Privacy Policy for Accrush

1. Introduction

Welcome to Accrush ("we," "our," or "us").

Company Details:

• Legal Entity: PURE ESSENCE TECH PTE. LTD.
• Registered Address: #03-01 Robinson 112, Singapore 068902, Singapore

We are committed to protecting your privacy and ensuring you have a positive experience with our AI role-play and companionship application ("Service"), which provides entertainment-focused interactions with multiple AI-generated characters. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

By accessing or using Accrush, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with any part of this policy, please do not use our Service.

2. Information We Collect

2.1 Information You Provide to Us

Account Information:

• Email address
• Username and password
• Date of birth (to verify age requirement)
• Profile information (name, gender)
• Optional profile details (biography, appearance)

AI Conversations:

• All messages and interactions with our AI companions
• Content you voluntarily share during conversations
• Feedback and ratings you provide about AI responses

User-Generated Content:

• Profile edits and updates
• Customization preferences
• Any content you post or share within the Service

Mood & Well-Being Logs:

• Daily mood check-ins or emotion tags you choose to record (for example, how you feel today);
• Optional notes or reflections you write about your day or emotional state.

These entries are used to personalize your in-app experience and are not treated as medical or clinical records, nor are they used to provide professional mental health services.

2.2 Information We Collect Automatically

Device Information:

• Device type and model
• Operating system and version
• Unique device identifiers (e.g., IDFA on iOS, GAID on Android) for advertising and analytics purposes
• IP address
• Geolocation data (country, region/state, city-level)

Usage Data:

• Login dates and times
• Features used and interaction patterns
• Time spent on different activities
• Error logs and performance data

AI Interaction Data:

• Conversation history and patterns
• AI model performance metrics
• User satisfaction indicators
• Character selection and interaction history (which AI characters you chat with and how often)
• Associations between your mood logs and your usage patterns (for example, whether you interact more with certain characters when you report a specific mood)
• Usage of assistance features, such as the "Inspiration" tool for generating suggested replies

Transaction & Virtual Currency Data:

• Purchase history of Gems (date, amount, transaction ID from App Store/Google Play)
• Current Gem balance
• Usage records of Gems (e.g., amount spent on chats, image generation, or inspiration features)
• Status of free allowances or trial periods

2.3 Information from Third Parties

We do NOT receive any personal information about you from third parties, except as related to advertising attribution.

Data Sources:

Most information we have comes from:

• You (what you provide to us)
• Your device (technical data automatically sent)
• Your usage (how you interact with our Service)

Third-Party Services We Use:

1. Authentication (if you choose social login):
   • Google/Apple verify your identity
   • We receive only: authentication confirmation (not your full account data)
   • You still create your profile manually in our app
2. Analytics Services:
   • Tools like Google Analytics collect usage data from your device
   • We receive only: aggregated, anonymized statistics
3. Payment Processors:
   • Stripe/Apple/Google handle transactions
   • We receive only: payment confirmation (success/failure)
   • We never see your credit card or payment details

2.4 Sensitive Personal Information

What We Do NOT Collect:

We do not knowingly collect or process sensitive personal information, including:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data (fingerprints, facial recognition)
• Health information used for diagnosis or treatment
• Sex life or sexual orientation
• Social security numbers, driver's license, or passport numbers
• Financial account login credentials
• Precise geolocation (we only collect approximate location)

Age Verification Exception: We collect date of birth solely for age verification purposes (18+ requirement).

2.5 Advertising Data

To provide our Services for free or at a reduced cost, we may display third-party advertisements. We and our advertising partners (including Unity Ads and others) may collect and use information about you, such as:

• Device identifiers (Advertising ID);
• Location data (approximate);
• In-app usage data (e.g., ad views, clicks, and interaction duration).

This data is used to serve personalized ads that are relevant to your interests.

