Privacy Policy

Last updated: 04.07.2023

Here are some important definitions to help you understand our terms and this Privacy Policy:

Spire Labs SRL. and our relevant affiliates are referred to as “Spire Labs”, “we”, “us”, and “our.”
Our mobile application Sona AI is referred to as “Sona AI” or “application”
Users are referred to as “users”, “you” or “your”, as applicable.
Your use of the applications (including downloading, installing, registering with, accessing, or otherwise using it) is referred to as “Use”.
To the extent information is: (i) associated with an identified or identifiable natural person and (ii) protected as personal data under applicable data protection laws, such information is referred to in this Privacy Policy as “Personal Data”.

Here are some important definitions to help you understand our terms and this Privacy Policy:

Spire Labs SRL. and our relevant affiliates are referred to as “Spire Labs”, “we”, “us”, and “our.”
Our mobile application Sona AI is referred to as “Sona AI” or “application”
Users are referred to as “users”, “you” or “your”, as applicable.
Your use of the applications (including downloading, installing, registering with, accessing, or otherwise using it) is referred to as “Use”.
To the extent information is: (i) associated with an identified or identifiable natural person and (ii) protected as personal data under applicable data protection laws, such information is referred to in this Privacy Policy as “Personal Data”.

Here are some important definitions to help you understand our terms and this Privacy Policy:

Spire Labs SRL. and our relevant affiliates are referred to as “Spire Labs”, “we”, “us”, and “our.”
Our mobile application Sona AI is referred to as “Sona AI” or “application”
Users are referred to as “users”, “you” or “your”, as applicable.
Your use of the applications (including downloading, installing, registering with, accessing, or otherwise using it) is referred to as “Use”.
To the extent information is: (i) associated with an identified or identifiable natural person and (ii) protected as personal data under applicable data protection laws, such information is referred to in this Privacy Policy as “Personal Data”.

Here are some important definitions to help you understand our terms and this Privacy Policy:

Spire Labs SRL. and our relevant affiliates are referred to as “Spire Labs”, “we”, “us”, and “our.”
Our mobile application Sona AI is referred to as “Sona AI” or “application”
Users are referred to as “users”, “you” or “your”, as applicable.
Your use of the applications (including downloading, installing, registering with, accessing, or otherwise using it) is referred to as “Use”.
To the extent information is: (i) associated with an identified or identifiable natural person and (ii) protected as personal data under applicable data protection laws, such information is referred to in this Privacy Policy as “Personal Data”.

A small note on how Avatars feature works.

Sona AI uses a Neural Network Model Stable Diffusion that allows users to generate personalized Avatars (“Avatars”).

Users upload 10 to 20 photos and select their gender.
Using these data, a copy of the Stable Diffusion model is retrained to personalize the model
After the model copy is retrained, it generates the Avatars
After the Avatars are generated, the copy of the model, along with uploaded photos, are deleted permanently from our servers
We do not use your Personal Data to generally train and/or create our separate artificial intelligence/products.

A small note on how Avatars feature works.

Sona AI uses a Neural Network Model Stable Diffusion that allows users to generate personalized Avatars (“Avatars”).

Users upload 10 to 20 photos and select their gender.
Using these data, a copy of the Stable Diffusion model is retrained to personalize the model
After the model copy is retrained, it generates the Avatars
After the Avatars are generated, the copy of the model, along with uploaded photos, are deleted permanently from our servers
We do not use your Personal Data to generally train and/or create our separate artificial intelligence/products.

A small note on how Avatars feature works.

Sona AI uses a Neural Network Model Stable Diffusion that allows users to generate personalized Avatars (“Avatars”).

Users upload 10 to 20 photos and select their gender.
Using these data, a copy of the Stable Diffusion model is retrained to personalize the model
After the model copy is retrained, it generates the Avatars
After the Avatars are generated, the copy of the model, along with uploaded photos, are deleted permanently from our servers
We do not use your Personal Data to generally train and/or create our separate artificial intelligence/products.

A small note on how Avatars feature works.

Sona AI uses a Neural Network Model Stable Diffusion that allows users to generate personalized Avatars (“Avatars”).

Users upload 10 to 20 photos and select their gender.
Using these data, a copy of the Stable Diffusion model is retrained to personalize the model
After the model copy is retrained, it generates the Avatars
After the Avatars are generated, the copy of the model, along with uploaded photos, are deleted permanently from our servers
We do not use your Personal Data to generally train and/or create our separate artificial intelligence/products.

We do our best to moderate the parameters of the Stable Diffusion model, however, it is still possible that you may encounter content that you may see as inappropriate for you.

We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you.

We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains what we do with your Personal Data (as defined below) and allows you to manage your Personal Data effectively.

Please read this Privacy Policy carefully to understand our privacy practices. The purpose of our Privacy Policy is to explain what data we collect, how it is used and shared, and how you can control it. If you do not want us to process your Personal Data as it is described in this Privacy Policy, please do not Use LucidAI.

By Using LucidAI, you understand and agree that we are providing you with tools for editing and adjusting photos and videos that you upload, and, if you so request, for generating or creating new content from them, for example with our Avatars feature.

If you have any questions about this Privacy Policy or LucidAI, please contact us at support@spirelabs.io (for additional contact information, please, see Section 12 of this Privacy Policy “How to Contact Us”).

This Privacy Policy DOES NOT apply to the information that:

We collect offline or on any of our other apps (e.g., LucidAI) or websites, including websites you may access through LucidAI.
You provide to or that is collected by any third party (e.g., any third-party application or website, even if the link to it is accessible through LucidAI).

We do our best to moderate the parameters of the Stable Diffusion model, however, it is still possible that you may encounter content that you may see as inappropriate for you.

We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you.

We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains what we do with your Personal Data (as defined below) and allows you to manage your Personal Data effectively.

Please read this Privacy Policy carefully to understand our privacy practices. The purpose of our Privacy Policy is to explain what data we collect, how it is used and shared, and how you can control it. If you do not want us to process your Personal Data as it is described in this Privacy Policy, please do not Use LucidAI.

By Using LucidAI, you understand and agree that we are providing you with tools for editing and adjusting photos and videos that you upload, and, if you so request, for generating or creating new content from them, for example with our Avatars feature.

If you have any questions about this Privacy Policy or LucidAI, please contact us at support@spirelabs.io (for additional contact information, please, see Section 12 of this Privacy Policy “How to Contact Us”).

This Privacy Policy DOES NOT apply to the information that:

We collect offline or on any of our other apps (e.g., LucidAI) or websites, including websites you may access through LucidAI.
You provide to or that is collected by any third party (e.g., any third-party application or website, even if the link to it is accessible through LucidAI).

We do our best to moderate the parameters of the Stable Diffusion model, however, it is still possible that you may encounter content that you may see as inappropriate for you.

We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you.

We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains what we do with your Personal Data (as defined below) and allows you to manage your Personal Data effectively.

Please read this Privacy Policy carefully to understand our privacy practices. The purpose of our Privacy Policy is to explain what data we collect, how it is used and shared, and how you can control it. If you do not want us to process your Personal Data as it is described in this Privacy Policy, please do not Use LucidAI.

By Using LucidAI, you understand and agree that we are providing you with tools for editing and adjusting photos and videos that you upload, and, if you so request, for generating or creating new content from them, for example with our Avatars feature.

If you have any questions about this Privacy Policy or LucidAI, please contact us at support@spirelabs.io (for additional contact information, please, see Section 12 of this Privacy Policy “How to Contact Us”).

This Privacy Policy DOES NOT apply to the information that:

We collect offline or on any of our other apps (e.g., LucidAI) or websites, including websites you may access through LucidAI.
You provide to or that is collected by any third party (e.g., any third-party application or website, even if the link to it is accessible through LucidAI).

We do our best to moderate the parameters of the Stable Diffusion model, however, it is still possible that you may encounter content that you may see as inappropriate for you.

We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you.

We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains what we do with your Personal Data (as defined below) and allows you to manage your Personal Data effectively.

Please read this Privacy Policy carefully to understand our privacy practices. The purpose of our Privacy Policy is to explain what data we collect, how it is used and shared, and how you can control it. If you do not want us to process your Personal Data as it is described in this Privacy Policy, please do not Use LucidAI.

By Using LucidAI, you understand and agree that we are providing you with tools for editing and adjusting photos and videos that you upload, and, if you so request, for generating or creating new content from them, for example with our Avatars feature.

If you have any questions about this Privacy Policy or LucidAI, please contact us at support@spirelabs.io (for additional contact information, please, see Section 12 of this Privacy Policy “How to Contact Us”).

