Privacy Policy — chaRIZZma

This Privacy Policy explains how chaRIZZma ("chaRIZZma," "we," "us," or "our") collects, uses, discloses, and protects information in connection with the chaRIZZma mobile application for iOS and Android, our website at charizzma.ai, and related services (collectively, the "Service"). By using the Service, you agree to this Policy. If you do not agree, do not use the Service. The Service is intended only for users 18 years of age or older.

1. Information We Collect

Information you provide.

• Account information. When you register with Sign in with Apple (iOS) or Google Sign-In (Android), we receive a name (or the name you provide) and an email address, which may be an Apple private relay address. We do not receive your Apple ID or Google Account password.
• Profile and practice content. Display name, profile details, goals, and preferences you enter, and the messages, prompts, and content you submit during practice.
• Voice and video. Audio and, for avatar or peer video features, video that you transmit during live sessions, plus any session recordings or transcripts created where that functionality is provided and enabled.
• Communications. Information you send when you contact us, report a user, or submit feedback.

Device permissions. With your consent through your operating system, the App accesses your microphone (for voice practice), your camera (for video features), and, only if you enable an in-person feature that requires it, your location. We use these permissions solely for the related feature, and you can manage them in your device settings.

Information collected automatically. Features used, session length and frequency, in-App actions, coaching and progress metrics, device model, operating system version, app version, language, time zone, general (city or region level) location inferred from IP address, and diagnostic, crash, and performance data.

Cookies and similar technologies. On charizzma.ai, cookies and similar technologies for functionality and analytics, as described in Section 8.

Information from third parties. From Apple or Google: subscription and transaction status (not your full payment card details) and the sign-in identifiers above.

We do not collect, and ask that you not provide, more sensitive information than necessary for the Service.

2. Voice, Video, Biometric, and AI Processing

The Service relies on real-time processing of your voice and, for some features, video to deliver interactive AI avatars and coaching and to enable peer and group practice. To provide these features, your audio and video may be transmitted to and processed by our third-party providers, including HeyGen (interactive avatar streaming and its subprocessors for language models and text-to-speech) and LiveKit (real-time transport).

We process voice and video to operate the Service, generate AI responses and coaching, transmit your session to other users where you use peer or group features, and maintain safety and security. [Confirm and adjust to your actual data flow: chaRIZZma does not use your voice or video to create a unique biometric identifier or template for the purpose of identifying you, and does not sell or share biometric information.] Where applicable law (including the biometric privacy laws of certain U.S. states) requires consent before processing voice or facial data, your use of the relevant feature, together with any separate consent we present in the App, constitutes that consent, and you may withdraw it by discontinuing the feature and deleting your account.

3. How We Use Information

We use information to: provide, operate, maintain, and secure the Service; generate AI responses, coaching, and progress tracking; match and connect you with other users where you use those features, and display your profile and session content to them as part of the feature; process subscriptions and manage your account (in coordination with Apple or Google); communicate with you about the Service; detect, investigate, and prevent fraud, abuse, objectionable content, and Terms violations, and keep users safe; analyze usage to improve the Service; and comply with legal obligations and enforce our agreements.

We use AI-generated content to improve our AI models only where you have expressly opted in. You can opt out at any time in settings, and opting out does not affect the core Service.

4. How We Disclose Information

We do not sell your personal information and do not share it for cross-context behavioral advertising. We disclose information only as follows:

• Service providers and processors. With vendors who perform services for us, under contracts limiting their use to providing those services.
• Key service providers. As of the date below, these include Apple (authentication and subscription processing on iOS), Google (authentication and subscription processing on Android), HeyGen (avatar streaming and its LLM and text-to-speech subprocessors), LiveKit (real-time transport), [cloud hosting provider], [analytics provider], and [crash and performance monitoring provider]. We update this list as providers change; for a current list, contact hello@charizzma.ai.
• Other users. Where you use peer, group, or in-person features, your display name, profile content, and live or recorded session content are shared with the users you interact with. Do not share anything in these features you do not want other users to see or retain.
• Legal and safety. When reasonably necessary to comply with law, enforce our Terms, respond to lawful requests, or protect the rights, property, or safety of chaRIZZma, our users, or the public.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

5. Data Retention

We retain personal information for as long as your account is active and as needed to provide the Service, then for the period necessary to comply with legal obligations, resolve disputes, prevent abuse, and enforce our agreements. Where feasible, we retain live voice and video only as long as needed to deliver the session and any enabled feature, then delete or de-identify it. When you delete your account, we delete or de-identify your personal information within thirty (30) days, except where retention is required by law or for limited, documented purposes such as safety records of reported abuse.

