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SIMULENCE PRIVACY POLICY

Effective Date: March 31, 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 platform, which includes the following applications and services (collectively, the "Services"):

  • Simulence Web App — the web application at app.simulence.ai
  • Simulence iOS App — the native iOS application available on the Apple App Store
  • Simulence Android App — the Android application available on Google Play
  • Creatid iOS App (formerly Identity Feeds) — the native iOS application available on the Apple App Store
  • Creatid Android App — the native Android application available on Google Play
  • Creatid Web — the web-based feeds experience at app.simulence.ai/feeds
  • Simulence Developer API — the Identity Infrastructure REST API
  • All related websites, online services, and features provided by Devmance LLC
  • Shared Platform: The Simulence and Creatid applications share common infrastructure and a unified user account system. Creating an account on any Service creates a single Simulence account. Data described in this Privacy Policy may be collected and shared across all Services. For example, content you create in the Creatid app is stored in the same systems and accessible through the Simulence web app, and vice versa.

    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.ai

    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)
  • Display name
  • Password (encrypted)
  • Profile photo (optional)
  • Social Sign-In Data:

    When you sign in using Apple Sign-In or Google Sign-In, we receive:

  • Your name (as provided by Apple or Google)
  • Your email address (Apple may provide a private relay email address)
  • A unique user identifier from Apple or Google
  • Authentication tokens for session management
  • We do not receive or store your Apple ID password or Google account password. Social sign-in is subject to Apple's Privacy Policy and/or Google's Privacy Policy.

    Security Verification Data:

    On our web application, 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 (the third-party AI models you choose to use)
  • 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
  • Self-concept session prompts and AI-generated post content (including text, image prompts, video prompts, and hashtags)
  • Visual evolution prompts, scene selections, and reference images you provide
  • Identity creation inputs (category, attributes, descriptions) and the content we generate for your AI identities
  • Draft posts (stored locally on your device and/or on our servers)
  • Mirror Identity Data (Mirror Feature):

  • When you create a Mirror identity, you provide a selfie photo or short intro video of yourself, and written or spoken answers about yourself
  • To generate your Mirror, we process this media (the facial and vocal characteristics it contains) together with your answers. We do not create or store a faceprint, voiceprint, iris or fingerprint scan, or any face- or voice-geometry template; we do not use facial recognition; and we do not use your selfie, video, or voice to identify, authenticate, or match you against any other person or database — it is used only to generate your Mirror's reading and portrait
  • To the extent the law in your jurisdiction would treat this information as biometric data, we process it solely to provide the Mirror you requested, with your consent
  • Explorer tier and above may optionally provide social media handles; where provided, we gather publicly available text associated with those handles for use in the analysis
  • This media is sent to a third-party AI provider (Google) for a one-time analysis that we use to generate your Mirror identity and its content (see Section 8.2 for what is deleted and retained)
  • You may submit a Mirror only of yourself; you must not submit another person's likeness or voice
  • 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 (web applications)
  • IP address and general location (city, state, country)
  • Device identifiers (device ID, advertising ID)
  • Screen resolution and display settings
  • Mobile-Specific Information (iOS and Android apps):

  • Push notification tokens (Firebase Cloud Messaging and Apple Push Notification service) for delivering notifications
  • Camera and photo library access data (when you grant permission to capture or select images for AI processing, profile photos, or content creation)
  • Microphone audio (when you grant permission; used for voice-to-text input so you can speak messages to identities — captured audio is processed for transcription and is not retained as a standalone recording)
  • Speech recognition data (when you grant permission; on-device speech recognition is used to transcribe your voice into text)
  • Documents folder access (when you grant permission; used to save AI-generated content and exports so you can access them outside the app)
  • Locally cached data including authentication tokens, draft posts, and image cache (up to 200 MB)
  • Keychain-stored credentials (iOS) and SharedPreferences data (Android)
  • App usage state (foreground/background status, session duration)
  • Location data (when you grant permission; used for contextual AI responses and local search in the Simulence iOS app)
  • You can grant or revoke any of these permissions at any time through your device's Settings app. Revoking permission disables only the related feature; it does not delete data already stored.

