Privacy Policy

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IMPORTANT PRIVACY INFORMATION

In order to use our app, we will ask you to enter your name and email. We will also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the app and to measure ads. For improving the app and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Amazon, Amplitude, Appsflyer, Facebook, Google, Tableau, TikTok. Therefore, some of the data is stored and processed on the servers of such third parties. This enables us to (1) analyze different interactions; (2) serve and measure ads (and show them only to a particular group of users, for example, only to subscribers). Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). If any questions will remain unanswered, please contact us at support@katochat.ai. 

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PRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use the Kato: AI Chat mobile application (the “App”), the services and products provided through it (together with the App, the “Service”), how such personal data will be processed. BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time; and (c) delete the App from your devices. Any translation from English version is provided for your convenience only. In the event of any difference in meaning or interpretation between the English language version of this Privacy Policy available at https://legal.katochat.ai/privacy-policy, and any translation, the English language version will prevail. The original English text shall be the sole legally binding version. “GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. “EEA” includes all current member states to the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland. “Process”, in respect of personal data, includes to collect, store, and disclose to others.

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1. PERSONAL DATA CONTROLLER

AV Wellbeing Solutions Limited, a company registered under the laws of the Republic of Cyprus, having its registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be the controller of your personal data.

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2. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data you give us voluntarily (for example, email address). We also may receive data about you from third parties (for example, when you sign in via Apple). We also collect data automatically (for example, your IP address).

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2.1. Data you give usYou provide us information about yourself when you register for and/or use the Service, including name, email address.2.2. Data provided by third partiesWhen you use sign in with Apple to register an account in the App, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the sign in with Apple screen. Find more about sign with Apple here.When you initiate a payment, we may receive from third-party payment service provider information about the transaction amount, date and time.2.3. Data we collect automatically:2.3.1. Data about how you found usWe collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).2.3.2. Device and Location dataWe collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, and Facebook ID. We also record the ads in our App with which you interact (and the Internet links to which those ads lead).2.3.3. Usage dataWe record how you interact with our Service. For example, we log your taps on certain areas of the interface, the features, and content you interact with, how often you use the App, how long you are in the App, your subscription orders.2.3.4. Advertising IDsWe collect your Apple Identifier for Advertising (“IDFA”), Identifier for Vendor (“IDFV”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

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3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:  3.1. To provide our Service This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

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To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.We use GrowthBook to release code better and measure the impact with data. GrowthBook processes usage and technical data for feature evaluation and optimization purposes, in accordance with its Privacy Notice.

3.2. To provide you with customer support We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy. 3.3. To communicate with you regarding your use of our Service We communicate with you, for example, by push notifications if you opt-in. These may include reminders or other information about the App. To opt out of receiving push notifications, you need to change the settings on your device.

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The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service’s users, as well as when they interacted with it, such as by tapping on links included in the message.We use Zendesk ticketing system to handle customer inquiries. When you send us inquiries via contact form or via email, we will store the details provided by you via Zendesk ticketing system, which enables us to track, prioritize and quickly solve your requests. Privacy Policy.

3.4. To research and analyze your use of the Service This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.

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To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy Policy. Appsflyer allows you to Opt Out of having data from my device sent to Appsflyer’s servers for apps usage collection.Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone, tablet or laptop), unique identifiers (including advertising identifiers). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features we should focus on. Amplitude provides more information on how they process data in its Privacy Policy.To perform our App analysis, we also use Tableau, a company providing interactive data visualization products focused on business intelligence. Tableau Software Privacy Policy.We use Google Tag Manager to manage tags on the App for conversion tracking and analytics. We use BigQuery, an analytical service provided by Google, which allows us to analyze large and complex datasets about the App. To know more about how Google processes your data, visit Google’s Privacy Policy.

3.5. To send you marketing communications We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features available on the App. We may show you advertisements on our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications from us, you need to change the settings on your device. 3.6. To personalize our ads We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products in your Facebook’s feed. How to opt out or influence personalized advertising iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads. Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here. In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

• Network Advertising Initiative – http://optout.networkadvertising.org/
• Digital Advertising Alliance – http://optout.aboutads.info/
• Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
• Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
• DAA AppChoices page – http://www.aboutads.info/appchoices

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We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, installed the App). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.We use Facebook Audience Network SDK, which is an in-app advertising network for mobile apps that helps us monetize our App by showing targeted ads that match the interests of our users. We use Facebook Advance Matching to optimize our Facebook ads to drive better results.Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our App (for example, show our ads to users who have made a purchase). Some other examples of events that may be used for tailoring ads include, in particular, installing our App. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location). TikTok’s Privacy Policy.

