Privacy Policies
AI Labs B.V. Privacy Policy
Sugarlab.ai (referred to as the "APP") is owned and operated by AI Labs B.V., a incorporated entity in the Netherlands, with its registered office at Zandoerleseweg 8D, 5511AA Knegsel, The Netherlands. Registered under the number 91632579
with the Kamer van Koophandel (KVK) in the Netherlands.
Sugarlab.ai is an online chat application utilizing artificial intelligence algorithms to create virtual and fictional characters (referred to as "AI Companions"). The APP also generates images and messages, facilitating interaction with the AI Companions. Certain Services offered by the APP may necessitate the creation of a user account. For the purposes of this Privacy Policy, the terms "you" and "your" pertain to you as the user of the APP.
GDPR
If you are a resident of the European Union, you are entitled to additional rights and protections under the European Union's General Data Protection Regulation 2016/679, commonly known as GDPR.
1. Definitions
To uphold your privacy, such Services will always be provided with your explicit consent.
This document elucidates how your data is processed when you visit the Website and utilize our Services.
Please refer to the following definitions as needed:
"Website" refers to Sugarlab.ai.
"Personal Data" includes information related to you, such as name, address, date of birth, gender, and other identifiers.
"Content" encompasses the information you provide, facilitating user registration and data upload on our Platform. It includes Personal Data and interactions with the AI Companions.
"Subscription" is an arrangement enabling you to benefit from or use the Services.
"Consent" refers to your freely given, specific, informed, and unambiguous indication of wishes, signifying agreement to the Processing of Personal Data.
"Performance of our Services" encompasses actions necessary for us to provide our Services.
"Personal Data" includes information related to you, such as name, address, date of birth, gender, and other identifiers.
"Visitor" denotes someone browsing the Website without a valid Subscription.
"Platform" denotes the APP.
"Processing" covers any operation on Personal Data, whether automated or not.
"Services" include steps enabling interaction with the AI Companions.
"User," "you," and "your" collectively refer to a person or company using the APP and/or Services.
2. Purpose of Personal Data Processing
When Visiting the Website
During your visit to the Website, we collect information for purposes such as:
Performing our Services;
Analyzing and understanding your behavior on the Website;
Improving the Website and Services;
Evaluating the effectiveness of marketing campaigns.
Customizing communications;
Enhancing data security;
When Registering and Using Our Services
After a free test of a few messages, registration is required for identification. We receive and store information entered on the Website, including name, date of birth, usage details, and browser information.
Provided Personal Data is used for purposes like creating a user account, interacting with AI Companions, and adapting Services to your needs.
When using the Platform, we automatically receive information from your browser or mobile, treated as non-Personal Data. This aggregated data may be shared with partners for site usage analysis.
Failure to provide Personal Data may impact Service performance, with notification in such cases.
Your Consent is obtained for Processing Personal Data, primarily for Service performance under a Subscription.
We Process Personal Data because it is necessary for:
Marketing analysis and market research.
Confirming Subscription;
Service performance;
Addressing complaints or requests;
Business administration and management
Other purposes with your provided Personal Data;
Marketing analysis and market research.
3. Personal Data Collection
3.1 Personal Data Collection for Visitors
Website visits can be anonymous. Anonymous metadata, processed through cookies, includes information for technical improvements, statistical, and marketing analysis. This metadata does not reveal personally identifiable information and is used for general purposes.
When you visit the Website, information received includes:
Browser and operating system type;
User navigation behavior and preferences.
Date and time of visit;
Server address;
Previous website visited;
Average page view duration;
IP address of the accessing device (e.g., PC, tablet);
3.2 Personal Data Collection for Users
Various methods are used to collect Personal Data from and about you:
Content provided via your personal account;
Communication through writing, telephone, fax, website registration, email, or other electronic forms, with monitoring and storage of such communication;
Personal Data from third parties or publicly available sources, including analytics providers, advertising networks/agencies, and search information providers.
Information provided during Subscription registration;
Automated technologies capturing technical data about equipment, browsing actions
4. Third-Party Marketing
Your explicit opt-in consent is obtained before sharing Personal Data with external companies for marketing purposes.
You can request the cessation of marketing messages at any time through the Website or third-party websites by adjusting marketing preferences or following opt-out links in messages.
5. Marketing
We may send marketing communications about services and other relevant information through alerts, newsletters, invitations, or updates via post, telephone, email, or digital channels.
6. Modification of Data Usage
We will exclusively utilize your Personal Data for the initially intended purposes unless we reasonably determine the need for an alternative purpose compatible with the original one. If you seek clarification on how the processing for a new purpose aligns with the original one, please reach out to us. In cases where Personal Data is required for an unrelated purpose, we will inform you, providing an explanation of the legal basis permitting such use. It's essential to acknowledge that, in compliance with relevant regulations, we may process your Personal Data without explicit knowledge or consent when necessary or permitted by law.
7. Cookie Management
You have the option to configure your browser settings to reject all or specific browser cookies, or receive alerts when websites attempt to set or access cookies. It's important to note that if you choose to disable or reject cookies, certain sections of the Website may become inaccessible or experience functionality issues.
8. Sharing of Personal Information
Sugarlab.ai may share your information with:
Professional advisers, such as lawyers, accountants, IT, or public relations advisers, when their advice or assistance is necessary;
Service providers engaged in delivering our Services;
Our employees.