6. Your Privacy Rights

6.1 Your rights. Depending on where you live, you may have rights to access or obtain a copy; correct; delete; obtain portability; opt out of sale, sharing, or targeted advertising; and appeal a denied request. We do not sell your personal information or use it for cross-context behavioral advertising, and we do not discriminate against you for exercising these rights.

6.2 How to exercise rights, and appeals. Use the in-App controls or email hello@charizzma.ai. We verify requests through your account and respond within the time required by applicable law. If we decline, you may appeal by emailing hello@charizzma.ai with the subject line "Privacy Request Appeal," and we will respond in writing, generally within 45 to 60 days, including the reasons for our decision.

6.3 California residents. Under the CCPA as amended by the CPRA, in the preceding 12 months we have collected and disclosed for a business purpose the following categories:

We do not sell personal information and have no actual knowledge of selling the personal information of consumers under 16. You may use an authorized agent and may be asked to verify your identity.

6.4 Other U.S. state residents. If you reside in Virginia, Colorado, Connecticut, Texas, Florida, or another state with a comprehensive privacy law, you have the rights in Section 6.1 to the extent your state's law provides, including the right to appeal. We do not sell your personal information, do not use it for targeted advertising, and do not engage in profiling that produces legal or similarly significant effects.

6.5 EEA, UK, and Switzerland. Where the GDPR or UK GDPR applies, our legal bases are: performance of our contract (to provide the Service), your consent (for optional features such as model-training opt-in and certain voice or video processing), our legitimate interests (security, abuse prevention, improvement), and compliance with legal obligations. You have rights of access, rectification, erasure, restriction, portability, and objection, and the right to lodge a complaint with your supervisory authority. International transfers are protected by appropriate safeguards such as Standard Contractual Clauses. [If you offer the Service in the EEA or UK, identify the controller of record and any required EU and UK representative.]

7. Security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding access to your device and your Apple ID or Google Account.

8. Cookies, Analytics, and Do Not Track

On charizzma.ai we use cookies and similar technologies for functionality, preferences, and analytics, which you can control through your browser settings. In the App, we and our analytics providers use SDKs to collect usage and diagnostic data. We do not use this data for cross-context behavioral advertising. Do Not Track: the Service does not currently respond to browser "Do Not Track" signals, because there is no common industry standard for interpreting them. To learn whether the third-party services we use honor DNT, review their privacy policies.

9. Children

The Service is for adults 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn we have collected information from a person under 18, we will suspend the account and delete the information.

10. International Users

We are based in the United States and process information there and in jurisdictions where our service providers operate. By using the Service, you understand your information may be transferred to and processed in the United States and other countries, which may have different data-protection laws than your own.

11. Account and Data Deletion

You can delete your account at any time within the App through account settings, and you can request account and data deletion through the web at charizzma.ai without reinstalling the App. Account deletion may take up to thirty (30) days to complete and includes deletion or de-identification of associated personal data, except limited information retained as described in Section 5. Once you initiate deletion, your account can no longer be used and you will lose access to all subscription features. To avoid additional charges, cancel your subscription through your Apple ID or Google Play account before deleting your account.

12. Changes to This Policy

We may update this Policy from time to time. We will revise the "Last updated" date below and, where changes are material, provide notice through the Service or by other reasonable means. Your continued use after the effective date constitutes acceptance.

13. Contact and Data Controller

Data Controller. The controller of your personal information is Creative Labs AI LLC. For EEA or UK users, [identify the controller of record and any required EU and UK representative].

chaRIZZma Creative Labs AI LLC Email: hello@charizzma.ai

Last updated: 2026-06-03