Privacy Policy

Persona App

1. Introduction

Persona Entertainment (“we,” “our,” or “us”) values your privacy and is committed to protecting your personal data. This Privacy Policy provides information required under Articles 13 and 14 of the EU General Data Protection Regulation 2016/679 (“GDPR”), including the purposes and legal bases for processing, recipients, international transfers, retention, and your rights, when you are using the services provided by us (the “Services”).

2. Controller

Persona Entertainment Oy
Business ID: 3469075-9
Registered office: Finland
Contact: support@personaavatar.com

3. Information We Collect

Information you provide to us directly. We collect information directly from you. For example, you provide information to us when you use our Services, communicate with us, register for an account, subscribe to our blog or newsletters, or participate in our social media discussions or promotions. The information you provide to us directly may be about you and others.

Automatically gathered information from your device/app usage, such as device type, operating system version, and usage statistics.

Information from payment platform providers, where purchases are managed through payment platform providers (we do not store payment details).

We may collect the following types of information:

• Account Information: username, email address, phone number.
• Demographic information: date of birth and general geographic location.
• Interests: such as categories like “Sports” or “Writing”.
• Interaction Data: chat history with AI-powered avatars.
• Technical Data: device type, operating system version, usage statistics.
• Advertising identifiers and approximate location: device advertising identifiers (such as Apple’s IDFA or Android’s Advertising ID) and approximate, IP-based location, shared with Meta solely to measure the performance of our advertising campaigns.
• Payment Information: managed securely through Apple’s In-App Purchase system (we do not store payment details).
• Communication with us: e.g. support requests, voluntary feedback.

Where we request personal data to create and administer an account and to provide the Services (such as account details), the provision of such data is necessary to enter into and perform a contract with you. If you do not provide the necessary personal data, we may not be able to create an account or provide some or all of the Services.

Information you provide directly to us may also include information that may be considered sensitive under applicable laws, such as login information, personal messages received or sent through our Services, or other information about yourself that you have provided while using our Services (for example, user content you voluntarily post that reveals your ethnicity, religion, or sexual orientation). Sensitive personal information is not required or necessary to use our Services; please do not include any sensitive personal information in your communications with us or our Services.

4. Children and Age Requirements

The Persona app is not intended for children under the age required by applicable local law. In jurisdictions where no specific age is defined, the minimum age is 13 years. We do not knowingly collect personal data from children. If you believe that a child has provided us with personal data, please contact us at support@personaavatar.com so that we can take appropriate steps.

5. Purposes and legal basis for processing

We process your personal data only where we have a legal basis under the GDPR. Depending on how you use the Services, we process personal data for the following purposes:

• Providing the Services and managing your account (including creating and maintaining your account, enabling core app features, and providing customer support). Legal basis: performance of a contract (GDPR Art. 6(1)(b)).
• Personalising your experience and optimising performance (for example, tailoring in-app interactions and improving app functionality). Legal basis: performance of a contract (GDPR Art. 6(1)(b)) and/or legitimate interests (GDPR Art. 6(1)(f)) in improving our Services.
• Security, fraud prevention, and ensuring service integrity. Legal basis: legitimate interests (GDPR Art. 6(1)(f)) and, where applicable, compliance with a legal obligation (GDPR Art. 6(1)(c)).
• Internal analytics and service improvement. Legal basis: legitimate interests (GDPR Art. 6(1)(f)) in understanding and improving our Services and user experience.
• Sending service communications and internal marketing messages (for example, updates, offers, and information about our services). Legal basis: legitimate interests (GDPR Art. 6(1)(f)) and/or consent (GDPR Art. 6(1)(a)) where required by applicable law. You can opt out of marketing communications at any time by using the unsubscribe link in the message (where available) or by contacting us at support@personaavatar.com. We do not sell or share your data with third parties for marketing purposes.
• Measuring the effectiveness of our marketing and advertising campaigns. Legal basis: legitimate interests (GDPR Art. 6(1)(f)) and, on iOS, your consent given via the App Tracking Transparency prompt.
• Legal compliance and responding to lawful requests (including from courts and authorities). Legal basis: compliance with a legal obligation (GDPR Art. 6(1)(c)) and/or legitimate interests (GDPR Art. 6(1)(f)) (for example, to establish, exercise, or defend legal claims).
• Corporate transactions (such as a merger, acquisition, or sale of assets). Legal basis: legitimate interests (GDPR Art. 6(1)(f)).

The Service does not use automated decision-making that produces legal or similarly significant effects.

