Privacy Policy

This Privacy Policy (the “Policy”) describes the types of information Richify Bilişim Teknolojileri Eğitim Danışmanlık ve Mühendislik Hizmetleri Ltd. Şti. and its affiliates (“richify.ai,” “we,” “our,” or “us” or “Company”) collects, uses, and shares in connection with your use of the Remi mobile application (“App”) and related services (collectively, the “Service”).

By using the Service, you are agreeing to the practices described in this Policy. If you do not agree with the practices described in this Policy, please do not use the Service.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date above and, in some cases, by providing you with additional notice (such as a notification within the App). Your continued use of the Service after any changes constitutes your acceptance of the updated Policy.

1. Information We Collect

Information Collected Automatically

When you install and use the App, we automatically collect:

• Device identifier: A unique UUID assigned to your device upon first use. This is your primary identifier — we do not require an email address, name, or account creation.
• Timezone: Used to schedule push notifications at appropriate local times (e.g., daily reminders at 9 AM your time).
• Push notification token: A Firebase Cloud Messaging (FCM) token, if you enable notifications. This token is automatically cleaned up if it becomes invalid (e.g., if you uninstall the App).
• Credit balance and usage data: Your remaining message credits, daily message counts, and purchase history (product type and device identifier).
• Date of first use: When your device was first registered with the Service.

Conversation Data

Remi is designed with a “zero history” architecture. Your conversations with Remi — including text messages — are processed in real-time to generate responses but are not stored on our servers after your session ends. We do not maintain logs, archives, or backups of your conversation content.

During an active session, your messages are sent to our AI provider to generate responses. These messages are not retained by us once the session concludes.

Voice Data

When you use voice mode, Remi's responses are converted to audio using our text-to-speech provider. The text of Remi's response is sent to the provider, which returns an audio stream played directly on your device. No audio data is stored on our servers.

Mobile Application Permissions

The App may request certain permissions to provide you with enhanced functionality:

• Push Notifications: To send you reminders and updates. You can disable this at any time through your device settings.
• Microphone: To enable voice interactions with Remi. If you choose to use voice features, audio is processed in real-time and is not stored.

You are not required to grant any of these permissions, but certain features of the Service may not function without them.

2. How We Use the Information We Collect

We may use your information for any of the following purposes:

• Provide, operate, and maintain the Service
• Process your real-time conversations with Remi
• Manage your credit balance and purchases
• Send you push notifications at appropriate times based on your timezone (if enabled)
• Analyze, maintain, improve, modify, and measure the Service
• Detect and prevent fraud, abuse, or misuse of the Service
• Comply with legal obligations and legal process

How We Use Your Data with AI Services

When you interact with Remi, we use your data in the following ways:

• Real-time processing: Your messages are sent to our AI service provider to generate conversational responses. These messages are not stored after your session ends.
• Third-party AI processing: To power Remi's conversational features, we transmit your messages to third-party AI service providers. By using the Service, you consent to this processing.
• Text-to-speech: When you use voice mode, Remi's text responses are sent to our text-to-speech provider to generate audio. The audio is streamed directly to your device and is not stored.
• No conversation storage: We do not store, log, or archive your conversations. Every session starts fresh with no history.
• No AI training on your data: Your conversations are not used to train or improve AI models.

3. When We Disclose the Information We Collect

We do not sell, rent, or trade your personal information. We may disclose your information in the following circumstances:

• Affiliates: We may disclose information to our affiliates for purposes consistent with this Privacy Policy.
• Service providers: We use third-party services to operate the App (listed in Section 4). These providers process data on our behalf and are bound by their respective privacy policies and contractual obligations.
• Legal requirements: We may disclose information if we believe in good faith that doing so is necessary to comply with applicable law, regulation, legal process, or governmental request.
• Safety and protection: We may disclose information to protect the rights, property, or safety of the Company, our users, or others.
• Business transfers: In connection with or during negotiations of any merger, acquisition, sale of assets, or similar transaction, your information may be transferred as part of that transaction.

4. Third-Party Services

Remi integrates with and relies on the following third-party service providers:

• Amazon Web Services (AWS): Cloud infrastructure and database hosting (EU-West-1 region)
• OpenAI: AI language model for generating conversational responses
• ElevenLabs: Text-to-speech for voice responses
• Firebase (Google): Push notification delivery via Firebase Cloud Messaging
• RevenueCat: In-app purchase and credit management
• Cloudflare: CDN, DDoS protection, and TLS termination
• Apple App Store / Google Play Store: Payment processing for credit purchases

Your use of third-party services in connection with the Service may be subject to those providers' own terms and privacy policies. We encourage you to review them. We are not responsible for the privacy practices of third-party providers.

5. Your Choices

Push Notifications. You can disable push notifications at any time through your device settings.

Voice Mode. You can choose not to use voice mode. Microphone access is only used when you actively engage the voice feature.

Data Deletion. You may request deletion of your device data at any time by contacting us at support@richify.ai.

6. Rights for Users in the European Economic Area and United Kingdom

The Company is considered the “data controller” of the “personal data” (as defined under the General Data Protection Regulation, “GDPR”) we process in connection with the Service.

The laws of the European Economic Area and the United Kingdom require data controllers to tell you about the legal grounds they rely on for using, sharing, or disclosing your personal data. We rely on the following legal bases:

• Contractual commitments: We use personal data to provide the Service and fulfill our obligations to you (e.g., processing your messages, managing your credits).
• Legitimate interests: We use personal data where it furthers our legitimate interests, such as improving the Service, preventing fraud, and ensuring security, provided these interests are not outweighed by your rights.
• Legal compliance: We use and disclose personal data as necessary to comply with our legal obligations.
• Consent: Where required by law, we rely on your consent (e.g., for sending push notifications).

