Cloud Robot LLC ("Cloud Robot," "Company," "we," "our," or "us") is committed to protecting your privacy and processing personal information in a transparent, lawful, and secure manner.
This Privacy Policy explains how we collect, use, disclose, transfer, retain, protect, and otherwise process personal information when you access or use:
• our mobile applications;
• our websites and landing pages;
• our artificial intelligence assistant;
• APIs and developer services;
• customer support services;
• Telegram-based functionality;
• and all related software, products, tools, features, and services (collectively, the "Services").
This Privacy Policy also explains:
• how we use Cookies and similar technologies;
• how artificial intelligence processes your content;
• how to exercise your privacy rights;
• how to delete your account;
• how we process information received through Telegram;
• how we transfer personal information internationally; and
• how we comply with applicable privacy legislation.
This Privacy Policy applies whenever you interact with the Services unless a separate privacy notice expressly applies.

1. Acknowledgement and Consent
By creating an account, accessing, or using the Services, you acknowledge that you have read, understood, and accepted this Privacy Policy.
Where consent constitutes the applicable legal basis for processing under applicable law, including the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – Law No. 13,709/2018 ("LGPD")), you freely, specifically, informedly, and unequivocally consent to the collection, use, storage, disclosure, transfer, sharing, and other processing of your Personal Information by the Company as described in this Privacy Policy.
This Privacy Policy constitutes the primary notice describing how the Company processes Personal Information. The purposes of processing, categories of Personal Information collected, legal bases for processing, categories of recipients, international data transfers, retention periods, data subject rights, account deletion procedures, and security measures are described in the relevant Sections of this Privacy Policy and form an integral part of your consent where consent is required by applicable law.
Where you choose to use Telegram-related functionality, certain information is processed independently by Telegram under Telegram's own Privacy Policy, Terms of Service, and other applicable policies. The Company is responsible only for Personal Information processed under its own control. Nothing in this Privacy Policy modifies or replaces Telegram's own privacy documentation.
Where consent is the applicable legal basis, you may withdraw your consent at any time using the methods described in this Privacy Policy. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal and does not affect processing based on any other legal basis available under applicable law.
Nothing in this Section limits or replaces any rights available to you under applicable privacy legislation, including the GDPR, UK GDPR, LGPD, CCPA/CPRA, or other applicable laws. Information regarding your privacy rights and the procedures for exercising them is set out in Section 11 (Your Privacy Rights) and Section 16 (Region-Specific Privacy Rights).

2. Scope of this Privacy Policy
This Privacy Policy applies to all personal information processed by the Company through the Services.
It does not apply to:
• third-party websites;
• third-party applications;
• independent payment providers;
• Telegram's own services;
• Apple;
• Google;
• or any other third party that independently determines the purposes and means of processing personal information.
Where you use Telegram-related functionality, Telegram independently processes certain information under its own Privacy Policy and Telegram API Terms of Service.
The Company is responsible only for personal information processed under its own control.