3.7. To process your payments We may provide paid products and/or services within the App. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors. 3.8. To enforce our Terms and Conditions of Use and to prevent and combat fraud We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use). 3.9. To comply with legal obligations We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

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4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA 

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users. We process your personal data under the following legal bases:  4.1. your consent Under this legal basis we may communicate with you regarding your use of our Service, for example, by sending you push notification reminding you to use the App.  4.2. to perform our contract with you; Under this legal basis we:

• Provide our Service (in accordance with our Terms and Conditions of Use)
• Customize your experience
• Provide you with customer support
• Communicate with you regarding your use of our Service
• Process your payments

4.3. for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data; We rely on legitimate interests:

• to research and analyze your use of the Service

Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).

• to send you marketing communications

The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.

• to personalize our ads

The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

• to enforce our Terms and Conditions of Use and to prevent and combat fraud

Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use. 4.4. to comply with legal obligations.

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5. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:  5.1. Service providers We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

• cloud storage providers (Amazon)
• data analytics providers (BigQuery, Facebook, Growthbook, Appsflyer, Amplitude)
• communication service providers (Zendesk)
• marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, TikTok)

5.2. Law enforcement agencies and other public authorities We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law. 5.3. Third parties as part of a merger or acquisition As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

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6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

To be in control of your personal data, you have the following rights: Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the App. Deleting your personal data. You can request erasure of your personal data as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations. Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof. Additional information for EEA-based users: If you are based in the EEA, you have the following rights in addition to the above: The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place. The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request to us as described below. To exercise any of your privacy rights, please send a request to support@katochat.ai.

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7. AGE LIMITATION

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.

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8. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards. In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

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9. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

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10. U.S. STATES PRIVACY NOTICE

Applicability If you reside in a state that has enacted consumer privacy laws, this section applies to you. This U.S. States Privacy Notice (“Notice”) supplements our Privacy Policy and provides disclosures required by laws in states such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia. This Notice is designed to supplement our Privacy Policy to ensure compliance with state-specific laws and applies to the collection, use, and sharing of your Personal Information through our websites, mobile applications, and other online or offline services (collectively, the “Services”). For California residents, this also serves as our California Notice at Collection. This Notice does not apply to information collected about employees, job applicants, or independent contractors in the context of employment. Definition of Personal Information The definition of “Personal Information” may vary by state law. Generally, it refers to “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” 1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT The table below outlines the categories of Personal Information we collect, along with examples and the third parties with whom such data may be shared. For more details, refer to our Privacy Policy. Additionally, we may share each of the above-listed categories of Personal Information with government entities if required:

• To comply with legal obligations, subpoenas, or law enforcement requests.
• To protect the rights, property, or safety of users, our company, or others.
• To enforce our policies or contractual obligations.

If we undergo a merger, acquisition, financing, bankruptcy, reorganization, or sale of company assets, we may transfer your Personal Information to involved corporate entities and their professional advisors. 2. WHY WE USE PERSONAL INFORMATION We process Personal Information for the following purposes:

• To provide and maintain our Services, including account creation, authentication, and access management.
• To process payments, subscriptions, and transactions.
• To conduct analytics and research for product development and service enhancements.
• To communicate with users, including customer support, service updates, and promotional offers.
• To prevent fraud, security threats, and unauthorized activities.
• To comply with legal and regulatory requirements.

For additional details, refer to our Privacy Policy. 3. WHAT PERSONAL INFORMATION WE SHARE In addition to the table above, our Privacy Policy provides further details regarding the categories of third parties with whom we share Personal Information (see Sections 3 and 5). Certain state privacy laws, such as those in California require us to disclose the categories of Personal Information that we have shared with third parties for business purposes over the past 12 months. During this period, we have disclosed all categories of Personal Information outlined in the “Сategories of Personal Information We Collect” section for business purposes. For example, we may share IP addresses and device identifiers with service providers that assist us with crash monitoring and reporting. Some U.S. states grant residents the right to opt out of sharing their Personal Information with third parties in exchange for valuable consideration (which may be classified as a “sale” or “share” under state privacy laws, even if no monetary transaction occurs). If you reside in one of these states and would like to limit the disclosure of your Personal Information to third parties for advertising or marketing purposes, please refer to the “Your Rights” section below. Privacy laws in some U.S. states broadly define the term “sale” to include sharing of information via cookies, pixels, and similar tracking technologies for certain targeted advertising activities. We do not sell Personal Information for monetary compensation. However, when you visit our websites, we and our advertising partners may collect device data and behavioral insights through tracking technologies, which could be interpreted as a “sale” or “sharing” under state laws, even if no money is exchanged. 4. YOUR RIGHTS Certain U.S. state privacy laws grant residents specific rights regarding their personal information. If you reside in a state with such laws, you may have the following rights: Right to Data Portability/Access You may have the right to request access to the specific pieces of personal information we have collected about you in the 12 months preceding your request. Where applicable, we may provide this data in an electronic, portable, and readily usable format. Right to Know You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding your request. Right to Deletion You may have the right to request that we delete the personal information we have collected from you. We will use commercially reasonable efforts to fulfill your request, subject to applicable laws. However, we may be required to retain certain information for legitimate business purposes or as required by law. Right to Opt-Out of Sales, Sharing, and Targeted Advertising You may have the right to opt out of certain uses of your personal information, including:

• The “sale” or “sharing” of your personal information as defined under state privacy laws.
• The use of your personal information for targeted advertising.

To opt out, you can:

• Visit our “Do Not Sell/Share My Personal Data” form.
• Submit a request via our support team.

Right to Limit the Use of Sensitive Personal Information Certain states provide the right to restrict how businesses use sensitive personal information. If applicable, please contact us at support@katochat.ai with the subject line “Limit the Use of Sensitive Personal Information.” We will process such requests in accordance with applicable laws. Right to Withdraw Consent Where applicable, you have the right to withdraw your consent for data collection and sharing. Right to Correct (Rectification) You may have the right to request that we correct inaccurate personal information we maintain about you. How to Exercise Your Rights To exercise any of the available privacy rights, please send a request to support@katochat.ai or use the privacy features available in our products. Verification. To ensure that we properly process your requests regarding your rights, we are required to verify your identity. The verification process may vary depending on the type of request and the Service you use. It may include confirming details such as your name, age, email address, date of subscription purchase, date of last activity, date of account creation, or other relevant Service usage data that reasonably identify you as the account owner. We may also request additional proof of identity if necessary, but we strive to minimize the information required. For certain requests, we may send a verification code or link to authenticate your identity. Authorized Agent. You may designate an authorized agent to exercise your rights on your behalf. If you have provided the authorized agent with a valid power of attorney, we will work directly with them to process your request. If a power of attorney or similar authorization has not been provided, we will contact you directly to confirm the agent’s authority and collect the necessary verification information. The authorized agent must verify both their own identity and that of the consumer they are representing. California “Shine the Light” Law California residents have the right to request, once per year, a list of third parties to whom we have disclosed their personal information for direct marketing purposes in the prior calendar year. To obtain this information from us, please send an email message to support@katochat.ai, which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Right to Appeal If we deny your request, you may have the right to appeal our decision. To do so, please contact us and explain your concerns. If you are dissatisfied with the result of the appeal, you may escalate the matter by contacting the Attorney General’s office in your state of residence. Non-Discrimination You have the right to exercise your privacy rights without fear of discrimination or retaliation. However, we may provide different levels of service or pricing based on the value of your personal information, as permitted by applicable law. Data Retention We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.

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11. DATA RETENTION AND SECURITY

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Security measures: We implement commercially reasonable technical and organizational safeguards to prevent unauthorized access, use, or disclosure. Our key security measures include:

• Encryption in transit: All personal data transmitted via our website is encrypted using HTTPS/TLS protocols.
• Aggregation: we combine data into summary statistics and strip out direct identifiers so the results can’t reasonably be linked back to an individual person
• Pseudonymization: processing of personal data in such a way that the data can no longer be attributed to a specific data subject without the use of additional information.
• Secure infrastructure: We store all personal and usage data on reputable cloud providers, such as Amazon Web Services (AWS), which comply with industry standards for physical and digital security.
• Encryption at rest: Where appropriate, we apply encryption to stored data to prevent access in case of unauthorized server access.
• Access control: Access to personal data is strictly limited to authorized employees, contractors, or service providers who need this data to operate or improve the Service. All such individuals are subject to contractual confidentiality obligations.
• Monitoring and logging: We monitor our systems for unauthorized access and regularly review our data processing practices to detect and respond to potential threats.
• Data minimization: We collect and store only the personal data necessary for the functioning of our services and limit retention periods accordingly.

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12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

Except as otherwise stipulated in this Privacy Policy, this App does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

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13. CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@katochat.ai. Effective as of: 01.04.2026