This Privacy Policy explains how Arconi Inc ("Arconi," "we," "us," or "our") collects, uses, and protects personal data when you use the Arconi platform and any services operated on it, including the Mr Darcy app.

This Privacy Policy applies to all services operated by Arconi, including branded conversational experiences such as "Mr Darcy" (each, a "Service").

If you do not agree with this Privacy Policy, please do not use the Services.

Language

This Privacy Policy may be provided in languages other than English for convenience. The English version is the legally binding and controlling version. If there is any inconsistency between a translated version and the English version, the English version will prevail.

---

Contents

1. Who We Are
2. What the Services Are
3. What Data We Collect
4. How We Use Your Data
5. AI Models and Your Conversations
6. Lawful Bases for Processing (GDPR)
7. Safety, Moderation, and Monitoring
8. Cookies and Tracking Technologies
9. Data Retention
10. How We Share Your Data
11. International Data Transfers
12. Your Privacy Rights
13. Additional Rights for EU/UK Users (GDPR)
14. Additional Rights for California Users (CCPA/CPRA)
15. Additional Rights for Other Jurisdictions
16. Children's Privacy
17. Security
18. Third-Party Links
19. Changes to This Privacy Policy
20. Contact Us

---

1. Who We Are

Arconi is operated by Arconi Inc, a Delaware corporation.

For the purposes of data protection laws (including the GDPR), Arconi Inc is the data controller responsible for your personal data.

Contact details

Mailing address: Arconi Inc, 169 Madison Ave STE 36083, New York, NY 10016, United States

---

2. What the Services Are

Arconi provides AI-powered conversational experiences: interactive fictional storytelling and character roleplay for adults.

Important context for this Privacy Policy:

• You are interacting with artificial intelligence, not real humans
• AI personas are fictional characters
• Your conversations are stored and processed by us and our service providers so the Services can work. They are private to your account, but they are not legally privileged communications
• Conversations on the Services can be personal. What you choose to share is up to you, and Section 3 explains how we treat sensitive information
• Do not share identifying details you would not want stored, such as government ID numbers, financial account details, passwords, or sensitive information about other people
• AI systems may generate inaccurate or inappropriate outputs despite safeguards

All Services are 18+ only. We do not knowingly collect data from children.

---

3. What Data We Collect

A. Information you provide directly

• Account information: email address, username, password
• Profile information: any optional details you add to your profile
• Conversation content: messages and prompts you send to AI systems
• Uploads: images or files you upload (if this feature is enabled)
• Communications: support requests, feedback, surveys
• Payment information: handled by third-party processors (we do not store full card numbers)
• Your privacy choices: your consent and opt-out choices, when you made them, and under which version of this policy

B. Information generated through use

• Chat data: messages, AI responses, timestamps, interaction metadata
• Character memory: details from your conversations that are saved so characters can refer back to them
• Device information: device type, operating system, browser type
• Usage data: features used, pages visited, actions taken
• Log data: IP address, access times, error logs
• Location: approximate location based on IP address (country/region only)
• Advertising click identifiers: if you arrive from an advertisement, the identifier the advertising platform attached to the link (see Section 8)

C. Information from third parties

• Payment processors: transaction status, billing country (from Stripe etc.)
• Authentication providers: basic profile info if you sign in via Google, Apple, etc.
• Analytics providers: aggregated usage data

Sensitive information in your conversations and profile

Because of the nature of the Services, your conversations and optional profile details may reveal sensitive information about you, such as your sexual orientation, details of your romantic or sex life, or your health and emotional state. We do not ask you for this information and you never have to provide it, but we recognise that personal conversations often include it.

We use this information only to:

• Provide the Services to you (so characters can respond to, and refer back to, what you have said)
• Monitor and maintain the quality of character responses (including, outside the EEA, the UK and Switzerland, through de-identified copies kept for a limited period after account deletion — see Section 9)
• Keep the Services safe, including recognising signs of crisis so a character can point you to support
• Meet our legal obligations

We do not use it for advertising, we do not share it with advertising platforms, and we do not use it to train AI models.

Where the law requires it (including in the EEA, the UK, and Switzerland), we process this information on the basis of your explicit consent, which we ask for before you start chatting. You can withdraw that consent at any time by deleting the relevant conversations or profile details, or by deleting your account. Because the Services cannot work without processing what you say, withdrawing consent entirely means we can no longer provide chat to you.