3. Information We Collect
The categories of information we collect depend on how you use the Services.
We may collect information:
• directly from you;
• automatically through your use of the Services;
• from third-party providers;
• through Telegram where you choose to use Telegram functionality; and
• through Cookies and similar technologies.
3.1 Information You Provide
You may voluntarily provide information including:
Account Information
• full name;
• username;
• email address;
• telephone number;
• password or authentication credentials;
• profile photograph;
• language preferences;
• account settings.
Subscription Information
Where applicable:
• subscription plan;
• billing information;
• payment confirmations;
• purchase history.
The Company does not store complete payment card details where payments are processed by independent payment processors.
User Content
You may submit content including:
• prompts;
• conversations;
• text;
• uploaded files;
• PDF documents;
• Word documents;
• spreadsheets;
• images;
• photographs;
• audio recordings;
• videos;
• AI instructions;
• feedback;
• support requests;
• survey responses.
You remain responsible for ensuring that you possess all necessary rights and permissions to provide any information relating to third parties.
3.2 Information Collected Automatically
When you access or use the Services, we automatically collect certain technical information.
This may include:
Device Information
• device identifiers;
• operating system;
• browser type;
• application version;
• device model;
• language settings;
• mobile carrier.
Usage Information
• features used;
• interactions with AI;
• timestamps;
• pages viewed;
• session duration;
• clickstream information;
• navigation events;
• search history within the Services;
• feature preferences.
Log Information
• IP address;
• authentication logs;
• diagnostics;
• crash reports;
• performance metrics;
• security logs;
• fraud detection signals.
Approximate Location
We may infer approximate geographic location from your IP address for purposes including:
• fraud prevention;
• localization;
• legal compliance;
• analytics.
We do not collect precise GPS location unless separately requested and authorized.
3.3 Information Received from Third Parties
We may receive personal information from:
• authentication providers;
• identity verification providers;
• payment processors;
• cloud hosting providers;
• analytics providers;
• customer support providers;
• marketing providers;
• fraud prevention services;
• business partners;
• publicly available sources.
Such information may include:
• authentication tokens;
• subscription status;
• payment confirmations;
• publicly available profile information;
• device identifiers;
• fraud indicators.
We process such information only where necessary for purposes described in this Privacy Policy.
3.4 Information Received Through Telegram
Certain functionality is made available through the Telegram API.
Where you choose to interact with the Services using Telegram, we may receive:
• Telegram User ID;
• Telegram username;
• profile information made available through Telegram;
• messages intentionally sent to the Service;
• prompts;
• uploaded files;
• images;
• voice messages;
• documents;
• technical authentication information necessary to process requests.
We collect only the information reasonably necessary to provide Telegram-related functionality.
We do not attempt to obtain information beyond permissions expressly granted by Telegram and your interactions with the Services.
Telegram independently processes personal information under its own Privacy Policy.
Deletion of your Cloud Robot account does not delete your Telegram account.
3.5 Cookies and Similar Technologies
We use Cookies and similar technologies to:
• operate the Services;
• authenticate users;
• remember preferences;
• improve functionality;
• analyze Website usage;
• maintain security;
• personalize user experience where permitted by law.
Where required by applicable law, non-essential Cookies remain disabled until you provide affirmative consent.
Further information is provided in Section 7 (Cookies and Similar Technologies).

4. How We Use Personal Information
The purposes described in this Section constitute the purposes for which the Company processes Personal Information under this Privacy Policy. Where consent constitutes the applicable legal basis for processing, your consent applies to the processing activities described in this Section.
We use personal information only where there is an appropriate legal basis and only for legitimate business purposes.
Depending upon how you use the Services, personal information may be processed to:
Provide the Services
• create user accounts;
• authenticate users;
• provide AI functionality;
• provide Telegram functionality;
• synchronize user settings;
• manage subscriptions;
• provide customer support;
• maintain account security.
Improve the Services
We continually improve the Services by:
• fixing software defects;
• improving usability;
• optimizing performance;
• improving accessibility;
• developing new functionality;
• evaluating reliability;
• monitoring system performance.
Security
Personal information may be processed to:
• prevent fraud;
• detect abuse;
• identify unauthorized access;
• investigate security incidents;
• enforce our Terms of Service;
• protect users;
• protect infrastructure.
Communications
We may communicate with users regarding:
• account activity;
• technical support;
• service announcements;
• legal notices;
• security incidents;
• privacy requests;
• account deletion requests.
Where permitted by law, we may also send newsletters, surveys, and promotional communications.
You may opt out of marketing communications at any time.
Legal Compliance
Personal information may be processed where necessary to:
• comply with applicable laws;
• respond to judicial proceedings;
• comply with governmental requests;
• establish, exercise, or defend legal claims;
• protect rights, safety, and property.
Research and Product Improvement
Subject to applicable law, anonymized or otherwise lawfully processed information may be used to:
• improve AI systems;
• improve Service performance;
• conduct testing;
• perform statistical analysis;
• improve security;
• evaluate new functionality.
Information obtained through Telegram is never used to train or improve AI models unless expressly permitted under Telegram's applicable Terms of Service and policies.