3. How We Use Your Information

We use the information we collect for the following purposes:

Service Provision:

• Create and manage your account
• Provide AI conversation services
• Personalize your entertainment and role-play interactions (for example, which characters or storylines we suggest)
• Process transactions and subscriptions

Service Improvement:

• Train and improve our AI models
• Develop new features and services
• Analyze usage patterns and trends
• Conduct research and development

We do not use your mood logs or conversations as medical or clinical data, and we do not provide diagnosis or treatment for mental health conditions.

Advertising:

• Serve personalized advertisements (using partners like Unity Ads);
• Measure the effectiveness of advertising campaigns;
• Analyze user interaction with ads.

Communication:

• Send service-related notifications
• Respond to your inquiries and support requests
• Provide updates about new features
• Send marketing communications (with your consent)

Security and Safety:

• Protect against fraud and unauthorized access
• Monitor for suspicious activities
• Enforce our terms of service
• Comply with legal obligations

4. AI Model Training and Data Usage

4.1 Conversation Data for AI Training

We use conversation data to improve our AI models and enhance the quality of interactions. Before using conversation data for training purposes, we:

• Remove personal identifiers and sensitive information where possible;
• Implement data anonymization and aggregation techniques;
• Limit access to training data to authorized personnel and systems.

We may use third-party AI providers (such as Google, for its Gemini family of models including Gemini 2.5 Pro) to process your inputs and generate responses. When we do so, your conversation data may be temporarily transmitted to those providers under contractual terms that require them to protect your data and use it only to provide AI services to us.

4.2 User Control Over Data Usage

You have the right to:

• Opt-out of having your conversations used for AI training (where supported in the app settings);
• Request deletion of specific conversations;
• Control how your data is used for model improvement.

4.3 Data Retention for AI Training

• Conversations used for training are retained for up to 2 years;
• You can request deletion at any time;
• Data is anonymized and/or aggregated to protect your privacy.

4.4 AI Model Limitations and Risks

Please be aware:

• AI responses may occasionally be inaccurate, inappropriate, or unexpected;
• Do not share sensitive personal information (e.g., full financial details, medical records);
• Conversations should not replace professional advice (medical, legal, financial, or psychological);
• AI companions are not capable of providing emergency assistance;
• Users are responsible for content they generate and input during AI interactions.

5. Data Sharing and Disclosure

We do not sell your personal information. We may share your information only in the following circumstances:

Service Providers:

• Third-party vendors who help us operate our Service;
• Payment processors for subscription management;
• Cloud hosting providers for data storage;
• Analytics providers for service improvement;
• AI infrastructure and model providers (for example, providers of large language models like Google Gemini) that process your inputs to generate AI responses, under strict contractual and technical safeguards.
• Advertising Partners: We share data with third-party advertising networks (such as Unity Ads and other programmatic advertising platforms) to serve advertisements. These partners may use their own tracking technologies (SDKs) to collect data from your device.

All service providers process your data only to perform services on our behalf and are bound by strict contractual obligations to keep your data confidential and implement appropriate security measures.

Legal Requirements:

• When required by law or legal process;
• To respond to lawful requests from public authorities;
• To protect our rights and property;
• To protect the safety of our users.

Business Transfers:

• In connection with a merger, acquisition, or sale of assets;
• If we undergo a change in ownership.

With Your Consent:

• When you explicitly authorize us to share your information;
• For specific purposes you have agreed to.

6. Content Moderation and Safety

Prohibited Content:

We prohibit and actively monitor for content that violates our Terms of Service and Acceptable Use Policy, including but not limited to:

• Illegal content under applicable laws;
• Child safety violations;
• Content promoting harmful or dangerous activities;
• Harassment, hate speech, or discriminatory content;
• Sexual or romantic content involving minors (real or fictional), non-consensual acts, exploitation, or other abusive behavior.

Enforcement Actions:

Depending on the severity and nature of the violation, we may take the following actions:

• Content removal or filtering;
• Written warning;
• Temporary account suspension (with specified duration);
• Permanent account termination;
• Reporting to relevant authorities (when legally required).

Your Right to Appeal:

If we take enforcement action against your account, you will be notified of:

• The specific content or conduct that violated our policies;
• The applicable policy provision;
• The action taken.

