AI Privacy Policy

Artificial Intelligence (AI) Privacy Policy

Comprehensive privacy disclosures for AI-powered features across Lado Tatishvili apps

Introduction

This AI Privacy Policy provides detailed information about how we use artificial intelligence (AI) services in our applications and how your data is processed when you interact with AI-powered features.

This policy is a supplement to our main Privacy Policy. It provides additional detail specifically for AI functionality.

CRITICAL: Read Before Using AI Features

When you use AI-powered features in our apps, your data is processed by third-party AI providers located in different countries, including the United States and China.

These providers operate independently of us and have their own privacy policies. By using AI features, you consent to:

  1. Your inputs being sent to third-party AI services
  2. International data transfers to countries with different privacy laws
  3. Processing according to each provider's privacy policy (linked below)
  4. Potential retention and use by AI providers as described in their policies

IF YOU DO NOT CONSENT TO THESE TERMS, DO NOT USE AI FEATURES IN THE APP. Many apps have non-AI alternatives for core functionality.

Which Apps Use AI?

Not all of our apps use AI features. To determine if your specific app uses AI:

How to Check:

  1. App Store Privacy Labels: Check the app's App Store page under "App Privacy" section. If AI features are present, data sharing with third parties will be disclosed.
  2. In-App Indicators: Apps with AI features will clearly label them (e.g., "AI-Powered", "Ask AI", "AI Assistant", "Smart Suggestions").
  3. App Description: The App Store description will mention AI/ML capabilities if present.

Default Assumption: If an app does NOT explicitly mention AI in its App Store page or interface, assume it does NOT use AI services.

Developer Commitment: We only integrate AI features where they provide clear value. We will never add AI "just because" or hide its use from users. All AI features are clearly labeled and optional where possible.

AI Service Providers We May Use

Depending on the app and feature, we may use one or more of the following AI service providers. Each provider has different policies, data locations, and retention practices.

Complete AI Provider Details

Provider Service Privacy Policy Data Location Retention
OpenAI ChatGPT, GPT-4, API OpenAI Privacy United States 30 days (API)
Anthropic Claude AI Anthropic Privacy United States 90 days (API)
Google Gemini AI Gemini Privacy United States Per Google policy
xAI Grok xAI Privacy United States Per xAI policy
Alibaba Cloud Qwen/Tongyi Qwen Privacy China Per Alibaba policy
DeepSeek DeepSeek AI DeepSeek Privacy China Per DeepSeek policy

IMPORTANT: Retention periods shown are typical for API usage but may vary. Each provider's privacy policy is the authoritative source. We recommend reading them before using AI features.

Provider Independence: We are NOT affiliated with any of these AI providers. They process your data independently according to their own policies. We cannot control their data practices.

What Data is Shared with AI Providers

The specific data shared depends on how you use AI features. Here's what MAY be shared:

Data We DO Share:

  • Your Inputs: Any text, prompts, questions, or commands you type into AI features
  • Context Data: Information needed for the AI to understand your request (e.g., previous conversation turns, document content you're working with)
  • User Content: If you ask AI to analyze your photos, documents, or other content, that content is sent to the AI provider
  • Technical Metadata: Minimal technical information like API request timestamps, token counts, model versions used
  • Usage Patterns: How you interact with AI features (frequency, feature usage, success rates) - aggregated and anonymized where possible

Data We DO NOT Share:

  • [NO] Your name or contact information (unless you explicitly include it in your AI input)
  • [NO] Your device identifiers (IDFA, device ID) - we anonymize requests where technically possible
  • [NO] Background data collection - AI providers only receive data when you actively use AI features
  • [NO] Data from other apps on your device
  • [NO] Your location (unless your AI query specifically includes location)
  • [NO] Your contacts, calendar, or other personal data stores (unless you explicitly paste/share that content)
  • [NO] Payment information - all payments are handled by Apple, not AI providers

User Responsibility: Be careful what you type into AI features. Do NOT include sensitive information (passwords, financial data, health records, etc.) in your AI prompts unless you understand and accept that it will be sent to third-party AI providers.

