We ask that you read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and disclose Personal Data, your rights in relation to your Personal Data, and how to contact us in the event you have a question, concern or grievance.
AI NOVEM LABS LLP is the legal entity that owns, operates and provides the Loyl application and related services. Loyl is a product/application developed and made available by AI NOVEM LABS LLP.
Loyl (“Loyl”, “We”, “Us” or “Our”) takes the privacy and security of your Personal Data seriously. We have developed this Privacy Policy to explain the types of Personal Data we may collect or otherwise process, the purposes for which such Personal Data may be used, the circumstances in which it may be disclosed, and the measures we take to protect it.
This Privacy Policy applies to individuals who access or use the Loyl application, website, platform or related services (collectively, the “Services”), including users who create an account, interact with our AI-powered features or communicate with us.
Your use of the Services is also subject to our Terms of Use and any other applicable terms or notices made available to you from time to time.
1Introduction
What we do?
Loyl provides AI-powered digital services that enable users to interact with AI-powered companion characters and other features through its application and related Services. The Services are designed to provide users with interactive and personalised experiences through artificial intelligence and related technologies.
Who do we work with?
In providing and operating the Services, we may work with third-party technology and service providers, including providers of artificial intelligence and large language model (“LLM”) technologies, hosting and infrastructure providers, authentication providers, security providers and other service providers necessary to operate and maintain the Services.
Status: whether Controller/Fiduciary or Processor?
AI Novem Labs LLP may act as a Data Fiduciary/Controller or Data Processor, depending on the nature and purpose of the processing.
Where Loyl determines the purposes and means of processing Personal Data in connection with the operation and administration of its Services, Loyl acts as a Data Controller.
Where Loyl processes Personal Data solely on behalf of and in accordance with the documented instructions of another entity, may act as a Data Processor.
Server Location
The Personal Data processed in connection with the Services may be stored and processed on servers and infrastructure located [X] including through third-party service providers engaged by AI NOVEM LABS LLP for hosting, cloud infrastructure, data storage, and other technology-related services.
Where Personal Data is transferred to or processed in a jurisdiction outside the jurisdiction in which the user is located, AI NOVEM LABS LLP shall undertake such transfer and processing in accordance with applicable data protection and privacy laws and shall implement appropriate contractual, technical, and organisational safeguards, where required.
2Terms used in this policy
Applicable Data Protection Laws
“Applicable Data Protection Laws” the relevant laws that governs the way in which we can use, process and store your personal data including but not limited to laws like EU- General Data Protection Regulation (GDPR), Digital Personal Data Protection Act, 2023 (DPDPA), California Consumer Protection Act (CCPA), or any other law as may be applicable depending on the geography of the data subject .
Personal Data
“Personal Data” means any data about an individual who is identifiable by or in relation to such data, or any equivalent concept recognised under Applicable Data Protection Laws.
Policy
“Policy” means this Privacy Policy, as amended or updated from time to time.
Services
“Services” means the Loyl application, platform, AI-powered features, AI companion characters and any other products, features or services made available by Loyl.
Data Fiduciary/Controller
“Data Fiduciary” or “Controller” means the person or entity that determines the purpose and means of processing Personal Data, as recognised under Applicable Data Protection Laws.
Data Processor
“Data Processor” means a person or entity that processes Personal Data on behalf of a Data Fiduciary/Controller.
Website
“Website” means the website or websites operated by AI NOVEM Labs LLP through which the Services or information relating to the Services are made available.
Data Principal/Data Subject (You)
“Data Principal” or “Data Subject” means the individual to whom the Personal Data relates, including a user or visitor of our Services, as applicable under the relevant Applicable Data Protection Laws.
3What information do we collect and for what purpose?
We collect and process Personal Data only to the extent reasonably necessary for specified and lawful purposes connected with providing, operating, securing, maintaining and improving our Services.
The nature and categories of Personal Data processed may vary depending upon the Services and features you use and the information you voluntarily provide.
Identity and Account Information
We may process information such as your name, username, account ID, email address, mobile number and other information required to create, authenticate and manage your account.
This information may be processed for creating and managing your account, authenticating you, providing access to the Services, communicating with you, providing customer support and maintaining account security.
Except for Personal Data that is specifically identified in this Privacy Policy as being collected or processed by us, information, including prompts, messages, conversations and other content entered, uploaded, generated or otherwise provided by you through the application is designed to remain stored locally on your personal device and is not stored or retained by Loyl on its servers. Such information is also not retained or stored by the third-party LLM service used to generate responses. The relevant information may be transmitted to the applicable LLM service only to the extent necessary to process your request and generate a response, and such service will not retain or use such information for its own purposes, subject to the applicable technical and contractual arrangements.
We retain your Identity and Account Information for one (1) year following the deletion of your account, after which such information will be securely deleted or anonymised, subject to applicable legal requirements.