5. AI Processing and User Content
Artificial intelligence functionality is a core component of the Services.
To provide AI-powered features, the Company processes prompts, conversations, uploaded files, images, documents, audio recordings, generated outputs, and other content that you voluntarily submit through the Services ("User Content").
5.1 How AI Processes User Content
Depending on the functionality you use, User Content may be processed to:
• generate responses;
• answer questions;
• summarize information;
• draft documents;
• translate content;
• analyze uploaded materials;
• generate recommendations;
• classify or organize information;
• improve readability and formatting;
• detect malicious or abusive content;
• identify technical errors;
• maintain service reliability;
• monitor system performance;
• prevent fraud and misuse; and
• comply with applicable legal obligations.
Processing may be carried out using artificial intelligence models operated by the Company and, where applicable, carefully selected third-party AI infrastructure providers acting solely on the Company's instructions.
5.2 User Responsibilities
You are solely responsible for User Content that you submit through the Services.
By submitting User Content, you represent and warrant that:
• you have all necessary rights and permissions to submit such content;
• submission of the content does not violate applicable law;
• submission does not infringe any intellectual property, privacy, confidentiality, contractual, or other rights of third parties;
• where personal information of another individual is included, you have an appropriate legal basis to provide such information.
Users should avoid submitting highly confidential, privileged, classified, export-controlled, or otherwise sensitive information unless strictly necessary for the intended use of the Services.
5.3 AI Model Improvement
Where permitted by applicable law, the Company may use lawfully processed information to:
• evaluate model performance;
• improve response quality;
• identify software defects;
• improve security;
• develop new AI functionality;
• test new features;
• conduct quality assurance;
• perform statistical analysis.
Where required by applicable law, such processing will occur only with an appropriate legal basis.
Where technically feasible, the Company will use anonymized or de-identified information for these purposes.
Where consent constitutes the applicable legal basis for certain AI-related processing activities, including the use of Personal Information for model evaluation, testing, quality assurance, or improvement, such processing will be carried out only after obtaining valid consent where required by applicable law.
5.4 Telegram Data Restrictions
The Company strictly complies with the Telegram API Terms of Service.
Accordingly:
• information obtained through Telegram is processed solely for providing the requested Telegram-related functionality;
• Telegram-derived information is not used to train, fine-tune, develop, improve, benchmark, or evaluate artificial intelligence or machine learning models except where expressly permitted under Telegram's applicable policies;
• the Company does not attempt to circumvent Telegram's technical or privacy controls;
• Telegram-derived information is not sold or licensed to third parties.
5.5 Human Review
To maintain the quality, safety, and security of the Services, authorized personnel may review limited portions of User Content where reasonably necessary to:
• investigate abuse;
• respond to support requests;
• diagnose technical problems;
• detect fraud;
• maintain security;
• comply with legal obligations.
Access is limited to personnel with an appropriate business need and is subject to confidentiality obligations and internal access controls.

6. Legal Bases for Processing Personal Information
Where the GDPR, UK GDPR, LGPD, or similar legislation applies, the Company processes personal information only where an appropriate legal basis exists.
Depending upon the circumstances, processing may rely on one or more of the following legal bases.
6.1 Performance of a Contract
Processing is necessary to:
• create and maintain user accounts;
• authenticate users;
• provide the requested Services;
• provide AI functionality;
• provide Telegram functionality;
• process subscriptions;
• provide customer support;
• perform contractual obligations.
6.2 Consent
Where required by applicable law, including the LGPD, the Company processes certain categories of Personal Information based on your freely given, specific, informed, and unambiguous consent.
Consent may serve as the legal basis for processing activities including, where applicable:
• optional analytics and advertising Cookies;
• optional personalization features;
• optional marketing communications;
• optional AI functionality;
• other processing activities for which applicable law requires consent.
Where consent is requested, it is obtained through the Services and applies to the processing activities described in this Privacy Policy.
You may withdraw your consent at any time using the methods described in Section 11. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal and does not affect processing based on another applicable legal basis.
Where another legal basis exists under applicable law, including contractual necessity, legitimate interests, compliance with legal obligations, protection of vital interests, or another lawful basis recognized under applicable law, the Company may continue processing Personal Information without relying on consent.
6.3 Legitimate Interests
Where permitted by applicable law, the Company may process personal information where necessary for legitimate interests including:
• improving the Services;
• maintaining security;
• preventing fraud;
• protecting infrastructure;
• improving AI quality where legally permitted;
• enforcing contractual rights;
• defending legal claims;
• improving user experience;
• conducting internal analytics.
Whenever legitimate interests are relied upon, the Company balances those interests against the rights and freedoms of affected individuals.
6.4 Compliance with Legal Obligations
Processing may be necessary to comply with:
• applicable legislation;
• judicial orders;
• regulatory requirements;
• governmental requests;
• tax obligations;
• accounting obligations;
• anti-money laundering legislation;
• sanctions legislation;
• consumer protection laws;
• data protection legislation.
6.5 Vital Interests
Where necessary, personal information may be processed to protect the vital interests of an individual.