How Data Flows to AI Providers

Understanding the technical data flow can help you make informed decisions:

Step-by-Step Data Flow:

  1. You Activate AI Feature: You tap "Ask AI", "Generate", "Analyze", or similar AI-powered button
  2. Data Preparation: Our app packages your input and necessary context
  3. Encryption: Data is encrypted using HTTPS/TLS for transmission
  4. API Request: Encrypted data is sent to the AI provider's API endpoint
  5. AI Processing: The AI provider processes your request on their servers
  6. Response Return: AI response is sent back to the app (encrypted)
  7. Display: The app displays the AI-generated response to you
  8. Storage: The AI provider may store your request according to their retention policy (see table above)

What Happens on Our Servers (if applicable):

  • Some apps route AI requests through our servers for API key management and abuse prevention
  • In these cases, we may temporarily cache requests for seconds to minutes to optimize performance
  • We do NOT permanently store AI inputs/outputs unless explicitly stated in the app (e.g., "Save AI conversation history" feature)
  • Cached data is automatically deleted within 24 hours maximum

Direct API Calls:

  • Some apps make direct API calls from your device to AI providers (no intermediary servers)
  • This means your data goes directly from your device → AI provider → back to your device
  • These apps will be labeled "Direct AI Connection" in their privacy labels

Data Retention by AI Providers

Each AI provider has different data retention practices:

OpenAI (ChatGPT, GPT-4):

  • API Usage: Retains data for 30 days for abuse monitoring, then deletes
  • Training: Does NOT use API data for model training (as of their current policy)
  • Exceptions: May retain longer if required by law or to investigate abuse
  • Source: OpenAI Privacy Policy

Anthropic (Claude):

  • API Usage: Retains conversation data for up to 90 days for trust & safety
  • Training: Does NOT use API data for model training (as of their current policy)
  • User Control: Enterprise customers can opt into zero retention
  • Source: Anthropic Privacy Policy

Google (Gemini):

  • Retention: Per Google's general data retention policies
  • Training: May use data to improve Google services unless opted out
  • Account Linking: May link data to your Google Account if you're signed in
  • Source: Gemini Privacy Hub

xAI (Grok):

  • Retention: Per xAI's privacy policy (review for latest)
  • X Integration: May integrate with X/Twitter ecosystem if applicable
  • Source: xAI Privacy Policy

Qwen (Alibaba Cloud):

  • Jurisdiction: Subject to Chinese data protection laws
  • Retention: Per Alibaba Cloud and Qwen policies
  • Source: Qwen Privacy Policy

DeepSeek:

  • Jurisdiction: Subject to Chinese data protection laws
  • Retention: Per DeepSeek privacy policy
  • Source: DeepSeek Privacy Policy

Policy Changes: AI providers may change their retention and training policies at any time. The links above provide the most current information. We update this page when we become aware of significant policy changes, but you should review provider policies directly before use.

International Data Transfers

Using AI features involves international data transfers. Here's what you need to know:

Critical Information for EU/EEA/UK Users

AI providers we use are primarily located in the United States and China. When you use AI features:

  • Your data WILL leave the EU/EEA/UK and be processed in countries that may not have equivalent data protection laws to GDPR
  • US-based providers: Process data in the United States under US law, which does not provide the same level of protection as GDPR
  • China-based providers: Process data in China under Chinese law, subject to Chinese government access requirements
  • No adequacy decision: China does not have an EU adequacy decision; US adequacy is complex (Data Privacy Framework for some companies)

Legal Basis for Transfers:

  • Your Explicit Consent: By using AI features after reading this notice, you explicitly consent to international transfers under GDPR Article 49(1)(a)
  • Contractual Necessity: Transfers are necessary to provide the AI functionality you requested
  • Standard Contractual Clauses: Where available, providers may use EU Standard Contractual Clauses with customers

You have the right to withdraw consent at any time by simply not using AI features. If you do not consent to international transfers, DO NOT use AI features in the app.

For California Users (CCPA/CPRA):

Sharing data with AI providers may constitute a "sale" or "sharing" of personal information under California law, even though no money is exchanged. You have the right to opt out.

How to Opt Out: Simply do not use AI features. There is no "partial opt-out" - AI features require data sharing to function.

For Brazilian Users (LGPD):

International transfers to countries without adequate protection require your consent or contractual safeguards. Your use of AI features after reading this disclosure constitutes consent under LGPD.

For Other Jurisdictions:

Check your local data protection laws regarding international transfers. Your use of AI features constitutes consent where legally permissible.

AI Model Training

A critical question: Will your data be used to train AI models?

