Privacy Policy – ImyMe

Effective Date: 11/25/2025
Last Updated: 11/25/2025

1. Introduction

Welcome to ImyMe. This Privacy Policy explains how [COMPANY LEGAL NAME] (“we,” “us,” or “our”) collects, uses, discloses, and protects your personal information when you use the ImyMe mobile application and related services (the “Service”).

We are committed to protecting your privacy and handling your personal data transparently and securely. This Privacy Policy complies with:

  • General Data Protection Regulation (GDPR) for users in the European Union
  • California Consumer Privacy Act (CCPA) for users in California
  • Other applicable privacy laws worldwide

Company Information:

  • Legal Entity: MicroCloudSystemsLLC
  • Address: 2807 N PARHAM RD STE 320
  • HENRICO, VA 23294-4458
  • Email: info@microcloudsystems.com
  • Data Protection Officer: [DPO EMAIL] (if applicable)

2. Information We Collect

We collect various types of information to provide and improve our Service.

2.1 Information You Provide Directly

Account Information:

  • Email address
  • Password (encrypted)
  • Display name
  • Profile picture (optional)
  • Date of birth (to verify age requirement)
  • Contact information

Persona Configuration:

  • Persona name and attributes
  • Personality preferences
  • Tone and style preferences
  • Custom persona settings

Communication Content:

  • Messages and conversations with the AI persona
  • Voice messages (if using voice features)
  • Text inputs and queries
  • Feedback and support communications

Personal Knowledge Base:

  • Notes, documents, and bookmarks you save
  • Personal information you choose to share
  • Links and references you provide

Calendar and Events:

  • Calendar events (if you connect your calendar)
  • Event details, times, and locations
  • Meeting attendees and descriptions

Preferences and Settings:

  • App settings and configurations
  • Notification preferences
  • Privacy and security settings
  • Likes, dislikes, and judgments

2.2 Information Collected Automatically

Device Information:

  • Device type, model, and operating system
  • Device identifiers (e.g., device ID, advertising ID)
  • Screen resolution and display settings
  • Language and timezone settings
  • Mobile carrier information

Location Data:

  • Precise location (GPS coordinates) with your consent
  • Approximate location (IP address-based)
  • Location history and movement patterns
  • Frequency of visits to specific locations
  • Time spent at locations

Activity and Usage Data:

  • App usage patterns and frequency
  • Features and functions used
  • Session duration and frequency
  • Device activity logs
  • App usage on device (with permission)
  • Device motion and sensor data (accelerometer, gyroscope)

Technical and Log Data:

  • IP address
  • Browser type and version (if using web interface)
  • Access times and dates
  • Error logs and crash reports
  • Performance metrics
  • Network connection type

Cookies and Tracking Technologies:

  • Session cookies
  • Persistent cookies
  • Local storage data
  • Analytics identifiers
  • Mobile device identifiers

2.3 Information from Third-Party Sources

Social Media and Connected Services:

  • Profile information from connected social accounts (with your permission)
  • Calendar data from connected calendar services
  • Location data from mapping services

Publicly Available Sources:

  • Information you make publicly available online (with your consent to access)

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Delivery and Core Functionality

AI Persona Operation:

  • Generate context-aware, personalized responses in conversations
  • Maintain conversation coherence using short-term and long-term memory
  • Simulate your persona based on your preferences and past interactions
  • Provide intelligent assistance based on your habits and context

Memory and Context Management:

  • Store and retrieve conversation history for context
  • Build and maintain semantic memory (understanding of your preferences)
  • Track episodic memories (activities, locations, events)
  • Provide relevant context from your personal knowledge base
  • Access calendar events to provide time-aware responses

Personalization:

  • Learn your preferences, interests, and communication style
  • Adapt responses to your persona configuration
  • Improve accuracy of predictions and suggestions
  • Customize the user experience

3.2 Service Improvement and Development

Research and Analytics:

  • Analyze usage patterns to improve features
  • Conduct research on AI and natural language processing
  • Test new features and functionality
  • Identify and fix bugs and errors
  • Improve AI model performance and accuracy

Training and Model Improvement:

  • Train AI models using anonymized conversation data
  • Improve natural language understanding
  • Enhance response quality and relevance
  • Develop new capabilities