What we do NOT collect

• We do not collect date of birth or government ID
• We do not collect precise GPS location
• We do not purchase personal data from data brokers
• We do not collect biometric or genetic data

---

4. How We Use Your Data

We use personal data for the following purposes:

Messages from characters and offers

Characters and the concierge may send you messages, and we may send you offers, in-app, by push notification, or by email. We tell you about this when you sign up. You can turn these off at any time in your notification preferences, and every such email includes an unsubscribe link. Where the law requires your consent for these messages, we only send them with your consent.

Turning these off does not stop service messages about your account, billing, security, or changes to our terms.

---

5. AI Models and Your Conversations

We do not use your conversations to train or fine-tune AI models.

How AI is used to run the Services

• Generating replies. To produce a character's response, we send the relevant parts of your conversation (and saved character memory) to third-party AI model providers. They act as our service providers: they are contractually restricted to processing this data on our behalf, and they are not permitted to use your conversations to train their own models. They may retain inputs for a limited period for abuse and security monitoring before deleting them.
• Quality monitoring. We use automated tools, including AI models, to score conversations for quality and safety. We use the results to improve our own configuration: the instructions and settings we give the AI, and how characters are written. This does not train a model on your words.
• Human review. A small number of authorised people may review conversations where needed for safety, support, or quality investigation. Access is limited to those who need it.

Aggregated statistics and quality scores

We produce aggregated statistics (for example, average conversation length or how often a feature is used) and keep quality scores derived from conversations. They contain none of your messages and do not identify you.

De-identified copies after account deletion

Outside the EEA, the UK and Switzerland, we may keep de-identified copies of conversations for a limited period after an account is deleted, so we can evaluate and improve quality. They are never used to train AI models and are never shared. Section 9 explains what is removed, how long they are kept, and how to have your conversations fully deleted instead.

If this changes

If we ever decide to use conversations to train or fine-tune AI models, we will update this policy before we start, tell you, and ask for your consent where the law requires it.

---

6. Lawful Bases for Processing (GDPR)

If you are located in the EU, UK, or Switzerland, we process personal data based on the following legal bases:

We do not train AI models on your conversations, so there is no legal basis listed for that activity. See Section 5. We do not keep de-identified copies of conversations for users in the EEA, the UK or Switzerland, so there is no legal basis listed for that either. See Section 9.

First-party analytics

We measure how the Services are used — which pages are viewed, which features are used, where people stop — and we write that measurement to our own systems. This data is not sold and is not shared with advertising platforms. We rely on legitimate interests for this processing: it is how we operate, debug and improve the Services, and it is limited to what we need for that purpose.

The analytics cookie. Part of this measurement uses a first-party cookie. In the EEA, the UK and Switzerland, we only set that cookie if you accept analytics in our cookie controls. Elsewhere it is set by default.

Without the cookie, we still record actions taken within the Services on our own servers (for example, that a signed-in account sent a message or started a checkout), because we need those records to run the Services. You have the right to object to first-party analytics: see Section 12.

This is separate from the third-party analytics and advertising described in Section 8, both of which require your consent where consent is legally required.

Where we rely on legitimate interests as a legal basis, we have considered and balanced our interests against the rights and freedoms of users.

Users located in the EU, UK, or Switzerland may object to processing based on legitimate interests as described in Section 12.

Special category data

Where we process special category personal data (see Sensitive information in your conversations and profile in Section 3), we do so on the basis of your explicit consent and only for the purposes described there. Providing this information is never required, and you may remove it at any time by deleting conversations or profile details in your account settings.

Our legitimate interests include

• Operating and improving the Services
• Monitoring and maintaining the quality of character responses
• Ensuring platform security and integrity
• Preventing fraud and abuse
• Understanding how users interact with the Services
• Keeping in touch with users about the Services

You may contact us to request information about our legitimate interests assessments.

---

7. Safety, Moderation, and Monitoring

To keep the platform safe, we may:

• Automatically scan content for policy violations
• Use automated tools to recognise signs that a user may be in crisis, so that a character can step out of the story and share support resources
• Review content manually where necessary
• Investigate abuse, fraud, or harmful behavior
• Take enforcement action, including account suspension or termination

These measures are applied proportionately and on a risk-based basis, and are not intended to result in continuous or systematic monitoring of all user activity.

We have no obligation to monitor all activity, but we reserve the right to do so where necessary for safety, compliance, or operational purposes.

Where the law requires us to report on our safety protocols (for example, how often crisis resources were shown), those reports contain no user identifiers.

Illegal content may be reported to appropriate authorities, including law enforcement and child safety organizations (such as NCMEC for content involving minors).

---

8. Cookies and Tracking Technologies

What are cookies?