Your Rights

If you are located in the EEA or the UK, you may:

• Request access to the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request erasure of your personal data
• Object to or request restriction of processing
• Request data portability
• Withdraw consent at any time (where processing is based on consent)
• Lodge a complaint with your local data protection authority

You may exercise these rights by contacting us at support@richify.ai. We will respond within 30 days of receiving your request.

7. Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to disclose certain information regarding the categories of personal information we collect.

The categories of personal information we collect include: device identifiers, usage data (message counts, credit balance), timezone information, and push notification tokens.

We do not sell or share your personal information as defined by the CCPA. We do not knowingly sell or share the personal information of minors under 16 years of age.

California residents have the right to:

• Know what personal information we collect, use, and disclose
• Request deletion of personal information we have collected
• Request correction of inaccurate personal information
• Not be discriminated against for exercising CCPA rights

To exercise these rights, contact us at support@richify.ai.

8. Your Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. We do not currently sell your personal information as defined under Nevada law.

9. Information for Turkish Users

If you are located in Turkey, the processing of your personal data is subject to the Turkish Law on the Protection of Personal Data (KVKK, Law No. 6698).

We may transfer personal data to third parties in Turkey and abroad as described in this Policy. Such transfers are conducted in compliance with KVKK requirements, including obtaining explicit consent where required or relying on other lawful transfer mechanisms.

Your Rights Under KVKK

As a data subject in Turkey, you have the right to:

• Learn whether your personal data is being processed
• Request information if your personal data has been processed
• Learn the purpose of processing and whether your data is used in accordance with its purpose
• Know third parties to whom your personal data is transferred domestically or abroad
• Request correction of incomplete or inaccurate data
• Request deletion or destruction of your personal data under certain conditions
• Request notification of corrections, deletions, or destructions to third parties
• Object to adverse consequences resulting from automated processing of data
• Request compensation for damages arising from unlawful processing

You may exercise these rights by submitting a request to support@richify.ai. We will respond within 30 days.

Data Retention

We retain your personal data in accordance with KVKK requirements and only for as long as necessary to fulfill the purposes described in this Policy.

10. Information for Australian Users

If you are located in Australia, the processing of your personal information is subject to the Australian Privacy Principles (“APPs”) under the Privacy Act 1988 (Cth).

Your Rights Under Australian Privacy Law

Under the Privacy Act, you have the right to:

• Access your personal information that we hold
• Request correction of your personal information if it is inaccurate, out-of-date, incomplete, irrelevant, or misleading
• Make a complaint about our handling of your personal information
• Opt-out of receiving marketing communications from us

To exercise these rights, please contact us at support@richify.ai. We will respond within 30 days.

Cross-Border Data Transfers

Your personal information may be transferred to and stored in countries outside of Australia, including the European Union and the United States. Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure the overseas recipient does not breach the APPs.

Complaints

If you have a complaint about how we have handled your personal information, please contact us. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

11. Children's Privacy

The Service is intended for users 13 years of age or older (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If we learn that we have collected information from a child under 13, we will take steps to delete such information promptly. If you believe a child has provided us with personal information, please contact us immediately at support@richify.ai.

12. Data Security

We implement technical, administrative, and physical safeguards designed to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and secure database connections with certificate verification
• API key authentication for all service requests
• Cloudflare protection against DDoS and malicious traffic
• Access controls that limit access on a need-to-know basis
• Regular security assessments and updates

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Data Breach Notification

In the event of a personal data breach, we will comply with applicable breach notification laws. Where required, we will notify affected users and relevant supervisory authorities within the timeframes prescribed by applicable law.

13. Data Retention

We keep your information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

Retention by Category

• Conversation data: Not retained. Processed in real-time and discarded after each session.
• Device records (identifier, credit balance, timezone): Retained for as long as the device is active with the Service.
• Push notification tokens: Retained while valid; automatically cleaned up when tokens become invalid (e.g., after App uninstall).
• Daily usage counts: Retained to manage credit balance and service operation.
• Purchase records: Retained as required for accounting, tax, and financial compliance purposes.

If you request deletion of your data, we will delete your device record within 30 days, except where retention is required by law.

14. International Data Transfers

Your information is primarily stored and processed in the European Union (AWS EU-West-1 region). Some data may be processed in other jurisdictions through our third-party service providers (e.g., OpenAI and ElevenLabs in the United States).

Transfer Safeguards for EEA/UK Users

For transfers of personal data from the European Economic Area, United Kingdom, or Switzerland to countries that have not received an adequacy decision, we rely on:

• European Commission-approved Standard Contractual Clauses (SCCs) incorporated into our agreements with service providers
• The UK International Data Transfer Agreement (IDTA) and/or the UK Addendum to the SCCs (where applicable)
• Supplementary technical and organizational measures where necessary

You may request additional information about our transfer safeguards by contacting us at support@richify.ai.

15. Changes to This Policy

We may change this Policy to reflect changes in the law, our information practices, or the features of the Service. We will post changes to this page and update the “Last Updated” date at the top. If the changes are material, we will provide you with additional notice (such as a notification within the App). We encourage you to review this Policy periodically.

16. Contact Us

If you have any questions about this Privacy Policy or our information practices, please contact us:

Email: support@richify.ai

Company Information:
Richify Bilişim Teknolojileri Eğitim Danışmanlık ve Mühendislik Hizmetleri Ltd. Şti.