    Log Information:

  • Access times and dates
  • API requests and responses
  • Error logs and crash reports
  • Performance metrics
  • Cookies and Tracking Technologies:

  • On our web applications, 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
  • Our mobile applications use local storage mechanisms (UserDefaults, Keychain, SharedPreferences) for similar purposes
  • See Section 12 for more details on cookies and mobile tracking
  • 3.3 Information from Third Parties

    AI Service Providers:

  • When you use our AI features, third-party AI providers process your inputs to generate outputs. These providers may collect and process data according to their own privacy policies. The current list of these providers, with links to their privacy policies, is set out in Section 6.1.
  • Payment Processing:

  • Stripe, our web payment processor, provides us with information about your payment transactions, subscription status, and billing events.
  • Apple (for App Store in-app purchases) provides us with transaction receipts, subscription status, and billing events via App Store Server Notifications.
  • Google (for Google Play in-app purchases) provides us with purchase tokens, subscription status, and billing events via Google Play Developer API.
  • Authentication Services:

  • Firebase Authentication processes your email and password to verify your identity.
  • Apple Sign-In provides identity verification for iOS users who choose this sign-in method.
  • Google Sign-In provides identity verification for users who choose this sign-in method.
  • Push Notification Services:

  • Firebase Cloud Messaging (FCM) and Apple Push Notification service (APNs) deliver push notifications to your mobile device. We store your device push token to send you notifications about activity relevant to your account (e.g., comments, likes, new followers, replies). You can disable push notifications through your device settings at any time.
  • 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:

  • Behavioral and quality metrics derived from your content
  • Identity evolution data
  • Anonymized data for 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 Infrastructure):

    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 retained for billing, analytics, and abuse-prevention purposes
  • 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

  • Generate aggregated, anonymized analytics about service usage that cannot reasonably identify you
  • Develop new features and services
  • Troubleshoot technical issues you report or that we detect
  • Conduct research (only for users who have explicitly opted in to Research Points; see Section 19)
  • 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 - OpenAI Privacy Policy
  • Anthropic - Anthropic Privacy Policy
  • Google - Google Privacy Policy
  • xAI - xAI Privacy Policy
  • Meta - Meta Privacy Policy
  • Black Forest Labs (image generation) - Black Forest Labs Privacy Policy
  • Runway ML (image generation) - Runway Privacy Policy
  • KlingAI (video generation) - KlingAI Privacy Policy
  • Luma AI (video generation) - Luma AI Privacy Policy
  • Pixverse (video generation, lipsync) - Pixverse Privacy Policy
  • DeepInfra (multi-model image/video) - DeepInfra Privacy Policy
  • Provider Jurisdiction by Content Type:

    Your text prompts, chat messages, and conversational content are processed exclusively by AI providers headquartered in the United States — OpenAI, Anthropic, Google, xAI, and Meta. We deliberately restrict text content to US-headquartered providers because text conversations are the most privacy-sensitive content type on our platform.

    Image and video generation may additionally use providers headquartered outside the United States — specifically Black Forest Labs (Germany) for certain image models, and KlingAI (China) and Pixverse (China) for certain video models. These providers receive only the inputs needed to generate the requested image or video (text prompts and any reference images you provide). They do not receive your chat history, account information, or other content. Each provider processes data subject to its own privacy policy linked above.

    If you prefer not to use international image or video providers, you can simply choose models in our Image / Video Generation views that are hosted by US providers. Model selection is per-request, and the provider responsible for each model is disclosed in the model picker.

