Privacy Policy

The controller of your personal data is the operator of Brolivo:

• Operator: [operator details pending]
• Address: [operator details pending]
• NIP (Polish tax number): [operator details pending]
• E-mail: brolivo@darebay.com

Write to the e-mail address above about anything in this policy, including requests about your personal data.

In the table, “contract” means Art. 6(1)(b) GDPR (we need the data to give you what you ask for), “legitimate interest” means Art. 6(1)(f) GDPR and “legal obligation” means Art. 6(1)(c) GDPR.

The periods below describe configured cleanup thresholds or operator policy targets. Scheduled cleanup, log deletion and backup deletion have not yet been verified for the current test service. These periods are not confirmed automatic deletion deadlines for that service. Contact brolivo@darebay.com for current information or a data request.

Our legitimate interests are: keeping the free service available and secure, keeping the app’s code up to date between store releases, preventing abuse, helping you with your own conversations, handling reports, measuring and improving answer quality, including tests of variants, and knowing which campaigns bring people to Brolivo. The operator must document how these interests are balanced against your rights and those of the people in your chats before this policy is finalized. You can object to this processing or ask for the available information at brolivo@darebay.com.

You don’t have to give us any data. Without the text of a request we cannot answer it, and without an e-mail address you cannot have an account. You can purchase in the app without an account.

The backup policy target is removal of deleted database data from backups within 35 days. We have not yet confirmed that the current test service enforces that schedule; contact brolivo@darebay.com for information about a specific deletion request.

In the app, RevenueCat verifies purchases using store receipts, purchase history, subscription status, technical app and device information, and random device or account identifiers. We do not send RevenueCat your chats, screenshots, e-mail address or advertising identifiers. When you sign in and restore purchases, we associate verified access with your account; signing out does not give the next account access to that subscription.

To prepare your answer, we send your submitted conversation or chosen import excerpt, draft, note and selected screenshots to third-party AI service providers. The permission screen names the services reachable under the current configuration: Kie AI, Anthropic, or both. Screenshots include visible names, photos and other image content. We do not send your account or device ID with the AI request.

We do not train AI models on your content. This describes Brolivo’s own use; it is not a promise about every provider. Kie’s terms permit content use for operating and improving its services. Its website privacy policy does not establish API chat training terms.

Kie’s service guide lists 2 months for text/metadata logs and 14 days for generated media. These are not confirmed deletion deadlines for uploaded screenshots, chat contents or upstream copies. We cannot confirm the complete retention or training terms of Kie’s downstream services.

For direct Anthropic API requests, Anthropic’s standard retention policy states deletion within 30 days, with contractual, feature-specific, safety and legal exceptions. Flagged inputs/outputs may remain for 2 years and safety classifications for 7 years. These terms do not cover requests sent through Kie AI.

AI permission is separate from your 18+ confirmation. You can decline before sending or withdraw it in Settings. We then require permission again before another AI request; an already submitted request cannot be recalled. A change to the disclosed recipients or notice requires renewed permission. Provider deletion requests can be sent to brolivo@darebay.com; deleting local history does not erase provider records.

Before sending text, we filter recognizable e-mail addresses, phone numbers, links and @handles. This cannot remove every personal detail, and it does not redact screenshot pixels. Our server also checks texts for signs of a crisis or of a person under 18, so it can show help contacts or stop instead of writing tips.

Our instructions and safety checks limit harmful or privacy-invasive answers. They do not guarantee that an answer or a public card contains no personal information.

Suggested replies and optional conversation details are generated from the material you submit. Recent results follow the local-history rules in the data table; our servers do not keep private conversation history or build a profile of your contacts.

We make no decisions about you by automated means that have legal or similarly significant effects (Art. 22 GDPR). Answers can be wrong or unsuitable, so read them before you send anything.

