Privacy Policy

1. Who we are and what this policy covers

Avatario is a mobile entertainment app in which you pick a themed room (a "group"), choose a fictional AI character (an "avatar" or "leader") and chat live with other people and with AI characters. This Privacy Policy explains what information the Avatario app and its backend service (together, "Avatario", "we", "us") collect, how it is used, and the choices you have. It applies to the Avatario app on Android and iOS and to the Avatario web service the app talks to.

Avatario is operated by Techno Pulse Ltd (the "operator"). Where data-protection law such as the UK GDPR or the EU GDPR applies, the operator is the data controller for the processing described here.

2. No account, no sign-in

Avatario does not ask you to create an account, sign in, or give us your name, email address, phone number or any other contact detail. We do not collect your precise location. Instead, the app uses two identifiers for your installation, described in the next section, so that your votes, your chosen leader and the groups you create can be told apart from other people's.

If you buy a subscription, you pay through the App Store or Google Play with your Apple ID or Google account. We never receive your name, email address or payment details (see 3.5).

3. The data we collect and why

3.1 Installation identifiers

Uninstalling the app removes both identifiers from the device, but it does not always give you new ones:

• On Android, the Android ID is not reset by uninstalling. The same value comes back when you reinstall the app on the same device, and it normally changes only when the device is reset to factory settings. On Android 8.0 and later it is tied to this app's signing key, so apps from other developers receive a different value; on older Android versions it is the same for every app on the device. If backup is switched on for your Google account, Android may also restore the app's stored settings, including the device token, when you reinstall the app or set up a new device.
• On iPhone and iPad, a reinstall creates a new device token. The user identity ID also changes, unless another app from the same developer is still installed on the device, in which case Apple supplies the same identifier for vendor again. Restoring the device from a backup can bring back both.

We do not use these identifiers for cross-app tracking or advertising profiles.

3.2 Messages and group activity

• Messages you send are transmitted to our service. If the group has AI voice or AI translation switched on, an AI model may rewrite or translate them (see section 4). They are then broadcast live to everyone in the group. Groups are live-only: the service does not keep a chat history. To make features work, it holds the most recent lines of each group in memory only. These are the last 200 lines, used to show the messages around a highlighted message when you open a notification. There are also the last 40 lines, used for AI replies and for picking relevant sponsored products (section 6). Newer lines push older ones out, and all of it is cleared whenever the service restarts.
• "Top messages" leaderboard. The app keeps, on your device, the messages you reacted to most. Up to three of them, with a few surrounding messages for context, are sent to our service and shown to all users as the app's "top comments". This is the only chat text we store.
• Reactions. When you react to a message, the reaction is sent to our service with your device token. It is counted there, one reaction per device per message, so everyone in the group sees the same totals and reaction milestones can be detected. The counts are kept in memory only.
• Polls, votes, reports and game activity. These are processed in memory on our service, keyed by your device token, so everyone in the group sees the same result. They include poll questions and options, votes, message reports, kick votes and kick bans, rewards given to messages, steers, Pong matches and spy activity.
• Influence. Influence is the in-app points balance you earn and spend as a leader. It is stored on our service for each group, device token and leader, so your balance survives a service restart. It contains no message text.
• Group reports. When you report a group, we store a one-way hash of your user identity ID with that group, so each person's report counts once. We also store the group's total report count.
• Private groups. A group owner can protect a group with a password. We store only a salted one-way hash of it, never the password itself. Failed password attempts are limited per IP address, in memory.
• Aggregate counters. Each group keeps running totals of messages, reactions and actions, and we count how often each video is shared. These are counts only and contain no message text.

3.3 Media you upload or create

• Poll attachments (a photo or video you pick or capture) are uploaded to our media storage and shown to everyone in the group.
• Video Studio recordings. When you use the Video Studio, the app screen-records the message replay on your device. The clip stays on your device, or in your photo library if you choose "Save video", unless you do one of three things:
  • share it;
  • post it into a group, which uploads it to our storage and shows it to the group;
  • ask for an AI remix or extension, which uploads the clip to our service and to our AI video provider (see section 4). The result is stored in our media storage.
  Messages you save in the Video Studio ("Saved messages") stay on your device.
• Milestone videos. When a message you reacted to crosses a reaction milestone, the app takes a screenshot of the chat (message bubbles and avatars only, never your keyboard or what you are typing). It sends the screenshot with the recent messages to our service, which asks an AI video model to generate a short celebration clip. The clip is then shown to the group. The job's input is deleted once the video has been made.
• Leaders and avatar portraits you create. When you create leaders for your own group, we store the details you give each one and show them to everyone who enters that group. These details are its name, persona text, AI prompt and narration, voice settings, relationships with other leaders, and portrait. A portrait is either an image you upload from your device or one generated by an AI image model from a description you type (the description is sent to the model provider, see section 4). If a portrait or persona depicts a real person, you, not the operator, are responsible for having the right to use their likeness. The operator does not vet user-created leaders, and will remove a leader on request from the person depicted or a rights holder (see section 10).
• Sponsored cards you create. If you run your own sponsored cards in your group, we store their text, link, price and any image or video you upload, and show them to the group (see section 6).