    Cloud Infrastructure:

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

  • Stripe (web payment processing, subscription management) - Stripe Privacy Policy
  • Apple (App Store in-app purchases, subscription management) - Apple Privacy Policy
  • Google (Google Play in-app purchases, subscription management) - Google Privacy Policy
  • Authentication:

  • Apple Sign-In (iOS authentication) - Apple Privacy Policy
  • Google Sign-In (cross-platform authentication) - Google Privacy Policy
  • Push Notifications:

  • Firebase Cloud Messaging / Apple Push Notification service (notification delivery) - Google Cloud Privacy Policy / Apple Privacy Policy
  • Search Infrastructure:

  • Pinecone - Pinecone Privacy Policy
  • Email Services:

  • SendGrid (transactional emails) - SendGrid Privacy Policy
  • Analytics, Advertising, and Performance (Web App Only — Subject to Cookie Consent):

  • Google Analytics (usage analytics) - Google Privacy Policy
  • Google Ads (conversion tracking and remarketing) - Google Privacy Policy
  • Meta Pixel (Facebook/Instagram conversion tracking, when enabled) - Meta Privacy Policy
  • These services are only loaded after you grant consent through our cookie preferences banner on the web application. Native iOS and Android apps do not use these web tracking technologies; instead they use Apple's App Tracking Transparency framework and Google Play's user choice framework where 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 (including through the Creatid apps):

  • Your public profile information (handle, display name, profile photo) is visible to all users across all Services
  • Your public posts, images, videos, carousels, and engagement metrics are visible to all users across all Services
  • Other users may share or interact with your public content
  • Shared identity profiles may be discoverable and adoptable by other users
  • Content you create on one Service (e.g., Creatid iOS) is accessible on all other Services (e.g., Simulence web app)
  • Only share content publicly that you are comfortable making available to the public across all of our applications.

    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 our 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 as set out in Commission Implementing Decision (EU) 2021/914 (available at https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en), and, for transfers from the United Kingdom, the UK International Data Transfer Addendum issued under section 119A of the Data Protection Act 2018
  • Adequacy decisions where applicable
  • Other lawful transfer mechanisms
  • You may request a copy of the relevant transfer mechanism (with commercially sensitive terms redacted) by contacting privacy@simulence.ai.

    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
  • Mirror Source Media: If you create a Mirror from a video, the source video is deleted promptly after the one-time analysis completes; we retain only still frames extracted from it, stored privately, to generate your identity's portrait. A source selfie image is retained as your portrait source, and selfie photos are also saved to your private uploads library (visible only to you) for reuse within the app. Social media handles you provide are not stored; only the public text gathered from them is used. The content generated for your Mirror identity is retained with your identity until you delete it or your account
  • 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

    Manage Research Participation: You can opt in or out of our Research Program through your account settings. The Research Program is the only context in which your content may be used for research and to train our own AI models; outside of that opt-in program, and for API content in all cases, we do not train AI models on your content (see Section 19).

    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.ai.

    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 CCPA/CPRA requests on your behalf. To submit a request as an authorized agent, email privacy@simulence.ai with:

    1. The full name and email address of the California resident on whose behalf the request is being made

    2. A description of the request being submitted

    3. Proof of the agent's authority to act on the resident's behalf — typically (a) a written and signed permission from the resident authorizing the agent to act, or (b) a valid power of attorney under California Probate Code §§ 4000–4465

    4. Verification of the resident's identity (we may contact the resident directly to confirm both the agent's authority and the resident's identity before fulfilling the request)

    We may deny requests where the agent cannot adequately demonstrate authority or where we cannot reasonably verify the resident's identity.

    To exercise your rights directly, contact us at privacy@simulence.ai.

    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. Download Your Data: Export a machine-readable copy of your data directly in the app, under Profile → Security → Export Your Data

    3. Email Request: Send a request to privacy@simulence.ai 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)
  • 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 solely for adults aged 18 and older. We do not knowingly collect personal information from individuals under 18.

    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 18: Account creation is blocked. The submitted date of birth is discarded immediately and no account or personal information is retained.
  • 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. Once verified, we retain the date of birth in your user profile in case we need to confirm account eligibility.

    10.2 If a Minor Creates an Account

    Users who misrepresent their age in order to create an account are in breach of our Terms of Service. If we become aware — through a user report, an internal review, or any other means — that an individual under 18 has created an account or provided personal information to us, we will suspend the account and delete the associated personal information as quickly as practicable.

