Privacy Policy

1. Introduction

This Privacy Policy explains how Sam Companion, operated by Lino Grubben (“we,” “us,” or “our”), collects, uses, shares, and protects personal information when you use our mobile application (“App”) and website (“Website”).

We are committed to respecting your privacy and protecting your personal data. This Privacy Policy complies with global privacy laws, including the EU General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Brazilian General Data Protection Law (LGPD), and other applicable laws. It outlines your rights and how we ensure your data is protected when using our services.

By accessing or using the App or Website, you agree to the terms outlined in this policy. If you do not agree with these terms, please refrain from using our services.

2. Data Controller and Contact Information

For the purposes of applicable data protection laws, the data controller of your personal data is:

Lino Grubben
Email: hello@samcompanion.com

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us using the information provided above.

3. Information We Collect

3.1 Personal Information

We collect the following types of personal information:

App and Website:

  • Contact Forms: Name, email address, and message content when you contact us via forms.
  • Account Creation (App): Name, email address, and optionally gender, age, or other non-mandatory details.
  • Purchases (Website): Payment information via Stripe, including billing details, for processing transactions.

3.2 Automatically Collected Information

We automatically collect the following information:

  • IP address
  • Device type, operating system, and unique device identifiers
  • App and Website usage patterns, interaction data, and crash reports
  • Cookie and tracker data via Google Analytics and pixels (e.g., Facebook Pixel) for analytics and marketing purposes

3.3 Cookies and Similar Technologies

We use cookies and similar technologies on the Website and App to track and analyze user behavior. You can manage your preferences for cookies through your browser settings or device settings. Where required by law, we display a cookie consent banner.

3.4 Special Category Data

We do not collect special category data (e.g., health, biometric data) as defined under GDPR and other data protection laws.

4. Legal Basis for Processing (for EU/EEA Users)

We process personal data based on the following legal bases:

  • Performance of a Contract: Data processing necessary to provide services, such as creating accounts or processing purchases.
  • Legitimate Interests: To improve services, analyze usage patterns, and ensure security.
  • Consent: For optional activities like receiving marketing communications and using non-essential cookies.
  • Compliance with Legal Obligations: Where required by law.

5. Purposes of Data Processing

We process personal data for the following purposes:

  • To create and manage accounts on the App.
  • To provide and improve services on the App and Website.
  • To process transactions and payments via Stripe.
  • To send notifications about updates, features, or legal changes.
  • To analyze and improve the functionality of the App and Website via cookies and analytics.
  • To comply with legal obligations or enforce our terms and policies.

6. User Rights

You have the following rights concerning your personal data:

  • Right of Access: Request access to your data.
  • Right to Rectification: Correct inaccurate or incomplete data.
  • Right to Erasure: Request deletion of your data.
  • Right to Restriction of Processing: Restrict data processing in certain circumstances.
  • Right to Data Portability: Receive your data in a structured, machine-readable format.
  • Right to Object: Object to direct marketing or processing based on legitimate interests.
  • Right to Withdraw Consent: Withdraw consent for data processing activities where consent was given.

To exercise these rights, contact us at hello@samcompanion.com. Requests will be handled within the timelines required by law.

7. Data Sharing and Disclosure

7.1 Service Providers

We share personal data with third-party service providers, such as:

  • Stripe: For payment processing on the Website.
  • OpenAI’s GPT API: For processing chatbot interactions in the App.
  • Google Analytics: For analyzing Website usage and behavior.

7.2 Legal Requirements and Protection

We may disclose personal data to comply with legal obligations or protect our rights.

7.3 Business Transfers

In the event of a merger or acquisition, personal data may be transferred to the acquiring entity.

8. Data Retention

We retain personal data for as long as necessary to fulfill the purposes outlined in this policy or as required by law:

  • Account data is retained while the account is active.
  • Payment data is retained as required for transaction processing and legal compliance.
  • Cookies and analytics data are retained as per cookie settings or as mandated by law.

9. Security Measures

We implement industry-standard security measures, including encryption and access controls, to protect personal data from unauthorized access, alteration, disclosure, or destruction. Security practices are reviewed regularly.

10. Children’s Privacy

The App and Website are not intended for children under the age of 13. If we become aware that we have collected personal data from children under 13, we will delete it promptly.

11. Cross-Border Data Transfers

We may transfer personal data outside of your home country, including to countries that may not have equivalent data protection laws. Appropriate safeguards, such as Standard Contractual Clauses, are implemented to protect your data.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via the App, Website, or email. We encourage you to review this policy periodically.

Effective Date: 28 November 2024

13. Contact Information

For questions or concerns about this Privacy Policy or our data practices, contact us at:
Email: hello@samcompanion.com

14. Additional Jurisdiction-Specific Disclosures

California Residents (CCPA)

You have rights under the CCPA, including the right to know, delete, and opt-out of data sales. Contact us to exercise these rights.

Brazilian Residents (LGPD)

You have rights under the LGPD, including the right to confirm data processing, access data, and correct inaccurate information. Contact us to exercise these rights.