3.3 Security and Fraud Prevention

  • Verify user identity and prevent unauthorized access
  • Detect and prevent fraudulent activity
  • Monitor for security threats and vulnerabilities
  • Enforce our Terms of Service
  • Protect users and our systems from abuse

3.4 Communications

  • Send service-related notifications and updates
  • Respond to your inquiries and support requests
  • Send administrative messages about your account
  • Provide important security and privacy notices
  • Send marketing communications (with your consent, where required)

3.5 Legal and Compliance

  • Comply with legal obligations and regulations
  • Respond to legal requests and court orders
  • Enforce our agreements and policies
  • Protect our rights, privacy, safety, or property
  • Resolve disputes

3.6 Business Operations

  • Billing and payment processing for subscriptions
  • Manage user accounts and subscriptions
  • Conduct business analytics and planning
  • Facilitate corporate transactions (mergers, acquisitions)

4. How We Share Your Information

We do not sell your personal information. We share your information only in the following circumstances:

4.1 Third-Party Service Providers

We share data with trusted service providers who assist in operating our Service:

AI and Machine Learning Providers:

  • Anthropic (Claude AI): Processes conversation data to generate AI responses
  • OpenAI (GPT, Embeddings): Generates AI responses and creates text embeddings for semantic search
  • These providers process your conversations and queries to provide AI functionality

Cloud Infrastructure:

  • Railway: Hosts our servers and databases
  • PostgreSQL (Railway): Stores structured data and vector embeddings
  • MongoDB (Railway): Stores flexible document data (personas, logs)
  • Redis (Railway): Manages session caching and short-term memory

Search and External APIs:

  • Web Search Providers (Tavily, SerpAPI): Provide web search capabilities
  • Weather Services (OpenWeatherMap): Provide weather information
  • Mapping Services (Google Maps, Mapbox): Provide location and mapping data

Payment Processors:

  • [PAYMENT PROCESSOR NAMES] for subscription billing and payment processing

Analytics and Monitoring:

  • Analytics services to understand usage patterns and improve the Service
  • Performance monitoring and error tracking services

All service providers are contractually required to:

  • Use your data only for specified purposes
  • Implement appropriate security measures
  • Comply with applicable privacy laws
  • Delete or return data when services end

4.2 Business Transfers

If we are involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you before your information is transferred and becomes subject to a different privacy policy.

4.3 Legal Requirements

We may disclose your information when required by law or in good faith belief that such action is necessary to:

  • Comply with legal obligations, court orders, or government requests
  • Enforce our Terms of Service or other agreements
  • Protect our rights, property, or safety, or that of users or the public
  • Detect, prevent, or address fraud, security, or technical issues
  • Respond to claims of illegal activity or violations of third-party rights

4.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

4.5 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you, for research, marketing, or other purposes.

5. Data Retention

5.1 Active Account Data

We retain your personal information while your account is active and as needed to provide you the Service.

5.2 Account Deletion

When you delete your account:

  • We will delete your personal data within 30 days of your deletion request
  • Some data may be retained in backup systems for up to 30 days, then permanently deleted
  • We may retain certain information longer if required by law or for legitimate business purposes

5.3 Legal and Compliance Retention

We may retain certain data longer when required for:

  • Legal, regulatory, or compliance obligations
  • Resolving disputes
  • Enforcing agreements
  • Preventing fraud and abuse

5.4 Anonymized Data

We may retain and use anonymized or aggregated data indefinitely for research, analytics, and service improvement.

6. Your Rights and Choices

Depending on your location, you may have various rights regarding your personal information.

6.1 GDPR Rights (EU Users)

If you are in the European Union, you have the following rights under GDPR:

Right of Access:

  • Request confirmation of whether we process your personal data
  • Obtain a copy of your personal data

Right to Rectification:

  • Request correction of inaccurate or incomplete personal data

Right to Erasure (“Right to be Forgotten”):

  • Request deletion of your personal data in certain circumstances

Right to Restriction of Processing:

  • Request that we limit how we use your personal data

Right to Data Portability:

  • Receive your personal data in a structured, machine-readable format
  • Transmit your data to another service provider

Right to Object:

  • Object to processing based on legitimate interests
  • Object to direct marketing

Right to Withdraw Consent:

  • Withdraw consent for processing at any time (where processing is based on consent)

Right to Lodge a Complaint:

  • File a complaint with your local data protection authority

Legal Basis for Processing:
We process your data based on:

  • Consent: For optional features like location tracking
  • Contract Performance: To provide the Service as agreed
  • Legitimate Interests: For service improvement, security, and analytics
  • Legal Obligations: To comply with applicable laws

6.2 CCPA Rights (California Users)

If you are a California resident, you have the following rights under CCPA:

Right to Know:

  • Request information about personal information we collect, use, disclose, and sell
  • Request specific pieces of personal information we have collected

Right to Delete:

  • Request deletion of your personal information (with certain exceptions)

Right to Opt-Out of Sale:

  • We do not sell your personal information
  • You have the right to opt out if this changes in the future

Right to Non-Discrimination:

  • We will not discriminate against you for exercising your CCPA rights

Authorized Agent:

  • You may designate an authorized agent to make requests on your behalf

CCPA Categories of Information:
We collect the following categories of personal information:

  • Identifiers (name, email, device ID)
  • Commercial information (subscription history)
  • Internet/electronic activity (usage data, logs)
  • Geolocation data
  • Sensory data (voice recordings, if applicable)
  • Inferences (preferences, characteristics)

6.3 General Rights (All Users)

Account Management:

  • Access your account settings at any time
  • Update your profile information
  • Manage privacy settings and preferences

Communication Preferences:

  • Opt out of marketing emails (service emails will continue)
  • Manage notification settings

Data Access and Export:

  • Request a copy of your data in portable format
  • Export conversation history and personal data

Data Deletion:

  • Delete specific conversations or data
  • Close your account and request full data deletion

6.4 How to Exercise Your Rights

To exercise any of these rights:

  • In-App: Use privacy settings and account management features
  • Email: Contact us at [PRIVACY EMAIL]
  • Support: Submit a request through our support system

We will respond to your request:

  • Within 30 days (GDPR)
  • Within 45 days (CCPA), extendable by 45 days if necessary

We may need to verify your identity before fulfilling your request to protect your privacy and security.

7. Data Security

We implement comprehensive security measures to protect your personal information:

7.1 Technical Safeguards

  • Encryption: Data encrypted in transit (TLS/SSL) and at rest (AES-256)
  • Access Controls: Role-based access controls and principle of least privilege
  • Authentication: Multi-factor authentication for sensitive operations
  • Secure Databases: Industry-standard database security practices
  • Network Security: Firewalls, intrusion detection, and network monitoring

7.2 Organizational Safeguards

  • Employee Training: Security and privacy training for all staff
  • Data Minimization: Collect only necessary data
  • Regular Audits: Security audits and vulnerability assessments
  • Incident Response: Documented procedures for security incidents
  • Vendor Management: Careful vetting of third-party service providers

7.3 Limitations

While we implement strong security measures, no system is completely secure. We cannot guarantee absolute security of your data. You are responsible for maintaining the security of your account credentials.

7.4 Data Breach Notification

In the event of a data breach that affects your personal information:

  • We will notify affected users without undue delay
  • We will notify relevant authorities as required by law
  • We will provide information about the breach and steps you can take to protect yourself

8. International Data Transfers

ImyMe operates globally, and your data may be transferred to and processed in countries outside your country of residence, including the United States.

8.1 Cross-Border Transfers

When we transfer data internationally:

  • We use appropriate safeguards to protect your data
  • We comply with applicable data transfer regulations
  • We ensure recipients provide adequate protection

8.2 EU-US Data Transfers

For data transfers from the EU to the US:

  • We rely on Standard Contractual Clauses (SCCs) approved by the European Commission
  • We implement supplementary measures to ensure adequate protection
  • We comply with GDPR requirements for international transfers

8.3 Your Rights

You have the right to obtain information about safeguards we use for international transfers and to object to transfers in certain circumstances.

9. Children’s Privacy

9.1 Age Requirement

ImyMe is not intended for children under 16 years of age. We do not knowingly collect personal information from anyone under 16.

9.2 Parental Responsibility

If you are a parent or guardian and believe your child under 16 has provided us with personal information, please contact us at [PRIVACY EMAIL], and we will delete that information promptly.

9.3 Age Verification

We implement age verification during account registration to prevent underage use.