7. Cookies and Similar Technologies
The Company uses Cookies and similar technologies to improve the functionality, security, performance, and usability of the Services.
7.1 Types of Technologies Used
For purposes of this Privacy Policy, "Cookies" include:
• HTTP Cookies;
• Session Cookies;
• Persistent Cookies;
• Local Storage;
• Session Storage;
• SDKs;
• Pixels;
• Web Beacons;
• Device Identifiers; and
• similar technologies.
7.2 Categories of Cookies
The Company uses the following categories of Cookies.
Strictly Necessary Cookies
These Cookies are required for operation of the Services.
Examples include:
• authentication;
• security;
• fraud prevention;
• load balancing;
• maintaining user sessions;
• remembering Cookie preferences.
These Cookies cannot be disabled because the Services cannot function properly without them.
Functional Cookies
Functional Cookies remember user preferences such as:
• language;
• accessibility settings;
• interface configuration;
• display preferences.
Where required by law, Functional Cookies are activated only after obtaining consent.
Analytics Cookies
Analytics Cookies help us understand:
• Website traffic;
• feature usage;
• navigation behavior;
• performance metrics;
• aggregated usage statistics.
Analytics providers may include Google Analytics, Firebase Analytics, Microsoft Clarity, Matomo, and similar providers.
Performance Cookies
Performance Cookies help evaluate:
• application stability;
• server response time;
• feature reliability;
• overall system performance.
Advertising Cookies
Where permitted by applicable law and subject to prior consent, Advertising Cookies may be used to:
• personalize advertising;
• measure campaign effectiveness;
• perform remarketing;
• create audience segments.
Advertising partners may include Google, Meta, LinkedIn, TikTok, X, and similar providers.
7.3 Cookie Consent
Where required by applicable law:
• non-essential Cookies remain disabled by default;
• users may accept all Cookies;
• reject non-essential Cookies; or
• customize Cookie preferences.
Consent may be withdrawn at any time through the Cookie Preference Center.
7.4 Managing Cookies
Users may manage Cookies through:
• the Cookie Preference Center;
• browser settings;
• device privacy settings.
Disabling certain Cookies may reduce the functionality of the Services.
7.5 International Transfers
Information collected through Cookies may be transferred internationally.
Appropriate safeguards described in Section 10 apply to such transfers.

8. How We Share Personal Information
The Company does not sell personal information except where expressly disclosed in this Privacy Policy or where permitted by applicable law.
We may disclose personal information only in the following circumstances.
8.1 Service Providers
Personal information may be shared with trusted providers assisting us in operating the Services, including:
• cloud infrastructure providers;
• AI infrastructure providers;
• payment processors;
• authentication providers;
• hosting providers;
• customer support providers;
• analytics providers;
• cybersecurity providers;
• fraud prevention providers;
• content moderation providers.
Each provider is contractually required to process personal information solely on our documented instructions and to implement appropriate security measures.
8.2 Corporate Transactions
Personal information may be disclosed in connection with:
• mergers;
• acquisitions;
• investments;
• financing transactions;
• reorganizations;
• sale of assets;
• bankruptcy proceedings;
• due diligence activities.
Recipients will remain bound by confidentiality obligations and applicable privacy laws.
8.3 Legal Compliance
The Company may disclose personal information where necessary to:
• comply with applicable law;
• comply with judicial proceedings;
• respond to lawful governmental requests;
• protect legal rights;
• investigate fraud;
• prevent unlawful activities;
• protect users or the public.
8.4 With Your Consent
The Company may disclose personal information where you expressly authorize or instruct us to do so.
8.5 Telegram
Where the Services integrate with Telegram:
• information may be transmitted through Telegram solely to provide requested functionality;
• Telegram independently determines how it processes information within its own platform;
• the Company does not control Telegram's independent processing activities.

9. International Data Transfers
Because the Services operate globally, personal information may be transferred to, stored in, or processed in countries other than the country in which you reside.
Where required by applicable law, the Company implements appropriate safeguards including:
• Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner's Office;
• adequacy decisions;
• binding contractual commitments;
• supplementary contractual, technical, and organizational safeguards;
• other lawful transfer mechanisms recognized under applicable privacy legislation.
Before transferring personal information internationally, the Company evaluates applicable legal risks and implements safeguards appropriate to the nature of the information being transferred.
Where Telegram-related functionality is used, Telegram may independently process information using its own global infrastructure in accordance with Telegram's applicable privacy documentation.
The Company remains responsible only for international transfers that occur under its own control.