You have the right to appeal our decision by contacting us at support@accrushchat.com within 30 days of the action. We will review your appeal and respond within 48 hours.

7. Data Security

We implement industry-standard security measures to protect your information:

Access Controls

• Multi-factor authentication for employee access;
• Principle of least privilege (role-based access);
• Audit logging of all data access;
• Regular access reviews and revocations.

Infrastructure:

• Cloud hosting with AWS/GCP/Azure;
• Geographically redundant backups;
• DDoS protection and web application firewalls;
• Regular third-party security assessments.

What This Means:

Your conversations are encrypted when sent to our servers and while stored. We can access conversation content when necessary for:

• Providing and improving the Service;
• Safety and abuse prevention;
• Legal compliance and user support.

When generating AI responses, some of your data (such as your messages and prompts) may be transmitted to our third-party AI providers over encrypted connections. These providers are required to protect your data and are only permitted to use it to provide AI services to us in accordance with our instructions and applicable law.

Authorized employees with a legitimate need may access your data under strict controls.

8. Data Retention

We retain your information for as long as necessary to provide our Service and fulfill the purposes described in this policy:

Account Information:

• Retained for the duration of your account;
• Deleted within 30 days of account termination, unless we are required by law to retain certain information for a longer period.

Conversation Data:

• Active conversations: retained until you delete them;
• Deleted conversations: removed within 30 days;
• Training data: retained for up to 5 years (in anonymized and/or aggregated form).

Usage Analytics:

• Retained for 2 years to improve our Service;
• Aggregated and anonymized after 1 year.

Legal Requirements:

• We may retain certain information longer if required by law;
• For resolving disputes and enforcing our agreements.

9. Your Rights and Choices

Depending on your location, you may have the following rights:

Access and Portability:

• Request a copy of your personal information;
• Export your conversation history;
• Obtain your data in a machine-readable format.

Correction:

• Update your account information;
• Correct inaccurate data;
• Modify your preferences.

Deletion:

• Request deletion of your account;
• Delete specific conversations;
• Request removal of personal information from our systems.

Opt-out:

• Opt-out of marketing communications;
• Disable data collection for AI training (where supported);
• Turn off personalized features where available.
• Opt-out of Targeted Advertising: You can control personalized ads via your device settings (e.g., "Ask App Not to Track" on iOS or "Delete advertising ID" on Android).

Restriction:

• Limit how we process your information;
• Suspend certain data processing activities;
• Restrict data sharing with third parties.

To exercise your rights, you can contact us at support@accrushchat.com or use the in-app settings where available.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for such transfers:

• Standard Contractual Clauses approved by the European Commission;
• UK International Data Transfer Addendum;
• Adequacy decisions for certain countries;
• Binding corporate rules where applicable.

11. Age Restrictions and Minor Protection

Minimum Age Requirement:

Our Service is strictly for users 18 years of age and older. We do not knowingly collect personal information from individuals under 18.

Age Verification:

• Users must confirm they are 18+ during account creation;
• We may implement additional verification measures where appropriate;
• False age declaration may result in immediate account termination.

If We Discover Underage Use:

If we learn that we have collected information from anyone under 18, we will:

1. Immediately suspend or disable the account;
2. Delete all associated personal data within 30 days, unless we are legally required to retain certain records for a longer period;
3. Take reasonable steps to prevent future access from the same credentials or device.

Reporting Underage Users:

If you believe someone under 18 is using our Service, please report immediately:

• Email: support@accrushchat.com
• Subject line: "Underage User Report"
• Include: Username or any identifying information.

Parents and Guardians:

If you believe your child under 18 has created an account, contact us immediately at support@accrushchat.com to request account deletion.

Why This Restriction:

Our AI companion Service involves mature themes and is designed for adult interactions. The age restriction protects minors from potentially inappropriate content.

12. Third-Party Services

Our Service may contain links to third-party websites and services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy on our Service;
• Sending you an email notification;
• Providing in-app notifications.