What you send often contains another person’s messages, name or photo, usually of the person you are talking to. We receive these data only from you, as part of your request, and use them only to write your answer. Our legal basis is legitimate interest (Art. 6(1)(f) GDPR): your interest in getting help with your own conversation. We limit what reaches us so that this interest does not override the other person’s rights:

• our servers do not save raw conversations or screenshots; local history, previews, reports and public cards have the separate rules in the data table;
• screenshots are sent in full for analysis, including any visible names and photos; we may resize images or split them into parts without removing their content;
• recognizable contact details are filtered from text before transfer, without a guarantee of full anonymization;
• we use safety instructions and checks, and do not build a cloud profile of your contacts.

Chats can reveal sensitive information, such as health, sex life or beliefs. Send only the material needed for your question and that you are entitled to share. Your AI permission does not give consent on another person’s behalf. Remove unnecessary identifying or sensitive details before sending.

We do not collect a contact list to identify or notify the people in your chats. This public policy explains the processing to them too. If you think your data reached us through someone else’s request, write to brolivo@darebay.com; we will assess the request and the information and deletion duties that apply.

We share data with the providers needed to run Brolivo. The AI permission screen identifies which of the following third-party AI service providers can receive the current request, including a fallback:

Where a provider acts as our processor, it is bound by the applicable processing agreement. The AI section distinguishes our handling from published provider terms and their limits. Authorities and courts receive data when the law requires it. We don’t sell data and have no advertising partners.

Resend applies when e-mail sign-in is enabled; Stripe applies when website checkout is available. The table describes supported services, not confirmation that every service is active. We still need to confirm the current hosting details, support-mail handling and applicable processing agreements before finalizing this policy.

The third-party AI service providers named above may process data outside the EEA, including the USA. The permission screen reflects the services reachable for your request. A model’s name alone does not establish who operates every upstream service. We have not confirmed Kie AI’s complete downstream locations or transfer safeguards; request the available information at brolivo@darebay.com.

RevenueCat processes subscription information in the USA; its Data Processing Addendum includes Standard Contractual Clauses for restricted international transfers. Expo processes app update checks in the USA; its terms provide the EU standard contractual clauses for its processing as a processor. We still need to confirm that they cover these requests. Apple and Google describe their own processing and transfers in their store privacy policies.

We use no advertising or analytics cookies and no advertising trackers. The website loads no third-party trackers at all and keeps only these items on your device:

Recent conversation cards can include a small screenshot preview held only in page memory on the web, or process memory in the app. It disappears when you reload or close the browser tab, close the app process or delete the conversation. Full screenshots and previews are not kept in saved device history or on our servers; the app tries to remove temporary image files when they are no longer needed. Cleanup failures may leave temporary copies on the device. The app keeps recent text inputs and results in memory for its current session; sending it to the background may keep that session open. This is not cloud account history.

The app also stores your calibration choices, writing preference, completed UTC practice dates and whether you have seen the first Pro offer on this device. Both the website and app keep a local AI-permission withdrawal marker that prevents further sends even if the server is temporarily unavailable. It records whether withdrawal is pending or completed and remains until you expressly grant permission again or clear the site’s or app’s stored data. The permission receipt itself is stored on our server. These are local settings, not training data. Imported chats are parsed locally: participant labels help you choose whose messages are yours, and only the selected messages, their roles and available timestamps are sent for analysis. The server does not save the imported file or transcript. The app can keep a temporary archive copy while you choose or switch between chats. It tries to remove temporary copies when they are no longer needed and during later cleanup, but no deletion deadline is guaranteed. Your original file remains under your control.

Stripe’s payment page sets its own cookies under Stripe’s policy. You can delete all of the above at any time in your browser’s settings (site data); you then get a new device ID.

The app stores a random installation identifier and sign-in credentials in protected device storage. On iOS, Keychain data can survive deleting and reinstalling the app. Deleting the app or clearing local history therefore does not itself erase the server-side device record, reports, usage records or purchase association. Delete my data in the app’s Settings (Your data on this phone) does: see Your rights. The app’s update component (Expo’s expo-updates) keeps in the app’s storage its own random installation ID, the values Expo’s update service asked it to send back, the app updates it has downloaded, the description of a failed start until the next update check carries it, and a log of its own update events, which never leaves the phone: each start removes its entries older than a day. They are not linked to your device ID or account. Deleting the app removes them (a backup of the phone can bring the ID back); Delete my data does not.