Current Training Policies (as of December 2025):

Providers That Do NOT Use API Data for Training:

  • OpenAI: Does NOT use API data for training (policy as of 2023+)
  • Anthropic: Does NOT use API data for training (policy as of 2024+)

Providers That MAY Use Data for Training:

  • Google (Gemini): May use data to improve Google services unless you opt out via Google account settings
  • xAI (Grok): Review xAI privacy policy for current training practices
  • Qwen: Review Alibaba/Qwen privacy policy for current training practices
  • DeepSeek: Review DeepSeek privacy policy for current training practices

IMPORTANT Caveats:

  • Policies can change - providers may start or stop using data for training
  • "Not used for training" typically has exceptions for abuse prevention, safety, legal compliance
  • Aggregated, anonymized, or de-identified data may have different rules
  • Human review for quality control may occur even if not used for automated training

Assumption for Privacy: You should assume that anything you input into an AI feature COULD potentially be used for model training or improvement, even if current policies say otherwise. Policies change, and there may be exceptions you're not aware of.

Safe Practice: Never input confidential, sensitive, or proprietary information into AI features unless you're comfortable with the possibility of it being retained, reviewed by humans, or used for improvement purposes.

Your Rights and Controls

You have various rights regarding your data processed by AI features:

Rights You Can Exercise:

1. Right to Opt Out (Universal)

  • Method: Simply don't use AI features in the app
  • Scope: Complete - if you don't use AI features, no data goes to AI providers
  • Alternatives: Many apps provide non-AI alternatives for core functionality

2. Right to Access (GDPR, CCPA, others)

  • Our Data: Request what AI-related data we have about you by emailing ladotatishvili@protonmail.com
  • Provider Data: You must contact AI providers directly using their privacy request processes
  • Limitation: We do NOT have access to data stored by AI providers on their servers

3. Right to Deletion (GDPR "Right to Erasure", CCPA "Right to Delete")

  • Our Data: Request deletion of AI-related data we control
  • Provider Data: You must contact AI providers directly - we CANNOT delete data on their servers
  • Limitation: Providers may retain data for their stated retention period or legal obligations

4. Right to Correction (GDPR, CPRA)

  • Limited Applicability: Most AI inputs are transient queries, not stored personal profiles
  • For Stored Data: Contact us to correct any AI-related data we maintain

5. Right to Object / Restrict Processing (GDPR)

  • Method: Don't use AI features, or contact us to disable AI features for your account (if app supports accounts)
  • Impact: AI-powered functionality will not be available

6. Right to Data Portability (GDPR)

7. Right to Withdraw Consent (GDPR, others)

  • Method: Stop using AI features at any time
  • Effect: Future data will not be shared; past data already shared with providers remains subject to their retention policies

IMPORTANT LIMITATION: Third-Party Rights Requests

We are NOT the data controller for data processed by AI providers. For rights requests regarding data held by AI providers, you must contact them directly:

We will assist where we can, but we do not have technical ability to delete or modify data stored on AI providers' servers.

Children's Privacy and AI

AI features raise special concerns for children's privacy:

AI Features and Children Under 13

COPPA Compliance (United States):

  • Apps designed for children under 13 (or "mixed audience" apps) do NOT include AI features that transmit data to third parties
  • If an app is NOT designed for children but a child uses it, AI features function the same as for adults
  • We do NOT knowingly collect personal information from children under 13 without parental consent

GDPR-K / UK Children's Code:

  • Apps likely to be accessed by children under 16 (EU/UK) use age-appropriate privacy settings
  • AI features that share data with third parties are disabled by default for users who identify as under 16
  • Parental consent mechanisms are implemented where required

General Best Practices:

  • We recommend children under 13 do NOT use AI features without parental supervision
  • Parents should review AI provider privacy policies before allowing children to use AI features
  • AI-generated content may not be age-appropriate; parental supervision recommended

For Parents and Guardians:

If your child has used AI features in our apps:

  1. Contact us immediately at ladotatishvili@protonmail.com
  2. Request deletion of any data we control
  3. Contact AI providers directly to request deletion of data on their servers
  4. Enable parental controls on the child's device to prevent future AI usage

Parental Control Options:

  • Use iOS Screen Time to restrict app usage or specific features
  • Enable "Ask to Buy" for in-app purchases that unlock AI features
  • Review app privacy settings together with your child
  • Consider using apps without AI features for younger children

Security Measures

We implement security measures to protect data transmitted to AI providers:

Our Security Practices:

Data in Transit:

  • Encryption: All AI API requests use HTTPS with TLS 1.2+ encryption
  • Certificate Pinning: Implemented where technically feasible to prevent man-in-the-middle attacks
  • No Unencrypted Transmission: AI data is NEVER sent over unencrypted connections

Data Minimization:

  • Only What's Needed: We send only the minimum data required for AI functionality
  • No Identifiers When Possible: We avoid sending device identifiers or user IDs when technically possible
  • Anonymization: Where feasible, we anonymize requests before sending to AI providers

API Key Security:

  • Server-Side Storage: API keys are stored on our secure servers, not in the app binary
  • Rate Limiting: We implement rate limiting to prevent abuse
  • Monitoring: We monitor for unusual patterns that might indicate compromise

Access Controls:

  • Developer Access: Only authorized developers have access to AI API configurations
  • Logging: We log API access for security monitoring (logs are anonymized and retained for 90 days max)

Security Limitations - IMPORTANT

Despite our security measures, you should be aware of inherent limitations:

  • Provider Security: Once data reaches the AI provider, it's subject to THEIR security practices, not ours
  • No Guarantee: No security is perfect - data breaches can occur at AI providers despite best efforts
  • Human Review: Some AI providers employ human reviewers who may see your inputs for quality/safety
  • Legal Access: AI providers may be compelled to disclose data to governments under legal process
  • Insider Risk: Provider employees with access to systems could potentially access data

Bottom line: Treat AI inputs like postcards, not sealed letters. Don't input anything you wouldn't write on a postcard.

Practical Usage Scenarios

To help you understand AI data processing in context, here are concrete examples:

Example Scenario 1: AI Writing Assistant

User Action: You use an AI feature to improve your writing (e.g., "Make this text more professional")

Data Shared:

  • Your original text
  • Your editing instruction ("make this more professional")
  • Technical metadata (timestamp, token count)

Data NOT Shared: Your name, contact info, other documents in the app, device location

Provider Processing: AI provider receives your text, processes it, returns improved version, retains according to policy

Privacy Impact: If your text contains sensitive info, it's now with the AI provider

Example Scenario 2: AI Image Analysis

User Action: You ask AI to describe what's in a photo

Data Shared:

  • The photo file itself
  • Your question ("What's in this photo?")
  • Technical metadata

Data NOT Shared: Other photos in your library, photo metadata (GPS location, date), your identity

Provider Processing: AI provider receives image, analyzes it, returns description, retains according to policy

Privacy Impact: If photo contains identifiable people or sensitive content, it's now with AI provider

Example Scenario 3: AI Chatbot Conversation

User Action: You have a multi-turn conversation with an AI chatbot in the app

Data Shared:

  • All your messages in the conversation
  • Conversation context (AI needs previous messages to respond coherently)
  • Session identifier (to maintain conversation continuity)

Data NOT Shared: Your conversations in other apps, your identity beyond the session

Provider Processing: AI provider stores conversation history for the duration of the session (and retention period), uses it to generate contextual responses

Privacy Impact: Longer conversations = more data retained by AI provider

Example Scenario 4: AI Data Analysis

User Action: You upload a spreadsheet and ask AI to analyze trends

Data Shared:

  • The entire spreadsheet contents
  • Your analysis request
  • Follow-up questions

Data NOT Shared: Other files on your device

Provider Processing: AI provider receives full spreadsheet, analyzes it, returns insights, retains according to policy

Privacy Impact: If spreadsheet contains business secrets, personal data, or confidential information, it's now with AI provider

Lesson from Examples: AI features are powerful but require data sharing. Before using any AI feature, ask yourself: "Am I comfortable with this specific data being sent to a third-party AI company in another country?" If the answer is no, don't use that AI feature with that data.

How to Opt Out of AI Data Processing

Complete step-by-step instructions for opting out:

Method 1: Don't Use AI Features (100% Effective)

  1. Identify AI features in the app (they're clearly labeled)
  2. Simply don't tap/use those features
  3. Use non-AI alternatives for core functionality where available

Result: Zero data sent to AI providers. This is the only 100% guaranteed method.

Method 2: Disable AI Features (If App Supports)

  1. Open app settings
  2. Look for "AI Features", "Smart Features", or similar section
  3. Toggle off AI features
  4. Restart app if prompted

Result: AI features are disabled in the app interface. Note: Not all apps support disabling AI.

