PRIVACY POLICY
RealAssistant
RealAssistant is operated by Neurotechnology Korlátolt Felelősségű Társaság, operating under the short name Neurotechnology Kft. (“RealAssistant,” “we,” “us,” or “our”).
This Privacy Policy explains how we collect, use, disclose, store, and protect information when you use the RealAssistant mobile application, our website, and related services (collectively, the “Service”).
1. Data Controller
Neurotechnology Kft. is the data controller responsible for the processing described in this Privacy Policy.
Legal name: Neurotechnology Korlátolt Felelősségű Társaság
Short name: Neurotechnology Kft.
Date of formation: May 3, 2023
Registered address: 1076 Budapest, Alpár utca 9. 2. em. 4. ajtó, Hungary
Company registration number: 01-09-415578
Tax number: 32275245-2-42
Email: artyom.mihailovich@gmail.com
Phone: +66 63 880 9158
2. Information We Collect
2.1 Videos, Audio, and Other User Content
Depending on the features you choose, the Service may process the following content:
- Videos selected from your photo library.
- Videos recorded using your device camera.
- Audio recorded using your device microphone.
- Audio extracted from your videos.
- Background music and other media that you choose to add.
- Descriptions, prompts, source and target languages, voice selections, and other processing settings.
- Generated translations, voice tracks, subtitles, enhanced video, and exported results.
Content is uploaded to our servers only when you initiate a feature that requires server-side processing. Some editing and storage operations may occur locally on your device. You are responsible for ensuring that you have all rights and permissions required to upload and process the content.
2.2 Device and Technical Information
- A pseudonymous app user identifier.
- Device platform, operating system version, app version, and device language.
- Push notification token, if you enable notifications.
- Processing task identifiers, task status, and timestamps.
- IP address and basic server request information.
- Error reports, diagnostics, and limited technical logs.
We do not intentionally use the pseudonymous app user identifier as an advertising identifier or combine it with your direct identity for advertising purposes.
2.3 Purchase Information
RealAssistant offers one-time consumable packages of video-processing minutes. We may receive and process:
- Product identifiers and purchase history.
- Apple transaction or receipt information used to validate a purchase.
- The number of minutes granted, consumed, and remaining.
- Purchase status, restoration or reconciliation status, and related timestamps.
- The pseudonymous app user identifier associated with the purchase balance.
Apple processes your payment details. We do not receive or store your full payment card number.
2.4 Device Permissions
- Camera: to record video inside the app.
- Microphone: to record speech and audio for a video.
- Photo Library: to select videos for editing or processing and, where you choose, to save exported results.
- Notifications: to tell you when a background processing task is complete, fails, or requires attention.
You can manage these permissions in your device settings. Disabling a permission may prevent the related feature from working.
3. How We Collect Information
- Directly from you when you select, record, upload, edit, or export content.
- Automatically from the app and our servers when you use the Service.
- From Apple in connection with in-app purchases and transaction validation.
- From RevenueCat in connection with purchase status, purchase reconciliation, and minute balances.
We do not access unrelated items in your photo library. The app processes only the content that you select or create for use with the Service.
4. How We Use Information
- Translate speech and generate AI voice tracks.
- Process, edit, enhance, and export video and audio.
- Continue eligible processing tasks in the background.
- Send status notifications about tasks you initiated.
- Validate purchases, grant purchased minutes, calculate usage, and prevent duplicate credit.
- Prevent fraud, abuse, and unauthorized access.
- Diagnose errors, maintain security, and improve reliability.
- Respond to support, privacy, and legal requests.
- Comply with applicable law and enforce our Terms and Conditions.
We do not use your videos, audio, or generated content for advertising. We do not use your content to train general-purpose artificial intelligence models unless we first obtain your explicit permission.
5. Legal Bases for Processing
Where the General Data Protection Regulation or similar law applies, we rely on one or more of the following legal bases:
- Performance of a contract: to provide the features you request and administer purchased minutes.
- Consent: for optional device permissions, notifications, or other processing where consent is required.
- Legitimate interests: to secure, maintain, troubleshoot, and improve the Service, provided those interests are not overridden by your rights.
- Legal obligation: to comply with tax, accounting, consumer protection, law enforcement, or other legal requirements.
Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect processing that occurred before withdrawal.
6. How We Share Information
We share information only as necessary to operate the Service, complete purchases, protect users, and comply with law.
6.1 Apple
Apple processes App Store payments and provides transaction information needed to validate purchases and respond to purchase-related issues.