Device and Technical Information
We may process technical information such as your IP address, device type, device identifiers, operating system, application version, browser type, language settings, timezone and diagnostic information.
This information may be processed to provide, maintain and secure the Services, troubleshoot technical issues, detect unauthorised access or misuse, investigate security incidents and maintain technical functionality.
Usage and Interaction Data
We may process information relating to your interaction with the Services, including features used, pages or screens accessed, access times, session information, referring source and similar usage information.
Such information may be processed to understand how the Services are used, monitor performance, identify technical issues, improve functionality and user experience, and maintain the security of the Services.
We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies generally visit link to be added
AI Interaction Data
When you interact with our AI-powered features or AI companion characters, you may provide prompts, messages, inputs, instructions or other content.
Such information may be processed to provide the AI-powered Services, generate responses, enable the functionality requested by you, personalise your experience, troubleshoot issues and maintain the security and functionality of the Services.
Where such information is transmitted to a third-party AI or LLM provider for the purpose of generating a response, such transmission will be limited to the information reasonably necessary for that functionality, subject to the applicable terms.
Voice and Video Interactions
Where you use voice or video interaction features, we may process audio, video, images, transcripts and related technical information as necessary to provide the requested functionality. For example, your speech may be converted into text and processed by an AI model to generate a response, which may subsequently be converted into synthetic speech.
We will not use audio, video or images for biometric identification, facial recognition or emotion recognition unless we specifically inform you and obtain any consent required under applicable law.
Cookies
Loyl may use cookies, SDKs and similar technologies within the Application to enable essential functionality, remember your preferences, improve your experience, understand how the Services are used, and support advertising and promotional activities.
These technologies may collect information such as device information, unique identifiers, usage information and interaction data. Where applicable, third-party service providers, including advertising and analytics providers, may also use such technologies for measurement, personalised advertising or other purposes disclosed in this Privacy Policy.
Where required by applicable law, we will obtain your consent before using non-essential cookies or similar technologies. You may also manage certain cookie or advertising preferences through your device settings or other controls provided by the relevant service provider.
Advertising and Sponsorships
We may work with third-party advertising partners and service providers to display advertisements within or outside the Application. These partners may use advertising identifiers, device information, usage information, cookies, SDKs and similar technologies to deliver, measure and personalise advertisements based on your interests and interactions with the Application or other services.
This may include showing you advertisements for products, services or content that may be relevant to your interests based on your previous interactions or activities. We may also use such technologies to measure advertising performance, limit the frequency of advertisements and detect or prevent advertising fraud.
Where required by applicable law, we will obtain your consent before enabling personalised or interest-based advertising. You may also be able to manage or disable personalised advertising through your device settings or the controls provided by the relevant advertising provider.
We do not sell or rent your Personal Data to advertisers. We will not use or disclose the contents of your private conversations with Loyl for personalised advertising purposes.
Communications and Support Information
We may process information contained in emails, messages, feedback, support requests, complaints and other communications that you send to us or through the Services.
Such information may be processed to respond to your communications, provide customer support, resolve complaints, maintain appropriate records and improve the Services.
Third-Party Account Information
If you choose to register for or access the Services through a third-party authentication provider, such as Google, Apple or another supported provider, we may receive certain information associated with your third-party account, such as your name, email address, profile information or unique account identifier, depending on the information made available by the relevant provider and the permissions granted by you.
Such information may be used to create, authenticate and manage your account and provide the Services.
Transaction and Payment Data
Where applicable, we may process information necessary to facilitate transactions or payments, including relevant contact details, transaction details and payment-related information.
Where payment processing is handled by a third-party payment service provider, the processing of payment information may be subject to that provider's applicable privacy policy and terms.
Other Personal Data Voluntarily Provided by You
You may voluntarily provide other Personal Data while using the Services or communicating with us.
We may process such information only for the specific feature, service, support or functionality requested by you, or for another purpose communicated to you at or before the time of collection.
Personal Data Contained in User-Generated Content
Our Services may allow you to enter, upload, generate or otherwise provide content, including text or other information, through the application.
You should exercise caution before voluntarily providing Personal Data about yourself or another individual through prompts, messages, uploads or other content submitted to the Services.
4User-entered information stored on your device
The application is designed so that information, including Personal Data, that you enter, upload, generate or otherwise provide while using certain features may remain stored locally on your personal device.
Where information remains solely stored on your personal device and is not transmitted to or otherwise made available to Loyl, we do not maintain a server-side copy of that information and do not have access to such information.
However, certain information may be transmitted from your device to Loyl or to a third-party service provider where such transmission is necessary to provide a particular feature or functionality, including the processing of prompts or messages by a third-party AI/LLM provider.
You are responsible for maintaining the security of your device and for managing, protecting, backing up or deleting information stored locally on your device.
