Privacy Policy

1. Introduction

This Privacy Policy describes how Privam ("we," "our," or "us") handles information in connection with our mobile application ("App"). Privam is developed and operated by Sayene, a brand of SayEnergy Sp. z o.o.

This Privacy Policy is an integral part of our Terms of Use, available at terms.html.

2. Information We Do NOT Collect

Privam is built on a privacy-first architecture. We do NOT collect:

• Personal information (names, email addresses, phone numbers)
• Chat conversations or message content
• User account information (no accounts required)
• Device identifiers or unique user identifiers
• Location data
• Contact lists or address books
• Photos, videos, or other media files
• Usage analytics or behavioral data
• Search queries or AI interaction history

3. How Privam Works

On-Device Processing

• All AI chat functionality operates entirely on your device
• AI models and configurations are downloaded directly to your device
• Your conversations never leave your device
• No internet connection required for core chat features
• No servers process or store your data

Local Data Storage

• AI models are stored locally on your device
• App settings and preferences are stored locally
• Chat (if any) history remains on your device only
• You can delete all data by uninstalling the app

4. Third-Party Services

Google AdMob (Free Version Only)

The free version of Privam displays advertisements through Google AdMob. Important details:

• Non-Personalized Ads: We only serve non-personalized advertisements
• No Personal Data Shared: We do not share any personal information with Google AdMob
• AdMob Privacy: Google AdMob may collect limited technical information for ad delivery. Please review Google's Privacy Policy for details
• Ad-Free Option: Premium version removes all advertisements

In-App Purchases

Premium features (when available) are available through:

• Google Play Store (Android)
• Apple App Store (iOS)

Purchase processing is handled entirely by these platforms according to their respective privacy policies and terms of service.

Gemma AI Technology

Privam uses Google's Gemma AI models, which operate entirely on your device:

• No data is sent to Google's servers
• Gemma models process conversations locally
• Gemma is provided under and subject to the Gemma Terms of Use found at ai.google.dev/gemma/terms

5. Data Security

Since we don't collect or transmit data, traditional data security concerns are minimized. However:

• All processing occurs on your secure device
• AI models are downloaded through secure connections
• App updates are delivered through official app stores
• No user data is stored on external servers

6. Your Privacy Rights

Data Control

• You have complete control over your data since it never leaves your device
• Delete all app data by uninstalling the application
• No account deletion needed (no accounts exist)

Advertising Choices

• Upgrade to Premium to remove all advertisements
• AdMob ads are non-personalized and don't track you

7. Children's Privacy

Privam does not knowingly collect personal information from children under 13 years of age. Since we don't collect any personal data, the app can be used by children, but we recommend parental supervision for AI interactions.

8. International Users

Privam is available globally and operates the same way regardless of location:

• No data collection occurs anywhere
• All processing remains on your device
• Compliant with GDPR, CCPA, and other privacy regulations by design

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do:

• The updated policy will be posted in the app and on our website
• The "Effective Date" will be updated
• Continued use of the app constitutes acceptance of changes
• Material changes will be prominently communicated

10. App Store Compliance

Google Play Store

• This policy meets Google Play's Data Safety requirements
• No personal or sensitive data is collected
• Non-personalized ads only in free version

Apple App Store

• This policy meets Apple's App Privacy requirements
• No data collection occurs
• Privacy nutrition label reflects zero data collection

11. Technical Information

Device Requirements

• Sufficient storage for AI model downloads
• Compatible device specifications for local AI processing
• No network requirements for core functionality (connection is required for initial model download)

Model Updates

• AI models may be updated periodically (this require internet connection)
• Updates downloaded directly to your device
• No personal data involved in update process

12. Contact Information

13. Governing Law

This Privacy Policy is governed by the laws of Poland, consistent with our Terms of Use.

14. Language Versions

This Privacy Policy is available in English as the base language. Additional language versions may also be provided. In case of conflicts between language versions, the English version prevails.

15. Summary