    10.3 Parent or Guardian Rights

    If you believe your child under 18 has created an account or provided personal information to us, please contact us immediately at privacy@simulence.ai. We will:

  • Review the account
  • Delete the associated personal information upon confirmation
  • Terminate the account
  • We do not operate a "minors" program. We do not market to minors, and we do not offer age-differentiated features or content tiers. The Services are designed, moderated, and rated for adult use.


    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, TRACKING TECHNOLOGIES, AND MOBILE DATA STORAGE

    We use cookies, web beacons, pixels, local storage mechanisms, 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. Our mobile applications use equivalent local storage mechanisms (UserDefaults, Keychain, SharedPreferences, and local databases) for similar purposes.

    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 and Mobile SDKs

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

  • Analytics providers (e.g., Google Analytics)
  • Advertising platforms (e.g., Google Ads, Meta Pixel — only when you consent to marketing cookies)
  • Payment processors (e.g., Stripe)
  • Our mobile applications include third-party SDKs that may store data locally:

  • Firebase SDK (authentication tokens, messaging tokens, configuration data)
  • Google Sign-In SDK (authentication state)
  • StoreKit 2 / Google Play Billing (purchase and subscription state)
  • Third-party cookies and SDK data storage 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 Consent Banner: Use the banner that appears on your first visit to accept, reject, or customize cookie categories at any time
  • 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 (as listed in Section 6.1)
  • 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

    You may request a copy of an earlier version of this Privacy Policy by contacting us at privacy@simulence.ai.


    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.ai

    Mail:

    Devmance LLC

    Attn: Privacy Officer

    11835 Carmel Mtn Rd Ste 1304-172

    San Diego, CA 92128

    15.2 EEA, UK, and Switzerland Users

    If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may contact us directly at privacy@simulence.ai for any matter related to your personal data. We will respond within the timeframes set out in Section 9.

    15.3 California Privacy Rights

    For California-specific privacy requests:

    Email: privacy@simulence.ai

    Mail:

    Devmance LLC

    Attn: California Privacy Rights

    11835 Carmel Mtn Rd Ste 1304-172

    San Diego, CA 92128

    15.4 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.ai.


    19. SPECIFIC PROVISIONS FOR AI AND MACHINE LEARNING

    19.1 AI Model Training

    We do not train AI models on your content by default. The third-party AI providers we work with (such as OpenAI, Anthropic, and Google) similarly do not train on customer content by default.

    The only exception is our opt-in Research Program (described in Section 4 of our Terms of Service). The program is opt-in only and off by default. If you choose to opt in, the data you contribute — including your identities' conversation content and derived research metrics — may be used to conduct research and to train, fine-tune, and improve our own AI models, as described in those Terms. API content is never used for training, regardless of Research Program participation. You can opt out at any time through your account settings.

    Aggregated, anonymized analytics — which cannot reasonably be used to identify you — may be used to operate, secure, and improve the Services.

    Third-Party AI Providers:

  • The AI providers listed in Section 6.1 process your inputs to generate outputs subject to their own privacy policies and data-handling practices.
  • We will update this Privacy Policy if any provider changes its default policy on customer-content training.
  • 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); precise location when permitted in mobile apps | YES |

    | Audio, electronic, visual, or similar information | Images, videos, microphone audio used for voice-to-text input (transcribed and not retained as a standalone recording), camera captures, and photo library selections in mobile apps | 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, Meta, Black Forest Labs, Runway ML, KlingAI, Luma AI, Pixverse, DeepInfra)
  • Cloud infrastructure providers (AWS, Google Cloud, Firebase)
  • Payment processors (Stripe, Apple App Store, Google Play)
  • Authentication providers (Apple Sign-In, Google Sign-In, Firebase Auth)
  • Push notification services (Firebase Cloud Messaging, Apple Push Notification service)
  • Email service providers (SendGrid)
  • Search infrastructure providers (Pinecone)
  • App distribution platforms (Apple App Store, Google Play Store)
  • Web-app analytics and advertising providers (Google Analytics, Google Ads, Meta Pixel — only loaded with your cookie consent on the web application)
  • 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. You are at least 18 years old, as required by Section 10 of this Privacy Policy and our Terms of Service

    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: March 31, 2026


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