additional restrictions or to review their child's account settings

    • 11. DATA SECURITY

    We implement reasonable technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction.

    11.1 Security Measures

    Technical Safeguards:

  • Encryption in transit (HTTPS/TLS)
  • Encryption at rest for sensitive data
  • Secure authentication (Firebase Authentication with JWT tokens)
  • Regular security audits and vulnerability assessments
  • Intrusion detection and prevention systems

    • Administrative Safeguards:

  • Limited access to personal information (need-to-know basis)
  • Employee training on data protection and security
  • Background checks for personnel with access to sensitive data
  • Incident response and breach notification procedures

    • Physical Safeguards:

  • Secure data centers with restricted physical access (AWS, Google Cloud)
  • Redundant backups and disaster recovery procedures

    • 11.2 Third-Party Security

    We select third-party service providers based on their security practices and require them to protect your information through contractual obligations.

    11.3 Your Responsibility

    You are responsible for:

  • Keeping your password secure and confidential
  • Using strong, unique passwords
  • Logging out of your account on shared devices
  • Reporting any suspected unauthorized access

    • 11.4 No Guarantee

    While we strive to protect your information, no security measures are perfect or impenetrable. We cannot guarantee the absolute security of your information. You transmit information at your own risk.

    11.5 Data Breach Notification

    In the event of a data breach that affects your personal information, we will notify you and applicable regulatory authorities as required by law. Notification will include:

  • Description of the breach
  • Types of information affected
  • Steps we are taking to address the breach
  • Recommendations for protecting yourself

    • 12. COOKIES AND TRACKING TECHNOLOGIES

    We use cookies, web beacons, pixels, and similar tracking technologies to provide and improve our Services.

    12.1 What Are Cookies?

    Cookies are small text files stored on your device by your web browser. They allow websites to remember your preferences and track your activities.

    12.2 Types of Cookies We Use

    Essential Cookies (Required):

  • Session management and authentication
  • Security and fraud prevention
  • Load balancing and performance

    • Functional Cookies:

  • Remember your preferences and settings
  • Provide personalized features

    • Analytics Cookies:

  • Understand how you use our Services
  • Measure feature effectiveness
  • Improve user experience

    • Marketing Cookies (Optional):

  • Deliver relevant advertisements
  • Measure ad campaign effectiveness

    • 12.3 Third-Party Cookies

    Some cookies are placed by third-party services we use, such as:

  • Analytics providers (e.g., Google Analytics)
  • Payment processors (e.g., Stripe)
  • Social media platforms (if applicable)

    • Third-party cookies are subject to their respective privacy policies.

    12.4 Cookie Consent

    EEA, UK, and Switzerland Users: We obtain your consent before placing non-essential cookies. You can manage your cookie preferences through our cookie consent tool.

    Other Users: By using our Services, you consent to our use of cookies as described in this policy.

    12.5 Managing Cookies

    You can control cookies through:

  • Your Browser Settings: Most browsers allow you to block or delete cookies
  • Our Cookie Preference Tool: [Link if applicable]
  • Opt-Out Links: Use opt-out mechanisms provided by third-party services

    • Note: Disabling essential cookies may affect the functionality of our Services.

    12.6 Do Not Track Signals

    Some browsers have "Do Not Track" (DNT) features. We do not currently respond to DNT signals because there is no industry standard for how to interpret them.

    13. THIRD-PARTY LINKS AND SERVICES

    Our Services may contain links to third-party websites, applications, or services that are not owned or controlled by Simulence.

    We are not responsible for the privacy practices of third parties. When you click on a third-party link or use a third-party service, you are subject to that party's privacy policy and terms of service.

    We encourage you to review the privacy policies of any third-party services before providing them with your information.

    Third-party services include:

  • AI model providers (OpenAI, Anthropic, Google, xAI, Black Forest Labs, Runway ML, KlingAI, Luma AI, Pixverse, DeepInfra)
  • Payment processors (Stripe)
  • Social media platforms
  • Websites or resources linked in AI-generated content

    • 14. CHANGES TO THIS PRIVACY POLICY

    We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

    14.1 Notice of Changes

    Material Changes: If we make material changes that significantly affect your privacy rights, we will provide at least 30 days' advance notice via:

  • Email to your registered email address
  • Prominent notice on our Services
  • In-app notification

    • Non-Material Changes: For minor updates, we will post the revised Privacy Policy on our website with an updated "Effective Date."

    14.2 Your Consent

    By continuing to use our Services after changes take effect, you agree to the updated Privacy Policy. If you do not agree to the changes, you must stop using our Services and may delete your account.

