PRIVACY POLICY PASSIONLAB AI – PRIVACY POLICY Last Updated / Effective Date: 01 Feb 2026 App Name: PassionLab AI Controller: Yusuf Dogan (operating as “PassionLab AI”) (“we”, “us”, “our”) Contact: [email protected] This Privacy Policy explains how we collect, use, disclose, and protect personal data when you use PassionLab AI, and the choices and rights available to you. By using the App, you understand that we will process your data as described in this Policy. Some features (such as voice features, microphone access, notifications, and photo access) require device permissions and/or consent. If you do not grant permissions, certain features may be limited or unavailable. You can manage permissions at any time in your device settings, and the App respects your device-level permission choices. AGE REQUIREMENT (18+) PassionLab AI is intended only for users who are 18 years of age or older. We do not knowingly collect personal data from individuals under 18. If you believe a person under 18 has provided personal data to us, please contact us and we will take appropriate steps. PERSONAL DATA WE PROCESS To provide the App, maintain security, and improve service quality, we may process the following categories of personal data: 2.1) Account and Identity Data Email address, username, and other account information you provide Sign-in method (e.g., Sign in with Apple / Google) 2.2) Profile and Preference Data Display name / nickname Age and/or date of birth Gender and relationship preferences (optional; if provided, used to personalize your experience) App settings (e.g., language/theme preferences) 2.3) Content Data Messages and interaction history with bots Message content and related technical/metadata (e.g., timestamps, delivery status) 2.4) Voice Feature Data Audio input captured via microphone when you use voice features (to provide the feature) Voice session transcripts (where generated as part of the feature) and technical session data (e.g., connection setup, session parameters, diagnostic signals) Note: Microphone access is controlled by your device permission settings. 2.5) Media Data Profile photo or other images you upload for profile updates 2.6) Technical and Usage Data Device model, operating system version, app version IP address (server logs) Crash logs, performance records, and diagnostic data (including network request logs and error reports) 2.7) Notification Data Push notification tokens (e.g., APNs/FCM token) Notification preferences 2.8) Purchase / Subscription Data Verification data related to subscriptions and in-app purchases made via Apple App Store / Google Play (e.g., transaction/product identifiers, verification result) Entitlements derived from verification (e.g., subscription tier, limits) Payment information (e.g., credit card details) is not collected or stored by PassionLab AI. Payments are processed by the relevant app stores. 2.9) Advertising / Attribution Data (if enabled) If we enable advertising and/or third-party attribution/measurement (e.g., Meta and/or an attribution provider such as AppsFlyer), we may process: Advertising identifiers (e.g., Apple IDFA where permitted, Google Advertising ID/GAID) Device and app identifiers used for attribution (e.g., IDFV on iOS, attribution SDK identifiers) Campaign and ad interaction data (e.g., install source, campaign IDs, ad clicks/impressions when available) Events used to measure performance (e.g., app install, app opens, and in-app events you choose to send for measurement) DEVICE PERMISSIONS The App may request the following permissions to provide features: Microphone: voice features Photo Library / Media: selecting/uploading a profile image Notifications: message/interaction updates You can manage these permissions at any time in your device settings. Disabling permissions may limit the related features. 3.1) App Tracking Transparency (iOS) (if enabled) If we use third-party advertising or attribution partners in a way that qualifies as “tracking” under Apple’s definition, iOS may display an App Tracking Transparency (ATT) permission prompt. If you decline, we will not access the device’s advertising identifier (IDFA) and attribution may be more limited. PURPOSES OF PROCESSING We may process personal data for the following purposes: Account creation, authentication, and session management Providing and maintaining the bot chat experience, including personalization and continuity Operating voice features, including technical delivery and troubleshooting Verifying purchases/subscriptions and managing entitlements/limits Security: detecting/preventing abuse, fraud, unauthorized access, and security incidents Product improvement: debugging, performance analysis, quality improvements, and improving the reliability and quality of conversations and features (including using message/voice transcripts to improve the service with appropriate safeguards) Compliance with legal obligations, responding to lawful requests, and resolving disputes LEGAL BASES FOR PROCESSING Where required by applicable law, we rely on one or more of the following legal bases: Contract performance: to provide the App and requested features Consent (and, where