Cookies are small text files placed on your device when you visit a website. They help websites function and provide information to operators.

Types of cookies we use

Third-party cookies and similar technologies

Some cookies and similar technologies (such as local storage) are placed by the third-party services we use to operate the Services:

Advertising measurement

When you arrive from an advertisement, the advertising platform may add a click identifier to the link you followed (for example fbclid, rdt_cid, ttclid, epik or li_fat_id). We store that identifier with your account or, if you have not registered, your guest session. If you later take an action such as entering the site, sending your first message, registering, starting a checkout or subscribing, we report that action directly from our servers to the platform that sent you — which may be Meta, Reddit, TikTok, Pinterest or LinkedIn.

Those reports can include the click identifier, a hashed (irreversibly scrambled) form of your email address, a hashed account identifier, your IP address, your browser's user agent and, for a purchase, its value and currency. The platform uses them to match the action to the advertisement you clicked and to improve which advertisements it shows. Under US state privacy laws this is sharing personal information for cross-context behavioral advertising; under EU and UK law it requires your consent.

These reports say only that an action happened and, for a purchase, its value. They never include the content of your conversations, which characters you talk to, or anything from your profile.

These reports only happen with advertising consent. The check is made at the moment each report would be sent, against the choice stored against your account or guest session — so it applies to reports sent hours or days later, from our servers, after your browsing session has ended. Withdrawing consent stops them from the next action onwards. It does not recall reports already sent.

We do not load those platforms' advertising pixels or tracking scripts into your browser ourselves. Where such tags have been configured in Google Tag Manager, the container itself only loads with advertising consent.

Managing cookies

You can manage cookies and tracking through:

• Our cookie controls: Visit /cookies at any time — from the age gate, or from the privacy and cookies section at the bottom of your profile page — to accept or reject analytics and advertising separately. Strictly necessary processing cannot be switched off, because the Services cannot run without it. Where consent is legally required, we do not place non-essential cookies or send advertising reports before consent is given.
• Browser settings: Most browsers let you block or delete cookies.

Opt-out links:

• Google Analytics, where the tag manager loads it: tools.google.com/dlpage/gaoptout

Global Privacy Control

We honour the Global Privacy Control (GPC) signal. If your browser or an extension sends GPC, we treat it as a refusal of advertising consent — in every jurisdiction, not only where the law requires it — and we record that refusal against your account or guest session so it also applies to reports sent later from our servers.

A GPC signal is never overridden by a later default. If you send GPC and then press an "accept" button, we still record a refusal. To grant advertising consent, stop sending GPC and then make the choice explicitly.

Do Not Track

There is no industry standard for Do Not Track signals. We do not currently respond to DNT signals but will update this policy if a standard is established. Global Privacy Control, described above, is honoured — it is a separate and more recent standard.

---

9. Data Retention

We retain personal data only as long as necessary. Specific retention periods:

Account deletion

When you delete your account:

• Account information is deleted within 30 days
• Conversation history and character memory associated with your account are deleted within 30 days
• Outside the EEA, the UK and Switzerland, we may keep de-identified copies of conversations, as described below
• Consent records are kept as described above
• Some data may be retained as required by law

De-identified copies

If you live in the EEA, the UK or Switzerland, we do not keep de-identified copies: your conversations are deleted.

Elsewhere, we may keep de-identified copies of conversations for up to 24 months after your account is deleted, to evaluate and improve the quality of character responses. De-identified copies have your account details, contact details, IP address, device information, profile and character memory removed, and names and other identifying details in the text are removed by automated tools. They are not linked to you or to each other. They are never used to train AI models and are never shared. We maintain and use them only in de-identified form and do not attempt to re-identify them.

Automated removal is not perfect. If you want your conversations fully deleted, delete them in your account settings before closing your account, or email privacy@arconi.ai at any time and we will delete them.

Conversation deletion

You can delete individual conversations or all history through your account settings. Deletion is processed within 30 days, and no de-identified copy is kept of conversations you delete yourself.

Backups

Backups are used only for disaster recovery. If we restore one, we re-apply deletions made since it was taken.

---

10. How We Share Your Data

We may share data with:

Sharing with advertising platforms

Where you have given advertising consent — or, in jurisdictions where advertising may run by default, where you have not opted out — we report conversion events to Meta, Reddit, TikTok, Pinterest and LinkedIn, as described in Section 8. Those reports can include a click identifier, a hashed email address, a hashed account identifier, your IP address, your user agent and, for a purchase, its value and currency.