3.4 Community themes

If you publish a colour theme to Community Themes, we store the theme's colours, the name you give it and the author name you type, and show them publicly to every user. Choose an author name you are comfortable sharing. A background photo you pick for your own theme stays on your device and is never published.

3.5 Subscriptions and purchases

Premium and Professional are auto-renewing subscriptions sold through the App Store and Google Play. Apple or Google takes the payment, handles renewals and cancellations, and keeps the purchase record under its own privacy policy. We never receive your payment details, name or email address.

• With each purchase, the app gives the store a one-way hash of your user identity ID (Apple's "application username" or Google's "obfuscated account ID"). The store uses it to link the purchase to this installation and to help prevent fraud.
• The app checks your subscription with the store directly on your device and stores your current plan on the device. Our service does not receive or store your receipts or purchase history.

3.6 Push notifications

If you allow notifications, the app registers with Google's Firebase Cloud Messaging, which also delivers to iPhones through Apple's push service. It then subscribes to a single notification topic shared by every installation. When a message crosses a reaction milestone in a group that has milestone notifications switched on, one notification goes to that topic, showing the group and leader name. Firebase holds a registration token for your installation, but we do not receive it. We store no list of devices and send no marketing notifications. You can turn notifications off at any time in your device's settings.

3.7 Data that stays on your device

Some data stays in the app's private storage on your device and is not synced to our servers, except as described above:

• your reaction history and daily goals;
• your persona unlocks;
• your recent-message buffer and saved messages;
• your theme library;
• your consent record;
• your subscription status;
• drafts of groups you are creating;
• cached avatar images and media.

Deleting the app deletes them from the device. If your device's own backup is switched on (Google backup on Android, iCloud or computer backup on iPhone and iPad), a copy may be held in that backup under your Google or Apple account and restored when you reinstall the app.

3.8 Technical and diagnostic data

• Our hosting provider records standard web-server logs (IP address, request path, timestamp, user agent) for security and operations.
• Every request from the app includes the app's version number and platform (Android or iOS), so that we can ask you to update when a version is too old to work.
• Our service uses your IP address, in memory, to limit abuse (for example, too many requests or password attempts) when no user identity ID is available.
• Our service keeps application logs that may include group identifiers, avatar identifiers and error details. We avoid logging message text.

We do not use third-party analytics or crash-reporting SDKs in the app. The Firebase component is included only to receive notifications, and Firebase Analytics is switched off.

4. How AI processing works

Several features send content to AI models hosted by Microsoft Azure (Azure OpenAI Service and Azure AI Foundry) on our behalf:

• Message rewriting and translation. When a group has AI voice or AI translation switched on, the text you send is passed to a language model to be restyled or translated. It is sent together with the leader's persona and the AI prompt and narration its owner wrote. Only the rewritten text is broadcast; your original leaves your device only for this processing.
• AI character replies. Recent group messages (up to the last 20) are sent to a language model so that an AI character can reply in context. Where a group has the AI companion switched on, recent lines of the conversation are also used to keep it going when few people are there.
• Steering. Text you type into a "steer" is analysed by a language model and turned into guidance for the AI characters.
• Video and image generation. Chat screenshots with recent messages, Video Studio clips you ask to remix or extend, and portrait descriptions may be sent to image, speech and video-generation models, to produce the media described in section 3.3. For milestone videos, the speakers' names in the message text are replaced with generic labels before it is sent.

These models are used under Microsoft's enterprise terms, which prohibit the use of your content to train their models. AI output may be inaccurate or inappropriate; it is not reviewed by a human before it appears.

5. Content you post is public

Public groups are open to every user of the app, and private groups to anyone who has the password. Anything you post in a group (messages, polls, media, videos, your leader's name) is visible to everyone in the group at that time. Top messages, published themes and milestone notifications are visible to all users. Treat what you post as public.

6. Sponsored cards and affiliate links

Group owners can turn on sponsored cards, which appear on a schedule while you are in that group. A card is either an ad written by the group owner, or a product from the group owner's Awin affiliate product feed.

• To pick affiliate products that fit the conversation, our service extracts keywords from the group's recent lines (see 3.2) and matches them against the feed on our own servers. No chat text is sent to Awin. The feed access token the owner enters is stored on our service so it can download the feed.
• When a card is shown or tapped, the app sends a small telemetry event to our service: the group, the card identifier, whether it was shown or tapped, the time, and your device token. The token is one-way hashed and truncated before storage and is used only to count distinct devices. No name or precise location is involved.
• Tapping a card opens the advertiser's or merchant's website in your browser. Affiliate links carry a tracking parameter so that the network can attribute a purchase to Avatario; from that point the merchant's and Awin's own privacy policies apply. Product images on affiliate cards are loaded directly from the network's servers, which will see your IP address.

