Privacy Policy

MFATECH ("we," "us" or "our") takes your privacy seriously. This Privacy Policy ("Privacy Policy") explains our data protection policy and describes the types of information we may process when you install and/or use the "ChatMira" software application for mobile devices and web (the "App").

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

Our Privacy Policy applies to all users, and others who access the App ("Users").

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

By entering any User Content (Input Content) and/or choosing an AI model in the App, you explicitly consent to the transfer of such data to the third-party AI service providers listed in Section IV for the sole purpose of generating the AI response. We engage these providers to process and create AI-generated User Content based on your inputs.

There are several categories of information that can be processed.

Functional Information

We ask for and process the following information when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App.

• Account Information: When you create an account, your email address, authentication provider information (Apple, Google), and device identifier are collected. We use your email address to identify your subscription purchases and manage your account.
• User Content: The text you enter into the message field, files you attach and send to the App, as well as any text or other content generated by AI via the App. Subject to your compliance with our Terms of Use, you may use your User Content for your own purposes. However, any use of User Content is at your sole risk.
• Contact and Support Information: Name, email address, and any other content included when you contact us via email or support form. We use this information to respond to your inquiries and fulfill your requests.

Please note that we engage third-party AI service providers — OpenAI, Anthropic, and Google — for the purpose of processing and creation of AI-generated User Content. By voluntarily entering any User Content and/or choosing an AI model in the App, you explicitly consent to the transfer of such data to the specific third-party AI service provider associated with the AI model you selected.

The data transferred is strictly limited to: (1) User Content: the text you voluntarily enter and any files you attach/send; and (2) Anonymized Message Identifier: a technical identifier required solely for processing the request and generating the response.

If you do not wish to share data with AI services, please do not input any content into the chat interface. If you do not wish to share your data with a specific third-party AI service provider, you may select a different provider via the App's settings before sending your message.

Information That Is Processed Automatically

When you use the App, certain information may be processed automatically:

• Device Details: Type of device, operating system version, model, screen size, device memory usage, battery life, and other device-specific information.
• Connection Information: Network type, IP address, timestamp and duration of sessions.
• Location-Related Information: Country code, region, city associated with your device, language setting, time zone.
• Log File Information: Automatically recorded when you use the App, including time and date of use and how you interact with the App.
• In-App Events: App usage patterns, feature interactions, session duration, and progression events.

Memory & Personalization Data

When the Memory feature is enabled, ChatMira may store contextual information from your conversations to provide personalized responses. This data is stored encrypted on our servers. You have full control to view, delete individual memories, or disable this feature entirely from your settings.

Payment Information

Our e-commerce provider (Apple) is responsible for billing, processing and charging for in-app purchases, handles your personal information and keeps it absolutely safe and secure. We cannot access or use your credit or debit card information.

We use your information for the following purposes:

• (a) To make our service available. We use functional information and automatically processed information to provide you with all requested services.
• (b) To improve, test and monitor the effectiveness of our App. We use automatically processed information to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.
• (c) To communicate with you. We use your contact information to send you service updates, security alerts, and support messages, receive your feedback, and let you know about our policies and terms.
• (d) To prevent fraud and spam, to enforce the law. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Use.

Your data is never used for advertising purposes or shared with third-party advertising networks. We do not sell any of your personal data to third parties.

If any new purposes for processing your personal data arise, we will let you know by introducing the corresponding changes to this Privacy Policy.

We will share your information with third parties only in the ways that are described in this Privacy Policy. We will not rent or sell your personal data to any third parties.

We confirm that all third-party AI service providers listed below provide the same or equal protection of user data as stated in this Privacy Policy and as required by applicable laws. However, we cannot guarantee the security of any information transmitted from us to any such third party.

We may engage the following third-party service providers:

We may disclose your personal information if needed for objective reasons, due to the public interest or in other unforeseen circumstances: as required by law; when we believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; if we are involved in a merger, acquisition, or sale of all or a portion of our assets.

We work in the cross-border area and provide our App to Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

We try to make sure that the recipient of any personal data provides proper protection of the personal data received, in accordance with current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country or international organization.

We take your privacy seriously and, therefore, encrypt your personal data before sending it to hosting organizations for storage purposes. We cooperate only with hosting organizations that have passed our security and reliability checks.

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period if information is necessary to comply with legal obligations (taxation, accounting, audit) or to maintain safety and data backup settings, prevent fraud or other malicious acts.

When you delete your account, all personal data is permanently removed from our servers within 30 days.

Applicable data protection laws give you certain rights regarding your personal information:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct, change, update or rectify your data.
• Data Retention and Deletion. You have the right to ask to delete all or some of the personal data that is held about you.
• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.
• Right to know about data sharing. You have the right to know whether your data is shared with third parties.

Under KVKK (Turkish Personal Data Protection Law No. 6698) and GDPR, you additionally have the right to know whether your personal data is being processed, the purpose of processing, the right to data portability, and the right to object to decisions based on automated processing.

To exercise any of these rights, please contact us at [email protected]. Your requests will be responded to within 30 days.

You also have the right to lodge a complaint with your local data protection or supervisory authority if you reasonably believe that your rights under applicable data protection laws have been breached.

Opt-out of Tracking

You can manage your activity tracking permissions on your device. Go to Settings > Privacy & Security > Tracking, then tap to turn off or turn on permission to track for a specific app. You can also disable the "Allow Apps to Request to Track" switch to prevent apps from accessing your device's Advertising Identifier.

Opt-out of Location Data Processing

If you do not want third-party service providers to use your location data, turn Location Services off for the App via Settings > Privacy > Location Services, then select the App and set the status to "Never".

Opt-out of Memory Feature

You can disable the Memory feature at any time from the App's settings. When disabled, no contextual data from your conversations will be stored. You can also delete individual memories from the Memory management screen.

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We implement appropriate technical and organizational measures designed to implement data-protection principles such as data minimization.

Server communication is encrypted via TLS/SSL protocols. Memory data is stored with AES-256 encryption. Device identifiers are hashed before storage. We seek your personal data to be encrypted with proper and strong encryption algorithms.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

Our App is not intended for children under the age of 13. We do not knowingly or intentionally collect or solicit any personal information from children. No one under the age of 13 is allowed to directly provide any personal information to the App.

Users aged 13–18 may use the application only with parental or legal guardian consent. The holders of parental responsibility are solely liable for preventing their children from providing personal information via the App without relevant verifiable parental consent.

If we learn that we have collected personal information from a child without verification of parental responsibility, we will erase that information as quickly as possible. If you reasonably believe that we might have any information from or about a child, please contact us immediately.

This Privacy Policy is updated regularly. Whenever we change this Privacy Policy, we will post those changes to this Privacy Policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

Continuing to use the App after changes means you accept the updated policy. The most current version is always accessible from within the App or at chatmira.com/privacy.

If you have any questions about this Privacy Policy, please feel free to contact us:

• Email: [email protected]
• Website: chatmira.com

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