Under the CCPA/CPRA and comparable US state laws, this constitutes "sharing" personal information for cross-context behavioral advertising, and may constitute a "sale" under the broad definition those statutes use. We do not receive money for it; the definitions are broader than money.

You can stop it at any time. Use the controls at /cookies, the "Do Not Sell or Share My Personal Information" link in the privacy and cookies section of your profile, or the Global Privacy Control signal — all three reach the same setting and all three take effect from the next event onwards. See Section 14.

What we do NOT do:

• We do not sell personal data for money
• We do not share the content of your conversations, your choice of characters, or your profile details with advertising platforms
• We do not use your conversations to train AI models, and we do not permit our AI providers to do so
• We do not share personal data with data brokers
• We do not share personal data for third parties' own direct marketing purposes

Business transfers

If Arconi is involved in a merger, acquisition, or sale of assets, your data may be transferred. We will notify you of any such change.

Aggregated data

We may share aggregated statistics that cannot identify you (e.g., usage statistics). We do not share de-identified copies of conversations.

---

11. International Data Transfers

Arconi operates globally. Your data may be processed in the United States or other countries where we or our service providers operate. These countries may have different data protection laws than your country.

Transfer safeguards

When transferring data internationally, we use appropriate safeguards:

• Standard Contractual Clauses (SCCs) approved by the European Commission, and the UK International Data Transfer Addendum, where they apply
• Contractual protections with all service providers
• Technical measures to secure data during transfer

Where international data transfers occur, we take steps to ensure appropriate safeguards are in place as described above.

---

12. Your Privacy Rights

Depending on your location, you may have the right to:

• Access your personal data
• Correct inaccurate data
• Delete your data
• Restrict certain processing
• Object to certain processing, including our first-party analytics, quality monitoring, and messages from characters and offers
• Port your data (receive it in a portable format)
• Withdraw consent where processing is based on consent

How to exercise your rights

• In the app: delete conversations or your account in account settings; manage advertising and analytics choices at /cookies; turn off messages from characters and offers in notification preferences or via the unsubscribe link in any such email
• By email: contact us at privacy@arconi.ai

We will respond within the timeframe required by applicable law (typically 30 days).

Appeals

If we decline your request, you can appeal by emailing privacy@arconi.ai with the subject "Privacy Appeal". If we refuse the appeal, we will tell you how to contact your state attorney general or other regulator.

Verification

To protect your privacy, we may need to verify your identity before processing requests.

No discrimination

We will not discriminate against you for exercising your privacy rights.

---

13. Additional Rights for EU/UK Users (GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have additional rights under the GDPR.

Your GDPR rights

• Access (Article 15): Get confirmation and a copy of your data
• Rectification (Article 16): Correct inaccurate data
• Erasure (Article 17): Delete your data ("right to be forgotten")
• Restriction (Article 18): Limit how we process your data
• Portability (Article 20): Receive your data in a portable format
• Object (Article 21): Object to processing based on legitimate interests
• Withdraw consent (Article 7): Withdraw consent at any time
• Automated decisions (Article 22): Rights related to automated decision-making

Right to complain

You have the right to lodge a complaint with a supervisory authority in your country.

Find your data protection authority: edpb.europa.eu/about-edpb/board/members_en

Contact for GDPR matters

Email: gdpr@arconi.ai

---

14. Additional Rights for California Users (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

Categories of personal information we collect

We use sensitive personal information only to provide the Services and for the other purposes the CCPA/CPRA permits without a right to limit. We do not use it to infer characteristics about you for advertising, and we do not sell or share it.

De-identified copies of conversations (see Section 9) are maintained and used only in de-identified form, and we do not attempt to re-identify them.

Your CCPA/CPRA rights

• Know: Request what personal data we collect and how we use it
• Access: Request a copy of your personal data
• Delete: Request deletion of your personal data
• Correct: Request correction of inaccurate data
• Limit sensitive data use: We use sensitive personal information only for purposes the law permits without offering a right to limit, so there is nothing further to limit
• Opt out of sale/sharing: Direct us to stop sharing your personal information for cross-context behavioral advertising
• Non-discrimination: Not be discriminated against for exercising rights

Do Not Sell or Share My Personal Information

We share personal information for cross-context behavioral advertising, as described in Section 10: when you take an action such as registering or subscribing, we report it to the advertising platform that sent you, together with a click identifier and hashed identifiers. We do not receive money for this, but it falls within the CCPA/CPRA definitions of "sharing" and potentially "sale".

