Politique de confidentialité
How Averlo collects, uses, shares, and protects information
La version anglaise de ces politiques fait foi. Toute traduction est fournie uniquement pour convenance.
This Policy describes personal information handled by Averlo, LLC, a Wyoming limited liability company, in operating Sugar AI at https://sugarai.fun/ and https://sugarai.art/. Averlo is the controller for processing it determines. NOWPayments is a separate controller for the cryptocurrency payment it processes. Our correspondence address is 1021 E Lincolnway Suite #10730, Cheyenne, Wyoming 82001, United States and privacy email is [email protected].
Sugar AI serves adults only. Private AI conversations can reveal intimate preferences and other sensitive information. This Policy explains that processing; it is not a promise that a conversation is privileged or inaccessible to authorized safety personnel.
1. Scope and Information Sources
We handle information from visitors, account holders, purchasers, community contributors and people submitting reports. It comes from you, your use of our services, and authentication, payment, and service providers. Information may also come from a rights holder, affected person or competent authority. Section 11 lists the categories we actually process.
2. Information and Purposes
- Account data: email, account identifier, login credentials or authentication references, settings and necessary eligibility information, used to authenticate and administer your account. Optional profile fields should not disclose a real person's identity.
- AI interaction data: prompts, messages, fictional character settings, generated media and associated metadata, processed to produce the response, maintain requested conversation history and supply the selected feature. Real-person images and characters are prohibited. Optional media inputs, if a feature accepts them, must meet the synthetic-content rules.
- Community data: posts you actively submit, captions, tags, selected public profile fields and interactions. Approved material becomes visible to the community. Creating privately is not consent to publish.
- Age confirmation: a first-party cookie recording that you confirmed you meet the age requirement. We do not collect identity documents, selfies, or biometric data for access or publication.
- Transaction data: credit pack, price in US dollars, order reference, payment outcome, and refund or dispute status returned by NOWPayments. Payment is cryptocurrency only. We do not receive card numbers or wallet private keys. Do not email those to support.
- Device and usage data: IP address, browser and device information, approximate location, login activity, and security events, for operating the service, preventing fraud, and troubleshooting. We do not use analytics or marketing cookies.
- Support and safety records: contact details, report content, affected URLs, moderation findings and necessary evidence, for responding to requests, enforcing policies, protecting people and meeting legal duties.
3. Sensitive Information and Consent
Chats may reveal sex life, sexual orientation, health information or other sensitive characteristics even when you do not enter them as a profile field. Where processing requires explicit consent or another special legal condition, we must obtain that consent or establish the applicable condition before processing. Accepting the Terms, starting to use the Service or paying is not by itself explicit consent to sensitive-data processing.
We do not currently ask you to opt in to a separate sensitive-data or marketing use. If we later rely on explicit consent, that choice will be separate from buying credits or accepting the Terms, and you will be able to withdraw it. Withdrawal would not undo processing already lawfully performed. Processing necessary for legal duties or legal claims requires its own valid basis.
Do not submit a real person's image, another person's sensitive information, government identifiers, financial credentials or records unrelated to a requested support or verification process. We do not infer consent from the fact that information appears in a prompt.
4. Legal Bases Where GDPR or UK GDPR Applies
- Contract: the account, inference and delivery processing objectively necessary to supply your requested service; this basis alone does not authorize special-category data processing.
- Legitimate interests: proportionate security, abuse prevention, service troubleshooting and legal-claim administration, following an assessment of users' rights and reasonable expectations.
- Legal obligation: required recordkeeping, reporting and lawful responses to competent authorities.
- Consent: only where a specific choice is actually offered. We do not currently use optional analytics or marketing cookies. Special-category information also needs an Article 9 condition where that law applies.
The Processing Schedule identifies the actual purposes and bases for material processing. We do not claim that one of these bases automatically permits every use of chat data.
5. AI Providers, Human Review and Training
Delivering a request may send the relevant prompt, context and media to the inference or moderation providers identified in Section 11. We minimize information sent and apply contractual and access controls appropriate to the processing. Authorized staff may inspect relevant content for a user-requested support investigation, abuse report or safety concern. Publication submissions undergo moderation before public display.
Averlo does not use your private chats or generated media to train its own models, and does not sell them for advertising. A contracted inference provider may process the prompt and media needed to produce the output you request. A content license in the Terms is not consent to train on personal information.
6. Disclosure and Public Content
Information may be disclosed to contracted infrastructure, inference, moderation, authentication, customer-service, and payment providers for their identified functions; authorized personnel and professional advisers; or a business successor under appropriate safeguards. Disclosure to courts, regulators, child-protection bodies or law enforcement is limited to what is lawful and necessary for the relevant duty or safety issue.