10. Data Retention
The Company retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy or as otherwise required or permitted by applicable law.
Retention periods are determined based on several factors, including:
• the nature and sensitivity of the personal information;
• the purposes for which the information was collected;
• the duration of the relationship with the user;
• applicable contractual obligations;
• statutory limitation periods;
• accounting and tax requirements;
• regulatory obligations;
• litigation and dispute resolution requirements;
• fraud prevention and cybersecurity needs.
When personal information is no longer required, the Company will securely:
• permanently delete it;
• irreversibly anonymize it; or
• otherwise render it permanently unreadable and inaccessible,
unless continued retention is required or permitted by applicable law.
10.1 Categories of Retention
Different categories of information may be retained for different periods.
Examples include:
Category
Typical Retention Purpose
Account information
Operation of the Services
Subscription records
Contract administration
Billing records
Accounting and tax compliance
Customer support communications
Service quality and dispute resolution
Authentication logs
Security and fraud prevention
AI conversations
Provision of requested functionality
Uploaded files
Provision of requested functionality
Security logs
Cybersecurity
Consent records
Demonstrating legal compliance
Privacy requests
Compliance with privacy legislation
Actual retention periods may vary depending upon legal obligations and operational requirements.
10.2 AI Content
Prompts, conversations, uploaded documents, generated outputs, and other User Content may be retained only for so long as reasonably necessary to:
• provide requested functionality;
• maintain Service quality;
• investigate abuse;
• diagnose technical issues;
• improve security;
• comply with applicable law;
• establish, exercise, or defend legal claims.
Where legally permitted, anonymized information may continue to be used for:
• statistical analysis;
• security;
• testing;
• evaluation of Service performance;
• development of new functionality.
10.3 Telegram Information
Information obtained through the Telegram API is retained only for so long as reasonably necessary to:
• provide Telegram-related functionality;
• authenticate requests;
• maintain Service security;
• prevent fraud;
• comply with legal obligations;
• enforce contractual rights.
Telegram-derived information is never retained for AI training or model improvement except where expressly permitted under Telegram's applicable Terms of Service and policies.
10.4 Backup Systems
Encrypted backup copies containing personal information may remain in secure disaster recovery systems for up to 90 days following deletion.
Backup copies:
• are protected through appropriate technical and organizational safeguards;
• are accessible only where operationally necessary;
• are automatically overwritten or permanently deleted in accordance with the Company's backup retention schedule.
10.5 Anonymized Information
Information that has been irreversibly anonymized or aggregated so that it can no longer reasonably identify an individual is no longer considered personal information.
Such information may be retained indefinitely for purposes including:
• analytics;
• scientific research;
• product improvement;
• Service security;
• testing;
• evaluation of artificial intelligence technologies where permitted by applicable law.

11. Your Privacy Rights
Depending on your jurisdiction and applicable law, you may have one or more of the following rights regarding your personal information.
These rights may include the right to:
• obtain confirmation that we process your personal information;
• access your personal information;
• receive a copy of your personal information;
• request correction of inaccurate or incomplete information;
• request deletion of personal information;
• request anonymization where applicable;
• request restriction of processing;
• object to processing based upon legitimate interests;
• withdraw consent;
• request data portability;
• object to direct marketing;
• object to certain automated decision-making;
• obtain information regarding international transfers;
• lodge a complaint with a competent supervisory authority.
Exercise of these rights may be subject to verification of identity and statutory exceptions.
11.1 Exercising Your Rights
Privacy requests may be submitted using the contact information provided in Section 19.
Before responding to certain requests, the Company may request reasonable information necessary to verify your identity.
Verification may include:
• confirmation through your registered email address;
• authentication through your account;
• confirmation of account ownership;
• additional identifying information reasonably necessary to protect personal information.
Where identity cannot reasonably be verified, the Company may refuse or delay processing to the extent permitted by applicable law.
11.2 Cookie Preferences
Where required by applicable law, users may:
• accept all Cookies;
• reject non-essential Cookies;
• customize Cookie settings;
• withdraw Cookie consent at any time.
Cookie preferences may be managed through:
• the Cookie Preference Center;
• browser settings; or
• device privacy settings.