This Privacy Policy DOES NOT apply to the information that:

We collect offline or on any of our other apps (e.g., LucidAI) or websites, including websites you may access through LucidAI.
You provide to or that is collected by any third party (e.g., any third-party application or website, even if the link to it is accessible through LucidAI).

1. INFORMATION WE COLLECT AND HOW WE COLLECT IT

We may collect several types of information, including but not limited to Personal Data, from and about you:

Directly from you when you provide it to us.
Automatically when you Use Sona AI. Information collected automatically may include Usage details and internet protocol (“IP”) addresses.
From third parties, for example, our Service Providers (as defined below).

We may collect several types of information, including but not limited to Personal Data, from and about you:

Directly from you when you provide it to us.
Automatically when you Use Sona AI. Information collected automatically may include Usage details and internet protocol (“IP”) addresses.
From third parties, for example, our Service Providers (as defined below).

We may collect several types of information, including but not limited to Personal Data, from and about you:

Directly from you when you provide it to us.
Automatically when you Use Sona AI. Information collected automatically may include Usage details and internet protocol (“IP”) addresses.
From third parties, for example, our Service Providers (as defined below).

We may collect several types of information, including but not limited to Personal Data, from and about you:

Directly from you when you provide it to us.
Automatically when you Use Sona AI. Information collected automatically may include Usage details and internet protocol (“IP”) addresses.
From third parties, for example, our Service Providers (as defined below).

2. INFORMATION YOU PROVIDE TO US DIRECTLY

When you Use Sona AI, you usually provide to us certain information, including your Personal Data:

Photos and (or) videos that you upload to Sona AI, for example to use the Avatars feature. Please note that we always delete all metadata that may be associated with your photos and (or) videos by default (including, for example, geotags) before temporarily storing them to our systems.
Some editing features may use TrueDepth API (developed by Apple) technologies that provide information about facial position, orientation, and topology. Such information is used only on-device and is never stored on our servers. For more information about TrueDepth API processing of your photos and videos, you may visit the following link.
Information about your gender: When you use our Avatars feature, we ask you about your gender. This information is used by the AI model solely to generate the Avatars in accordance with the indicated gender: for example, if you choose to identify your gender as a female, then you will receive conventionally more feminine-like Avatars.
Your email: When you create an account with Sona AI, we ask you to provide your email that will be further used for your sign-in process.
If you contact us, records, copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted online or offline), in order to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other ssers inquiries in relation to Sona AI.

When you Use Sona AI, you usually provide to us certain information, including your Personal Data:

Photos and (or) videos that you upload to Sona AI, for example to use the Avatars feature. Please note that we always delete all metadata that may be associated with your photos and (or) videos by default (including, for example, geotags) before temporarily storing them to our systems.
Some editing features may use TrueDepth API (developed by Apple) technologies that provide information about facial position, orientation, and topology. Such information is used only on-device and is never stored on our servers. For more information about TrueDepth API processing of your photos and videos, you may visit the following link.
Information about your gender: When you use our Avatars feature, we ask you about your gender. This information is used by the AI model solely to generate the Avatars in accordance with the indicated gender: for example, if you choose to identify your gender as a female, then you will receive conventionally more feminine-like Avatars.
Your email: When you create an account with Sona AI, we ask you to provide your email that will be further used for your sign-in process.
If you contact us, records, copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted online or offline), in order to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other ssers inquiries in relation to Sona AI.

When you Use Sona AI, you usually provide to us certain information, including your Personal Data:

Photos and (or) videos that you upload to Sona AI, for example to use the Avatars feature. Please note that we always delete all metadata that may be associated with your photos and (or) videos by default (including, for example, geotags) before temporarily storing them to our systems.
Some editing features may use TrueDepth API (developed by Apple) technologies that provide information about facial position, orientation, and topology. Such information is used only on-device and is never stored on our servers. For more information about TrueDepth API processing of your photos and videos, you may visit the following link.
Information about your gender: When you use our Avatars feature, we ask you about your gender. This information is used by the AI model solely to generate the Avatars in accordance with the indicated gender: for example, if you choose to identify your gender as a female, then you will receive conventionally more feminine-like Avatars.
Your email: When you create an account with Sona AI, we ask you to provide your email that will be further used for your sign-in process.
If you contact us, records, copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted online or offline), in order to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other ssers inquiries in relation to Sona AI.

When you Use Sona AI, you usually provide to us certain information, including your Personal Data:

Photos and (or) videos that you upload to Sona AI, for example to use the Avatars feature. Please note that we always delete all metadata that may be associated with your photos and (or) videos by default (including, for example, geotags) before temporarily storing them to our systems.
Some editing features may use TrueDepth API (developed by Apple) technologies that provide information about facial position, orientation, and topology. Such information is used only on-device and is never stored on our servers. For more information about TrueDepth API processing of your photos and videos, you may visit the following link.
Information about your gender: When you use our Avatars feature, we ask you about your gender. This information is used by the AI model solely to generate the Avatars in accordance with the indicated gender: for example, if you choose to identify your gender as a female, then you will receive conventionally more feminine-like Avatars.
Your email: When you create an account with Sona AI, we ask you to provide your email that will be further used for your sign-in process.
If you contact us, records, copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted online or offline), in order to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other ssers inquiries in relation to Sona AI.

3. INFORMATION WE COLLECT AUTOMATICALLY

When you Use Sona AI, we may automatically collect certain data about you. This data is needed for operation of Sona AI and, among others, may be used for in-app analytics or marketing purposes. The data we collect automatically includes:

Device information: Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system, and mobile network information.
Usage details: Details of your Use of Sona AI, including frequency of Use, areas and features of the application that you access and engagement with particular features. This information is used for in-app event analytics and, upon your consent, for marketing purposes.
(If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by Sona AI, please follow the instructions below.

If you use an iOS device:

Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
Tap to turn off or turn on permission to track for Sona AI.

Such automatically collected data helps us operate Sona AI and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use Sona AI and what you like and dislike the most.

The technologies we use for automatic data collection may include:

We use third-party analytics tools, such as Google Firebase, Meta, AppsFlyer and Amplitude, to help us measure traffic and usage trends for Sona AI. These tools collect information via third-party analytics software development kits incorporated into Sona AI, which includes your pseudonymised user ID and the information about Sona AI web pages you visit when following the links available to you on Sona AI, your actions in Sona AI application and basic information about the type of subscription you have. We collect and use this analytics information in an aggregated manner with analytics information from other users so that it cannot reasonably be used to identify any particular user. For information on how third party analytics tools collect and process your data and to opt out of such collection and processing, generated by your Use of Sona AI, please contact us at support@spirelabs.io.

When you Use Sona AI, we may automatically collect certain data about you. This data is needed for operation of Sona AI and, among others, may be used for in-app analytics or marketing purposes. The data we collect automatically includes:

Device information: Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system, and mobile network information.
Usage details: Details of your Use of Sona AI, including frequency of Use, areas and features of the application that you access and engagement with particular features. This information is used for in-app event analytics and, upon your consent, for marketing purposes.
(If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by Sona AI, please follow the instructions below.

If you use an iOS device:

Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
Tap to turn off or turn on permission to track for Sona AI.

Such automatically collected data helps us operate Sona AI and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use Sona AI and what you like and dislike the most.

The technologies we use for automatic data collection may include:

We use third-party analytics tools, such as Google Firebase, Meta, AppsFlyer and Amplitude, to help us measure traffic and usage trends for Sona AI. These tools collect information via third-party analytics software development kits incorporated into Sona AI, which includes your pseudonymised user ID and the information about Sona AI web pages you visit when following the links available to you on Sona AI, your actions in Sona AI application and basic information about the type of subscription you have. We collect and use this analytics information in an aggregated manner with analytics information from other users so that it cannot reasonably be used to identify any particular user. For information on how third party analytics tools collect and process your data and to opt out of such collection and processing, generated by your Use of Sona AI, please contact us at support@spirelabs.io.

When you Use Sona AI, we may automatically collect certain data about you. This data is needed for operation of Sona AI and, among others, may be used for in-app analytics or marketing purposes. The data we collect automatically includes:

Device information: Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system, and mobile network information.
Usage details: Details of your Use of Sona AI, including frequency of Use, areas and features of the application that you access and engagement with particular features. This information is used for in-app event analytics and, upon your consent, for marketing purposes.
(If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by Sona AI, please follow the instructions below.

