01Data controller
The controller of personal data collected through the SpiriIA platform and services is VELTYZ GROUP LLC (contact: admin@spiriia.com).
02Data we collect
When you use SpiriIA, we collect and process the following categories of data:
- Account and identification data: e-mail address, unique user identifier (UUID), display name, phone number (for messaging channels such as WhatsApp, Telegram, SMS or any other channel SpiriIA offers), hashed password.
- AI interaction data & content: text, prompts, voice recordings and files, and exchanges entered or transmitted in the conversation interfaces.
- Payment and subscription data: payment status, transaction identifiers, amount and currency, plan and subscription status (including renewal and cancellation dates), your payment-related support requests, your consent choices (recurring payment, one-click payment, marketing) and an indicator of whether a payment method has been saved with Stripe. We never receive or store your card number: it is entered on a payment page hosted by the payment provider.
- Technical and browsing data: IP address (anonymised), browser type, identifiers of the messaging channel you use (WhatsApp, Telegram, Discord, Messenger, Instagram, SMS, web chat, or any other messaging channel SpiriIA offers), error logs, and timestamps natively attached to messages.
03Purposes and legal bases for processing
- Providing the service (performance of the contract): generating personalised text, voice and visual responses.
- Managing subscriptions and credits (performance of the contract): transmission to the payment providers (Stripe, PayPal and Inflowpay, the latter acting as Merchant of Record for payments made through it) to process payments, validate access, manage automatic renewals and track credit balances.
- Payment-related messages (performance of the contract): renewal reminders sent in the chat before each charge, receipts and payment support. These are transactional messages, not marketing.
- Fraud prevention (legitimate interest): strong authentication (3-D Secure) requested for a first purchase and from USD 100; ceilings and frequency limits may be applied.
- One-click payment (consent): saving your card with Stripe (never with SpiriIA) for later purchases in one click. Your consent is explicit and you may withdraw it at any time with the /remove_card command (or menu entry) in the chat or by contacting support.
- Marketing (consent): marketing messages are sent only with a separate, optional consent, which you may withdraw at any time with the /marketing command in the chat. Refusing or withdrawing it affects neither your use of the service nor transactional messages.
- Payment disputes and accounting (legitimate interest — defence of legal claims; legal obligation): providing payment providers and banks with the evidence needed to respond to a chargeback (delivery, acceptance of the Terms of Sale, history) and retaining transaction records.
- Security and archiving (legal obligation & legitimate interest): detecting abuse, preventing fraud and securely archiving your consent.
05Technical sub-processors & international transfers
To operate the service, VELTYZ GROUP LLC relies on the following categories of technical sub-processors:
- Payment providers: Stripe, PayPal, Inflowpay (INFLOW PAY, acting as Merchant of Record for payments made through Inflowpay). Payment pages are hosted by the provider; each provider also processes your data under its own privacy policy.
- Database: Supabase.
- Generative AI engines (text, voice, image): OpenAI (GPT, Whisper), Google (Gemini), Anthropic (Claude), Mistral AI, Meta (Llama), FLUX, Suno, Stable Audio, Midjourney, ElevenLabs, Runway.
- Interface & messaging platforms: Meta (WhatsApp Business API, Messenger, Instagram), Telegram, Discord, and any other messaging channel SpiriIA offers.
- Telephony & SMS: Telnyx, where an SMS or voice channel is enabled.
- Website hosting & domains: Hostinger International Ltd.
- Automation & orchestration services: n8n, Traefik, Docker.
- Transactional e-mail & support: Gmail (support e-mails), Brevo, Google Workspace, SendGrid, Mailchimp, Resend.
- Encrypted utility services (third-party APIs): calls to third-party contextual information services (weather data, currency conversion) are executed in a strictly anonymised manner, without transmitting directly identifying data.
All data transfers outside the European Economic Area are governed by the EU-US Data Privacy Framework (DPF) and/or the European Commission's Standard Contractual Clauses (SCCs).
Several of these sub-processors, as well as VELTYZ GROUP LLC itself (established in the United States), may process data outside the European Economic Area, in particular in the United States. This concerns notably Stripe, PayPal, OpenAI, Google, Anthropic, Meta (WhatsApp) and Telegram. Inflowpay is established in the European Union.
Prompts and conversations are transmitted to AI model providers through secure APIs covered by no-retention clauses. Your personal exchanges are never used or sold to train or improve third-party public AI models.
06Sensitive data
SpiriIA is a tool for entertainment and personal development, not a medical service, and it does not ask you for health data. If you choose to talk about topics that data-protection laws treat as sensitive (health, beliefs, sexual orientation…), they are retained in SpiriIA’s long-term memory only with your explicit consent (Article 9(2)(a) GDPR), which you can give, refuse or withdraw at any time with the /sensitive command. Criminal convictions and offences are never stored. Full details: Sensitive data.
07Your rights (GDPR / international rights)
You have the right to access, rectify, erase (the "right to be forgotten"), restrict, port and object to the processing of your personal data.
All requests should be sent by e-mail to admin@spiriia.com.
You may withdraw any consent you have given (marketing, one-click payment) at any time, without affecting the lawfulness of processing carried out before the withdrawal. For marketing, use the /marketing command in the chat; for one-click payment, use the /remove_card command (or menu entry) in the chat or contact support.
For the detailed deletion procedure, see our Data deletion page.