12. Account Deletion
The Company provides users with the ability to permanently delete their account and associated personal information, subject to applicable legal requirements.
This Section explains:
• how to request deletion;
• how deletion requests are processed;
• what information will be deleted;
• what information may continue to be retained;
• how deletion affects AI content, Telegram functionality, subscriptions, and third-party services.
12.1 Requesting Account Deletion
Users may request deletion of their account at any time.
Through the Application
Where available:
• Open the App.
• Navigate to Settings.
• Select Account.
• Choose Delete Account.
• Confirm the deletion request.
Through Customer Support
If access to the account is unavailable, users may submit a deletion request by contacting:
privacy@[company-domain].com
12.2 Identity Verification
To prevent unauthorized deletion requests, fraud, or identity theft, the Company may require reasonable verification before processing a deletion request.
Verification may include:
• confirmation of account ownership;
• authentication through the registered email address;
• additional identifying information;
• supporting documentation where appropriate.
If verification cannot reasonably be completed, the Company may refuse or postpone processing until adequate verification has been obtained.
12.3 Processing Deletion Requests
Following successful verification, the Company will begin processing the deletion request without undue delay.
Unless a longer period is required by applicable law, most personal information associated with the account will be permanently deleted or irreversibly anonymized within 30 days.
Deletion may occur in multiple technical stages depending upon system architecture.
Where appropriate, users may receive confirmation that deletion has been completed.
12.4 What Happens When Your Account Is Deleted
Following completion of the deletion process:
• the account will be permanently closed;
• authentication credentials will be disabled;
• access to the Services will terminate;
• saved settings and preferences will be removed;
• AI conversation history stored by the Company will be deleted or anonymized;
• uploaded files maintained by the Company will be deleted or anonymized;
• AI-generated outputs associated with the account will be deleted unless retention is legally required.
Deletion is generally irreversible.
Once completed, deleted accounts cannot ordinarily be restored.
12.5 Active Subscriptions
Deleting an account does not automatically cancel subscriptions purchased through:
• Apple App Store;
• Google Play;
• or another third-party payment platform.
Subscription cancellation must be completed directly through the relevant payment provider.
Deletion of an account does not automatically entitle the user to a refund unless required by applicable law or the applicable payment provider's policies.
12.6 Information Deleted
Subject to applicable law, deletion generally includes:
• profile information;
• account credentials;
• saved preferences;
• prompts;
• conversations;
• uploaded documents;
• uploaded images;
• uploaded audio;
• uploaded videos;
• AI-generated outputs stored by the Company;
• account metadata used solely for operation of the account.
12.7 Information That May Continue to Be Retained
Certain information may continue to be retained following account deletion where required or permitted by applicable law.
Examples include:
• payment records;
• invoices;
• accounting documentation;
• tax records;
• fraud prevention records;
• cybersecurity logs;
• authentication logs;
• security incident records;
• customer support communications;
• records of privacy requests;
• consent records;
• litigation materials;
• information required to comply with legal obligations.
Retained information continues to be protected in accordance with this Privacy Policy.
12.8 AI Content
Where permitted by applicable law:
• conversations;
• prompts;
• uploaded files;
• generated outputs;
• and other User Content
associated with the deleted account will be permanently deleted or irreversibly anonymized where maintained by the Company.
Deletion does not affect:
• information previously exported by the user;
• information previously downloaded by the user;
• information previously shared with third parties.
12.9 Telegram
Where Telegram functionality is used:
• deletion applies only to information controlled by the Company;
• Telegram independently determines its own retention practices;
• deletion of a Cloud Robot account does not delete a Telegram account;
• requests relating to Telegram-hosted information must be submitted directly to Telegram.
12.10 Legal Holds
The Company may postpone deletion where information is subject to:
• ongoing litigation;
• anticipated legal proceedings;
• governmental investigations;
• regulatory inquiries;
• court orders;
• legal preservation obligations.
Deletion will proceed once the applicable legal obligation has expired.
12.11 Exceptions
The Company may deny or partially fulfill a deletion request where:
• retention is required by applicable law;
• identity cannot reasonably be verified;
• retention is necessary to establish, exercise, or defend legal claims;
• deletion would adversely affect the rights of another individual;
• information forms part of anonymized datasets;
• retention is required to comply with the Telegram API Terms of Service or other binding legal obligations.
12.12 Withdrawal of a Deletion Request
Where technically feasible and before permanent deletion has been completed, users may withdraw a deletion request by contacting the Company.
Once permanent deletion has occurred, restoration of the account is generally not possible.