Under the GDPR you have the right to:

• access your data and get a copy of it;
• have inaccurate data corrected;
• have your data erased: you can delete your account yourself on the account page or in the app’s Settings and, without an account, delete an app install’s data in the app’s Settings (Delete my data);
• restrict the processing;
• data portability, for the data you gave us;
• object at any time to processing based on our legitimate interest, including the campaign code;
• withdraw AI permission in Settings at any time, without affecting the lawfulness of earlier processing or automatically deleting a provider’s existing records.

Write to brolivo@darebay.com. We answer within one month; for complex requests we can extend this by two more months and will tell you why. We may ask you to confirm that it is you, for example with a code sent to your e-mail address. Without an account we usually cannot tell which data are yours, because we don’t know who uses a device ID.

You can complain to the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl, or to the data protection authority of the EU country where you live or work.

Deleting an account, or an app install’s data with Delete my data, removes its subscription association and requests deletion of that customer’s RevenueCat record. RevenueCat processes deletion asynchronously. Store purchase records remain subject to Apple’s or Google’s policies and legal retention duties. Deleting the app, an account or an install’s data does not cancel store billing: cancel it in the App Store or Google Play; Restore purchases can bring an active subscription back.

Delete my data in the app (Settings → Your data on this phone) deletes at once, without an account: the install’s 18+ confirmation and AI permission receipt, the campaign code of its first visit, its usage counters, its store purchase association, any public cards linked to it (their pages stop opening; copies others saved can remain; the app itself makes none) and its link in its own reports and in sessions; the app then forgets its local data and starts as a new install with a new device ID. Kept: reports without that link for their retention period, a card someone reported, hidden and without that link, while its reports are kept, AI call and answer-quality records, which hold no device ID, totals without IDs, backups until their retention ends, and the app update component’s installation ID, which stays on the phone until you delete the app (a phone backup can bring it back), with Expo’s records of update checks for as long as Expo keeps them. If we have blocked an install, its data is deleted on request to brolivo@darebay.com. Deleting an account in the app also deletes that install’s data. On the website, clear the site’s data in your browser for the local data. Deleting an account on the website does not delete the browser’s own device record, its usage counters or its link in reports. You may request access to your data, or deletion of a website guest’s server records, without creating an account: write to brolivo@darebay.com. We may need limited information to locate the relevant device or purchase record and verify your authority. Never send a password, sign-in code, session token or full private conversation. The retention rules and any applicable legal exceptions remain relevant.

If you are in Ukraine, you also have the rights given by the Law of Ukraine No. 2297-VI “On Personal Data Protection”, including the right to:

• know the sources of your data, the purposes of processing, where the data are and who processes them;
• get access to your data and learn who receives them;
• object to the processing and withdraw your consent;
• demand that we change or delete your data;
• be protected from unlawful processing and from accidental loss or destruction of your data;
• complain to the Ukrainian Parliament Commissioner for Human Rights or go to court.

Write to brolivo@darebay.com; we answer within 30 calendar days.

Brolivo is only for people aged 18 or over. If you tell a tool that you are under 18, the automatic check removes the 18+ confirmation from your device record; it does not delete an account. Stop using the service if you are under 18. You can delete your account in account settings. For help removing an underage person’s account or data, contact brolivo@darebay.com; the operator handles that request individually.

Data travel encrypted (HTTPS). Sign-in codes and session tokens are stored only as hashes, and IP addresses only as hashes with a key that changes daily. Logs never contain your texts, screenshots or e-mail address. Only the people who run Brolivo have access to the servers, as far as their work needs it. If a data breach puts your rights at risk, we will tell you and the supervisory authority as the law requires.

When we change this policy, we publish the new version here with a new date (this version: October 13, 2026). If a change is material, we tell account holders by e-mail before it takes effect. The operator arranges these notices individually before the change takes effect.

Questions about this policy or your data: brolivo@darebay.com.