If you use an iOS device:

Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
Tap to turn off or turn on permission to track for Sona AI.

Such automatically collected data helps us operate Sona AI and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use Sona AI and what you like and dislike the most.

The technologies we use for automatic data collection may include:

We use third-party analytics tools, such as Google Firebase, Meta, AppsFlyer and Amplitude, to help us measure traffic and usage trends for Sona AI. These tools collect information via third-party analytics software development kits incorporated into Sona AI, which includes your pseudonymised user ID and the information about Sona AI web pages you visit when following the links available to you on Sona AI, your actions in Sona AI application and basic information about the type of subscription you have. We collect and use this analytics information in an aggregated manner with analytics information from other users so that it cannot reasonably be used to identify any particular user. For information on how third party analytics tools collect and process your data and to opt out of such collection and processing, generated by your Use of Sona AI, please contact us at support@spirelabs.io.

When you Use Sona AI, we may automatically collect certain data about you. This data is needed for operation of Sona AI and, among others, may be used for in-app analytics or marketing purposes. The data we collect automatically includes:

Device information: Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system, and mobile network information.
Usage details: Details of your Use of Sona AI, including frequency of Use, areas and features of the application that you access and engagement with particular features. This information is used for in-app event analytics and, upon your consent, for marketing purposes.
(If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by Sona AI, please follow the instructions below.

If you use an iOS device:

Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
Tap to turn off or turn on permission to track for Sona AI.

Such automatically collected data helps us operate Sona AI and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use Sona AI and what you like and dislike the most.

The technologies we use for automatic data collection may include:

We use third-party analytics tools, such as Google Firebase, Meta, AppsFlyer and Amplitude, to help us measure traffic and usage trends for Sona AI. These tools collect information via third-party analytics software development kits incorporated into Sona AI, which includes your pseudonymised user ID and the information about Sona AI web pages you visit when following the links available to you on Sona AI, your actions in Sona AI application and basic information about the type of subscription you have. We collect and use this analytics information in an aggregated manner with analytics information from other users so that it cannot reasonably be used to identify any particular user. For information on how third party analytics tools collect and process your data and to opt out of such collection and processing, generated by your Use of Sona AI, please contact us at support@spirelabs.io.

4. HOW WE PROCESS YOUR PHOTOS AND VIDEOS

We care about your privacy. With this in mind, most processing activities occur on your device only. There are, however, two exceptions to it: when you apply Art Styles to your photos and when you generate Avatars, since these functions require sophisticated computing resources to be performed.

Art Styles. To apply Art Styles, you have to upload your original photo to Sona AI. At this point, your photo is stored on our servers (provided by Amazon Web Services (USA)). It is needed for your convenience so that you don’t have to re-upload the original photo every time to apply any new Art Style. This also helps you spend less Internet traffic and makes the processing of Art Styled photos faster. We store your original photo on our servers for no longer than 24 hours. After 24 hours your original photo is deleted.
Avatars. In order to generate Avatars, you have to upload 10-20 photos to Sona AI. At this point, your photos are stored on our servers (provided by Amazon Web Services (USA)). Then, a copy of the Stable Diffusion model is created to be retrained with your photos to personalize the model and to create your Avatars. Immediately after the successful generation of Avatars, your original photos are deleted from our servers. Your purchased Avatars are stored on our servers so that they remain accessible to you in LucidAAI at any time and from any device until you decide to delete them.

You can also always request us to delete your photos or Avatars by contacting us at support@spirelabs.io.

Notwithstanding anything to the contrary elsewhere in this Privacy Policy:

We do not use photos, videos or Avatars to identify any individual user.
We do not use your photos, videos or Avatars for authentication, advertising, or marketing purposes, or to otherwise target a user in a similar manner.
We do not use your photos, videos or Avatars to build a user profile, or otherwise attempt, facilitate, or encourage third parties to identify anonymous users or reconstruct user profiles based on your photos, videos or Avatars.
We do not transfer, share, sell, or otherwise provide your photos, videos or Avatars to advertising platforms, analytics providers, data brokers, information resellers or other such parties.

We care about your privacy. With this in mind, most processing activities occur on your device only. There are, however, two exceptions to it: when you apply Art Styles to your photos and when you generate Avatars, since these functions require sophisticated computing resources to be performed.

Art Styles. To apply Art Styles, you have to upload your original photo to Sona AI. At this point, your photo is stored on our servers (provided by Amazon Web Services (USA)). It is needed for your convenience so that you don’t have to re-upload the original photo every time to apply any new Art Style. This also helps you spend less Internet traffic and makes the processing of Art Styled photos faster. We store your original photo on our servers for no longer than 24 hours. After 24 hours your original photo is deleted.
Avatars. In order to generate Avatars, you have to upload 10-20 photos to Sona AI. At this point, your photos are stored on our servers (provided by Amazon Web Services (USA)). Then, a copy of the Stable Diffusion model is created to be retrained with your photos to personalize the model and to create your Avatars. Immediately after the successful generation of Avatars, your original photos are deleted from our servers. Your purchased Avatars are stored on our servers so that they remain accessible to you in LucidAAI at any time and from any device until you decide to delete them.

You can also always request us to delete your photos or Avatars by contacting us at support@spirelabs.io.

Notwithstanding anything to the contrary elsewhere in this Privacy Policy:

We do not use photos, videos or Avatars to identify any individual user.
We do not use your photos, videos or Avatars for authentication, advertising, or marketing purposes, or to otherwise target a user in a similar manner.
We do not use your photos, videos or Avatars to build a user profile, or otherwise attempt, facilitate, or encourage third parties to identify anonymous users or reconstruct user profiles based on your photos, videos or Avatars.
We do not transfer, share, sell, or otherwise provide your photos, videos or Avatars to advertising platforms, analytics providers, data brokers, information resellers or other such parties.

We care about your privacy. With this in mind, most processing activities occur on your device only. There are, however, two exceptions to it: when you apply Art Styles to your photos and when you generate Avatars, since these functions require sophisticated computing resources to be performed.

Art Styles. To apply Art Styles, you have to upload your original photo to Sona AI. At this point, your photo is stored on our servers (provided by Amazon Web Services (USA)). It is needed for your convenience so that you don’t have to re-upload the original photo every time to apply any new Art Style. This also helps you spend less Internet traffic and makes the processing of Art Styled photos faster. We store your original photo on our servers for no longer than 24 hours. After 24 hours your original photo is deleted.
Avatars. In order to generate Avatars, you have to upload 10-20 photos to Sona AI. At this point, your photos are stored on our servers (provided by Amazon Web Services (USA)). Then, a copy of the Stable Diffusion model is created to be retrained with your photos to personalize the model and to create your Avatars. Immediately after the successful generation of Avatars, your original photos are deleted from our servers. Your purchased Avatars are stored on our servers so that they remain accessible to you in LucidAAI at any time and from any device until you decide to delete them.

You can also always request us to delete your photos or Avatars by contacting us at support@spirelabs.io.

Notwithstanding anything to the contrary elsewhere in this Privacy Policy:

We do not use photos, videos or Avatars to identify any individual user.
We do not use your photos, videos or Avatars for authentication, advertising, or marketing purposes, or to otherwise target a user in a similar manner.
We do not use your photos, videos or Avatars to build a user profile, or otherwise attempt, facilitate, or encourage third parties to identify anonymous users or reconstruct user profiles based on your photos, videos or Avatars.
We do not transfer, share, sell, or otherwise provide your photos, videos or Avatars to advertising platforms, analytics providers, data brokers, information resellers or other such parties.

We care about your privacy. With this in mind, most processing activities occur on your device only. There are, however, two exceptions to it: when you apply Art Styles to your photos and when you generate Avatars, since these functions require sophisticated computing resources to be performed.

Art Styles. To apply Art Styles, you have to upload your original photo to Sona AI. At this point, your photo is stored on our servers (provided by Amazon Web Services (USA)). It is needed for your convenience so that you don’t have to re-upload the original photo every time to apply any new Art Style. This also helps you spend less Internet traffic and makes the processing of Art Styled photos faster. We store your original photo on our servers for no longer than 24 hours. After 24 hours your original photo is deleted.
Avatars. In order to generate Avatars, you have to upload 10-20 photos to Sona AI. At this point, your photos are stored on our servers (provided by Amazon Web Services (USA)). Then, a copy of the Stable Diffusion model is created to be retrained with your photos to personalize the model and to create your Avatars. Immediately after the successful generation of Avatars, your original photos are deleted from our servers. Your purchased Avatars are stored on our servers so that they remain accessible to you in LucidAAI at any time and from any device until you decide to delete them.