13. Security
The Company is committed to protecting personal information through administrative, technical, physical, and organizational safeguards designed to reduce the risk of unauthorized access, disclosure, alteration, destruction, loss, misuse, or other unlawful processing.
Our information security program is designed taking into account:
• the nature of the Services;
• the categories of personal information processed;
• the risks presented by the processing activities;
• industry best practices; and
• applicable legal and regulatory requirements.
Our security measures may include, where appropriate:
• encryption of personal information in transit using industry-standard protocols;
• encryption of sensitive personal information at rest;
• role-based access controls;
• least-privilege access principles;
• multi-factor authentication for privileged administrative access;
• network segmentation;
• vulnerability management;
• penetration testing;
• malware protection;
• security monitoring;
• logging and audit trails;
• disaster recovery and business continuity procedures;
• secure software development lifecycle (SSDLC);
• periodic security assessments;
• employee confidentiality obligations; and
• mandatory security awareness training.
Access to personal information is limited to personnel and authorized service providers who require such access to perform their duties.
Where third-party service providers process personal information on our behalf, we require appropriate contractual commitments regarding confidentiality, security, and compliance with applicable privacy laws.
Although the Company implements commercially reasonable safeguards, no method of electronic transmission, storage, or processing is completely secure. Accordingly, we cannot guarantee absolute security.
Users are responsible for maintaining the confidentiality of their account credentials and should notify the Company immediately of any suspected unauthorized access or security incident involving their account.

14. Children's Privacy
The Services are intended for individuals who have reached the minimum age required under applicable law in their jurisdiction.
Unless otherwise permitted by applicable law, the Company does not knowingly collect personal information from children without appropriate authorization from a parent or legal guardian.
If the Company becomes aware that personal information has been collected from a child in violation of applicable law, the Company will take reasonable steps to:
• investigate the circumstances;
• suspend processing where appropriate;
• permanently delete or anonymize the relevant information without undue delay unless retention is legally required; and
• implement measures designed to prevent similar occurrences.
Parents or legal guardians who believe that a child has provided personal information through the Services may contact the Company using the contact information provided below.

15. Third-Party Services
The Services may integrate with, link to, or otherwise enable access to third-party services.
Examples include:
• Telegram;
• payment providers;
• cloud hosting providers;
• authentication providers;
• analytics providers;
• customer support platforms;
• artificial intelligence infrastructure providers;
• content delivery networks;
• social media platforms; and
• embedded third-party content.
These third parties operate independently from the Company and maintain their own:
• privacy policies;
• terms of service;
• security practices;
• retention policies; and
• compliance programs.
The Company is not responsible for:
• the availability of third-party services;
• the content of third-party websites or applications;
• the independent privacy practices of third parties;
• independent processing activities carried out by third parties; or
• changes made by third parties to their services.
Users should carefully review the privacy documentation applicable to each third-party service before using it.
15.1 Third-Party Processors
Where third-party providers process personal information on behalf of the Company, such providers act only pursuant to written agreements requiring them to:
• process personal information solely on documented instructions;
• implement appropriate technical and organizational safeguards;
• maintain confidentiality;
• assist the Company in complying with applicable privacy legislation;
• securely delete or return personal information upon termination of the relevant services, where applicable.

