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:

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

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:

Apple processes your payment details. We do not receive or store your full payment card number.

2.4 Device Permissions

You can manage these permissions in your device settings. Disabling a permission may prevent the related feature from working.

3. How We Collect Information

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

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:

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:

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:

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:

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

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:

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:

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