You can also always request us to delete your photos or Avatars by contacting us at support@spirelabs.io.

Notwithstanding anything to the contrary elsewhere in this Privacy Policy:

We do not use photos, videos or Avatars to identify any individual user.
We do not use your photos, videos or Avatars for authentication, advertising, or marketing purposes, or to otherwise target a user in a similar manner.
We do not use your photos, videos or Avatars to build a user profile, or otherwise attempt, facilitate, or encourage third parties to identify anonymous users or reconstruct user profiles based on your photos, videos or Avatars.
We do not transfer, share, sell, or otherwise provide your photos, videos or Avatars to advertising platforms, analytics providers, data brokers, information resellers or other such parties.

5. THE PURPOSES AND OUR LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

We use your information other than photos and videos for the following purposes:

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Sona AI (e.g., the Terms of Use).
To provide you with support and to respond to your inquiries. If you share your Personal Data (including your name and contact information) to ask a question about Sona AI, we will use that Personal Data to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other users inquiries in relation to Sona AI. It is our legitimate interest to provide you with high-quality support.
To notify you about changes to Sona AI or any products or services we offer or provide through Sona AI, including by sending you technical notices, notices about your account/subscription, including expiration and renewal notices, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt-out of push notifications by changing the settings on your mobile device). It is our legitimate interest to keep you updated on your use of Sona AI.
To present to you and others with Sona AI and its contents and any other information, products or services that you request from us. We do so to provide you with the services according to our contractual obligation.
To monitor aggregated metrics such as total number of users, traffic, and demographic patterns (including via Service Providers as specified in Section 7). It is our legitimate interest to make aggregated analytics of our audience as it helps us understand our business metrics and improve our product.
To provide, improve, test, and monitor the effectiveness of Sona AI in an aggregated manner. It is our legitimate interest to make analytics of our audience as it helps us understand our product and business metrics.
When you choose to use the Avatars feature, you provide your gender identification, which is used to retrain the separate copy of the Stable Diffusion model to generate Avatars based on your particular photos. It is our contractual obligation to ensure that we provide you with the requested service. This data is deleted immediately after the Avatars are successfully generated.
In order to apply Art Styles, for you to use them faster and more conveniently, we store your original photo for 24 hours. After 24 hours your original photo will be deleted.
To provide personalized content and information to you in relation to Sona AI, which could include online ads or other forms of marketing (including via email). We do so upon your explicit consent.
Upon users’ consent, for marketing purposes in order to find audiences similar to our users. For this processing we share, among others, users’ Use details, device information, and in-app purchase details with our third-party advertising partners.
In any other way, as described in this Privacy Policy.

We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or authorized by you in accordance with this Section 5 or collect any Personal Data that is not required for the mentioned purposes (“purpose limitation principle”).

For any new purpose of processing that is not compatible with any of the purposes mentioned above, we will ask for your separate explicit consent.

To the extent necessary for any of the processing purposes, we take all reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete and current. We also undertake to collect only such amount and types of your Personal Data that are strictly required for the purposes mentioned in this Section 5 (“data minimization principle”).

We use your information other than photos and videos for the following purposes:

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Sona AI (e.g., the Terms of Use).
To provide you with support and to respond to your inquiries. If you share your Personal Data (including your name and contact information) to ask a question about Sona AI, we will use that Personal Data to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other users inquiries in relation to Sona AI. It is our legitimate interest to provide you with high-quality support.
To notify you about changes to Sona AI or any products or services we offer or provide through Sona AI, including by sending you technical notices, notices about your account/subscription, including expiration and renewal notices, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt-out of push notifications by changing the settings on your mobile device). It is our legitimate interest to keep you updated on your use of Sona AI.
To present to you and others with Sona AI and its contents and any other information, products or services that you request from us. We do so to provide you with the services according to our contractual obligation.
To monitor aggregated metrics such as total number of users, traffic, and demographic patterns (including via Service Providers as specified in Section 7). It is our legitimate interest to make aggregated analytics of our audience as it helps us understand our business metrics and improve our product.
To provide, improve, test, and monitor the effectiveness of Sona AI in an aggregated manner. It is our legitimate interest to make analytics of our audience as it helps us understand our product and business metrics.
When you choose to use the Avatars feature, you provide your gender identification, which is used to retrain the separate copy of the Stable Diffusion model to generate Avatars based on your particular photos. It is our contractual obligation to ensure that we provide you with the requested service. This data is deleted immediately after the Avatars are successfully generated.
In order to apply Art Styles, for you to use them faster and more conveniently, we store your original photo for 24 hours. After 24 hours your original photo will be deleted.
To provide personalized content and information to you in relation to Sona AI, which could include online ads or other forms of marketing (including via email). We do so upon your explicit consent.
Upon users’ consent, for marketing purposes in order to find audiences similar to our users. For this processing we share, among others, users’ Use details, device information, and in-app purchase details with our third-party advertising partners.
In any other way, as described in this Privacy Policy.

We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or authorized by you in accordance with this Section 5 or collect any Personal Data that is not required for the mentioned purposes (“purpose limitation principle”).

For any new purpose of processing that is not compatible with any of the purposes mentioned above, we will ask for your separate explicit consent.

To the extent necessary for any of the processing purposes, we take all reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete and current. We also undertake to collect only such amount and types of your Personal Data that are strictly required for the purposes mentioned in this Section 5 (“data minimization principle”).

We use your information other than photos and videos for the following purposes:

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Sona AI (e.g., the Terms of Use).
To provide you with support and to respond to your inquiries. If you share your Personal Data (including your name and contact information) to ask a question about Sona AI, we will use that Personal Data to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other users inquiries in relation to Sona AI. It is our legitimate interest to provide you with high-quality support.
To notify you about changes to Sona AI or any products or services we offer or provide through Sona AI, including by sending you technical notices, notices about your account/subscription, including expiration and renewal notices, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt-out of push notifications by changing the settings on your mobile device). It is our legitimate interest to keep you updated on your use of Sona AI.
To present to you and others with Sona AI and its contents and any other information, products or services that you request from us. We do so to provide you with the services according to our contractual obligation.
To monitor aggregated metrics such as total number of users, traffic, and demographic patterns (including via Service Providers as specified in Section 7). It is our legitimate interest to make aggregated analytics of our audience as it helps us understand our business metrics and improve our product.
To provide, improve, test, and monitor the effectiveness of Sona AI in an aggregated manner. It is our legitimate interest to make analytics of our audience as it helps us understand our product and business metrics.
When you choose to use the Avatars feature, you provide your gender identification, which is used to retrain the separate copy of the Stable Diffusion model to generate Avatars based on your particular photos. It is our contractual obligation to ensure that we provide you with the requested service. This data is deleted immediately after the Avatars are successfully generated.
In order to apply Art Styles, for you to use them faster and more conveniently, we store your original photo for 24 hours. After 24 hours your original photo will be deleted.
To provide personalized content and information to you in relation to Sona AI, which could include online ads or other forms of marketing (including via email). We do so upon your explicit consent.
Upon users’ consent, for marketing purposes in order to find audiences similar to our users. For this processing we share, among others, users’ Use details, device information, and in-app purchase details with our third-party advertising partners.
In any other way, as described in this Privacy Policy.

We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or authorized by you in accordance with this Section 5 or collect any Personal Data that is not required for the mentioned purposes (“purpose limitation principle”).

For any new purpose of processing that is not compatible with any of the purposes mentioned above, we will ask for your separate explicit consent.

To the extent necessary for any of the processing purposes, we take all reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete and current. We also undertake to collect only such amount and types of your Personal Data that are strictly required for the purposes mentioned in this Section 5 (“data minimization principle”).