You have three ways to stop it, and all three set the same control:

1. Do Not Sell or Share My Personal Information — also linked from the privacy and cookies section at the bottom of your profile page, where it is shown persistently to California residents and residents of other states with comparable statutes.
2. The cookie controls at /cookies.
3. Global Privacy Control — we honour the GPC browser signal automatically, in every jurisdiction, and record it as a refusal. No request or account is needed.

Opting out takes effect from the next event onwards. It does not recall reports already sent. Opting out does not degrade the Services in any way: chat, characters, memory and history are unchanged, and we do not charge a different price or offer a different level of service to anyone who opts out.

We do NOT:

• Sell personal information for money
• Share the content of your conversations with advertising platforms
• Share personal information with data brokers
• Knowingly sell or share the personal information of consumers under 16 (the Services are 18+)

How to exercise your rights

Email: privacy@arconi.ai Subject line: "California Privacy Request"

We will respond within 45 days (extendable to 90 days with notice).

You may designate an authorized agent to make requests on your behalf.

Shine the Light

California Civil Code § 1798.83 permits California residents to request information about disclosure to third parties for direct marketing. We do not disclose personal information to third parties for their direct marketing purposes.

---

15. Additional Rights for Other Jurisdictions

Australia

If you are in Australia, you have rights under the Privacy Act 1988 (Cth) and Australian Privacy Principles. You may:

• Access your personal information
• Request correction of inaccurate information
• Complain to the Office of the Australian Information Commissioner (OAIC)

Canada

If you are in Canada, you have rights under PIPEDA and provincial privacy laws. You may:

• Access your personal information
• Request correction of inaccurate information
• Withdraw consent (subject to legal restrictions)
• Complain to the Office of the Privacy Commissioner of Canada

Brazil

If you are in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD), including access, correction, deletion, portability, and information about sharing.

Japan

If you are in Japan, you have rights under the Act on the Protection of Personal Information (APPI), including to request disclosure, correction, deletion, and cessation of use of your personal data. Your data is processed in the United States and other countries outside Japan, as described in Section 11. You may complain to the Personal Information Protection Commission.

Other locations

If you are in a jurisdiction with privacy laws not specifically addressed above, contact us at privacy@arconi.ai to learn how we accommodate your rights.

---

16. Children's Privacy

The Services are not intended for anyone under 18 years of age. We do not knowingly collect personal data from minors.

Age confirmation

We use age-screening measures, including:

• An age confirmation gate upon first access
• Age confirmation during registration

We may introduce additional age-assurance checks, for example in particular countries or for particular features. If we do, we will update this policy first to explain what information those checks involve.

If a minor has used the Services

If you are a parent or guardian and believe your child under 18 has provided us with personal data, please contact us immediately at privacy@arconi.ai.

If we learn that a user is under 18, we will close the account and delete the associated personal data as quickly as possible, except where we are legally required to keep it. We do not keep de-identified copies of those conversations.

---

17. Security

We implement reasonable technical and organizational measures to protect personal data.

Technical measures

• Encryption in transit (TLS/SSL)
• Encryption at rest
• Access controls and authentication
• Monitoring and logging

Organizational measures

• Access to personal data limited to the small number of people who need it
• Confidentiality obligations for everyone with access

No guarantee

No system is 100% secure. We cannot guarantee absolute security. You use the Services at your own risk.

Breach notification

In the event of a data breach affecting your personal data, we will notify you and relevant authorities as required by applicable law.

Your responsibilities

You are responsible for:

• Keeping your account credentials confidential
• Using strong, unique passwords
• Notifying us of any unauthorized access

---

18. Third-Party Links

The Services may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties.

We are not responsible for the privacy practices of third parties. We encourage you to read their privacy policies.

---

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

How we notify you

For material changes, we will provide notice through:

• Posting the updated policy on our website
• Updating the "Last updated" date and version at the top of this policy
• Email notification (for material changes)
• In-app notification

Your continued use

Continued use of the Services after changes take effect means you accept the updated Privacy Policy. If you do not agree, stop using the Services. Where a change needs your consent, we will ask for it rather than rely on continued use.

Prior versions

We maintain prior versions of this Privacy Policy and can provide them upon request.

---

20. Contact Us

For privacy questions or requests:

Arconi Inc

Mailing address: Arconi Inc, 169 Madison Ave STE 36083, New York, NY 10016, United States

We aim to respond to all inquiries within 30 days.

---

Summary of Key Points

---

Acknowledgment

By using the Services, you acknowledge that:

• You understand the Services involve AI, not humans
• Your conversations are stored and processed so the Services can work, and are not legally privileged
• Data may be processed to operate, protect, and improve the platform
• Your conversations are not used to train AI models
• You have read and understood this Privacy Policy