Privacy Policy

Last updated: June 12, 2026

This Privacy Policy explains how CLOSEAI TECHNOLOGY CO., LTD (trading as "CharacterMe") ("CharacterMe", "we", "us" or "our") collects, uses, discloses and safeguards your personal information when you access the CharacterMe website or use any related mobile/desktop applications, products or services (collectively, the "Service").

By accessing or using the Service, you acknowledge that you have read, understood and agree to the practices described in this Privacy Policy and to any update we may make from time to time.

1. Definitions

Term	Meaning
Personal Data / Personal Information	Any information relating to an identified or identifiable natural person.
Processing	Any operation performed on Personal Data such as collection, storage, use, disclosure or deletion.
Controller	The entity that determines the purposes and means of Processing Personal Data (CharacterMe).
Processor / Service Provider	A third party that Processes Personal Data on behalf of the Controller.

2. Who We Are (Data Controller)

CLOSEAI TECHNOLOGY CO., LTD
7 Copperfield Road, Coventry, West Midlands, England, United Kingdom CV2 4AQ

Email (general enquiries): support@characterme.ai
Email (privacy enquiries / DPO): privacy@characterme.ai

3. Information We Collect

Category	Examples	Legal Basis*
Account Data	Email, username, password (hashed), avatar	Contract performance
Profile & Preference Data	Languages, notification settings, saved characters	Legitimate interest
Payment & Subscription Data	Transaction IDs, last 4 digits of card, membership tier, purchase history, gem balance (processed by Stripe, Apple, Google – we never store full card data)	Contract performance / Legal obligation
Content & Messages	Chat transcripts, prompts, uploads, feedback	Contract performance / Legitimate interest
Usage & Device Data	IP address, device ID, OS, browser, timestamps, crash logs	Legitimate interest
Cookies & Tracking Data	Session cookies, analytics cookies, referrer URLs	Consent (where required)

*Legal bases under EU GDPR / UK GDPR. If another jurisdiction applies, we rely on equivalent grounds.

4. How We Use Your Information

Provide & maintain the Service (e.g. create accounts, enable chat, deliver content).
Process transactions & manage memberships (e.g. membership purchases, gem allocations, renewal processing).
Personalise your experience (e.g. suggested characters, language preferences).
Improve & develop new features, models and algorithms. We may analyse anonymised or pseudonymised chat logs to train and evaluate our language models; any such training excludes identifiers and follows strict access controls.
Communicate with you (support, system alerts, renewal reminders, marketing – subject to your preferences).
Detect, prevent & address abuse, security incidents and fraud.
Content moderation & safety – enforce our Terms of Service, Community Guidelines, and applicable laws (see Section 4A below).
Comply with legal obligations (tax, accounting, law-enforcement requests).

4A. AI Content Safety & Data Processing for Moderation

As an AI-powered platform, we implement comprehensive content safety measures that involve additional data processing:

AI Input/Output Filtering: All user prompts and AI-generated responses are processed through automated content safety filters in real time. These filters detect and block content involving sexual exploitation of minors, extreme violence, hate speech, fraud, self-harm, and other prohibited categories.
Sensitive Keyword Detection: We maintain and regularly update a keyword and pattern library to flag potentially harmful content for further review.
Model Safety Policies: Our AI models are trained and fine-tuned with safety guardrails that limit generation of harmful, illegal, or policy-violating content.
Human Review: Flagged content may be reviewed by trained human moderators under strict confidentiality and data-minimization protocols. Only the minimum data necessary for review is exposed to moderators.
Automated Patrol & Monitoring: We conduct periodic automated scans of publicly visible content (character profiles, descriptions, tags) to detect policy violations proactively.
Abuse Reports: When users submit abuse reports, we process the reported content and associated metadata to investigate and take appropriate action.

Data processed for safety purposes is retained only as long as necessary for investigation, enforcement, and legal compliance, and is subject to the same security measures described in Section 8.

5. Cookies & Similar Technologies

We use first-party and third-party cookies, pixels and local storage to:

Keep you signed in and maintain session security;
Remember preferences (e.g. theme, language);
Measure site traffic and usage trends via analytics tools (e.g. Google Analytics);
Deliver and measure marketing campaigns.

You can manage or disable cookies in your browser settings. Some features may not function properly without certain cookies.

6. How We Share Information

We disclose Personal Data only as described below:

Service Providers & Processors: Cloud hosting, content delivery, analytics, support, payment processing, content moderation services.
Affiliates & Subsidiaries: Entities under common control that operate parts of the Service.
Legal & Safety: To comply with law, enforce our Terms, respond to lawful requests, protect rights, property or safety of us, our users or the public.
Business Transfers: In connection with a merger, acquisition, bankruptcy or asset sale; you will be notified of any change of control.
With Your Consent: If you instruct us or explicitly consent to such sharing.

We do not sell or rent your Personal Data.

7. International Transfers

Our servers are primarily located in the United States and Singapore (AWS). By using the Service, you consent to the transfer of your Personal Data outside your country of residence. Where required, we rely on Standard Contractual Clauses or equivalent safeguards.

8. Security Measures

Encryption in transit (TLS 1.2+) and at rest for core databases
Least-privilege access controls & multi-factor authentication for staff
Routine penetration testing & vulnerability scanning
Incident response procedures and data-breach notification protocols
Content moderation staff undergo background checks and sign confidentiality agreements

No system is 100% secure; you use the Service at your own risk.

9. Data Retention & Deletion

We retain Personal Data only for as long as necessary to fulfil the purposes described above, comply with applicable law, resolve disputes and enforce our agreements.

You may request deletion of your account via in-app settings or by emailing support@characterme.ai. Certain records (e.g. transaction logs, moderation records) may be kept as required by law.

10. Your Rights

Depending on where you live, you may have rights to:

Access the Personal Data we hold about you;
Rectify inaccurate or incomplete data;
Erase (delete) your Personal Data ("right to be forgotten");
Restrict or object to certain processing;
Data portability (receive a copy in a structured format);
Opt-out of marketing communications at any time;
Lodge a complaint with a supervisory authority.

To exercise these rights, contact privacy@characterme.ai. We may need to verify your identity.

Additional Disclosures – California (CCPA/CPRA)

California residents have the right to request notice of categories of Personal Information collected, request deletion, opt-out of "sale" or "sharing", and request non-discrimination. We honour Global Privacy Control (GPC) signals. Submit CCPA requests at privacy@characterme.ai.

11. Automated Decision-Making & Profiling

We do not make solely automated decisions that have legal or similarly significant effects on you. Our conversational AI produces responses based on your prompts; you can always choose not to rely on or follow such outputs. Automated content moderation systems may restrict access to certain content or features, but such decisions can always be appealed through our support channels.

12. Third-Party Links

The Service may contain links to external sites. We are not responsible for the privacy practices of such sites. Please review their policies.

13. Changes to This Policy

We may modify this Privacy Policy periodically. If we make material changes, we will notify you via the Service or email. The "Last updated" date at the top indicates when changes were last made.

14. Contact Us

Questions or concerns?
Data Protection Officer
CLOSEAI TECHNOLOGY CO., LTD
Email: privacy@characterme.ai
Registration Number: 16937331
Postal: 7 Copperfield Road, Coventry, West Midlands, England, United Kingdom CV2 4AQ