Last Modified August 03, 2024
This Privacy Policy intends to provide you with detailed information on how we collect, use, and safeguard your personal information when you use the Dream Companion and its associated services (the “Website” or “Services”).
Please take the time to read this Privacy Policy carefully to understand our policies and practices regarding your personal information. Before accessing or using the Website or Services, you will have to carefully review and agree to this Privacy Policy.
We may update this Privacy Policy from time to time to reflect changes in our data practices or for other operational, legal, or regulatory reasons. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at info@mydreamcompanion.com.
GDPR
If you are a resident of the European Union, you are entitled to enhanced rights and protection provided by the General Data Protection Regulation 2016/679, commonly referred to as GDPR. These rights include, but are not limited to, transparency regarding the processing of your personal data, the right to access and rectify your information, the right to erasure, the right to restrict processing, and the right to data portability. We are committed to upholding these rights and ensuring compliance with the GDPR in our handling of your personal data.
Definitions
At Dream companion, we are committed to respecting your privacy. In this document, we provide clear information on how your data is processed when you visit the Website and when you use our Services.
At any time, please refer to the following definitions:
Content: means the information that you will provide us with, so that we can register you as a User and the information you will upload on our Platform, such information shall include your Personal Data and the discussions with the AI Companions;
Consent: means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to you;
Performance of our Services: means the actions necessary for us to provide our Services;
Personal Data: means any information relating to you, as an identified person, directly or indirectly, such as your name, address, marital status, date of birth, gender, office location, position, company name, spoken languages, photos, your identification number, your location data, or factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity, your networks and connections made available to us, or obtained on your behalf and any personal information you would provide us with;
Platform: means the Website, App(s), and Services.
Processing: means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Services: means all the steps for enabling you to chat with the AI Companions;
Subscription: means an arrangement between Dream Companion and you to enable you to benefit from and / or use the Services;
User, you and your: collectively mean a person or company that has visited or is using the Website, App(s) and/or Services;
Visitor: means anyone who is browsing the Website without a valid Subscription;
Website: means mydreamcompanion website available at: https://www.mydreamcompanion.com/.
Purpose of Personal Data Processing
When you visit the Website, we will collect information for the following purposes:
Analyzing and understanding your behavior on the Website;
Performing our Services;
Making improvements to the Website and Services;
Enabling us to enhance, customize, or modify our communications;
Improving data security;
Determining whether marketing campaigns are effective.
We use third-party services, including Meta Pixel, Meta CAPI, Google Ads Conversion Tracking, Google Analytics 4, TikTok Pixel, TikTok CAPI, Snapchat Pixel, Snapchat CAPI, Reddit Pixel, Juicy Ads Pixel, Juicy Ads Pixel, Juicy Ads CAPI, Trafficjunky Pixel and Hotjar, to collect and analyze data about user interactions with our Website and Services. This data is used to understand user behavior, optimize the user experience, and improve marketing efforts.
When registering and using our Services
After a free test of a few conversations, you will be asked to register so we can identify you. At this stage, we receive and store any information you enter on the Website or that you provide us with in any other way. The types of Personal Data collected may include (but are not limited to) your name, date of birth, usage information regarding your use of our Services, and browser information.
The Personal Data you provide is used for purposes such as allowing you to set up a User account and profile that can be used to interact with the AI Companions. We may also draw upon this Personal Data to adapt the Services to your needs and to develop new tools.
When you use the Platform, we automatically receive and record information on our server logs from your browser or mobile, including your location, IP address, cookie information, and the page you requested. We treat this data as non-Personal Data, except where we are required to do otherwise under applicable law. We only use this data in aggregate form. We may provide this information to our partners about how our customers, collectively, use the Website and the Platform.
If you fail to provide your Personal Data, we may not be able to perform the Services pursuant to the Subscription. In this case, we may have to cancel the Service, provided that we will notify you if this is the case at the time.
AI-Generated Content and Data Privacy
We use advanced artificial intelligence to generate content and facilitate user interactions with AI Companions. All AI-generated content and personal conversations are processed and stored securely using robust encryption protocols. Personal data and conversations are treated with strict confidentiality. Our systems are designed to ensure that personal data is not accessed, disclosed, altered, or destroyed without explicit authorization. This data is used solely for enhancing and personalizing the user experience and for improving our AI models to provide more accurate and engaging interactions. We employ advanced security measures, including encryption, access controls, and regular security audits, to protect the integrity and confidentiality of your data.
Use of Data for AI Improvement
We may use user data to continuously improve our AI and services. This includes analyzing interactions to refine AI responses and develop new features that better meet user needs. User data used for these purposes is anonymized or aggregated, ensuring that individual users cannot be identified. By using aggregated and anonymized data, we are able to enhance the performance and accuracy of our AI while maintaining the highest standards of user privacy. Our goal is to leverage this data to deliver a superior and more intuitive user experience, ensuring that our AI evolves to meet the diverse needs of our users.
Transparency on Data Storage and Security
We retain user data only as long as necessary to fulfill the purposes for which it was collected, including to comply with any legal, accounting, or reporting requirements. To protect your personal data, we implement industry-standard security measures, including but not limited to encryption, firewalls, secure access protocols, and regular vulnerability assessments. Our data storage practices are designed to ensure that your information is kept secure throughout its lifecycle, from the moment it is collected until it is securely deleted. We conduct regular security audits and assessments to identify and mitigate potential risks to your data.
