Privacy Policy

Effective Date: September 2026. This Privacy Policy (this "Policy") describes how VOCOSMOS PTE. LTD., a company incorporated in Singapore ("rizzora.ai", "we", "us" or "our"), and its affiliates collect, use, store, disclose and protect your personal information.

This Policy applies to the rizzora.ai website, mobile applications and any other services that link to this Policy (collectively, the "Services"). The Services currently centre on text interaction and do not collect voice or video data, subject to the features offered in the product at the relevant time.

Capitalised terms not defined in this Policy have the meanings set forth in the Terms of Service. Personal data is handled in accordance with the laws applicable to the relevant processing. The location of our company does not displace mandatory protections available to you under those laws. In case of conflict between language versions, the English version shall prevail unless applicable law requires otherwise.

Special Notice

• Your rights and the conditions for exercising them may vary according to the laws applicable to you and the relevant processing.
• Any additional protection required by applicable law forms part of the safeguards described in this Policy and prevails over an inconsistent provision.

1. Information We Collect

We collect information based on how you use the Services.

Information you provide directly:

• identifiers (name, email, username, account ID);
• demographic information (date of birth, approximate location, language preferences);
• interest preferences, account settings and character preferences;
• payment information (processed by third-party payment providers; we do not store full payment-card details); and
• chat content, preferences you submit and other content generated through interaction with the Services. Such conversations may contain sensitive personal information that you choose to disclose. Avoid providing information that is unnecessary for your use of the Services.

Information collected automatically:

• device and usage data (IP address, device type, browser type, operating system, access times, approximate geolocation);
• interaction behaviour (page views, conversation duration, feature usage); and
• cookies and similar technologies used for login status, security and analytics.

From other sources:

• third-party login information (basic profile data provided when signing in with Apple, Google or Facebook); and
• publicly available data, used only for service improvement and in compliance with applicable law.

We do not knowingly collect personal information from individuals under 18 years of age. The Services are intended solely for users aged 18 and above. If we become aware that we have inadvertently collected information from a minor, we will delete it promptly.

2. How We Use Information

We use the information we collect to:

• provide and personalise AI conversations, including processing messages and using relevant conversation history and saved preferences for continuity and memory features;
• improve AI models and algorithms, subject to the lawful basis, purpose limitations and choices described below;
• process subscriptions, payments, Stamina purchases and account management;
• protect the security of the Services and prevent fraud and abuse;
• comply with legal obligations, respond to law-enforcement requests or protect our rights; and
• communicate with you (service notices and policy updates; marketing communications only with your consent, which you may withdraw at any time).

Generative AI-related use

Processing a conversation to generate a reply or maintain conversation memory is distinct from using personal data to train or improve a model. To generate replies and maintain conversation continuity and memory, we and our AI service providers may process the current conversation and relevant history. That processing is necessary to provide the Services and is not model training. By using the Services, you consent to our use of related chat content, preferences and interaction data for model training and optimisation in accordance with this Policy, preferring de-identified or aggregated processing where appropriate. You may withdraw that consent by giving reasonable notice to [email protected]. You need not delete your account first. After withdrawal, you may continue to use the basic conversation and memory features of the Services. Withdrawal does not affect processing lawfully carried out beforehand. Where the law requires separate consent, we will obtain it separately. Use of the Services alone does not replace that separate consent. Access to the Services is not conditioned on ongoing consent to training.

Legal bases for processing

We primarily process your data on the following bases: performance of a contract with you; our legitimate interests, where they do not override your rights; your consent; and legal obligations.

3. When We Disclose Information

We may disclose information:

• to service providers involved in delivering the Services, including AI model and inference providers, hosting, payment processing, analytics and customer support, as necessary for their functions and subject to applicable contractual and data-protection requirements. Relevant conversation content may be transmitted to an AI provider to generate a reply. Such transmission does not, by itself, authorise unrelated use or model training;
• when required by law or court order, or to protect the rights and safety of us and others;
• in connection with a business transfer, such as a merger or acquisition, subject to this Policy; and
• with your explicit consent.

