Privacy Policy

Effective date: March 1, 2026

This privacy policy applies to the Jelly AI mobile application and web application at jellyai.chat (collectively referred to as "Application") created and operated by Jelly AI, with contact address support@jellyai.chat (hereby referred to as "Service Provider" or "Data Controller") as a Freemium service. This service is intended for use "AS IS".

1. Information Collection and Use

The Application collects information when you download and use it. This information may include:

The Application collects your device's approximate location to provide personalized content, relevant recommendations, and location-based services. Aggregated and anonymized location data also helps the Service Provider analyze user behavior, identify trends, and improve the overall performance of the Application.

2. How We Use Your Information

We use your information to: provide the Jelly AI service including AI chat, content generation, and voice features; personalize AI character interactions based on your conversation history and stated preferences (this personalization uses your general interaction data, not special category data as described in Section 4); process your transactions and manage subscriptions; communicate with you about updates, support, and important notices; analyze usage patterns in aggregated form to enhance app performance; ensure the safety and security of our platform; enforce our Terms of Service and content policies; and comply with legal obligations.

3. Legal Basis for Processing (GDPR/KVKK)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data under the EU/UK GDPR. If you are located in Turkey, we process your data under the Turkish Personal Data Protection Law (KVKK, Law No. 6698), which provides similar protections. Our legal bases for processing are: (a) Contract Performance — processing necessary to provide the Jelly AI service, including AI chat, content generation, and subscription management; (b) Consent — for processing your approximate location data, marketing communications, the use of non-essential cookies and tracking technologies, and the processing of special category data as described in Section 4 (you may withdraw consent at any time through your account settings or by contacting us at support@jellyai.chat, and withdrawal is as simple as the original consent); (c) Legitimate Interest — for analytics, fraud prevention, service improvement, and platform security, where these interests are not overridden by your data protection rights; (d) Legal Obligation — where processing is required to comply with applicable laws, regulations, or legal proceedings.

4. Sensitive and Special Category Data

Due to the nature of Jelly AI as an adult companion application, your interactions may reveal information related to your sexual preferences or orientation, which constitutes special category data under GDPR Article 9 and sensitive personal information under CPRA. Before you can access adult-themed features, you will be asked to provide separate, specific, and informed consent to the processing of such data. This consent is: freely given (the Application can be used without adult features if consent is declined); specific to the processing of sensitive data for delivering adult-themed AI interactions; informed by this Privacy Policy and the consent notice presented in the Application; and withdrawable at any time by contacting support@jellyai.chat or through your account settings, with the same ease as giving consent. Upon withdrawal, adult-themed features will be disabled but your account will remain active. This data is processed with strict confidentiality safeguards, is not used for profiling, advertising, or recommendation purposes beyond delivering the requested interaction, and is not shared with third parties except AI model providers processing your messages under data processing agreements.

5. Third-Party Services and Data Processors

The Application utilizes third-party services that process data on our behalf (data processors) or independently (data controllers). Below are the links to the Privacy Policy of the third-party service providers used by the Application:

The roles of our third-party service providers are as follows: Google Cloud/Firebase acts as a data processor for infrastructure, authentication, and data storage under a Google Cloud Data Processing Addendum; RevenueCat and Adapty act as data processors for subscription and payment management under their respective data processing agreements; AI model providers act as data processors for generating chat responses, images, videos, and voice content under data processing agreements (specific providers and their retention practices may vary; contact us for current details); Facebook acts as a joint controller or independent data controller for data collected through Facebook integrations (such as analytics pixels), subject to Facebook's own data policy; Microsoft Clarity acts as a data processor for session analytics and heatmaps on our web application, which may involve recording user interactions on our website.

The Service Provider may disclose your information: as required by law, such as to comply with a subpoena or similar legal process; when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; and with trusted service providers who work on their behalf under data processing agreements, who do not have an independent use of the information disclosed to them, and have agreed to adhere to the rules set forth in this privacy statement.