We use your information other than photos and videos for the following purposes:

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Sona AI (e.g., the Terms of Use).
To provide you with support and to respond to your inquiries. If you share your Personal Data (including your name and contact information) to ask a question about Sona AI, we will use that Personal Data to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other users inquiries in relation to Sona AI. It is our legitimate interest to provide you with high-quality support.
To notify you about changes to Sona AI or any products or services we offer or provide through Sona AI, including by sending you technical notices, notices about your account/subscription, including expiration and renewal notices, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt-out of push notifications by changing the settings on your mobile device). It is our legitimate interest to keep you updated on your use of Sona AI.
To present to you and others with Sona AI and its contents and any other information, products or services that you request from us. We do so to provide you with the services according to our contractual obligation.
To monitor aggregated metrics such as total number of users, traffic, and demographic patterns (including via Service Providers as specified in Section 7). It is our legitimate interest to make aggregated analytics of our audience as it helps us understand our business metrics and improve our product.
To provide, improve, test, and monitor the effectiveness of Sona AI in an aggregated manner. It is our legitimate interest to make analytics of our audience as it helps us understand our product and business metrics.
When you choose to use the Avatars feature, you provide your gender identification, which is used to retrain the separate copy of the Stable Diffusion model to generate Avatars based on your particular photos. It is our contractual obligation to ensure that we provide you with the requested service. This data is deleted immediately after the Avatars are successfully generated.
In order to apply Art Styles, for you to use them faster and more conveniently, we store your original photo for 24 hours. After 24 hours your original photo will be deleted.
To provide personalized content and information to you in relation to Sona AI, which could include online ads or other forms of marketing (including via email). We do so upon your explicit consent.
Upon users’ consent, for marketing purposes in order to find audiences similar to our users. For this processing we share, among others, users’ Use details, device information, and in-app purchase details with our third-party advertising partners.
In any other way, as described in this Privacy Policy.

We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or authorized by you in accordance with this Section 5 or collect any Personal Data that is not required for the mentioned purposes (“purpose limitation principle”).

For any new purpose of processing that is not compatible with any of the purposes mentioned above, we will ask for your separate explicit consent.

To the extent necessary for any of the processing purposes, we take all reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete and current. We also undertake to collect only such amount and types of your Personal Data that are strictly required for the purposes mentioned in this Section 5 (“data minimization principle”).

6. YOUR RIGHTS

Access, modification, correction and erasure. You can send us an email at support@spirelabs.io to request access to, modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you. You can also request deletion of your account inside the app, both for iOS and Android users. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

EEA/UK residents. Individuals residing in the European Economic Area (“EEA”) and the United Kingdom (“UK“) have certain statutory rights in relation to their Personal Data including under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR“) and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (SI 2020/1586), as may be amended from time to time (“UK GDPR“) (collectively, the “GDPR“), including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

Access to your Personal Data: You have a right to request information about whether we have any Personal Data about you, to access your Personal Data (including in a structured and portable form) that you have provided to us, when Using Sona AI and that we have about you. You can do this by contacting us.
Rectification of your Personal Data: You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information may affect your experience when Using Sona AI features and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is incomplete or inaccurate, you have a right to contact us and ask us to correct such Personal Data.
Restriction of processing: You also have the right to demand restriction of processing of your Personal Data, for example, if you contest the accuracy of the Personal Data which inaccuracy is verified by us.
Erasure of your Personal Data: If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent, or object to the processing of your Personal Data, or where the processing of your Personal Data does not otherwise comply with the GDPR, or if your Personal Data have to be erased for compliance with a legal obligation under EU or EU member state law, you have the right to contact us and ask us to erase such Personal Data. Please be aware that erasing some Personal Data may affect your ability to Use Sona AI.
Right to portability of your Personal Data: If we process your Personal Data on the basis of your consent, or if this is necessary for the performance of our contract, you have the right to request us to receive any Pesonal Data you provided us in a structured, commonly used and machine-readable format. You may further ask us to give that Personal Data to another party.
Right to object processing or otherwise using your Personal Data: Where we are processing your Personal Data based on our legitimate interest, you may object to the processing or otherwise using your Personal Data. You can do this by contacting us. Please be aware that our inability to process or otherwise use some of your Personal Data may affect your ability to Use Sona AI. If you have opted in to receiving marketing communications, you have the right to opt out of those at ay time.
Right to withdraw your consent at any time: Where you may have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
Right to lodge a complaint with a supervisory authority: Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.

Residents of California, Virginia, Colorado, Utah, and Connecticut may have statutory rights under state comprehensive privacy law including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

Right to request the categories of Personal Information collected about you. Sona AI will provide, where relevant and required by law, the types of data we collect.
Right to request the categories of sources from which your Personal Information is collected. Sona AI will provide, where relevant and required by law, the types of tools and organizations we use to collect data.
Right to request the business or commercial purpose for collecting your Personal Information. Sona AI will provide, where relevant and required by law, the purposes to collect data.
Right to request the categories of third parties to whom Personal Information is disclosed, and the categories of Personal Information disclosed. Sona AI will provide, where relevant and required by law, information regarding the other organizations that may receive your Personal Information.
Right to request the specific pieces of Personal Information collected about you. Sona AI will provide, where relevant and required by law, your Personal Information.
Right to request that Personal Information collected about you be deleted. We may keep Personal Information for legal reasons but will accommodate deletion requests when required. Please be aware that erasing some Personal Data may affect your ability to Use Sona AI.
Request that your inaccurate Personal Information be corrected. If you believe your Personal Information is not correct you may provide Personal Information to replace the erroneous data.
Request that Sona AI does not sell or share your Personal Information. Each state may interpret a “sale” of Personal Information differently, however, if you are a resident of the states above or Nevada and request that your Personal Information not be sold Sona AI will honor that request. Individuals in California may request their information not be shared with any third party.

Please keep in mind that in case of a vague request to exercise any of the aforementioned right we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your user or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.

Please note that we will process your request within 1 month after receiving it. We may extend this period by two months where necessary, taking into account the complexity and number of the requests. If we extend the response period, we will let you know within one month from your request. We will not discriminate against you for exercising your rights under the law.

Opting Out of Promotional Emails

IF REQUIRED BY LAW, WE WILL ASK FOR YOUR CONSENT TO SEND YOU PROMOTIONAL AND MARKETING EMAILS. IF YOU WISH TO OPT-OUT OF OUR PROMOTIONAL AND MARKETING EMAILS, YOU CAN OPT-OUT FROM OUR PROMOTIONAL AND MARKETING EMAIL LIST BY USING ANY OF THE FOLLOWING METHODS:

by following the opt-out links in any marketing email sent to you; or through Sona AI settings on your mobile device; or
by contacting us at any time using the contact details in How to Contact Us Section.

Access, modification, correction and erasure. You can send us an email at support@spirelabs.io to request access to, modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you. You can also request deletion of your account inside the app, both for iOS and Android users. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

EEA/UK residents. Individuals residing in the European Economic Area (“EEA”) and the United Kingdom (“UK“) have certain statutory rights in relation to their Personal Data including under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR“) and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (SI 2020/1586), as may be amended from time to time (“UK GDPR“) (collectively, the “GDPR“), including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

Access to your Personal Data: You have a right to request information about whether we have any Personal Data about you, to access your Personal Data (including in a structured and portable form) that you have provided to us, when Using Sona AI and that we have about you. You can do this by contacting us.
Rectification of your Personal Data: You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information may affect your experience when Using Sona AI features and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is incomplete or inaccurate, you have a right to contact us and ask us to correct such Personal Data.
Restriction of processing: You also have the right to demand restriction of processing of your Personal Data, for example, if you contest the accuracy of the Personal Data which inaccuracy is verified by us.
Erasure of your Personal Data: If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent, or object to the processing of your Personal Data, or where the processing of your Personal Data does not otherwise comply with the GDPR, or if your Personal Data have to be erased for compliance with a legal obligation under EU or EU member state law, you have the right to contact us and ask us to erase such Personal Data. Please be aware that erasing some Personal Data may affect your ability to Use Sona AI.
Right to portability of your Personal Data: If we process your Personal Data on the basis of your consent, or if this is necessary for the performance of our contract, you have the right to request us to receive any Pesonal Data you provided us in a structured, commonly used and machine-readable format. You may further ask us to give that Personal Data to another party.
Right to object processing or otherwise using your Personal Data: Where we are processing your Personal Data based on our legitimate interest, you may object to the processing or otherwise using your Personal Data. You can do this by contacting us. Please be aware that our inability to process or otherwise use some of your Personal Data may affect your ability to Use Sona AI. If you have opted in to receiving marketing communications, you have the right to opt out of those at ay time.
Right to withdraw your consent at any time: Where you may have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
Right to lodge a complaint with a supervisory authority: Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.

