Privacy Policy

1. Who This Policy Applies To

This Privacy Policy applies to all users of the Service, regardless of age or location. The Service is intended for a general audience. Parents and guardians who permit minors to use the Service are responsible for supervising that use and are subject to this Privacy Policy in connection with the minor's account and data.

We may apply additional data protections for certain users as required by applicable law in their jurisdiction. If you have questions about how we handle data for a minor in your care, contact us at support@rezona.ai.

2. Information We Collect

2.1. Information You Provide

When you create an account or use the Service, you may provide us with:

• Account registration data: Username, email address, and any other information submitted at sign-up.
• User-generated content: Memeplays, memes, remixes, text inputs, audio recordings, images, videos, AI prompts, comments, and any other content you create, upload, or publish on the Service ("Your Content").
• Communications: Direct messages, comments, reactions, and any communications you send to other users or to us through support channels.

2.2. Identity Verification Data

To access certain features of the Service, we may collect identity or consent verification data as required. The type of data collected depends on the feature being accessed and the laws and regulations applicable in your jurisdiction. Verification data is stored securely and used only for the purpose for which it was collected.

2.3. Virtual Items & Transaction Data

When you use virtual item features within the Service, we collect and process transaction data necessary to operate those features, including records of purchases, transfers, and balances associated with your account at the specific purchasing time. All purchases of virtual items are processed through authorized third-party payment merchants and platform vendors.

Stratava does not collect, receive, or store your payment card details, bank account information, or any other raw payment credentials. Your payment data is governed by the relevant authorized vendors' privacy policy.

2.4. Automatically Collected Data

When you use the Service, we automatically collect certain technical and usage data:

• Log data: IP address, device name, operating system version, app configuration, timestamps of use, in-app actions, and crash logs, collected via third-party diagnostic tools when an error occurs.
• Analytics data: We use analytics tools to understand how users interact with the Service. We have disabled all features of these tools that collect or report personal data, including Demographics and Interest Reports, User ID features, Advertising Reporting Features, and data sharing within analytics tools.
• Push notification interaction data: Whether a push notification was delivered and whether it was tapped, tied to Service activity events.

2.5. Social & Interaction Data

When you interact with other users on the Service, we generate and store data associated with those interactions. This includes, but is not limited to, data related to your connections with other users, the nature and frequency of your communications, and any actions you take in relation to other users' accounts or content.

2.6. Risk & Anti-Fraud Data

To protect the integrity of the Service and its users, we collect and process signals for fraud detection and risk control purposes, including transaction frequency and velocity, high-value transaction flags, and device identifiers and behavioral signals used to detect unauthorized or suspicious activity. This data is used solely for risk management and anti-fraud enforcement and is not used for advertising purposes.

2.7. AI Feature Data

When you use our AI-powered features, we collect AI inputs (prompts, source content, images, voice recordings, and any other materials you submit), AI outputs generated in response to your inputs, and your interactions with AI features including ratings, edits, and regenerations. See Section 5 for information on how AI data is used.

2.8. Third-Party Data

We may receive limited data from third parties in connection with your use of the Service, including from Apple and Google in connection with in-app purchases, account authentication, and platform compliance, and from third-party service providers who help us operate the Service, subject to contractual restrictions.

3. How We Use Your Information

We use the information we collect for the following purposes:

Operating the Service

• Providing, maintaining, and improving the Service and its features.
• Creating and managing your account.
• Displaying your content to other users in accordance with your settings.
• Enabling and enforcing social features (follow relationships, DM eligibility, block status).

Virtual Items & Transactions

• Processing, recording, and displaying virtual item purchase and transfer transactions.
• Maintaining accurate virtual item balances.
• Sending push notifications and in-app alerts for transaction events.
• Enforcing transaction eligibility rules.

Safety & Security

• Detecting and preventing fraud, unauthorized transactions, and abuse.
• Risk control and anti-cheat enforcement.
• Enforcing our Community Guidelines and Terms of Service.
• Moderating content and taking enforcement action where necessary.
• Reporting illegal content to relevant authorities where required by law.

AI Development

• Operating AI-powered features within the Service.
• Improving and developing our AI models and systems using AI inputs, outputs, and interaction data, in accordance with the license granted in our Terms of Service.
• Researching and developing new features, products, and services, using Your Content and usage data in accordance with the license granted in our Terms of Service.
• Creating de-identified, anonymized, or aggregated data, which we may use for any lawful purpose.

Legal & Compliance

• Complying with applicable laws, regulations, and legal processes.
• Responding to intellectual property complaints.
• Retaining records as required by applicable law.

Communications

• Responding to support requests.
• Notifying you of changes to these policies or the Service.

4. How We Share Your Information

We do not sell your personal information to third parties. We share your information only in the following circumstances:

With other users

• Content you publish on the Service is visible to other users in accordance with your privacy settings.
• Virtual item transfers may display sender and recipient usernames to the relevant parties.
• Direct messages are visible only to the participants in the conversation.

With service providers

• We work with third-party companies to help operate the Service, including analytics providers, content moderation tools, identity verification services, and fraud detection systems. These providers access only the data necessary to perform their tasks and are contractually prohibited from disclosing or misusing it.

With Apple and Google

• In connection with in-app purchases, authentication, and platform compliance, we share and receive limited data with Apple Inc. and Google LLC as necessary to operate the Service on their platforms.