6.2 RevenueCat
We use RevenueCat to:
- Validate and reconcile in-app purchases.
- Prevent duplicate purchase credit.
- Maintain purchase status and purchased-minute information.
- Support limited purchase analytics and troubleshooting.
RevenueCat processes information under its own privacy policy, available at https://www.revenuecat.com/privacy-policy.
6.3 Hosting, Processing, and AI Service Providers
We may use hosting, storage, speech recognition, translation, text-to-speech, media processing, and AI service providers. Depending on the feature, these providers may process:
- Videos, audio, and generated media.
- Text, prompts, translations, and processing settings.
- Task identifiers and limited technical information.
We require service providers to protect information and use it only to provide services to us, subject to applicable contractual and legal requirements.
6.4 Legal, Safety, and Business Disclosures
We may disclose information when reasonably necessary to:
- Comply with law, legal process, or a valid government request.
- Enforce our Terms and Conditions.
- Detect, prevent, or investigate fraud, abuse, or security incidents.
- Protect the rights, property, or safety of users, the public, or the company.
If the company is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction subject to appropriate safeguards.
7. Data Retention
- Source video and audio uploaded for processing: retained for no longer than 7 days after processing, unless a shorter period is operationally possible or longer retention is required to resolve a user-requested issue.
- Generated media and processing results stored on our servers: retained for no longer than 7 days.
- Task metadata and server logs: retained for no longer than 30 days, except where longer retention is necessary for security, fraud prevention, dispute resolution, or legal compliance.
- Push notification tokens: retained only while needed to deliver requested notifications or until they become invalid or you disable notifications.
- Pseudonymous identifiers, purchase records, and minute balances: retained as needed to provide the Service, prevent duplicate purchase credit, resolve disputes, and meet legal, accounting, and tax obligations.
Projects or exported media stored locally remain on your device until you delete them, delete the app, or the operating system removes them. Apple and RevenueCat may retain purchase information under their own policies and legal obligations.
8. Data Deletion and Privacy Requests
To request access, correction, deletion, restriction, or portability, email artyom.mihailovich@gmail.com with the subject “RealAssistant Privacy Request.”
Because the Service may use a pseudonymous identifier rather than a traditional account, we may ask you to provide the identifier shown in the app or other information reasonably necessary to verify and locate your data.
We may retain information that we are legally required or permitted to keep, including:
- Transaction, accounting, and tax records.
- Security, fraud-prevention, and dispute records.
- Information needed to establish, exercise, or defend legal claims.
Deleting data from RealAssistant does not delete records controlled independently by Apple or RevenueCat. You may also remove local projects and change permissions through the app and your device settings.
9. International Data Transfers
Our service providers may process information in countries other than the country where you live. Where required, we use appropriate safeguards for international transfers, such as adequacy decisions, standard contractual clauses, or other lawful mechanisms.
10. Data Security
We use reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure. No system is completely secure, and we cannot guarantee absolute security.
11. Children
The Service is not directed to children under 13, or a higher minimum age where required by local law. We do not knowingly collect personal data from children below the applicable age. If you believe a child has provided personal data, contact us so we can investigate and delete it where required.
12. No Sale or Advertising Tracking
We do not sell your personal data. We do not use your videos, audio, or generated content for cross-context behavioral advertising, and we do not use the Service to track you across third-party apps or websites for advertising.
13. Your Privacy Rights
Depending on your location, you may have the right to:
- Access personal data we hold about you.
- Correct inaccurate or incomplete data.
- Request deletion of data.
- Restrict or object to certain processing.
- Withdraw consent where processing is based on consent.
- Receive certain data in a portable format.
- Lodge a complaint with a competent data protection authority.
Users in the European Economic Area may contact their local supervisory authority. You may submit a request to artyom.mihailovich@gmail.com.
14. Automated Decision-Making
The Service uses automated technologies to translate, generate speech, and process media. These features do not make legal or similarly significant decisions about you.
15. Third-Party Links and Services
The Service may link to or interact with third-party services. Their privacy practices are governed by their own policies, and we encourage you to review them.
16. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in the Service, law, or our practices. We will update the effective date and provide additional notice where required.
17. Contact Us
For privacy questions, requests, or complaints, contact:
Legal name: Neurotechnology Korlátolt Felelősségű Társaság
Short name: Neurotechnology Kft.
Registered address: 1076 Budapest, Alpár utca 9. 2. em. 4. ajtó, Hungary
Company registration number: 01-09-415578
Tax number: 32275245-2-42
Email: artyom.mihailovich@gmail.com
Phone: +66 63 880 9158