Residents of California, Virginia, Colorado, Utah, and Connecticut may have statutory rights under state comprehensive privacy law including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

Right to request the categories of Personal Information collected about you. Sona AI will provide, where relevant and required by law, the types of data we collect.
Right to request the categories of sources from which your Personal Information is collected. Sona AI will provide, where relevant and required by law, the types of tools and organizations we use to collect data.
Right to request the business or commercial purpose for collecting your Personal Information. Sona AI will provide, where relevant and required by law, the purposes to collect data.
Right to request the categories of third parties to whom Personal Information is disclosed, and the categories of Personal Information disclosed. Sona AI will provide, where relevant and required by law, information regarding the other organizations that may receive your Personal Information.
Right to request the specific pieces of Personal Information collected about you. Sona AI will provide, where relevant and required by law, your Personal Information.
Right to request that Personal Information collected about you be deleted. We may keep Personal Information for legal reasons but will accommodate deletion requests when required. Please be aware that erasing some Personal Data may affect your ability to Use Sona AI.
Request that your inaccurate Personal Information be corrected. If you believe your Personal Information is not correct you may provide Personal Information to replace the erroneous data.
Request that Sona AI does not sell or share your Personal Information. Each state may interpret a “sale” of Personal Information differently, however, if you are a resident of the states above or Nevada and request that your Personal Information not be sold Sona AI will honor that request. Individuals in California may request their information not be shared with any third party.

Please keep in mind that in case of a vague request to exercise any of the aforementioned right we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your user or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.

Please note that we will process your request within 1 month after receiving it. We may extend this period by two months where necessary, taking into account the complexity and number of the requests. If we extend the response period, we will let you know within one month from your request. We will not discriminate against you for exercising your rights under the law.

Opting Out of Promotional Emails

IF REQUIRED BY LAW, WE WILL ASK FOR YOUR CONSENT TO SEND YOU PROMOTIONAL AND MARKETING EMAILS. IF YOU WISH TO OPT-OUT OF OUR PROMOTIONAL AND MARKETING EMAILS, YOU CAN OPT-OUT FROM OUR PROMOTIONAL AND MARKETING EMAIL LIST BY USING ANY OF THE FOLLOWING METHODS:

by following the opt-out links in any marketing email sent to you; or through Sona AI settings on your mobile device; or
by contacting us at any time using the contact details in How to Contact Us Section.

Access, modification, correction and erasure. You can send us an email at support@spirelabs.io to request access to, modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you. You can also request deletion of your account inside the app, both for iOS and Android users. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

EEA/UK residents. Individuals residing in the European Economic Area (“EEA”) and the United Kingdom (“UK“) have certain statutory rights in relation to their Personal Data including under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR“) and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (SI 2020/1586), as may be amended from time to time (“UK GDPR“) (collectively, the “GDPR“), including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

Access to your Personal Data: You have a right to request information about whether we have any Personal Data about you, to access your Personal Data (including in a structured and portable form) that you have provided to us, when Using Sona AI and that we have about you. You can do this by contacting us.
Rectification of your Personal Data: You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information may affect your experience when Using Sona AI features and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is incomplete or inaccurate, you have a right to contact us and ask us to correct such Personal Data.
Restriction of processing: You also have the right to demand restriction of processing of your Personal Data, for example, if you contest the accuracy of the Personal Data which inaccuracy is verified by us.
Erasure of your Personal Data: If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent, or object to the processing of your Personal Data, or where the processing of your Personal Data does not otherwise comply with the GDPR, or if your Personal Data have to be erased for compliance with a legal obligation under EU or EU member state law, you have the right to contact us and ask us to erase such Personal Data. Please be aware that erasing some Personal Data may affect your ability to Use Sona AI.
Right to portability of your Personal Data: If we process your Personal Data on the basis of your consent, or if this is necessary for the performance of our contract, you have the right to request us to receive any Pesonal Data you provided us in a structured, commonly used and machine-readable format. You may further ask us to give that Personal Data to another party.
Right to object processing or otherwise using your Personal Data: Where we are processing your Personal Data based on our legitimate interest, you may object to the processing or otherwise using your Personal Data. You can do this by contacting us. Please be aware that our inability to process or otherwise use some of your Personal Data may affect your ability to Use Sona AI. If you have opted in to receiving marketing communications, you have the right to opt out of those at ay time.
Right to withdraw your consent at any time: Where you may have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
Right to lodge a complaint with a supervisory authority: Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.

Residents of California, Virginia, Colorado, Utah, and Connecticut may have statutory rights under state comprehensive privacy law including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

Right to request the categories of Personal Information collected about you. Sona AI will provide, where relevant and required by law, the types of data we collect.
Right to request the categories of sources from which your Personal Information is collected. Sona AI will provide, where relevant and required by law, the types of tools and organizations we use to collect data.
Right to request the business or commercial purpose for collecting your Personal Information. Sona AI will provide, where relevant and required by law, the purposes to collect data.
Right to request the categories of third parties to whom Personal Information is disclosed, and the categories of Personal Information disclosed. Sona AI will provide, where relevant and required by law, information regarding the other organizations that may receive your Personal Information.
Right to request the specific pieces of Personal Information collected about you. Sona AI will provide, where relevant and required by law, your Personal Information.
Right to request that Personal Information collected about you be deleted. We may keep Personal Information for legal reasons but will accommodate deletion requests when required. Please be aware that erasing some Personal Data may affect your ability to Use Sona AI.
Request that your inaccurate Personal Information be corrected. If you believe your Personal Information is not correct you may provide Personal Information to replace the erroneous data.
Request that Sona AI does not sell or share your Personal Information. Each state may interpret a “sale” of Personal Information differently, however, if you are a resident of the states above or Nevada and request that your Personal Information not be sold Sona AI will honor that request. Individuals in California may request their information not be shared with any third party.

Please keep in mind that in case of a vague request to exercise any of the aforementioned right we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your user or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.

Please note that we will process your request within 1 month after receiving it. We may extend this period by two months where necessary, taking into account the complexity and number of the requests. If we extend the response period, we will let you know within one month from your request. We will not discriminate against you for exercising your rights under the law.

Opting Out of Promotional Emails

IF REQUIRED BY LAW, WE WILL ASK FOR YOUR CONSENT TO SEND YOU PROMOTIONAL AND MARKETING EMAILS. IF YOU WISH TO OPT-OUT OF OUR PROMOTIONAL AND MARKETING EMAILS, YOU CAN OPT-OUT FROM OUR PROMOTIONAL AND MARKETING EMAIL LIST BY USING ANY OF THE FOLLOWING METHODS:

by following the opt-out links in any marketing email sent to you; or through Sona AI settings on your mobile device; or
by contacting us at any time using the contact details in How to Contact Us Section.

Access, modification, correction and erasure. You can send us an email at support@spirelabs.io to request access to, modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you. You can also request deletion of your account inside the app, both for iOS and Android users. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

EEA/UK residents. Individuals residing in the European Economic Area (“EEA”) and the United Kingdom (“UK“) have certain statutory rights in relation to their Personal Data including under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR“) and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (SI 2020/1586), as may be amended from time to time (“UK GDPR“) (collectively, the “GDPR“), including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

Access to your Personal Data: You have a right to request information about whether we have any Personal Data about you, to access your Personal Data (including in a structured and portable form) that you have provided to us, when Using Sona AI and that we have about you. You can do this by contacting us.
Rectification of your Personal Data: You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information may affect your experience when Using Sona AI features and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is incomplete or inaccurate, you have a right to contact us and ask us to correct such Personal Data.
Restriction of processing: You also have the right to demand restriction of processing of your Personal Data, for example, if you contest the accuracy of the Personal Data which inaccuracy is verified by us.
Erasure of your Personal Data: If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent, or object to the processing of your Personal Data, or where the processing of your Personal Data does not otherwise comply with the GDPR, or if your Personal Data have to be erased for compliance with a legal obligation under EU or EU member state law, you have the right to contact us and ask us to erase such Personal Data. Please be aware that erasing some Personal Data may affect your ability to Use Sona AI.
Right to portability of your Personal Data: If we process your Personal Data on the basis of your consent, or if this is necessary for the performance of our contract, you have the right to request us to receive any Pesonal Data you provided us in a structured, commonly used and machine-readable format. You may further ask us to give that Personal Data to another party.
Right to object processing or otherwise using your Personal Data: Where we are processing your Personal Data based on our legitimate interest, you may object to the processing or otherwise using your Personal Data. You can do this by contacting us. Please be aware that our inability to process or otherwise use some of your Personal Data may affect your ability to Use Sona AI. If you have opted in to receiving marketing communications, you have the right to opt out of those at ay time.
Right to withdraw your consent at any time: Where you may have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
Right to lodge a complaint with a supervisory authority: Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.

Residents of California, Virginia, Colorado, Utah, and Connecticut may have statutory rights under state comprehensive privacy law including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).