The updated policy will be effective 30 days after posting, unless the changes affect your rights, in which case we will provide at least 60 days' notice.

14. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Support Team:

• Email: support@accrushchat.com
• Response time: Within 48 hours.

15. Legal Basis for Processing (GDPR/UK GDPR)

If you are in the European Economic Area or United Kingdom, our legal basis for processing your personal information includes:

Contractual Necessity (Article 6(1)(b)):

• To provide our Service to you;
• To fulfill our obligations under our Terms of Service.

Legitimate Interests (Article 6(1)(f)):

• To improve and develop our Service;
• To prevent fraud and maintain security;
• For marketing purposes (with opt-out option).

Consent (Article 6(1)(a)):

• For sending marketing communications;
• For using data for AI training (where consent is required);
• For collecting certain types of information.

Legal Obligation (Article 6(1)(c)):

• To comply with applicable laws and regulations;
• To respond to lawful requests from authorities.

16. California Privacy Rights (CCPA)

If you are a California resident, you have the following rights:

16.1 Categories of Personal Information We Collect

Category	Examples	We Collect
A. Identifiers	Email, username, device ID, IP address	✓ Yes
B. California Customer Records	Name, contact info, date of birth	✓ Yes
C. Protected characteristics	Date of birth (for age verification only; not used to infer sensitive attributes such as race or religion)	✓ Yes
D. Commercial information	Purchase history of virtual goods, Gem balance	✓ Yes
F. Internet Activity	App usage, interaction patterns	✓ Yes
G. Geolocation	Approximate location	✓ Yes
K. Inferences	User preferences, AI interaction patterns	✓ Yes

Categories we do NOT collect:

• Protected characteristics such as race, religion, or sexual orientation;
• Biometric information;
• Audio/video recordings (we do not currently support image/audio uploads);
• Employment information;
• Education records.

16.2 Your CCPA Rights

• Right to Know: Request categories and specific pieces of personal information collected.
• Right to Delete: Request deletion of your personal information.
• Right to Opt-Out: We do not sell personal information.
• Right to Non-Discrimination: Equal service regardless of privacy choices.

16.3 How to Exercise Your Rights

Submit requests via:

• Email: support@accrushchat.com
• In-app: Profile > Settings > Privacy Policy

Response time: Within 45 days. We may request additional information to confirm your identity.

16.4 Authorized Agents

You may designate an authorized agent to submit requests on your behalf by providing written authorization.

By using Accrush, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

16.5 California "Shine The Light" Law

California Civil Code Section 1798.83 permits California residents to request information about whether we have disclosed personal information to third parties for their direct marketing purposes.

Our Policy: We do NOT share personal information with third parties for their direct marketing purposes.

Therefore, there are no third-party names and addresses to disclose under this law.

16.6 California Minors' Privacy Rights (Users Under 18)

⚠️ Important: Our Service requires users to be 18 or older.

California "Eraser Law" (Business & Professions Code § 22581):

If you are under 18, reside in California, and somehow created an account:

• You have the right to request removal of content you publicly posted;
• Contact: support@accrushchat.com;
• Subject: "Minor Content Removal - California";
• We will remove the content from public view within 30 days.

Limitations:

• Content may remain in backup systems (not publicly accessible);
• We cannot remove content reposted by others;
• We cannot remove content required by law to retain.

For Parents/Guardians:

If your child under 18 created an account:

• Contact: support@accrushchat.com immediately;
• Subject: "Minor Account Deletion - California";
• Include: Your relationship to the minor and proof;
• We will delete the account and associated data within 30 days, subject to any legal retention requirements.

17. Data Breach Notification

In the unlikely event of a data breach affecting your personal information:

Our Response:

• Investigation within 24 hours of discovery;
• Notification to you within 72 hours where required by law (e.g., GDPR);
• Notification to supervisory authorities as required by applicable regulations.

What We'll Tell You:

• Nature and extent of the breach;
• Types of data affected;
• Potential consequences;
• Mitigation measures taken;
• Steps you should take to protect yourself.

Contact for breach-related questions: support@accrushchat.com.