With law enforcement and authorities

• We may disclose personal data where required by law, court order, or governmental authority, or where we reasonably believe disclosure is necessary to protect the safety of any person, prevent fraud, or enforce our Terms of Service. We report suspected child sexual abuse material (CSAM) to the applicable authorities as required by law.

In connection with a business transfer

• In the event of a merger, acquisition, asset sale, or restructuring involving Stratava, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer through the Service or by email before it takes effect.

5. AI-Generated Content & Data

When you use our AI features, your AI inputs and the outputs generated from them are treated as Your Content under our Terms of Service. We may use your AI inputs, AI outputs, and your interactions with AI features to improve and develop our AI models and systems, in accordance with the license you grant us under our Terms of Service.

AI inputs and outputs are stored on our servers and associated with your account for as long as your account is active, subject to our data retention practices in Section 6. If you delete Your Content or your account, we will stop using your AI inputs for new model training going forward. However, we cannot and will not "untrain" AI models that have already been trained using your data. Anonymized or aggregated data derived from your inputs may be retained. Such anonymized or aggregated data is no longer personal information and may be used by us without restriction.

6. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to the following:

• Account data: Retained while your account is active and for a defined period following account deletion, as required for legal and operational purposes.
• Transaction and financial data: Purchase and transfer records are retained for the period required by applicable financial recordkeeping laws in relevant jurisdictions, which may extend beyond account deletion.
• Risk and fraud data: Transaction frequency, behavioral signals, and fraud flags are retained for a defined period for anti-fraud and platform integrity purposes.
• Push notification interaction data: Retained for a defined period for analytics and operational purposes.
• AI input and output data: Retained for model training purposes as described in Section 5. Deletion requests are honored prospectively.
• Log and diagnostic data: Retained for a defined period for security, debugging, and service improvement purposes.
• Verification data: Retained for the period required by applicable identity verification and compliance laws in relevant jurisdictions.
• Social and interaction data: Retained while your account is active and deleted upon account deletion, subject to any applicable legal hold.
• Content in remixed works: Where Your Content has been incorporated into another user's memeplay through the remix feature, it may persist on the Service after you delete the original, in accordance with the remix license described in our Terms of Service.

When data is no longer required for any of the above purposes, we delete or anonymize it.

7. Data Security

We use HTTPS and other commercially reasonable technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. You are responsible for maintaining the security of your account credentials and for any activity that occurs under your account. If you believe your account has been compromised, contact us at support@rezona.ai immediately.

No method of electronic transmission or storage is 100% secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights, we will notify you and the relevant authorities in accordance with applicable law.

8. Cross-Border Data Transfers

Stratava HK Limited is based in Hong Kong. However, the data we collect may be processed, stored, or transferred to countries or territories outside Hong Kong where our service providers operate. These jurisdictions may have data protection laws that differ from those in your country of residence.

Where we transfer personal data across borders, we apply appropriate safeguards - such as standard contractual clauses or equivalent mechanisms recognized under applicable law - to ensure your data is protected to a standard consistent with this Privacy Policy.

By using the Service, you acknowledge that your data may be transferred to and processed in countries outside your own.

9. Your Rights & Controls

Depending on your jurisdiction, you may have the following rights in relation to your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request that we correct inaccurate or incomplete personal data.
• Deletion: Request deletion of your account and associated personal data, subject to the limitations described in Section 6 and our Terms of Service.
• Portability: Request that we provide your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Objection: Object to certain uses of your personal data, including the use of your AI inputs for model training, where permitted by applicable law.
• Withdrawal of consent: Where we process your data on the basis of consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, contact us at support@rezona.ai. We will respond within a reasonable timeframe and in accordance with applicable law. We may need to verify your identity before processing your request.

10. Third-Party Links & Services

The Service may contain links to or interoperate with third-party websites, services, or content. Stratava does not control and is not responsible for the privacy practices of any third-party service. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Service.

11. User Data Deletion Request

You may request deletion of your personal data in the following ways:

• By email: Send a request to support@rezona.ai with the subject line "Data Deletion Request," including the email address or username associated with your account.
• In-app: Go to Profile -> Settings -> Account Deletion -> Delete Account.

We will process your request within a reasonable timeframe. Please be aware of the following limitations:

• Remixed content: Where Your Content has been incorporated into another user's memeplay, it may remain on the Service after your account is deleted, in accordance with the remix license in our Terms of Service.
• Financial records: Transaction records may be retained for the period required by applicable financial recordkeeping laws, even after account deletion.
• AI model training: We will stop using your data for new AI model training upon deletion, but we cannot reverse training that has already taken place.
• Fraud and risk data: Data used for anti-fraud purposes may be retained for a defined period to prevent circumvention of enforcement actions.
• Legal holds: We may be required to retain certain data where required by law, court order, or regulatory authority.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, features, or applicable law. For material changes - such as new data collection practices, new sharing arrangements, or changes that affect your rights - we will provide advance notice through the Service, by email to the address associated with your account, or by other reasonable means, at least [30] days before the changes take effect.

Non-material changes or updates required for legal or regulatory compliance may take effect immediately. We encourage you to review this page periodically.

Your continued use of the Service after the effective date of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree to the revised policy, you must stop using the Service.