6. When do we disclose the information we collect

We share information only to the extent necessary in the following situations:

• Partners. We share information with our partners and affiliates, who may use the information we share in accordance with this policy.
• Merchants and service providers. We share information with consultants, service providers, and other merchants who need that information to perform work or provide services on our behalf. Such parties include, for example, companies that provide data storage, payment services, technical support and services, customer service, analytics, fraud prevention, content moderation, legal services, and marketing and advertising services. These parties may either operate as separate data controllers or as our data processors.
• Advertising measurement. We use Meta’s (Facebook’s) advertising SDK to measure the effectiveness of our own marketing campaigns — specifically, to understand whether an app install resulted from an ad we placed. This involves sharing limited device-level identifiers and approximate (IP-based) location with Meta. This data is not used to display advertising within our app, and we do not share your data with advertising networks for the purpose of targeting ads to you elsewhere on the Internet. Any other analytics we perform are solely for improving our services and user experience.
• Legal obligations. We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with law enforcement, legal or regulatory process, such as when responding to a warrant, subpoena, court order or other applicable laws and regulations.
• Business transfer. We may disclose certain information in connection with, or in the course of negotiating or entering into, a merger, sale of business assets, financing arrangements or the sale of all or a portion of our business to another company.
• Other disclosures with your consent or instructions. We may also disclose your information to third parties when you ask us to do so. This is the case, for example, when you instruct us to disclose information about you because you recommend us or our services to your friends or acquaintances.

7. AI-Powered Features and Third-Party AI Services

The Persona app includes interactive AI-powered avatar features (“AI Features”) provided through our technology partner Unith Ltd. To enable these features, certain limited user data — your voice input and the content of your conversation with the avatar — is transmitted to third-party AI service providers in order to generate a response.

No account identifiers, email addresses, device identifiers, precise location, or personal profile information are included in these transmissions. Data is transmitted solely to provide the requested in-app functionality, is not used for advertising, and is not used to train AI models. All data in transit is encrypted using TLS.

Video synthesis and lip-sync animation are processed exclusively on Unith’s own infrastructure (AWS, EU region) and do not involve third-party AI processing of user data.

Your consent

Before completing registration, the app will request your explicit permission to process your voice and conversation data as described above. This consent is required to use the app, as AI avatar interaction is an essential feature of the service.

You may withdraw this consent at any time in the app’s account settings. Withdrawing consent will disable AI interaction features.

Third-party AI providers’ data protection

All third-party AI providers act as data processors under contractual data processing agreements. They are required to process data only according to our instructions and to maintain security measures equivalent to or exceeding those described in this policy.

8. International data transfers

Your data may be processed outside the EU/EEA. When this occurs, we ensure appropriate safeguards, such as Standard Contractual Clauses, are in place. In particular, AI processing services described in the AI-Powered Features section above may involve data transfers to the United States; Standard Contractual Clauses or equivalent safeguards are in place with each provider. Advertising measurement data shared with Meta Platforms, Inc. may be processed in the United States; Meta’s Standard Contractual Clauses (or equivalent safeguards) apply to this transfer.

You may request further information about the safeguards we use by contacting us at support@personaavatar.com.

9. Data Retention

We retain personal data for as long as your account is active or as needed to provide the service, unless a longer retention period is required by law. You may request deletion at any time. We may also retain certain information for limited periods where necessary for: (i) security and fraud prevention; (ii) compliance with legal obligations; (iii) resolving disputes; and/or (iv) enforcing our agreements.

10. Your Rights (GDPR)

• Access: request a copy of your personal data.
• Rectification: correct or update inaccurate or incomplete personal data.
• Erasure: request deletion of your personal data in certain circumstances.
• Portability: request transfer of your personal data in a portable format in certain circumstances.
• Restriction: request that we restrict processing of your personal data in certain circumstances.
• Objection: object to processing based on legitimate interests, and object to direct marketing at any time.
• Withdraw consent: where processing is based on consent, you may withdraw your consent at any time (withdrawal does not affect the lawfulness of processing before withdrawal).

Contact us at support@personaavatar.com to exercise these rights. You also have the right to lodge a complaint with your local supervisory authority. In Finland, this is the Finnish Data Protection Ombudsman.

11. Security

We implement industry-standard security measures to protect your data from unauthorized access, alteration, or disclosure. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Changes to this policy

We may update this policy from time to time. We will indicate the last modification date in this policy. If we make a material change to the policy, you will be notified in an appropriate manner consistent with legal obligations, such as by email or through a prominent posting on our website or mobile application. By continuing to use the Services, you confirm that you have read and understood the most recent version of this policy.

13. Contact

If you have questions about this Privacy Policy, contact us at: support@personaavatar.com