6. Cookies and Web Tracking

Our web application at jellyai.chat uses cookies and similar tracking technologies. Essential cookies are required for core functionality such as authentication and session management; these cannot be disabled. Analytics cookies (including Microsoft Clarity session recordings and heatmaps) are used to understand how users interact with our web application. Third-party cookies may be set by our analytics partners. For users in the EEA, UK, or Turkey, non-essential cookies (analytics, third-party) are only activated after you provide consent through our cookie consent banner, which provides equally prominent options to accept or reject non-essential cookies. You may change your cookie preferences at any time through our cookie settings panel accessible from the footer of our website. Disabling non-essential cookies will not affect core functionality of the Application.

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside your country of residence, including the United States, where our cloud infrastructure providers (Google Cloud, Firebase) maintain servers. These transfers are necessary to perform our contract with you (i.e., to provide the Jelly AI service). For users in the EEA or UK, we ensure that such transfers are protected by appropriate safeguards as required by GDPR Chapter V, including Standard Contractual Clauses (SCCs) approved by the European Commission, data processing agreements with all third-party service providers, and technical and organizational security measures. For users in Turkey, transfers are conducted in accordance with KVKK requirements. You may request a copy of the relevant transfer safeguards by contacting support@jellyai.chat.

8. Data Storage and Security

Your data is stored securely using industry-standard encryption both in transit (TLS) and at rest. We use Firebase and Google Cloud infrastructure to protect your information. The Service Provider implements physical, electronic, and procedural safeguards to protect information processed and maintained. Chat messages are processed by AI models to provide the service and are not shared with unrelated third parties. While we strive to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.

9. Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, the Service Provider will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by GDPR Article 33. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify affected users directly without undue delay. For California residents, we will comply with California Civil Code Section 1798.82 breach notification requirements.

10. Data Retention

We retain different categories of data for different periods: Chat messages and AI interaction history are retained for as long as your account is active and for up to 90 days after account deletion. Account information (user ID, device ID, age, gender) is retained for as long as your account is active and deleted within 30 days of account deletion. Transaction and billing records are retained for up to 7 years to comply with tax and financial reporting obligations. Analytics and usage data is retained in aggregated and anonymized form indefinitely. Voice messages and audio data are retained for as long as your account is active and deleted within 30 days of account deletion. IP addresses and device information are retained for up to 12 months for security purposes. If you would like us to delete your data, please contact us at support@jellyai.chat and we will respond within one month of receiving your request.

11. Your Data Rights (EEA/UK/Turkey)

If you are located in the European Economic Area or United Kingdom, you have the following rights under the EU/UK GDPR. If you are located in Turkey, you have equivalent rights under KVKK (Law No. 6698). These rights include: Right of Access — you may request a copy of the personal data we hold about you. Right to Rectification — you may request correction of inaccurate personal data. Right to Erasure — you may request deletion of your personal data where there is no compelling reason for its continued processing (subject to legal retention requirements described in Section 10). Right to Restriction — you may request that we restrict the processing of your personal data in certain circumstances. Right to Data Portability — you may request to receive your personal data in a structured, commonly used, machine-readable format. Right to Object — you may object to the processing of your personal data based on legitimate interests. Right to Withdraw Consent — where processing is based on consent, you may withdraw it at any time through your account settings or by contacting us, without affecting the lawfulness of prior processing. To exercise any of these rights, please contact us at support@jellyai.chat. We will respond to your request within one month (GDPR) or 30 days (KVKK). If your request is complex, we may extend this period by up to two additional months and will inform you of any such extension. You also have the right to lodge a complaint with your local data protection supervisory authority (for Turkey: KVKK at kvkk.gov.tr).

12. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA): Right to Know — you may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collecting it, and the categories of third parties with whom we share it. Right to Delete — you may request that we delete personal information we have collected from you, subject to certain exceptions. Right to Correct — you may request correction of inaccurate personal information. Right to Opt-Out of Sale/Sharing — we do not sell your personal information for monetary consideration. However, certain analytics tools (such as Microsoft Clarity and Facebook) may constitute "sharing" of personal information for cross-context behavioral advertising under CPRA. You may opt out of this sharing by: using the "Do Not Sell or Share My Personal Information" link available on our website; sending an opt-out request to support@jellyai.chat; or enabling a recognized opt-out preference signal (such as Global Privacy Control) in your browser, which we will honor as a valid opt-out request. Right to Limit Use of Sensitive Personal Information — your precise geolocation and information that may reveal sexual orientation are classified as sensitive personal information under CPRA. You may limit the use and disclosure of this data to what is necessary to provide the service by using the "Limit the Use of My Sensitive Personal Information" link on our website or contacting support@jellyai.chat. Right to Non-Discrimination — we will not discriminate against you for exercising any of your privacy rights. To exercise your California privacy rights, you may: email support@jellyai.chat or use the privacy request links on our website. You may also designate an authorized agent to submit requests on your behalf (we may require verification of the agent's authority). We will verify your identity before processing your request and respond within 45 days, with a possible 45-day extension if reasonably necessary.

13. Voice and Audio Data

The Application allows you to send voice messages that are processed by AI models to generate responses. Voice audio data is transmitted to our AI service providers for real-time processing; AI providers do not retain your audio after processing. The resulting transcription or AI response is stored as part of your conversation history for as long as your account is active (and deleted within 30 days of account deletion, as described in Section 10). The original audio files are retained on our servers for up to 30 days after creation, after which they are automatically deleted. We do not create voiceprints, voice templates, or other biometric identifiers from your voice data. If you are located in a jurisdiction with specific biometric data laws (such as Illinois BIPA, Texas CUBI, or Washington state biometric law), please be aware that your voice data is processed solely to provide the voice messaging feature and is not used for biometric identification purposes.

14. AI Model Training and Improvement

We may analyze patterns in chat interactions to improve the quality of AI responses and the overall Jelly AI service. Before any data is used for improvement purposes, it is stripped of personal identifiers and aggregated so that it cannot be traced back to individual users. Individual conversations are not shared with or sold to third parties for their own AI training purposes. Third-party AI model providers process your messages to generate real-time responses under data processing agreements and do not retain your data for their own model training. You may opt out of having your data included in future service improvement analysis by contacting support@jellyai.chat; upon receiving your request, we will exclude your account data from improvement datasets going forward. This opt-out does not affect the processing of your messages necessary to provide the service.

15. Opt-Out Rights

You can stop all collection of information by the Application by uninstalling the mobile app or ceasing to use the web application. You may opt out of analytics tracking through your device settings or browser cookie settings. You may opt out of marketing communications by following the unsubscribe instructions in any marketing email. You may opt out of the sharing of personal information with analytics partners by contacting us at support@jellyai.chat. You may withdraw consent for location data collection through your device's location settings.

16. Age Restrictions

The Application is intended exclusively for users aged 18 and older. We do not knowingly collect personal information from anyone under the age of 18. If we discover that a user under 18 has provided personal information or created an account, we will promptly delete their account and all associated data from our servers. If you are a parent or guardian and believe that a minor has provided us with personal information, please contact us immediately at support@jellyai.chat so that we can take the necessary actions.

17. EU/UK Representative

If you are located in the EEA or UK and have questions or concerns about our data processing practices, you may contact our designated representative for data protection matters at support@jellyai.chat. We are committed to working with you and any applicable data protection authorities to resolve any complaints regarding the transfer or processing of your personal data that we cannot resolve with you directly.

18. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time. The Service Provider will notify you of material changes to this Privacy Policy by updating this page, displaying a notice within the Application, or sending you a notification. The updated effective date will be posted at the top of this page. You are advised to review this Privacy Policy regularly. Continued use of the Application after changes are posted constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes, you should stop using the Application.

19. Your Consent

By using the Application, you are consenting to the collection, processing, and use of your information as set forth in this Privacy Policy now and as amended by us. For users in the EEA/UK, this consent supplements (but does not replace) the specific legal bases described in Section 3 above.

20. Contact Us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at support@jellyai.chat