Right to request the categories of Personal Information collected about you. Sona AI will provide, where relevant and required by law, the types of data we collect.
Right to request the categories of sources from which your Personal Information is collected. Sona AI will provide, where relevant and required by law, the types of tools and organizations we use to collect data.
Right to request the business or commercial purpose for collecting your Personal Information. Sona AI will provide, where relevant and required by law, the purposes to collect data.
Right to request the categories of third parties to whom Personal Information is disclosed, and the categories of Personal Information disclosed. Sona AI will provide, where relevant and required by law, information regarding the other organizations that may receive your Personal Information.
Right to request the specific pieces of Personal Information collected about you. Sona AI will provide, where relevant and required by law, your Personal Information.
Right to request that Personal Information collected about you be deleted. We may keep Personal Information for legal reasons but will accommodate deletion requests when required. Please be aware that erasing some Personal Data may affect your ability to Use Sona AI.
Request that your inaccurate Personal Information be corrected. If you believe your Personal Information is not correct you may provide Personal Information to replace the erroneous data.
Request that Sona AI does not sell or share your Personal Information. Each state may interpret a “sale” of Personal Information differently, however, if you are a resident of the states above or Nevada and request that your Personal Information not be sold Sona AI will honor that request. Individuals in California may request their information not be shared with any third party.

Please keep in mind that in case of a vague request to exercise any of the aforementioned right we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your user or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.

Please note that we will process your request within 1 month after receiving it. We may extend this period by two months where necessary, taking into account the complexity and number of the requests. If we extend the response period, we will let you know within one month from your request. We will not discriminate against you for exercising your rights under the law.

Opting Out of Promotional Emails

IF REQUIRED BY LAW, WE WILL ASK FOR YOUR CONSENT TO SEND YOU PROMOTIONAL AND MARKETING EMAILS. IF YOU WISH TO OPT-OUT OF OUR PROMOTIONAL AND MARKETING EMAILS, YOU CAN OPT-OUT FROM OUR PROMOTIONAL AND MARKETING EMAIL LIST BY USING ANY OF THE FOLLOWING METHODS:

by following the opt-out links in any marketing email sent to you; or through Sona AI settings on your mobile device; or
by contacting us at any time using the contact details in How to Contact Us Section.

7. SHARING OF COLLECTED INFORMATION

We do not rent or sell your Personal Data, including photos and videos, to any third parties outside the Company or its Affiliates (as defined below).

Parties with whom we may share your Personal Data.

We may share your Personal Data, and other collected information with third-party organizations such as contractors and service providers that we use to support our business and who are bound by confidentiality and data protection terms (consistent with this Privacy Policy) to keep your Personal Data confidential and use it only based on our instructions (“Service Providers”).

Such Service Providers include:

cloud providers Google Cloud Platform and Amazon Web Services, which we use when you choose to upload your photos or videos to Sona AI,
third-party analytics, as specified in this Privacy Policy,
email delivery services;

For the avoidance of doubt, we do not share or transfer your photos, videos and Avatars to third parties (except temporarily storing your photos, videos and Avatars to our cloud providers Google Cloud Platform and Amazon Web Services to provide online processing function, and thereafter deleting such photos, videos and Avatars as described in this Privacy Policy). We use only secure places of storage, such as Google Cloud Platform and Amazon Web Services. Google LLC and Amazon Web Services, Inc. are located in the United States of America.

What happens in the event of a change of control. If we sell or otherwise transfer part or the whole of the Company or our assets to another organization (e.g., in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation), your Personal Data and any other collected information may be among the items sold or transferred.

Responding to legal requests and preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

We do not rent or sell your Personal Data, including photos and videos, to any third parties outside the Company or its Affiliates (as defined below).

Parties with whom we may share your Personal Data.

We may share your Personal Data, and other collected information with third-party organizations such as contractors and service providers that we use to support our business and who are bound by confidentiality and data protection terms (consistent with this Privacy Policy) to keep your Personal Data confidential and use it only based on our instructions (“Service Providers”).

Such Service Providers include:

cloud providers Google Cloud Platform and Amazon Web Services, which we use when you choose to upload your photos or videos to Sona AI,
third-party analytics, as specified in this Privacy Policy,
email delivery services;

For the avoidance of doubt, we do not share or transfer your photos, videos and Avatars to third parties (except temporarily storing your photos, videos and Avatars to our cloud providers Google Cloud Platform and Amazon Web Services to provide online processing function, and thereafter deleting such photos, videos and Avatars as described in this Privacy Policy). We use only secure places of storage, such as Google Cloud Platform and Amazon Web Services. Google LLC and Amazon Web Services, Inc. are located in the United States of America.

What happens in the event of a change of control. If we sell or otherwise transfer part or the whole of the Company or our assets to another organization (e.g., in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation), your Personal Data and any other collected information may be among the items sold or transferred.

Responding to legal requests and preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

We do not rent or sell your Personal Data, including photos and videos, to any third parties outside the Company or its Affiliates (as defined below).

Parties with whom we may share your Personal Data.

We may share your Personal Data, and other collected information with third-party organizations such as contractors and service providers that we use to support our business and who are bound by confidentiality and data protection terms (consistent with this Privacy Policy) to keep your Personal Data confidential and use it only based on our instructions (“Service Providers”).

Such Service Providers include:

cloud providers Google Cloud Platform and Amazon Web Services, which we use when you choose to upload your photos or videos to Sona AI,
third-party analytics, as specified in this Privacy Policy,
email delivery services;

For the avoidance of doubt, we do not share or transfer your photos, videos and Avatars to third parties (except temporarily storing your photos, videos and Avatars to our cloud providers Google Cloud Platform and Amazon Web Services to provide online processing function, and thereafter deleting such photos, videos and Avatars as described in this Privacy Policy). We use only secure places of storage, such as Google Cloud Platform and Amazon Web Services. Google LLC and Amazon Web Services, Inc. are located in the United States of America.

What happens in the event of a change of control. If we sell or otherwise transfer part or the whole of the Company or our assets to another organization (e.g., in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation), your Personal Data and any other collected information may be among the items sold or transferred.

Responding to legal requests and preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

We do not rent or sell your Personal Data, including photos and videos, to any third parties outside the Company or its Affiliates (as defined below).

Parties with whom we may share your Personal Data.

We may share your Personal Data, and other collected information with third-party organizations such as contractors and service providers that we use to support our business and who are bound by confidentiality and data protection terms (consistent with this Privacy Policy) to keep your Personal Data confidential and use it only based on our instructions (“Service Providers”).

Such Service Providers include:

cloud providers Google Cloud Platform and Amazon Web Services, which we use when you choose to upload your photos or videos to Sona AI,
third-party analytics, as specified in this Privacy Policy,
email delivery services;

For the avoidance of doubt, we do not share or transfer your photos, videos and Avatars to third parties (except temporarily storing your photos, videos and Avatars to our cloud providers Google Cloud Platform and Amazon Web Services to provide online processing function, and thereafter deleting such photos, videos and Avatars as described in this Privacy Policy). We use only secure places of storage, such as Google Cloud Platform and Amazon Web Services. Google LLC and Amazon Web Services, Inc. are located in the United States of America.

What happens in the event of a change of control. If we sell or otherwise transfer part or the whole of the Company or our assets to another organization (e.g., in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation), your Personal Data and any other collected information may be among the items sold or transferred.

Responding to legal requests and preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

8. DATA SECURITY

We use reasonable and appropriate information security safeguards to help keep the collected information secure and to secure it from accidental loss and unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your collected information, we cannot guarantee the security of the collected information transmitted to or through Sona AI or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed. Any transmission of your collected information is at your own risk. We are not responsible for the circumvention of security measures contained in Sona AI. Please understand that there is no ideal technology or measure to maintain 100% security. Among others, we utilize the following information security measures:

Encryption of your Personal Data in transit and in rest.
All collected information is stored on our secure servers behind firewalls.
Organizational and legal measures. For example, our employees and employees of our subsidiaries have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of Sona AI. We impose strict liability on such employees for any disclosures, unauthorized accesses, alterations, destructions and misuse of your Personal Data.
Conducting periodical data protection impact assessments in order to ensure that the Company fully adheres to the principles of “privacy by design”, “privacy by default” and others. We also commit to undertake a privacy audit in case of the Company's merger or takeover.

The safety and security of your information also depend on you. Your privacy settings may also be affected by changes to the social media services, through which you may share your photos and videos. We are not responsible for the functionality, privacy, or security measures of any other organization.

Security breaches: If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email (if it was provided) and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in the Privacy Policy, we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.

If you want to report a security incident related to Sona AI, please contact us at support@spirelabs.io.