required, explicit consent): for device-permission-based features, certain preference data, and where required for advertising/attribution Legitimate interests: security, fraud prevention, and service reliability/improvement (balanced against your rights) Legal obligations: compliance with applicable laws and lawful requests Where we rely on consent, you can withdraw it at any time (for example, through device settings or in-app controls where available). DISCLOSURE / SHARING OF PERSONAL DATA We do not sell or rent your personal data. We may disclose personal data only as necessary to operate the App and provide services, subject to appropriate safeguards: 6.1) Service Providers (Processors) We may use third-party service providers to support: Infrastructure/hosting and data storage CDN/file delivery Push notification services (APNs/FCM) Analytics and crash/error monitoring Voice processing / TTS / ASR technical services AI conversation service providers These providers act as “processors” (or equivalent roles) and process personal data only on our documented instructions and only as needed to provide services to us. 6.2) Legal Requirements We may disclose personal data if required to comply with applicable law, regulation, legal process, or valid governmental/legal requests. 6.3) Payments / Subscriptions Purchases are processed by Apple App Store / Google Play. We process only the verification data and derived entitlements necessary to grant access and manage limits. 6.4) Business Transfers If we are involved in a merger, acquisition, reorganization, financing, or sale of assets, personal data may be transferred as part of that transaction, subject to appropriate confidentiality and security measures. 6.5) Advertising, Attribution, and Measurement Partners (if enabled) If enabled, we may work with advertising platforms and attribution/measurement providers to measure campaign performance, detect fraud, and understand how users find the App. Depending on the integration, these partners may process certain identifiers and event data for measurement purposes, subject to their own privacy policies and contractual safeguards with us. Where required, we will request any necessary permissions (e.g., ATT on iOS) before enabling such processing. DATA LOCATION / INTERNATIONAL TRANSFERS Our primary servers in Germany. However, personal data may be processed in other countries where we or our service providers operate. Where required by applicable law, we use legally recognized transfer mechanisms and appropriate safeguards for international transfers. RETENTION We retain personal data only for as long as necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law. Our general approach: Account data: while your account is active, and until deletion thereafter (subject to legal requirements) Messages/interaction history: as long as needed to provide the service, or until you delete it / request deletion / delete your account (subject to legal requirements) Technical/security/diagnostic logs: retained for 30 days by default, unless a longer period is necessary to investigate security incidents, prevent abuse, or resolve disputes Push tokens: while valid; deleted/updated upon logout, disabling notifications, or account deletion (as applicable) Purchase verification records: as needed for entitlements, reconciliation, fraud prevention, and dispute handling DATA SECURITY We implement appropriate technical and organizational measures to protect personal data, which may include secure transport (e.g., TLS), access controls, role-based authorization, monitoring, and data minimization. No method of transmission or storage is 100% secure. YOUR RIGHTS AND CHOICES Depending on where you live, you may have rights under applicable data protection laws. These rights may include: Access: request confirmation and a copy of your personal data Correction: request correction of inaccurate or incomplete data Deletion: request deletion of your personal data (subject to legal exceptions) Portability: request a portable copy of certain data Restriction: request restriction of processing in certain cases Objection: object to certain processing (including some legitimate-interest processing) Withdraw consent: where processing is based on consent Lodge a complaint: with a data protection authority (where applicable) To exercise your rights, contact us at [email protected]. We may need to verify your identity before fulfilling requests. ACCOUNT DELETION You can delete your account in the App by following: “Settings > Account > Delete Account”. After account deletion, we delete, anonymize, or otherwise render inaccessible your personal data, except where retention is required or permitted by law (e.g., security, fraud prevention, dispute resolution). Some deletions may take a limited period to complete due to technical constraints. CHANGES TO THIS POLICY We may update this Policy from time to time. The updated Policy will be effective when posted within the App and/or on our website. If changes are material, we may notify you through the App or other appropriate means. CONTACT Web: https://www.passionlabai.com/ Email: [email protected]