Deleting the application, clearing application data, changing devices or modifying device settings may result in the loss of information stored locally on your device.
5AI processing and third-party AI/LLM services
The Services may use third-party artificial intelligence and large language model providers to process information submitted by you and generate responses.
When you interact with an AI-powered feature, the relevant prompts, messages, inputs or other information may be transmitted to the applicable AI/LLM provider for the limited purpose of processing your request and generating a response.
Loyl does not maintain a server-side copy of conversations that remain solely stored on your personal device and does not have access to such conversations unless you sentence to be completed
We do not use the content of your private conversations, voice calls, video interactions, or other private communications with the Services to train, develop, or improve third-party general-purpose artificial intelligence (“AI”) models. Any processing of such content by third-party AI service providers is carried out solely to provide, maintain, secure, and support the Services, in accordance with the applicable contractual and data protection requirements.
6Data minimisation
We seek to collect and process only such Personal Data as is reasonably necessary for the specific purposes described in this Privacy Policy.
The categories of Personal Data processed may vary depending upon the Services or features you use and the manner in which you interact with us.
We do not seek to collect additional categories of Personal Data or use Personal Data for materially different purposes without providing appropriate notice or obtaining consent where consent is required under Applicable Data Protection Laws.
7Disclosure of personal data
We may disclose Personal Data that we actually collect or otherwise process where such disclosure is reasonably necessary for providing the Services, complying with Applicable Data Protection Laws or fulfilling another specified and lawful purpose.
Depending on the Services you use, recipients may include:
our employees, officers, representatives and authorised personnel;
entities within our corporate group, where applicable;
hosting, cloud infrastructure, IT, security and technical service providers;
payment service providers and other providers involved in processing transactions;
professional advisers, insurers and other service providers where reasonably necessary;
governmental authorities, regulators, courts, law enforcement agencies or other authorised persons where required or permitted by Applicable Data Protection Laws; and
other persons where you have specifically authorised or directed us to make the disclosure.
Where we engage a Data Processor to process Personal Data on our behalf, we will take reasonable measures to ensure that such processing is carried out in accordance with Applicable Data Protection Laws and our instructions.
8Other permitted purposes for processing personal data
In addition to the specific purposes described in this Privacy Policy, we may process or disclose Personal Data where reasonably necessary:
- to comply with applicable laws, regulations, court orders or other legal processes;
- to respond to lawful requests from governmental authorities, regulators, courts or law enforcement agencies;
- to detect, prevent or investigate fraud, misuse, unauthorised access, security incidents or other prohibited activities;
- to establish, exercise or defend legal claims;
- to enforce our Terms of Use, agreements or other applicable terms;
- to protect the rights, property or safety of you, Loyl, our users or any other person; or
- to resolve disputes and otherwise protect our legitimate business interests, to the extent permitted by Applicable Data Protection Laws.
9Restriction on providing sensitive personal data
Our Services are not designed to require users to provide sensitive or special-category Personal Data through their conversations with AI companion characters or other features.
You should exercise caution before providing sensitive or highly personal information through the Services, including information relating to health, financial information, government-issued identification documents or numbers, biometric information, religious or philosophical beliefs, political opinions, sexual orientation or other information that may receive special protection under Applicable Data Protection Laws.
Where you voluntarily provide such information, it may form part of the content submitted by you and may be processed to the extent necessary to provide the functionality requested by you, subject to Applicable Data Protection Laws.
10Legal bases/grounds of processing
We process Personal Data only for specified and lawful purposes and on a lawful basis available to us under Applicable Data Protection Laws.
Depending on the circumstances, processing may be undertaken:
- Based on consent: where we are required to obtain your consent for a particular processing activity, we will seek such consent in accordance with Applicable Data Protection Laws and provide appropriate information regarding the processing.
- For performance of a contract or provision of Services: where processing is necessary to provide the Services requested by you or to take steps at your request before entering into an agreement.
- For compliance with legal obligations: where processing is necessary for compliance with applicable laws, regulations, court orders or other legally binding requirements.
- For legitimate interests, where applicable: where permitted under Applicable Data Protection Laws, including for maintaining the security of our Services, preventing misuse and protecting our systems, rights and business interests, provided that such interests are not overridden by applicable rights and interests.
Where processing is based on consent, you may withdraw your consent in accordance with Applicable Data Protection Laws. Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal.
11Retention of personal data
Your Personal Data will not be retained for longer than is reasonably necessary for the purpose for which it was collected or processed, unless a longer retention period is required or permitted under Applicable Data Protection Laws.
Personal Data that remains solely stored on your personal device and is not transmitted to or otherwise made available to Loyl is not retained by us.
Where Personal Data is no longer required for the relevant purpose and there is no legal, regulatory, contractual or other lawful requirement to retain it, we will take reasonable steps to delete, anonymise or securely dispose of such Personal Data in accordance with our data retention practices and Applicable Data Protection Laws.
