1) Who We Are / Contact
Controller/Operator: Tracy Team
Contact Email: fernandomortara562@outlook.com
2) Age Requirement (17+)
Tracy is intended for users aged 17 and older. We do not knowingly collect personal information from anyone under 17. If you believe a minor has provided personal information, contact us and we will take steps to delete it.
3) Information We Collect
We collect information in three main ways: (a) information you provide, (b) information collected automatically, and (c) information collected through cookies and similar technologies.
- Information you provide: account information (name, username, email), customer support content, and any content you choose to upload or enter for persona creation and chat simulations.
- Automatically collected: device information, usage data, crash logs, and location (only if you allow it; precise or approximate depending on permissions).
- Cookies and similar technologies: used for login, preferences, performance measurement, and reliability (may include web beacons).
4) How We Use Information
- Provide and maintain the App and features.
- Personalize your experience.
- Improve the App and develop new features.
- Ensure safety and security; prevent fraud and abuse.
- Provide customer support.
- Comply with legal obligations and enforce agreements.
We do not sell your personal information.
5) AI Features and Processing of Uploaded Text/Images
Tracy includes AI-related features to help you create virtual personas and engage in immersive chat simulations.
- Processing location: your uploaded/entered text and images are processed on Tracy Team’s own servers.
- No third-party sharing for processing: we do not share your uploaded text/images with any third party for processing.
- No training/marketing: your uploaded text/images are not used to train third-party models and are not used for marketing.
- Deletion after processing: once processing is complete, uploaded text/images are deleted promptly from our servers unless you choose to store content in your account (e.g., saving a persona or conversation).
- Your control: you choose whether to upload content and whether to generate AI outputs.
6) Photos and Face-Related Data
- No facial recognition or biometric identification; no biometric templates are created.
- Photos/images are used only for the specific generation request you initiate.
- Uploaded photos/images are deleted promptly after processing.
- Generated results are stored locally on your device by default where applicable.
- Photos/images are not used for training or marketing.
7) Legal Bases (Where Required)
Depending on your location, we rely on one or more legal bases such as contract performance, legitimate interests, consent (for optional features like location), and compliance with legal obligations.
8) Sharing and Disclosure
We share information only as needed and in the minimum necessary way:
- With your consent.
- Service providers (processors): under contractual obligations to protect information and use it only for providing services to us.
- Legal requirements: when required by law or legal process.
- Protect rights and safety: to prevent fraud, abuse, or security incidents.
AI processing note: your uploaded text/images for AI processing are processed on our own servers and are not shared with third parties for processing.
9) International Transfers
Your information may be processed in countries other than where you live. Where required, we use appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent lawful transfer mechanisms.
10) Data Retention
- Account data: retained while your account is active.
- After account deletion: delete or anonymize within 30 days.
- Usage analytics: up to 12 months.
- Customer support: up to 6 months.
- AI uploads: deleted promptly after processing unless you choose to save content.
11) Security
We use reasonable safeguards such as encryption (in transit and at rest where appropriate), access controls, regular audits/monitoring, and backups. No method of transmission or storage is 100% secure.
12) Your Privacy Rights and Choices
Depending on your location, you may have rights such as access, correction, deletion, restriction/objection, and withdrawal of consent.
To exercise your rights, email fernandomortara562@outlook.com. We aim to respond within 5 business days.
13) Location Permissions
If you enable location access, you can change or revoke that permission at any time in your device settings. If you do not enable it, the App will not collect location data.
14) Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will update the Effective Date and may provide additional notice within the App where required by law.
15) Dispute Resolution
To the extent permitted by law, any dispute arising out of or relating to this Privacy Policy will be resolved by binding arbitration. The governing law will be the law of the jurisdiction where Tracy Team is primarily established, without regard to conflict of laws principles. The seat of arbitration will be Tracy Team’s principal place of business, and the arbitration will be conducted in English.