PRIVACY POLICY

PRIVACY NOTICE

1. PREAMBLE
 

1.1 PromethistAI a.s., with its registered office at Salvátorská 931/8, Staré Město, 110 00 Prague 1, Czech Republic, Identification Number 086 71 281, entered into the Commercial Register maintained by Prague City Court, Section B, Insert No. 24826 (“we” or “Company”), provides you with the following information (“Information”) in relation to personal data processing in connection with the application Elysai (“Application”) operated by us. This information is provided in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, “GDPR”) and other applicable laws.

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1.2 Personal data means any information that can be used to identify you or that is attributable to you as a natural person. Any terms undefined in this Information that are defined in GDPR shall have the same meaning as in GDPR.

2. SCOPE,  PURPOSE AND LEGAL BASIS OF DATA PROCESSING
 

2.1 We process the following data when you interact with the Application for the purpose of testing and improving our conversational AI system:

• Technical Data: UserID, Device ID (iOS, Android), session ID, session activity logs, and demographic data inferred from interactions (e.g., language or region).

• Conversational Data: Transcripts of your interactions with the AI, including semantic and emotional insights derived from your language to influence and personalize future interactions. Some of this information may be sensitive, such as your feelings or mental health concerns.
  Processing is based on your consent granted via the mandatory in-app consent prompt tied to your Device ID upon your first interaction (Article 6(1)(a) GDPR). For research purposes, we may rely on Article 89 GDPR with appropriate safeguards. Sharing such information is voluntary but necessary for the Application’s functionality.

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2.2 Your data is processed using third-party AI technologies (e.g., GPT models provided by OpenAI) and stored pseudonymously via your User ID for use in future sessions. We do not collect your email address. If you do not wish your previous sessions to be linked, you can request data deletion as outlined in Section 5.3.

 

2.3 We do not send newsletters or marketing communications, as we do not collect contact information for such purposes.

3. RECIPIENTS
 

3.1 We may share your personal data with third parties, if: (a) you have consented to such disclosure; (b) we are under a legal obligation to do so; (c) it is necessary for the purpose of legal proceedings or in relation thereto, or to exercise or protect our rights; (d) we are required to disclose your personal data to new entities or third parties due to organizational changes within the Company or in connection with the transfer of our business or any part thereof. We may also share your personal data with some reliable third parties in accordance with contracts entered into with them. They include, for example: (a) our professional advisors and auditors; or (b) IT technology providers. We share data with third-party AI providers (e.g., OpenAI, ElevenLabs) under data processing agreements to process conversational data.

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3.2 When transferring personal data outside the European Economic Area (EEA), we comply with GDPR Chapter V, transferring only to countries with an adequacy decision by the European Commission or to parties with appropriate safeguards (e.g., Standard Contractual Clauses).

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3.3 In an exceptional case when your personal data are transferred outside of the European Economic Area, we will observe all respective requirements set out in the GDPR to ensure the protection of such data, in particular, we will transfer them only to countries that were acknowledged by the European Commission as having an adequate level of protection of personal data, or to parties who have appropriate safeguards in place (such as Standard Contractual Clauses or binding corporate rules).

4. DURATION OF PROCESSING
 

4.1 We process your personal data only for the time period necessary to fulfill the purposes outlined above or as required by applicable laws. Your data is linked to a persistent session profile tied to your User ID, and we retain it for 18 months after your last interaction with the Application to support research and improvement. After this period, all personal data attributable to you as an identifiable natural person are erased, though we may retain anonymized data for research purposes.

5. YOUR RIGHTS
 

In relation to the personal data provided to us, you have the following rights:

 

5.1 Right of access: You have the right to obtain from us confirmation as to whether or not your personal data are being processed, and, where that is the case, to access such personal data and the related information, in particular concerning the purpose of personal data processing, its duration, categories of personal data processed and recipients to whom the personal data are disclosed. Such right to access may nevertheless be restricted based on the rights and freedoms of others.

 

5.2 Right to rectification: Upon your request, we shall correct inaccurate or amend incomplete personal data related to you.

 

5.3 Right to Erasure (Right to be Forgotten): You may request erasure under GDPR conditions (e.g., data no longer needed, consent withdrawn). To delete your data, use the in-app Settings menu, where your User ID is automatically attached to an email sent to support@elysai.com. Upon receipt, we will delete all associated personal data within 30 days.

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5.4 Right to restrictions of processing: Under the conditions set out in GDPR (for example when the accuracy of personal data is contested by you or the personal data were unlawfully processed), we shall, upon your request, restrict processing of your personal data; in such case, we shall process such personal data only for limited reasons set out in GDPR or other applicable laws.

 

5.5 Right to data portability: Under the conditions set out in GDPR and to the extent of our technical capabilities, you shall have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format and to transmit those data to another controller without hindrance from us.

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5.6. Right to object: In certain cases (in particular with respect to personal data processed on the basis of our legitimate interest) you may object to the processing of your personal data. In such cases, we may be required to cease further processing of such personal data.

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​5.7 Right to Withdraw Consent: You may withdraw consent at any time (without affecting prior processing) by requesting deletion via the in-app Settings menu as described in Section 5.3.

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5.8 Right to contact the Supervisory Authority: You shall have the right to contact our Company at info@promethist.ai with inquiries and/or complaints regarding personal data processing. You shall also have the right to lodge a complaint with the Supervisory Authority (Czech Office for Protection of Personal Data, with its registered office at Pplk. Sochora 27, 170 00 Prague 7, Czech Republic, E-mail: posta@uoou.cz, website: https://www.uoou.cz).

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6. AGE RESTRICTIONS

6.1 The Application is not intended for users under 16 (or the applicable age of consent in your jurisdiction). By consenting, you confirm you meet this requirement. We do not knowingly process data from minors without parental consent.

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7. SECURITY

7.1 We implement technical and organizational measures (e.g., encryption, and access controls) to protect your data against unauthorized access, loss, or alteration.

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8. CHANGES TO THIS NOTICE

8.1 We may update this Notice. Significant changes will be notified via the Application. The current version is dated April 1, 2025.

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9. CONTACT US

9.1 For questions, contact support@elysai.com.

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