Privacy Policy

digitalsoul.chat Privacy Policy

Last updated: February 20, 2026

Privacy Policy
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This Privacy Policy describes how ITMATTER Inc. ("DigitalSoul", "we", "us", or "our"), a corporation registered in Ontario, Canada (2301-120 Homewood Ave, Toronto, ON, M4Y 2J3), collects, uses, and discloses information about You when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Our Service is intended solely for individuals who are 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that a person under 18 has provided us with personal data, we will delete it immediately.

Interpretation and Definitions
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Interpretation
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The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions
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For the purposes of this Privacy Policy:

  * Account means a unique account created for You to access our Service or parts of our Service.

  * Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  * Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to ITMATTER Inc., 2301-120 Homewood Ave, Toronto, ON, M4Y 2J3, Canada.

  * Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  * Country refers to: Ontario, Canada

  * Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  * Personal Data is any information that relates to an identified or identifiable individual.

  * Service refers to the DigitalSoul mobile application and website, collectively, accessible from https://www.digitalsoul.chat.

  * Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

  * Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  * You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.


Collecting and Using Your Personal Data
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Types of Data Collected
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Account Data
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To use DigitalSoul, You must create an account. We collect:

  * Email address (provided directly by You or via Google Sign-In)

  * Authentication tokens associated with Your Google account (when using Google Sign-In)

  * A unique user identifier assigned to Your account

Conversation and Content Data
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When You interact with AI characters on our platform, we collect and store the content of those conversations. This includes messages You send and receive. This data is necessary to deliver the core functionality of the Service, including facilitating conversations with our generative AI models. You may voluntarily share personal or sensitive information during conversations; we encourage You to share only what is necessary.

Subscription and Payment Data
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If You purchase a subscription, we process data necessary to manage Your subscription. Payment transactions are handled by our third-party payment processors, Stripe and RevenueCat. We do not store Your full payment card details on our servers. We retain records of subscription status, purchase history, and transaction identifiers to manage Your access to paid features.

Usage Data
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Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect crash reports and diagnostic data to identify and fix bugs.

Communications Data
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If You contact us for support or send us inquiries via email, we collect the information you provide in those communications, including Your email address and the content of Your message.

Tracking Technologies and Cookies
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We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  * Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

  * Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  * Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

  * Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

  * Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Use of Your Personal Data
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The Company may use Personal Data for the following purposes:

  * To provide and maintain our Service, including to monitor the usage of our Service.

  * To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

  * Conversation facilitation: To process and display messages exchanged with AI characters, enabling the core functionality of the Service.

  * AI model improvement: We may use conversation data to improve and fine-tune the generative AI models that power our Service. Before using conversation data for this purpose, we remove or anonymize personal identifiers so that the data can no longer be reasonably linked to a specific individual.

  * For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

  * Subscription and billing management: To process payments, manage Your subscription, and handle billing-related communications.

  * To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation. Push notifications will only be sent with Your prior explicit consent once that feature is implemented.

  * To manage Your requests: To attend and manage Your requests to Us.

  * Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, abuse, and security incidents.

  * For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

  * For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and Your experience.

We may share Your personal information in the following situations:

  * With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You. These providers act as data processors on our behalf and are contractually bound to protect Your data and use it only for the purposes we specify. We do not sell Your personal data to any third party.

  * For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

  * With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

  * With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

  * With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Third-Party Service Providers
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We use third-party service providers to operate and deliver the Service. These providers act as data processors on our behalf and are contractually bound to protect Your data and use it only for the purposes we specify. We do not sell Your personal data to any third party.

The categories of third-party providers we work with include:

  * Authentication and infrastructure providers: We use cloud-based services to manage user authentication, database storage, and backend infrastructure. These providers may collect device identifiers and usage data as part of their services.

  * Payment processors: Payment transactions for subscriptions are handled by a third-party payment processor. We do not store Your full payment card details on our servers. Payment data is collected and processed directly by the payment processor under their own privacy policy and security standards. We retain only records of subscription status, purchase history, and transaction identifiers necessary to manage Your access to paid features. Our payment processor is Stripe, Inc. — see stripe.com/privacy.

  * Subscription management providers: We use a third-party service to manage in-app subscription entitlements and purchase history across platforms. This provider may collect device identifiers and subscription transaction data.