We do not sell personal data or share it for cross-context behavioural advertising.

Requests concerning applicable opt-out rights may be submitted to [email protected].

4. Your Rights and Choices

Depending on your location and applicable law, you may have the following rights.

General rights:

• access, correction and, where provided by applicable law, deletion of your personal information. Account deletion may also be requested through the Services;
• restriction of, or objection to, certain processing;
• data portability, where technically feasible;
• withdrawal of consent, without affecting the lawfulness of processing before withdrawal; and
• opt-out of marketing communications.

Model training. You may withdraw consent to the use of personal data for model training by giving reasonable notice to [email protected]. Account deletion is not required. We shall explain the likely consequences and cease the relevant consent-based processing, including by our data intermediaries and agents, unless continued processing without consent is required or authorised by law. Withdrawal does not affect prior lawful processing and does not prevent us from continuing to generate replies and provide memory features.

Access and correction. Subject to applicable conditions and exceptions, you may request access to personal data held about you, information concerning its use or disclosure, and correction of inaccurate or incomplete information. Retention and disposal remain subject to applicable legal requirements.

Automated processing. Where applicable law provides rights concerning automated decision-making or profiling, you may exercise those rights in accordance with the relevant conditions and procedures.

Additional choices. Applicable law may provide rights to deletion, a copy of your information, restrictions on certain uses or disclosures, and additional protections for sensitive information. Any available right to appeal a decision on a privacy request, or to exercise your rights without unlawful discrimination, remains unaffected.

To exercise your rights, use the available account controls or contact [email protected]. We may take reasonable steps to verify your identity and shall respond within the periods required by applicable law. Where an extension is permitted and required, we shall notify you of the applicable response period and any information required by law.

5. Data Security and Retention

We implement reasonable technical and organisational measures to protect data, including encryption, access controls and regular security assessments. No system is completely secure.

Retention periods:

• Account information is retained while necessary for the purposes for which it was collected and for applicable legal or business requirements. Following closure, retention shall be limited to what remains necessary for those requirements. Personal data shall be deleted or anonymised when retention is no longer justified.
• Chat records are retained while needed to provide memory features of the Services. You may delete them at any time. After account closure they are processed in accordance with the principles above.
• Payment records are retained as required by tax and accounting laws.
• Data used for model training: any retention of identifiable data remains subject to the applicable lawful basis, withdrawal of consent and retention limitations. Data that has been effectively anonymised may be retained where it no longer identifies an individual. Anonymisation shall not be relied upon to avoid obligations concerning data that remains identifiable.

6. International Data Transfers

Personal data may be processed in jurisdictions other than your own, including where we or our service providers operate. Any transfer shall be subject to the safeguards required by applicable law, which may include recognised adequacy arrangements, contractual protections or another lawful transfer mechanism. We shall ensure the standard of protection required for the relevant transfer.

7. Protection of Children

The Services are intended solely for users aged 18 and above. We do not knowingly collect personal information from individuals under 18. If we become aware of such collection, we will promptly delete the information and terminate the corresponding account.

If you are a parent or guardian and discover that a minor has used the Services without authorisation, please contact us immediately and we will assist in addressing the matter.

8. Policy Updates

We may update this Policy from time to time. Material changes and their effective date shall be notified through the Services or by email. An update shall not, of itself, authorise a new use of personal data or constitute consent where separate consent is required by law. Your rights to withdraw consent and exercise other applicable data-protection rights remain unaffected.

9. Contact Us

For questions, to exercise your rights or to lodge a complaint, please contact:

Email: [email protected]

Company: VOCOSMOS PTE. LTD.

Registered office: 139 Cecil Street, #03-03, YSY Building, Singapore 069539

Data-protection enquiries and requests may be submitted to [email protected]. You may also raise concerns with the competent regulatory or supervisory authority in accordance with applicable law.