User Rights
Users have the right to access, rectify, and delete their personal data. You can request access to the personal data we hold about you, correct any inaccuracies, and request the deletion of your data at any time. We are committed to ensuring these rights are upheld in accordance with applicable laws and regulations. If you wish to exercise any of these rights, please contact us at info@mydreamcompanion.com. We will respond to your request promptly and will work with you to address any concerns you may have about your data. Additionally, you have the right to object to the processing of your data and to request the restriction of processing under certain circumstances. We are dedicated to ensuring that your rights are fully respected and protected.
You give your Consent to the Processing of your Personal Data for the following specific purposes:
Processing is necessary for the performance of the Services pursuant to a Subscription.
We Process your Personal Data because it is necessary:
For the Performance of our Services
To provide you with confirmation regarding the Subscription
To deal with any complaint or request you may have
For any other purpose for which you provide us with your Personal Data
For the administration and management of our business and
To perform marketing analysis and to conduct market research.
3.1 Personal Data Collection for Visitors
The Website can be visited anonymously. The Website may process anonymous metadata through cookies such as the URL of the requested file, the amount of data transferred, the date and time of the request from the User, Internet browser information, operating system type, the IP address of the used device, the Internet service provider, reference links such as user clicks on certain links. This metadata cannot be used by the Website to obtain personally identifiable information. This information is only used for general purposes, such as technical improvements, statistical and marketing analysis.
When you visit the Website, we may automatically receive some information that identifies, for each page accessed:
The type of browser and operating system you have used
The IP (Internet Protocol) address of the device which has accessed it (example PC, tablet)
The date and time of your visit to the Website
The address of your server
The previous website visited
The average duration of page view
The navigation behavior and preferences of the user.
3.2 Personal Data Collection for Users
We use different methods to collect Personal Data from and about you, including through:
From the information you provide to us when you register for a Subscription
From the Content you provide to us via your personal account on the Website
When you communicate with us in writing, by telephone, fax, website registration, email, or other forms of electronic communication. In this respect, we may monitor, record and store any such communication
Automated technologies or interactions. As you interact with the AI Companions, we may automatically collect technical data about your equipment, browsing actions and patterns. Our moderation team checks that you are in compliance with law and we collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies and
Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below technical data from the following parties
Analytics providers such as Google Analytics
Advertising networks/agencies and Search information providers.
We may send you marketing about services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters, and invitations to events or functions which we believe might be of interest to you or to update you with information (such as legal or commercial news) that we believe may be relevant to you. We may communicate this to you in a number of ways including by post, telephone, email, or other digital channels.
We will get your express opt-in consent before we share your Personal Data with any company outside Miracle AI UG (haftungsbeschränkt) for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website or third-party websites and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.
We use various cookies on the Website to improve your experience and to enhance the performance of our Services. Cookies are small text files stored on your device when you access our Website. We use two types of cookies:
Session Cookies: These are temporary cookies that remain in your browser's cookie file while you are visiting our Website and are automatically deleted when you close your browser.
Persistent Cookies: These remain in your browser's cookie file for much longer (though how long will depend on the lifetime of the specific cookie).
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.
Email Marketing
We use Klaviyo to send marketing emails to our users. By providing your email address, you consent to receive promotional emails from us through Klaviyo. These emails may include information about our products, services, special offers, events, and other updates we believe may be of interest to you. This consent applies to customers outside of New Zealand, the EU, and Great Britain.
Types of Emails You May Receive
When you provide your email address, you can expect to receive:
Managing Your Preferences
You have control over your email preferences and can manage them at any time. If you wish to stop receiving marketing emails from us, you can opt out by:
Data Privacy and Security
We are committed to protecting your privacy and ensuring the security of your personal data. Your email address and other personal information will be handled in accordance with our Privacy Policy. We use industry-standard security measures to protect your data from unauthorized access, disclosure, alteration, or destruction.
Third-Party Services
Our marketing emails may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these third-party sites. Please review their privacy policies before providing any personal information.
Frequency of Emails
We strive to send emails at a reasonable frequency to keep you informed without overwhelming your inbox. However, the exact frequency may vary based on your interactions and preferences.
Consent Withdrawal
You can withdraw your consent to receive marketing emails at any time by using the unsubscribe link in our emails or contacting our support team. Once we receive your request, we will promptly remove you from our marketing list.
Contact Information
If you have any questions or concerns about our email marketing practices, please contact us at:
Data Privacy
We respect your privacy and are committed to protecting your personal information. Any data collected for email marketing purposes will be handled in accordance with our Privacy Policy. Klaviyo, as our email marketing service provider, adheres to strict privacy and data protection standards to ensure your information is secure.
Data Collection and Use:
Data Sharing:
Data Security:
Compliance with Regulations
We adhere to all relevant regulations and guidelines regarding email marketing, including the CAN-SPAM Act and GDPR. This means we:
Contact Us
If you have any questions or concerns about our email marketing practices, please contact us at:
For more information on how we handle your personal data, please refer to our Privacy Policy.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your information with:
Service providers we work with to deliver the Services
Our professional advisers where it is necessary for us to obtain their advice or assistance including lawyers, accountants, IT, or public relations advisers
Legal and regulatory authorities, as required by applicable laws and regulations and Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at info@mydreamcompanion.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made multiple requests. In this case, we will notify you and keep you updated.
We reserve the right to update this privacy policy at any time. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at info@mydreamcompanion.com.
You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us in the first instance.