10. Cookies and Tracking Technologies

10.1 What We Use

We use cookies and similar technologies to:

  • Maintain your session and keep you logged in
  • Remember your preferences and settings
  • Analyze usage and improve the Service
  • Provide personalized content and features

10.2 Types of Technologies

Cookies:

  • Session Cookies: Temporary, deleted when you close the app/browser
  • Persistent Cookies: Remain until expiration or deletion

Local Storage:

  • Store data locally on your device for faster access and offline functionality

Mobile Identifiers:

  • Device advertising IDs for analytics (can be reset in device settings)
  • Device identifiers for authentication and security

10.3 Your Choices

Browser/App Settings:

  • Most browsers allow you to refuse cookies or alert you when cookies are sent
  • Mobile devices allow you to reset advertising identifiers

Do Not Track:

  • We currently do not respond to “Do Not Track” signals as there is no industry standard

Opt-Out:

  • You can opt out of certain tracking through device settings
  • Disabling cookies may limit Service functionality

11. Third-Party Links and Services

11.1 External Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these external sites.

11.2 Third-Party Privacy Policies

When you interact with third-party services through ImyMe:

  • Their privacy policies govern their data practices
  • We encourage you to review their privacy policies
  • We are not responsible for their data handling

11.3 Integration Services

If you connect third-party services (calendar, social media, etc.):

  • We access only the data you authorize
  • You can disconnect services at any time
  • Disconnecting may limit Service functionality

12. California Privacy Rights

12.1 Shine the Light Law

California Civil Code Section 1798.83 permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

12.2 CCPA Rights

See Section 6.2 for detailed CCPA rights and how to exercise them.

13. Nevada Privacy Rights

Nevada residents may opt out of the sale of certain personal information. We do not sell personal information as defined by Nevada law. If you have questions, contact us at [PRIVACY EMAIL].

14. Changes to This Privacy Policy

14.1 Updates

We may update this Privacy Policy from time to time to reflect:

  • Changes in our data practices
  • Changes in applicable laws or regulations
  • New features or services
  • Feedback from users and regulators

14.2 Notification

We will notify you of material changes by:

  • Email to your registered address
  • In-app notification
  • Posting a notice in the app or on our website
  • Updating the “Last Updated” date at the top of this policy

14.3 Review and Consent

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

For material changes that require consent under applicable law:

  • We will obtain your explicit consent before the changes take effect
  • You may decline and close your account if you do not agree

15. Contact Us

15.1 Privacy Questions

For questions, concerns, or requests regarding this Privacy Policy or our data practices:

MicroCloudSystemsLLC

  • Privacy Email: [PRIVACY EMAIL]
  • Support Email: [SUPPORT EMAIL]
  • Address: 2807 N PARHAM RD STE 320
  • HENRICO, VA 23294-4458
  • Data Protection Officer: [DPO EMAIL] (if applicable)

15.2 EU Representative

For users in the European Union, our EU representative (if required) can be contacted at:

  • [EU REPRESENTATIVE NAME AND ADDRESS]

15.3 Response Time

We aim to respond to all privacy inquiries within:

  • 30 days for general inquiries
  • 30 days for GDPR requests
  • 45 days for CCPA requests

16. Supervisory Authority

16.1 Right to Lodge Complaints

If you are in the EU, you have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights or applicable data protection laws.

16.2 Data Protection Authorities

You can find your local data protection authority at:

  • https://edpb.europa.eu/about-edpb/board/members_en

17. Additional State-Specific Rights

Residents of certain U.S. states may have additional privacy rights under state laws. If you believe you have additional rights under your state’s privacy laws, please contact us at info@microcloudsystems.com.

Summary of Key PointsWhat We Collect:

  • Account information, conversations, location, activity, preferences, calendar, usage data

Why We Collect:

  • Provide AI persona service, improve functionality, personalize experience, security

Who We Share With:

  • AI providers (Anthropic, OpenAI), cloud infrastructure (Railway), maps/weather APIs, payment processors
  • We do NOT sell your data

Your Rights:

  • Access, correct, delete your data; export data; opt out of communications; close account

Data Retention:

  • Active until account deletion; 30-day deletion timeline after request

Security:

  • Encryption, access controls, regular audits, incident response procedures

Age Requirement:

  • 16 years or older

Contact:

By using ImyMe, you acknowledge that you have read and understood this Privacy Policy.

Last Updated: 11/25/2025