For a payment dispute we use transaction and relevant account records. Private intimate conversations are not routinely sent as proof of delivery; any exceptional disclosure needs a specific lawful justification and minimization. For a safety or consent dispute, evidence may be shared with an independent reviewer under confidentiality safeguards. Statutory copyright notices and counter-notices may be forwarded as explained in the DMCA Policy.
When you publish a community post, eligible viewers can see the post and associated public profile information. They may copy it. Withdrawal from public display does not recover copies already made outside our systems. We do not promise absolute confidentiality for information that must be lawfully disclosed.
We do not sell personal information and do not share it for cross-context behavioral advertising. Paying an infrastructure or inference provider is not permission to use intimate data for advertising.
7. Cookies
The Cookies Policy lists the storage we use. We use cookies needed to sign you in, remember your language, and remember your adult-access confirmation. We do not use analytics or advertising cookies. A cookie set on sugarai.fun is not sent to sugarai.art, and the reverse is also true.
8. Retention, Deletion and Security
We retain information only for the purpose, the law, a payment dispute, or a documented legal hold. A hold covers the relevant evidence. It is not a reason to keep all intimate content indefinitely. Restricted safety evidence is separated from ordinary user access and is not used as training data. Section 11 states the retention rule for each category.
Deletion requests may be sent to [email protected]. We verify requests proportionately. Active records, published posts, backups, and provider copies can take different amounts of time to delete. Credit purchases do not renew, so account deletion does not involve cancelling a subscription. Records retained for a legal reason stay limited to that reason.
We apply access limitations, secure transmission, logging, provider oversight and incident-response arrangements appropriate to the information. No service can guarantee perfect security. Material safeguards and any legally required breach notifications must reflect actual implementation.
9. International Transfers and Regional Contacts
Averlo is incorporated in Wyoming, United States. Account data is stored with our infrastructure provider, and prompts may be processed by inference providers in the United States or other countries where those providers operate. Where EEA or UK rules apply, a transfer uses an available lawful mechanism. We have not appointed a separate EEA or UK representative. You may ask about applicable safeguards at [email protected].
10. Your Rights and Automated Decisions
Depending on the law that applies and its scope, you may request access, correction, deletion, portability, restriction, an objection, withdrawal of consent, an advertising opt-out, or review of a denied request. California rights may include information about collection and disclosure, correction, deletion, opt-out of sale/sharing and limits on specified sensitive-data uses. Other U.S. states provide rights where their laws apply. EEA/UK users may complain to their supervisory authority. We do not require a user to waive such rights to submit a safety complaint.
Send a request to [email protected] with sufficient information to identify the account or processing. An authorized representative can act where law permits. We respond within the applicable legal period and explain any permitted extension or denial. Where available, appeal a denial by replying to it; the denial notice will identify the appeal route. We will not unlawfully discriminate for exercising rights.
Automated moderation, fraud controls or age checks can make mistakes. An affected user can seek human review through [email protected]. We do not use an AI companion to determine employment, credit, housing or another similarly consequential eligibility decision about a user.
11. Processing and Retention
| Category | What we process | How long |
|---|---|---|
| Account | Email, account identifier, and sign-in session, stored with our authentication and database provider | While the account is open. Deleted after account deletion, except limited safety, fraud, or legal records |
| Chats and media | Prompts, messages, and generated media, sent to the inference provider needed to produce the output you request | Until you delete the content or the account, unless a safety or legal hold applies to a specific item |
| Community | Posts you submit and the public profile fields you choose to show | While the post is published, then as needed for safety or legal duties after removal |
| Age confirmation | The mature_ok cookie on your device. No identity document or biometric data | Until the cookie expires or you delete it |
| Payments | Credit pack, US dollar price, order reference, and payment status from NOWPayments. No card numbers or wallet private keys | As needed for purchase records, refunds, fraud prevention, and legal duties |
| Analytics and advertising | None. We do not sell personal information or use advertising cookies | Not applicable |
| Model training | We do not train Averlo models on your private chats or media | Not applicable |
| Support and safety | Messages you send us and records needed to investigate a report | For the request and any required safety or legal period |
12. Updates and Contact
We publish material changes with the notice or renewed choice required by law. A change to this Policy is not retroactive consent to a new use of sensitive information.
Controller: Averlo, LLC. Address: 1021 E Lincolnway Suite #10730, Cheyenne, Wyoming 82001, United States. Privacy: [email protected]. Safety or removal reports: [email protected].