Contacting us: You can provide your feedback or report a technical issue by using the ”Send Feedback“ button in Sona AI settings. The email will be sent from your email to support@spirelabs.io, and the message will contain the following diagnostics information that will help us to resolve your issue/address your request:

Phone model
Device OS and version
App version
User device ID
Language
Remaining space

This information is used to assess your feedback and/or identify the problem if you are reporting one and is NOT USED to identify users individually.

Contacting you: If you are using Sona AI you may receive electronic communications from us (e.g., by posting in-app notices in Sona AI, push notifications or emails). These communications may include notices about Sona AI or its in-app subscriptions: e.g., changes/updates to features of Sona AI and their scope, prices of in-app subscriptions, technical and security notices, as well as updates to this Privacy Policy and Sona AI Terms of Use. Upon your consent, we will also share with you our marketing materials about new products, features or offers from Sona AI and its affiliates.

We use reasonable and appropriate information security safeguards to help keep the collected information secure and to secure it from accidental loss and unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your collected information, we cannot guarantee the security of the collected information transmitted to or through Sona AI or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed. Any transmission of your collected information is at your own risk. We are not responsible for the circumvention of security measures contained in Sona AI. Please understand that there is no ideal technology or measure to maintain 100% security. Among others, we utilize the following information security measures:

Encryption of your Personal Data in transit and in rest.
All collected information is stored on our secure servers behind firewalls.
Organizational and legal measures. For example, our employees and employees of our subsidiaries have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of Sona AI. We impose strict liability on such employees for any disclosures, unauthorized accesses, alterations, destructions and misuse of your Personal Data.
Conducting periodical data protection impact assessments in order to ensure that the Company fully adheres to the principles of “privacy by design”, “privacy by default” and others. We also commit to undertake a privacy audit in case of the Company's merger or takeover.

The safety and security of your information also depend on you. Your privacy settings may also be affected by changes to the social media services, through which you may share your photos and videos. We are not responsible for the functionality, privacy, or security measures of any other organization.

Security breaches: If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email (if it was provided) and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in the Privacy Policy, we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.

If you want to report a security incident related to Sona AI, please contact us at support@spirelabs.io.

Contacting us: You can provide your feedback or report a technical issue by using the ”Send Feedback“ button in Sona AI settings. The email will be sent from your email to support@spirelabs.io, and the message will contain the following diagnostics information that will help us to resolve your issue/address your request:

Phone model
Device OS and version
App version
User device ID
Language
Remaining space

This information is used to assess your feedback and/or identify the problem if you are reporting one and is NOT USED to identify users individually.

Contacting you: If you are using Sona AI you may receive electronic communications from us (e.g., by posting in-app notices in Sona AI, push notifications or emails). These communications may include notices about Sona AI or its in-app subscriptions: e.g., changes/updates to features of Sona AI and their scope, prices of in-app subscriptions, technical and security notices, as well as updates to this Privacy Policy and Sona AI Terms of Use. Upon your consent, we will also share with you our marketing materials about new products, features or offers from Sona AI and its affiliates.

We use reasonable and appropriate information security safeguards to help keep the collected information secure and to secure it from accidental loss and unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your collected information, we cannot guarantee the security of the collected information transmitted to or through Sona AI or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed. Any transmission of your collected information is at your own risk. We are not responsible for the circumvention of security measures contained in Sona AI. Please understand that there is no ideal technology or measure to maintain 100% security. Among others, we utilize the following information security measures:

Encryption of your Personal Data in transit and in rest.
All collected information is stored on our secure servers behind firewalls.
Organizational and legal measures. For example, our employees and employees of our subsidiaries have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of Sona AI. We impose strict liability on such employees for any disclosures, unauthorized accesses, alterations, destructions and misuse of your Personal Data.
Conducting periodical data protection impact assessments in order to ensure that the Company fully adheres to the principles of “privacy by design”, “privacy by default” and others. We also commit to undertake a privacy audit in case of the Company's merger or takeover.

The safety and security of your information also depend on you. Your privacy settings may also be affected by changes to the social media services, through which you may share your photos and videos. We are not responsible for the functionality, privacy, or security measures of any other organization.

Security breaches: If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email (if it was provided) and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in the Privacy Policy, we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.

If you want to report a security incident related to Sona AI, please contact us at support@spirelabs.io.

Contacting us: You can provide your feedback or report a technical issue by using the ”Send Feedback“ button in Sona AI settings. The email will be sent from your email to support@spirelabs.io, and the message will contain the following diagnostics information that will help us to resolve your issue/address your request:

Phone model
Device OS and version
App version
User device ID
Language
Remaining space

This information is used to assess your feedback and/or identify the problem if you are reporting one and is NOT USED to identify users individually.

Contacting you: If you are using Sona AI you may receive electronic communications from us (e.g., by posting in-app notices in Sona AI, push notifications or emails). These communications may include notices about Sona AI or its in-app subscriptions: e.g., changes/updates to features of Sona AI and their scope, prices of in-app subscriptions, technical and security notices, as well as updates to this Privacy Policy and Sona AI Terms of Use. Upon your consent, we will also share with you our marketing materials about new products, features or offers from Sona AI and its affiliates.

We use reasonable and appropriate information security safeguards to help keep the collected information secure and to secure it from accidental loss and unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your collected information, we cannot guarantee the security of the collected information transmitted to or through Sona AI or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed. Any transmission of your collected information is at your own risk. We are not responsible for the circumvention of security measures contained in Sona AI. Please understand that there is no ideal technology or measure to maintain 100% security. Among others, we utilize the following information security measures:

Encryption of your Personal Data in transit and in rest.
All collected information is stored on our secure servers behind firewalls.
Organizational and legal measures. For example, our employees and employees of our subsidiaries have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of Sona AI. We impose strict liability on such employees for any disclosures, unauthorized accesses, alterations, destructions and misuse of your Personal Data.
Conducting periodical data protection impact assessments in order to ensure that the Company fully adheres to the principles of “privacy by design”, “privacy by default” and others. We also commit to undertake a privacy audit in case of the Company's merger or takeover.

The safety and security of your information also depend on you. Your privacy settings may also be affected by changes to the social media services, through which you may share your photos and videos. We are not responsible for the functionality, privacy, or security measures of any other organization.

Security breaches: If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email (if it was provided) and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in the Privacy Policy, we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.

If you want to report a security incident related to Sona AI, please contact us at support@spirelabs.io.

Contacting us: You can provide your feedback or report a technical issue by using the ”Send Feedback“ button in Sona AI settings. The email will be sent from your email to support@spirelabs.io, and the message will contain the following diagnostics information that will help us to resolve your issue/address your request:

Phone model
Device OS and version
App version
User device ID
Language
Remaining space

This information is used to assess your feedback and/or identify the problem if you are reporting one and is NOT USED to identify users individually.

Contacting you: If you are using Sona AI you may receive electronic communications from us (e.g., by posting in-app notices in Sona AI, push notifications or emails). These communications may include notices about Sona AI or its in-app subscriptions: e.g., changes/updates to features of Sona AI and their scope, prices of in-app subscriptions, technical and security notices, as well as updates to this Privacy Policy and Sona AI Terms of Use. Upon your consent, we will also share with you our marketing materials about new products, features or offers from Sona AI and its affiliates.

9. DATA RETENTION

Your Personal Data, other than photos, videos and Avatars. Normally, the retention term would be the term of your account existence. It means that we will retain your Personal Data, other than your photos, videos or Avatars, until you delete your account or request us to delete your data (by contacting us at support@spirelabs.io). Please note that deletion of Sona AI application does not imply the deletion of your account and your data!

Your original photos and videos that you upload for editing are processed on your device only and are not stored with our servers unless you choose to apply Art Styles to your photos. In case of applying Art Styles, your original photo is stored on our server for 24 hours. We need it to allow you edit photos more smoothly, so that you do not have to re-upload your original photo multiple times to apply different Art Styles. Moreover, such an approach helps you spend less Internet traffic and makes the processing of Art Styled photos faster.

Your original photos that you upload to generate Avatars are deleted immediately after successful Avatars generation. At the same time, your Avatars are stored on our servers (provided by Google Cloud Platform (Ireland and USA) and Amazon Web Services (USA)) to be available to you at any time from any device until you decide to delete them (e.g., within the app or via a request you send us at support@spirelabs.io).

We may retain your Personal data in connection with your privacy-related requests and communications with us, if any, as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Data, we may continue to retain and use anonymized data previously collected that can no longer be used for personal identification.