Method 3: Delete App (Nuclear Option)

  1. If you're uncomfortable with AI data practices and can't avoid AI features
  2. Delete the app
  3. Look for alternative apps without AI features

Result: No future data sharing. Past data already shared with AI providers remains subject to their retention policies.

Method 4: Request Account Deletion (For Apps with Accounts)

  1. Email ladotatishvili@protonmail.com with subject "Delete My Account"
  2. Provide your account email/username
  3. Specify "Delete all AI-related data"
  4. We'll confirm deletion within 30 days

Result: We delete AI-related data we control. You must separately contact AI providers to delete data on their servers.

Method 5: Provider-Level Opt-Out (Partial)

Some AI providers offer opt-out mechanisms:

  • Google (Gemini): Google Account privacy settings - can disable data usage for improvements
  • OpenAI: Check OpenAI privacy settings if you have an account (note: app API usage may be separate from OpenAI account)
  • Others: Check each provider's privacy policy for opt-out options

Limitation: Provider-level opt-outs typically don't prevent initial data transmission, only subsequent use (e.g., for training).

What Opt-Out Does NOT Do:

  • [NO] Does NOT delete data already sent to AI providers in the past
  • [NO] Does NOT retroactively undo processing that already occurred
  • [NO] Does NOT guarantee providers will delete data before their stated retention period
  • [NO] Does NOT prevent legal/law enforcement access to data providers already have

Bottom line: Opt-out prevents FUTURE data sharing. For past data, you must contact AI providers directly to request deletion (which they may or may not honor depending on retention policies and legal obligations).

Changes to This AI Privacy Policy

AI technology and provider policies evolve rapidly. Here's how we handle updates:

Update Policy:

  • Frequency: We review this policy quarterly and update when significant changes occur
  • Notification: Material changes will be announced via app update notes and/or email (if you have an account)
  • Effective Date: Changes take effect on the "Changed" date shown in the metadata above
  • Your Consent: Continued use of AI features after changes = acceptance of new policy

What Triggers a Policy Update:

  • Adding or removing AI providers
  • Significant changes to AI provider privacy policies
  • New AI features that process data differently
  • Changes to data retention practices
  • Legal/regulatory changes requiring policy updates
  • User feedback indicating policy clarifications needed

How to Stay Informed:

  • Check this page periodically (bookmark it)
  • Review app update notes when updating apps
  • Subscribe to notifications (if app supports)
  • Follow our developer updates (if we publish any)

Important: We are NOT responsible for changes to AI providers' privacy policies. Providers can change their policies at any time. The links to provider policies in this document provide the most current information - we recommend checking them periodically if you use AI features regularly.

Contact Us - AI Privacy Questions

If you have questions, concerns, or requests specifically about AI privacy practices:

Email: ladotatishvili@protonmail.com

Subject Line: Use "AI Privacy Question" for faster routing

Response Time: We respond within 72 hours for privacy inquiries

Developer: Lado Tatishvili

Location: Tbilisi, Georgia

What to Include:

  • Which app you're asking about (include app name)
  • Which AI feature you're concerned about
  • Specific privacy question or request
  • Your jurisdiction (if relevant for legal rights)

Summary and Key Takeaways

The Most Important Things to Remember:

  1. AI Features = Data Sharing: Using AI features means your data goes to third-party AI companies in other countries
  2. Read Provider Policies: Each AI provider has different privacy practices - read their policies before use
  3. International Transfers: Your data will leave your country and be processed under different privacy laws
  4. Opt-Out is Simple: Just don't use AI features - that's the only 100% effective opt-out
  5. Think Before You Type: Assume anything you input to AI could be retained, reviewed, and potentially used for training
  6. Children Require Extra Care: Children under 13-16 should not use AI features without parental supervision and consent
  7. We're Independent: We don't control AI providers' practices - they're independent companies
  8. Policies Change: AI provider policies can change - check links periodically if you use AI regularly

Final Recommendation

AI features are powerful tools but require informed consent. Before using any AI feature:

  • Read this entire policy
  • Review the relevant AI provider's privacy policy
  • Consider whether the data you're sharing is appropriate for third-party processing
  • Make an informed decision about whether the benefits outweigh the privacy trade-offs

If you're uncomfortable with ANY aspect of AI data processing, do not use AI features. We respect your choice and provide non-AI alternatives where possible.

This AI Privacy Policy is effective as of the date shown in the metadata above. For the general privacy policy covering non-AI features, see Privacy Policy.

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