  * Analytics providers: We use analytics services to understand how users interact with the Service, identify usage trends, and improve performance. These services may collect usage data including app interactions, session duration, and device information.

  * Crash reporting and diagnostics providers: We use crash reporting tools to detect and fix bugs. These services may collect device information, operating system version, and app state at the time of a crash.

Retention of Your Personal Data
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The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Specifically:

  * When You request deletion of Your account, we will delete Your personal data, including Your profile information, conversation history, and account records, promptly and without undue delay.

  * Certain data may be retained for a limited additional period where required to comply with legal obligations, resolve disputes, enforce our agreements, or for legitimate security and fraud prevention purposes. In such cases, we will retain only the minimum data necessary and will inform you of this in our response to your deletion request.

  * Usage logs and anonymized analytics data that cannot reasonably be linked back to You may be retained for longer periods for service improvement purposes.

Transfer of Your Personal Data
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Your data is stored on servers located in Canada. Some of our third-party service providers (including Google Firebase, Stripe, and RevenueCat) are based in the United States and process data on servers located outside of Canada. It means that this information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data
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You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. If You wish to delete Your DigitalSoul account and all associated personal data, You may do so by:

  * Using the in-app account deletion option available in Your account settings, or

  * Visiting digitalsoul.chat/profile, or

  * Emailing us at support@digitalsoul.chat with the subject line "Account Deletion Request"

Upon receiving a verified deletion request, we will delete Your account and associated personal data, including Your profile, conversation history, and any stored content. Deletion is permanent and cannot be undone.

Please note that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

Your Rights and Choices
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Depending on Your jurisdiction, You may have the following rights with respect to Your personal data:

  * Access: The right to request a copy of the personal data we hold about You.

  * Correction: The right to request that we correct inaccurate or incomplete personal data.

  * Deletion: The right to request that we delete Your personal data.

  * Portability: The right to receive Your personal data in a structured, machine-readable format.

  * Objection: The right to object to certain types of processing, including processing based on our legitimate interests.

  * Withdrawal of consent: Where processing is based on Your consent, You may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us at support@digitalsoul.chat. We will respond to Your request within 30 days.

Disclosure of Your Personal Data
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Business Transactions
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If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement
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Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements
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The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  * Comply with a legal obligation
  * Protect and defend the rights or property of the Company
  * Prevent or investigate possible wrongdoing in connection with the Service
  * Protect the personal safety of Users of the Service or the public
  * Protect against legal liability

Security of Your Personal Data
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We implement commercially reasonable technical and organizational measures to protect Your personal data against unauthorized access, disclosure, alteration, or destruction. All data transmitted between Your device and our servers is encrypted using industry-standard HTTPS/TLS protocols.

However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Push Notifications
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We plan to introduce push notifications in a future version of the Service. Push notifications will only be sent to You with Your prior explicit consent. You may opt out of push notifications at any time through Your device settings. We will not send push notifications without first obtaining Your explicit permission.

Children's Privacy
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DigitalSoul is intended exclusively for users who are 18 years of age or older. We do not knowingly collect personal data from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us immediately at support@digitalsoul.chat. Upon verification, we will delete such data from our systems without delay.

Applicable Privacy Law
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As a company incorporated in Ontario, Canada, we comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25).

If You are located in the European Economic Area (EEA) or United Kingdom, You may also have rights under the General Data Protection Regulation (GDPR) or UK GDPR. We process Your data on the following lawful bases:

  * Performance of a contract: Processing necessary to provide You with the Service (account management, conversation facilitation, subscription management).

  * Legitimate interests: Analytics, security, fraud prevention, and AI model improvement using anonymized data.

  * Consent: Push notifications and any other processing for which we have obtained Your explicit consent.

  * Legal obligation: Processing required to comply with applicable law.

Links to Other Websites
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Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy
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We may update Our Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify You by updating the "Last updated" date at the top of this policy and, where required by law, by providing additional notice (such as in-app notification or email).

You are advised to review this Privacy Policy periodically for any changes. Your continued use of the Service after any changes constitutes Your acceptance of the updated policy.

Contact Us
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If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

ITMATTER Inc. (DigitalSoul)
2301-120 Homewood Ave, Toronto, ON, M4Y 2J3, Canada

By email: support@digitalsoul.chat
Website: digitalsoul.chat