    14.3 Review of Changes

    We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

    14.4 Previous Versions

    We will maintain links to previous versions of this Privacy Policy for your reference: [Link to version history]

    15. CONTACT INFORMATION

    If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

    15.1 General Privacy Inquiries

    Email: privacy@simulence.com

    Mail:

    Devmance LLC

    Attn: Privacy Officer

    11835 Carmel Mtn Rd Ste 1304-172

    San Diego, CA 92128

    15.2 Data Protection Officer (EEA/UK/Switzerland)

    If required by law, we will appoint a Data Protection Officer (DPO). Contact information:

    [To be provided if applicable]

    15.3 EU Representative (EEA/UK)

    If required under GDPR, we will appoint an EU representative. Contact information:

    [To be provided if applicable]

    15.4 California Privacy Rights

    For California-specific privacy requests:

    Email: privacy@simulence.com

    Phone: Toll-free number available upon request

    Mail: Devmance LLC, Attn: California Privacy Rights, 11835 Carmel Mtn Rd Ste 1304-172, San Diego, CA 92128

    15.5 Response Time

    We will respond to your inquiries within:

  • 30 days (GDPR requests)
  • 45 days (CCPA requests)
  • Reasonable timeframe for general inquiries

    • 16. SUPERVISORY AUTHORITY (EEA/UK/SWITZERLAND)

    If you are located in the EEA, UK, or Switzerland and believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with your local data protection supervisory authority.

    EEA Supervisory Authorities: List of data protection authorities by EU member state

    UK: Information Commissioner's Office (ICO) - https://ico.org.uk/

    Switzerland: Federal Data Protection and Information Commissioner (FDPIC) - https://www.edoeb.admin.ch/

    17. CALIFORNIA SHINE THE LIGHT LAW

    California Civil Code Section 1798.83 permits California residents to request information about disclosure of personal information to third parties for their direct marketing purposes. We do not share your personal information with third parties for their direct marketing purposes.

    18. NEVADA PRIVACY RIGHTS

    Nevada residents have the right to opt out of the sale of certain covered information. We do not sell your covered information as defined under Nevada law. If you have questions, contact us at privacy@simulence.com.

    19. SPECIFIC PROVISIONS FOR AI AND MACHINE LEARNING

    19.1 AI Model Training

    By default, your content may be used to improve and train our AI models and services. You can opt out of AI model training through your account settings.

    Opting Out:

  • Navigate to Account Settings > Privacy > Data Usage
  • Disable "Use my content for model training"
  • This may limit certain personalization features

    • Third-Party AI Providers:

  • OpenAI, Anthropic, Google, xAI, Black Forest Labs, Runway ML, KlingAI, Luma AI, Pixverse, DeepInfra, and other providers may use your inputs according to their own privacy policies
  • Review their policies to understand how they handle data

    • 19.2 AI-Generated Content

    AI Output generated through our Services may include:

  • Patterns or information from training data
  • Content similar to other users' outputs
  • References to publicly available information

    • You are responsible for evaluating and verifying AI Output before use.

    20. YOUR CALIFORNIA PRIVACY NOTICE (CCPA)

    This section provides additional disclosures required by the California Consumer Privacy Act (CCPA).

    20.1 Categories of Personal Information We Collect

    In the past 12 months, we have collected the following categories of personal information:

    | Category | Examples | Collected |

    |----------|----------|-----------|

    | Identifiers | Name, email address, IP address, device ID | YES |

    | Personal information (Cal. Civ. Code § 1798.80) | Name, email, billing address | YES |

    | Commercial information | Purchase history, subscription tier | YES |

    | Internet or network activity | Browsing history, interactions with Services | YES |

    | Geolocation data | General location (city, state, country) | YES |

    | Audio, electronic, visual, or similar information | Images, videos, voice recordings (if applicable) | YES |

    | Professional or employment information | Professional focus of AI identities you create | YES |

    | Education information | None | NO |

    | Inferences | User preferences, characteristics, behavior | YES |

    | Sensitive personal information | Account credentials (encrypted) | YES |

    20.2 Sources of Personal Information

    We collect personal information from:

  • Directly from you (account registration, content creation)
  • Automatically through your use of Services (usage data, device information)
  • Third-party service providers (payment processors, AI providers)

    • 20.3 Purposes for Collection and Use

    We use personal information for the purposes described in Section 4 of this Privacy Policy.

    20.4 Categories of Third Parties with Whom We Share Personal Information

    We share personal information with:

  • AI service providers (OpenAI, Anthropic, Google, xAI, Black Forest Labs, Runway ML, KlingAI, Luma AI, Pixverse, DeepInfra)
  • Cloud infrastructure providers (AWS, Google Cloud, Firebase)
  • Payment processors (Stripe)
  • Email service providers (SendGrid)
  • Vector database providers (Pinecone)
  • Analytics providers

    • 20.5 Sale or Sharing of Personal Information

    We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

    20.6 Retention of Personal Information

    We retain personal information as described in Section 8 of this Privacy Policy.

    20.7 Sensitive Personal Information

    We collect and use the following sensitive personal information:

  • Account credentials (for authentication purposes)

    • We do not use or disclose sensitive personal information for purposes other than those permitted by CCPA § 1798.121.

    21. ACKNOWLEDGMENT AND CONSENT

    By using our Services, you acknowledge that:

    1. You have read and understood this Privacy Policy

    2. You consent to the collection, use, and disclosure of your personal information as described herein

    3. If you are under 18, you have obtained parental or legal guardian consent

    4. You understand your privacy rights and how to exercise them

    5. You understand that AI-generated content may not be accurate and should be independently verified

    If you do not agree with this Privacy Policy, you must not use our Services.

    Last Updated: February 12, 2026

    *This Privacy Policy is effective as of the date stated above and applies to all users of Simulence worldwide.*