16. Region-Specific Privacy Rights
16.1 European Economic Area, United Kingdom and Switzerland
If you are located within the European Economic Area ("EEA"), the United Kingdom, or Switzerland, you may have rights under the GDPR, UK GDPR, and applicable national legislation, including:
• access;
• rectification;
• erasure;
• restriction of processing;
• objection to processing;
• data portability;
• withdrawal of consent;
• objection to direct marketing; and
• the right not to be subject to certain automated decisions where required by law.
Where processing relies on legitimate interests, you may object to such processing where permitted by applicable law.
You also have the right to lodge a complaint with the competent supervisory authority.
16.2 California Residents
If you are a California resident, you may have additional rights under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA").
Subject to applicable law, these rights may include:
• the right to know what categories of personal information we collect;
• the right to know the purposes for which personal information is used;
• the right to know the categories of third parties with whom information is shared;
• the right to access personal information;
• the right to correct inaccurate personal information;
• the right to request deletion;
• the right to obtain a copy of specific personal information;
• the right to opt out of the sale or sharing of personal information, where applicable;
• the right to limit the use of sensitive personal information, where applicable; and
• the right not to receive discriminatory treatment for exercising privacy rights.
The Company does not sell personal information as that term is defined under the CCPA/CPRA unless expressly disclosed in this Privacy Policy or otherwise required by law.
16.3 Brazil (LGPD)
Individuals located in Brazil may exercise the rights provided under the Lei Geral de Proteção de Dados ("LGPD").
Subject to applicable law, such rights include:
• confirmation of processing;
• access to personal data;
• correction of incomplete, inaccurate, or outdated information;
• anonymization, blocking, or deletion of unnecessary personal data;
• portability;
• deletion of data processed on the basis of consent where applicable;
• information regarding entities with whom personal information has been shared;
• information regarding the consequences of refusing consent;
• withdrawal of consent; and
• review of automated decisions where required by law.
Where required by Brazilian law, the Company will designate an Encarregado (Data Protection Officer) responsible for communications with data subjects and the ANPD.
Where consent constitutes the applicable legal basis under the LGPD, the Company obtains, records, manages, and documents such consent in accordance with applicable Brazilian law.
Where permitted by Articles 7 or 11 of the LGPD, the Company may process Personal Information on legal bases other than consent, including the performance of a contract, compliance with legal obligations, the regular exercise of rights in judicial, administrative, or arbitration proceedings, legitimate interests, and other legal bases recognized under the LGPD.

17. Telegram API Compliance
The Company is committed to complying with the Telegram API Terms of Service and all applicable Telegram policies.
Accordingly:
• information obtained through Telegram is processed solely for the purpose of providing, maintaining, securing, and supporting the Services;
• the Company collects only the minimum information reasonably necessary to provide the requested Telegram-related functionality;
• Telegram-derived information is not used to train, fine-tune, develop, benchmark, evaluate, or improve artificial intelligence systems except where expressly permitted by Telegram's applicable Terms of Service and policies;
• the Company does not sell, license, or otherwise commercialize Telegram-derived personal information;
• the Company does not interfere with, circumvent, override, or attempt to bypass Telegram's technical, security, or privacy controls;
• Telegram-related functionality may be modified, suspended, or discontinued where reasonably necessary to comply with changes to Telegram's policies, legal requirements, or technical specifications; and
• nothing in this Privacy Policy modifies or replaces Telegram's own Terms of Service, Privacy Policy, or other applicable Telegram policies.

18. Changes to this Privacy Policy
The Company may amend or update this Privacy Policy from time to time to reflect:
• changes in applicable law;
• regulatory guidance;
• judicial decisions;
• technological developments;
• changes to the Services;
• changes to our business operations;
• changes relating to artificial intelligence technologies;
• changes to Telegram APIs and other third-party platforms; or
• improvements to our privacy and security practices.
Where required by applicable law, we will provide notice of material changes through one or more of the following methods:
• publication on our Website;
• in-application notifications;
• email notification;
• push notifications; or
• any other legally appropriate means.
The "Last Updated" date appearing at the beginning of this Privacy Policy indicates the date on which this Privacy Policy was most recently revised.
Your continued use of the Services after the effective date of an updated Privacy Policy constitutes your acknowledgment of the revised Privacy Policy except where applicable law requires additional consent.
Where an amendment to this Privacy Policy materially changes the purposes of processing or otherwise requires renewed consent under applicable law, the Company will obtain such consent before applying the relevant changes.

19. Contact Information
If you have any questions regarding this Privacy Policy, wish to exercise your privacy rights, submit an account deletion request, or obtain additional information regarding our privacy practices, please contact us:
Cloud Robot LLC
Privacy Officer / Data Protection Officer (where applicable)
Website: https://www.larchie.com
Email: support@larchie.com
Postal Address: 99 WALL STREET,STE#183 NEW YORK, NY 10005
For individuals located in Brazil, requests under the LGPD may also be submitted to the Company's designated Encarregado (Data Protection Officer) using the contact information above.
Where required by applicable law, the Company will respond to verified requests within the applicable statutory time limits.

20. Changes to Your Rights and Contacting Supervisory Authorities
Nothing in this Privacy Policy limits any rights that you may have under applicable data protection laws.
If you believe that the Company has processed your personal information in violation of applicable law, you may contact us using the details above.
Where permitted by applicable law, you also have the right to submit a complaint to the competent supervisory authority in your jurisdiction without first contacting the Company.