Chiaro AI

Privacy Policy

Privacy Policy

Table of Contents

  1. Introduction
  2. Data Controller Information
  3. What Data We Collect
  4. How We Use Your Data
  5. Legal Basis for Processing
  6. Data Sharing and Third Parties
  7. Data Storage and Security
  8. Your Rights
  9. Children's Privacy
  10. International Data Transfers
  11. California Privacy Rights
  12. Changes to This Policy
  13. Contact Us
  14. Changelog

1. Introduction

Welcome to Chiaro AI ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App"). Please read this privacy policy carefully. By using the App, you agree to the collection and use of information in accordance with this policy.

2. Data Controller Information

Data Controller: Anatoly Terentyev

Email: [email protected]

3. What Data We Collect

3.1 Camera and Photos

  • Data Collected: Photos you take or select from your library
  • Purpose: To analyze landmarks, artworks, and provide contextual information
  • Legal Basis: Legitimate interest in providing core app functionality
  • Retention: Photos are processed in real-time and not stored on our servers.

3.2 Location Data

  • Data Collected: Precise GPS coordinates, location metadata, city preferences
  • Purpose: To provide location-specific information and recommendations
  • Legal Basis: Consent (you can disable location services)
  • Retention: Location data is stored locally with your conversation history

3.3 User Preferences

  • Data Collected: City, language, theme settings, position sharing preferences
  • Purpose: To personalize your app experience
  • Legal Basis: Legitimate interest in providing customized services
  • Retention: Until you change preferences or delete the app

3.4 Usage Analytics

  • Data Collected: Daily counts, audio guide usage, app session data
  • Purpose: To enforce usage limits and improve our services
  • Legal Basis: Legitimate interest in service management
  • Retention: Daily counters reset every 24 hours

3.5 Device Information

  • Data Collected: Device type, OS version, app version, region settings
  • Purpose: To ensure app compatibility
  • Legal Basis: Legitimate interest in technical functionality
  • Retention: Duration of app usage

3.6 Conversation Data

  • Data Collected: Questions, AI responses, conversation metadata
  • Purpose: To maintain conversation history
  • Legal Basis: Contract performance
  • Retention: Until you delete conversations or uninstall the app

3.7 Purchase Information

  • Data Collected: Subscription status, purchase transactions
  • Purpose: To manage premium features and subscriptions
  • Legal Basis: Contract performance
  • Retention: Duration of subscription plus 3 years

3.8 Identifiers (for tracking)

  • Data Collected: Apple IDFA (if granted), device identifiers
  • Purpose: Personalized advertising, campaign measurement, and attribution
  • Legal Basis: Consent (you will be asked via Apple's AppTrackingTransparency prompt)
  • Retention: As determined by our advertising partners, typically up to 24 months

4. How We Use Your Data

We use the collected data for:

  • Service Delivery: Analyzing photos, providing location-based information
  • Personalization: Remembering your preferences and conversation history
  • Service Improvement: Understanding usage patterns to enhance features
  • Security: Preventing fraud and unauthorized access
  • Legal Compliance: Meeting our legal obligations
  • Communication: Sending important app updates (with your consent)
  • Advertising & Marketing: If you grant permission, we and our partners use device identifiers to deliver personalized ads and measure their effectiveness across apps and websites

5. Legal Basis for Processing

Under GDPR, we process your data based on:

  • Consent: For location services and optional features
  • Contract: To provide the services you've requested
  • Legitimate Interests: For service improvement and security
  • Legal Obligation: When required by law

6. Data Sharing and Third Parties

We share data with:

  • Anthropic Claude API: For AI-powered responses (text only, no images)
  • Supabase: For secure cloud storage of app configuration
  • RevenueCat: For subscription management
  • Apple StoreKit: For processing in-app purchases
  • Apple CloudKit: For syncing preferences across devices
  • Core Location Services: For GPS functionality

Important Note:

  • We may share certain identifiers (such as Apple's Identifier for Advertisers (IDFA) or similar device identifiers) with third-party partners for advertising and measurement purposes
  • These partners may use the data to track your activity across apps and websites they do not own
  • We do NOT sell your personal data for monetary compensation

7. Data Storage and Security

  • Local Storage: Most data is stored locally on your device
  • Cloud Storage: Limited server-side storage for API configurations
  • Encryption: All data transmissions use TLS/SSL encryption
  • Access Controls: Strict authentication for server communications
  • No Image Storage: Photos are processed in memory, never stored on servers

8. Your Rights

8.1 GDPR Rights (EU/UK Users)

  • Access: Request a copy of your data
  • Rectification: Correct inaccurate data
  • Erasure: Request deletion of your data
  • Restriction: Limit how we process your data
  • Portability: Receive your data in a portable format
  • Objection: Object to certain processing activities

8.2 How to Exercise Your Rights

  • In-App: Use Settings → Privacy to manage preferences
  • Data Deletion: Settings → Delete All Data
  • Apple Data Request: Settings → Request My Data
  • Contact Us: Email [email protected] for assistance

9. Children's Privacy

We do not knowingly collect data from children under 13 (or 16 in the EU). If you believe we have collected data from a child, please contact us immediately at [email protected].

10. International Data Transfers

  • API calls to Anthropic may process data in the United States
  • We ensure appropriate safeguards through encryption and minimal data transfer

11. California Privacy Rights

11.1 CCPA Rights

California residents have the right to:

  • Know what personal information is collected
  • Know if personal information is sold or disclosed
  • Say no to the sale of personal information
  • Access their personal information
  • Equal service and price

11.2 Categories of Information Collected

  • Identifiers: Device ID, location data
  • Internet Activity: App usage data
  • Geolocation Data: GPS coordinates
  • Visual Information: Photos (processed locally)

We do not sell personal information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

  • Posting the new Privacy Policy in the app
  • Updating the "Last Updated" date
  • Sending an in-app notification for material changes

13. Contact Us

For privacy-related questions or to exercise your rights:

Email: [email protected]

Response Time: We aim to respond within 30 days.

14. Changelog

Version 1.0 - July 30, 2025

Initial privacy policy publication

Apple App Store Additional Disclosures

Data Used to Track You

  • Identifiers (Advertising ID)
  • Usage Data (interactions with ads)

Data Linked to You

  • Location (if enabled)
  • Usage Data
  • Identifiers

Data Not Linked to You

  • Diagnostics (if shared with Apple)

Privacy Nutrition Label

  • Location: Used for location-based recommendations
  • Identifiers: Used for subscription status
  • Usage Data: Used for analytics and improvement
  • User Content: Photos processed locally

This privacy policy is provided in English. Translations may be available, but the English version shall prevail in case of any discrepancy.

Document Information

Last Updated: July 30, 2025

Effective Date: July 30, 2025

Anatoly Terentyev

Email: [email protected]

Data Controller: Anatoly Terentyev

Email: [email protected]