We do not build advertising profiles about you and we do not sell personal data.

7. Device permissions

You can revoke any of these in your device settings; the related feature will stop working.

8. Service providers and international transfers

We use the following providers to run Avatario. Each processes data only on our instructions and under its own security commitments:

• Microsoft Azure for hosting the Avatario service and its video rendering, real-time messaging, table and queue storage, and the Azure OpenAI / Azure AI Foundry language, image, speech and video models. Our service is hosted in the European Union (Sweden Central).
• Cloudflare R2 for storing avatar portraits, poll media, sponsored-card media, posted videos and generated videos.
• Google Firebase Cloud Messaging, with Apple Push Notification service on iPhone, for delivering milestone notifications (see 3.6).
• Awin for the affiliate product feed, product images and tracking links, only in groups that have affiliate cards switched on (see section 6).
• TikTok and X, only if you yourself choose "Post to TikTok" or "Post to X" from the Video Studio. The clip is handed to that app on your device and their terms apply. Separately, videos posted into groups may be published by the operator to the operator's own TikTok account, as described in section 3.3.
• Apple (App Store) and Google (Google Play) for app distribution, and for subscription payments, renewals and refunds, under their own policies (see 3.5).

Some providers may process data outside the UK / EEA. Where they do, transfers rely on the providers' standard contractual clauses or an adequacy decision.

9. How long we keep data

• Chat messages: no chat history is stored. The recent lines described in 3.2 are held in memory only, until newer lines replace them or the service restarts.
• Top-messages leaderboard: kept until displaced by a higher-scoring message.
• Reactions, polls, votes, message reports, rewards, steers, matches and spy activity: in memory only. They are cleared when the poll or match ends, as they age out, or when the service restarts. Kick bans last one minute.
• Avatar claims: expire automatically after 5 minutes without a heartbeat.
• Influence balances: kept with no fixed expiry, so they survive restarts. You can ask us to delete them (section 10).
• Group reports (hashed identity and report count): kept while the group exists and deleted with it.
• AI video edit limit records: no longer counted after 5 days, and deleted the next time the limit is checked.
• AI video jobs: the input is deleted when the job finishes. The resulting video is kept like other media.
• Media (poll attachments, avatar portraits, sponsored-card media, posted and generated videos): kept until the group, leader or card is deleted, or until we remove them in routine clean-up.
• Ad telemetry: daily aggregate counters and hashed device tokens, kept for up to 90 days.
• Groups, leaders, sponsored cards and published themes: kept until deleted by their owner or by us.
• Subscriptions: we keep no purchase records. Apple and Google keep them under their own policies.
• Server logs: kept by our hosting provider for a limited period for security.

10. Your rights and choices

Depending on where you live, you may have the right to access, correct, delete or restrict the personal data we hold about you, to object to certain processing, to data portability, and to complain to a supervisory authority (in the UK, the Information Commissioner's Office).

Because Avatario has no accounts, we cannot look up "your" data by name, and the app does not display its identifiers. If you contact us (section 14), tell us which groups you used or created, roughly when, and what content is concerned. We will locate and delete what we can. You can also:

• delete groups and leaders you own from within the app, which also removes their media;
• uninstall the app, which deletes the data and identifiers stored on the device. A later reinstall can receive the same identifiers again (see 3.1), so if you also want the data held on our service deleted, contact us (section 14);
• leave a group to release your leader and stop your messages being broadcast;
• turn off notifications in your device's settings;
• manage or cancel a subscription in your App Store or Google Play settings (see our Support page).

If a leader created by another user depicts you (your name, likeness or photograph), or a character or artwork you hold the rights to, you can ask us to remove or alter it. Contact us (section 14) with the group and leader name and a short statement of who you are or what rights you hold. We treat a real person's request about their own likeness as a priority.

11. Children

Avatario carries the age rating shown on its Google Play and App Store listings. Groups contain unmoderated AI-generated and user-generated content, so parents and guardians should supervise younger users. We do not knowingly collect personal data from children below the age of digital consent in their country (13 in the UK and the United States, 13 to 16 in the EU). Because Avatario has no accounts, we do not ask for a date of birth. If you believe a child below that age has used the app and that data about them is held on our service, contact us and we will delete it.

12. Security

Traffic between the app and our service is encrypted (HTTPS / secure WebSockets). Media is kept in private storage and can be reached only through our service or through short-lived signed links that our service issues. Private-group passwords are stored only as salted hashes, and requests to our service are rate-limited. No system is perfectly secure, and because groups are public by design, the strongest protection is not to post information you would not want others to see.

13. Changes to this policy

We may update this policy as the app changes. The effective date at the top will change, and if the changes are material the app will ask you to accept them again on its next launch.

14. Contact

Questions, requests or complaints about privacy: contact@technopulse.co.uk.