Where Loyl acts as a Data Processor, retention of Personal Data may be determined by the applicable contractual arrangements or documented instructions of the relevant Data Fiduciary/Controller.
12Transfer of data
If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and USA and process it there
Your Personal Data may be processed or stored in jurisdictions other than the jurisdiction in which you reside, including jurisdictions where data protection laws may differ from those applicable in your jurisdiction.
Where Personal Data is transferred across jurisdictions, Loyl will take reasonable steps to ensure that such transfer and processing are undertaken in accordance with Applicable Data Protection Laws and appropriate contractual, technical and organisational safeguards.
Third-party AI/LLM, hosting, infrastructure, authentication, and other technology providers may process information from locations outside India, depending on the services and infrastructure used by Loyl.
13Know your rights
Subject to Applicable Data Protection Laws and any limitations or exceptions available under such laws, you may have rights in relation to your Personal Data, including:
- Right to Access: the right to obtain information about Personal Data processed by us, to the extent provided under applicable law.
- Right to Correction: the right to request correction of inaccurate or incomplete Personal Data.
- Right to Erasure: the right to request deletion of Personal Data where such right is available under applicable law.
- Right to Withdraw Consent: where processing is based on consent, the right to withdraw such consent in accordance with applicable law.
- Right to Grievance Redressal: the right to raise a grievance concerning our processing of your Personal Data.
- Right to Nominate: where applicable under the DPDP Act or other Applicable Data Protection Laws, the right to nominate another individual to exercise your rights in the event of your death or incapacity.
The availability and scope of these rights may vary depending upon the Applicable Data Protection Laws and the nature of the processing.
You may exercise your applicable rights by contacting us using the contact details provided in the “Getting in Touch” section below.
We may take reasonable steps to verify your identity before processing a request relating to your Personal Data.
Where a request is submitted through an authorised representative, we may require appropriate evidence of such authority.
We will review and respond to valid requests within the period prescribed under Applicable Data Protection Laws.
14Personal data of children
The Services are not intended for use by Children (Under the age of 18 years), and Loyl does not knowingly collect or use Personal Data relating to children. We do not knowingly permit children to access or use the Services.
Where required by applicable law, we may process a child's Personal Data only to the extent permitted by law and with the prior consent of the child's parent or legal guardian, where such consent is legally required. If we become aware that Personal Data of a child has been inadvertently collected, we will take reasonable steps to delete such Personal Data without undue delay, subject to any legal or regulatory requirement requiring its retention.
If we become aware that any child has accessed or used the Services or that we have collected Personal Data relating to a child, we will take reasonable steps to restrict or terminate such access and, where appropriate, delete such Personal Data, subject to any legal, regulatory, security or other lawful retention requirements.
If you are a parent or lawful guardian and believe that a child has provided Personal Data to us or accessed or used the Services, please contact us using the contact details provided below.
15Confidentiality and security of personal data
We take reasonable technical, organisational and administrative measures designed to protect Personal Data against unauthorised access, disclosure, alteration, loss, misuse or destruction.
Our security measures may include, as appropriate:
- access controls and authentication mechanisms;
- encryption or other appropriate security measures for information transmitted or stored through our systems;
- password protection;
- secure data transfer mechanisms;
- limiting access to Personal Data to authorised personnel and service providers who require such access for legitimate business purposes;
- contractual confidentiality and data protection obligations for relevant service providers; and
- periodic review of our security practices and procedures.
No method of transmission or electronic storage is completely secure. Accordingly, while we seek to use reasonable measures to protect Personal Data, we cannot guarantee absolute security.
17Getting in touch
We have designated a person responsible for addressing questions, concerns and grievances relating to this Privacy Policy and the processing of Personal Data.
If you have any questions, concerns, requests or grievances regarding this Privacy Policy or our processing of your Personal Data, you may contact us at:
- Entity
- AI Novem Labs LLP
- to be added
- Address
- T11-18B Fairway East, M3M Golf Estate Phase 2, Sector 65, Gurugram, Haryana, 12210 1
- Grievance Officer / DPO
- to be added
We will review and address grievances in accordance with Applicable Data Protection Laws and within the timelines prescribed under applicable law.
18Changes to this policy
From time to time, we may change and/or update this Privacy Policy to reflect changes in our Services, business practices, technology or Applicable Data Protection Laws.
If this Privacy Policy changes in any material way, we will post the updated version on the Website or through the Services and, where required by Applicable Data Protection Laws, provide an appropriate notice.
We recommend that you periodically review this Privacy Policy to remain informed about how we process and protect Personal Data.
Any changes to this Privacy Policy will become effective upon posting of the updated Policy, unless otherwise specified and your continued usage of our services will be considered as an acceptance of our updated website terms and policies.