Legal and regulatory authorities, as mandated by applicable laws and regulations;
We commit not to disclose, sell, trade, or transfer your personal information to third parties without your explicit consent, except as explicitly outlined in this Privacy Policy.
This Privacy Policy does not extend to the practices of service providers and other third parties not under our ownership or control, or individuals not employed or managed by us.
9. Handling Sensitive Information
We will refrain from soliciting Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, along with genetic and biometric data designed for unique identification or health-related information. Should you decide to provide us with such sensitive information, you acknowledge your voluntary disclosure of such data.
10. Data Security
We have implemented suitable security measures to prevent accidental loss, unauthorized access, use, alteration, or disclosure of your Personal Data.
Procedures are in place to address any suspected Personal Data breaches, and we commit to notifying you and any relevant regulatory authorities of breaches where legal obligations necessitate.
11. Data Retention Period
We retain your personal information for the duration of your account's existence or as necessary to fulfill the purposes for which it was collected or to provide you with the Services. In cases where account termination occurs, your personal information is retained for a specified period. Typically, we store your personal information for six years after you cease being a User of our Services, starting from the date of account closure. Retention periods may undergo alterations based on business or regulatory requirements.
12. Authority Representation
This Privacy Policy is presented on behalf of AI Labs B.V. In the context of this Privacy Policy, references to "we" or "us" pertain to AI Labs B.V..
We have designated a Controller within our team, responsible for overseeing inquiries related to this Privacy Policy. For any questions or requests regarding your legal rights, please contact the Controller using the details provided below.
Contact details: Hello@sugarlab.ai
13. Personal Data Access Request
You possess the right to access your Personal Data at any time. This empowers you to receive a copy of the Personal Data held about you and verify the lawful processing of such information.
14. Minors' Personal Information
AI Labs B.V. refrains from providing Services and collecting personal information from individuals under 18 years of age or the equivalent minimum age based on jurisdiction. Our Services are intended solely for adults aged 18 and above. In the event we discover misinformation from an individual under 18, or the equivalent minimum age based on jurisdiction, steps will be taken to promptly delete the information and block the user.
15. Third-Party Website Links
The Website may contain links to third-party websites, plug-ins, and applications. Enabling these links may allow third parties to collect or share data about you. We lack control over these third-party websites and are not accountable for their privacy statements. We encourage you to review the Privacy Policy of each website accessible through the Website.
16. Company Merger
In the event of AI Labs B.V. merging with or being acquired by another company or organization, or selling all or part of its assets, your personal information may be disclosed to our advisers and potential purchasers or their advisers. Such information may form part of the transferred assets. However, personal information will invariably remain subject to this Privacy Policy.
17. Right to Rectify
You possess the entitlement to prompt rectification of any inaccurate Personal Data concerning you from the Controller.
This allows you to correct any incomplete or inaccurate data within our possession about you. However, a verification process may be necessary to ensure the accuracy of the new data you provide to us.
18. Right to Be Forgotten
You retain the right to request the Controller's prompt erasure of Personal Data concerning you, and the Controller commits to executing this erasure without undue delay.
This empowers you to request the deletion or removal of Personal Data where there is no compelling reason for us to continue processing it. You also have the right to request the deletion or removal of your Personal Data if you have successfully exercised your right to object, if we processed your information unlawfully, or if local law requires erasure. However, we may not always comply with erasure requests for specific legal reasons, which will be communicated to you if applicable at the time of your request.
Please voice your objection to the processing of your Personal Data promptly if you believe such processing infringes on your fundamental rights and freedoms. You also have the right to object when we process your Personal Data for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds to process your information, overriding your rights and freedoms.
19. Right to Request Processing Restriction of Your Personal Data
This empowers you to request our Controller to temporarily suspend the processing of your Personal Data in the following circumstances:
if you wish to verify the accuracy of the Personal Data;
when our processing of the Personal Data is deemed unlawful, and you prefer suspension over erasure, requesting us to halt the processing instead;
when you require us to retain the data for legal claims; or
if you object to our processing of your Personal Data, and we need to verify whether we have overriding legitimate grounds to continue using it.
20. Withdrawal of Consent
We are dedicated to making the withdrawal process as straightforward as giving consent.
You reserve the right to withdraw your consent at any time. The withdrawal of consent will not impact the lawfulness of processing your Personal Data based on consent before its withdrawal.
Upon withdrawing your consent, we may be unable to provide further Services, and we will take reasonable steps, utilizing available technology, to promptly delete your user account. Additionally, we will eliminate the Personal Data collected for internal use.
In the event of consent withdrawal, we are not accountable for any remaining Content hosted on third-party websites.
21. Response Time Limit
We endeavor to respond to all valid requests within one month. Occasionally, the response time may extend if your request is particularly complex or if multiple requests are made. In such instances, you will be duly notified.
22. Privacy Policy Amendments and Your Obligation to Update Us
This Privacy Policy may undergo revisions periodically. Consequently, a few modifications may be applied. The most recent version of the Privacy Policy will govern the use of your information. In case of substantial changes in the way we handle your Personal Data, we will notify you through posting and email communication to seek your approval. By continuing to access or use the Services following the effective date of such changes, you agree to abide by the updated Privacy Policy.
It is advisable to keep a copy of this document and feel free to reach out to Hello@sugarlab.ai with any questions or concerns regarding our Privacy Policy.
Revision Date: [31/01/2024]
