Privacy Policy

# COMPLETE PRIVACY POLICY
## PRIVACY POLICY – TALK TO GOD

This Privacy Policy describes how CENTRO DE EMISIÓN DE CONTENIDOS SL, Tax ID B63955678, with registered office at Diputació 188, mezzanine 116, ZIP 08015, Barcelona, Spain ("We"), collects, uses and protects the personal data of users ("You") of the Talk to God application and its associated website.

---

### 1. DATA CONTROLLER

**CENTRO DE EMISIÓN DE CONTENIDOS SL**  
Tax ID: B63955678  
Address: Diputació 188, mezzanine 116, ZIP 08015, Barcelona, Spain  
Contact: info@movilive.com

### 2. PURPOSE OF PROCESSING

Personal data is collected for the following purposes:
- Enable the technical operation of the application
- Personalize the user's spiritual experience
- Manage accounts, preferences and language
- Process in-app purchases and subscriptions
- Provide conversational memory (paid users only)
- Generate anonymous statistics to improve the service
- Comply with legal, tax and security obligations
- Prevent misuse and fraud

### 3. DATA COLLECTED

We may collect:

**Identification data:**
- Unique device identifier (deviceId)
- Username (optional)
- Date of birth and gender (optional)
- Email address (only if provided by the user)

**Usage data:**
- Selected language
- Country of connection
- Device type and operating system
- Application version
- Frequency and duration of use
- Conversation mode used (chat, audio, video)

**Conversation data (paid users only):**
- Text of conversations with the AI assistant
- Audio and video generated during use (processed in real time, not permanently stored)
- Conversation history from the last 60 days (encrypted)

**Advertising identifiers:**
- IDFA (Apple iOS)
- Advertising ID (Google Android)

**Payment data:**
- Subscription and purchase information
- Processed exclusively by Apple App Store and Google Play Store
- NEVER stored by CENTRO DE EMISIÓN DE CONTENIDOS SL

**Statistical data (anonymous and aggregated):**
- Number of active users by language
- Number of questions by mode
- Credit consumption by subscription type
- Technical errors and system performance

**Legal acceptance data:**
- Date and time of acceptance of Terms of Use
- Date and time of acceptance of Privacy Policy
- Specific version of each document accepted
- Language of presentation
- Platform used (iOS/Android)
- Application version at the time of acceptance
- Anonymized IP address (for audit purposes only)

**Legal basis:** Compliance with legal obligations (GDPR Art. 6.1.c)  
**Purpose:** Demonstrate explicit consent in accordance with GDPR  
**Retention:** Minimum 5 years from last interaction or account closure

### 4. LEGAL BASIS FOR PROCESSING

Processing is based on:
- Explicit user consent (acceptance of terms and policy)
- Contract execution (use of the application and contracted services)
- Compliance with legal obligations (tax, accounting, security)
- Legitimate interest in improving the service and preventing fraud

### 5. DATA RETENTION

**Account and subscription data:**
- While the account is active
- Up to 5 years after account closure (tax obligations)

**Conversations (paid users only):**
- Maximum 60 days from each conversation
- Automatic deletion after this period
- Immediate deletion if requested by the user

**Statistical data:**
- Indefinitely (completely anonymized)

**Payment data:**
- Managed by Apple/Google according to their policies

**Legal acceptance data:**
- Minimum 5 years from last interaction with the application
- Up to 10 years in case of active legal disputes
- In accordance with retention obligations established by:
  - Spanish Commercial Code (Art. 30)
  - General Data Protection Regulation (Art. 5.1.e)
  - Applicable tax and accounting regulations

This data is NOT deleted even if the user requests the "right to be forgotten", as its retention is covered by mandatory legal obligations (GDPR Art. 17.3.b).

### 6. USER RIGHTS

In accordance with GDPR, CCPA, LGPD and other applicable regulations, you may exercise the following rights:

- Access to your personal data
- Rectification of inaccurate or incomplete data
- Erasure of data (right to be forgotten)
- Restriction of processing
- Data portability (receive copy in structured format)
- Opposition to processing
- Withdrawal of consent at any time

To exercise these rights, send a request to: **info@movilive.com**

**Response times:**
- Conversation deletion: immediate (maximum 48 hours)
- Complete account deletion: up to 30 days
- Data portability: up to 30 days
- Other rights: up to 30 days

**Important note:** Data deletion does not imply refund of active subscriptions or recovery of unused credits.

### 7. DATA SECURITY

CENTRO DE EMISIÓN DE CONTENIDOS SL implements technical and organizational measures to protect your data:

**Technical measures:**
- AES-256 encryption for stored conversations
- TLS/SSL encryption in all data transmissions
- Secure servers on Google Cloud Platform with ISO 27001 certifications
- Restricted access controls
- Periodic security audits
- Encrypted backups

**Organizational measures:**
- Staff trained in data protection
- Internal confidentiality policies
- Incident response protocols
- Confidentiality agreements with suppliers

In the event of a security breach affecting personal data, we will notify the competent authorities and affected users in accordance with applicable legislation.

### 8. INTERNATIONAL TRANSFERS

Data may be processed on servers located inside and outside the European Union, specifically in:
- Google Cloud Platform servers (locations: EU and USA)
- OpenAI services (USA) for AI processing

Adequate protection guarantees are applied in accordance with:
- GDPR (European Union)
- Standard Contractual Clauses approved by the European Commission
- Privacy Shield Framework (when applicable)
- CCPA (California, USA)
- LGPD (Brazil)
- Local regulations of each country

### 9. COOKIES AND SIMILAR TECHNOLOGIES

The website and application may use cookies and similar technologies for:
- Usage analytics (Google Analytics, Firebase Analytics)
- Content and language personalization
- Contextual advertising (if applicable)
- Performance and technical optimization

**Types of cookies used:**
- Technical cookies (essential for operation)
- Analytical cookies (usage statistics)
- Preference cookies (language, settings)

The user can configure their device or browser to limit or block these technologies in Settings > Privacy.

### 10. SHARING DATA WITH THIRD PARTIES

We do NOT sell or share personal data with third parties for commercial purposes.

We may share data only with:

**Essential service providers:**
- Google Cloud Platform (hosting and database)
- OpenAI (AI processing)
- Apple and Google (payment processing)
- Analytics services (anonymized data)

**Legal obligations:**
- Judicial or administrative authorities when legally required
- Compliance with court orders or applicable regulations

All service providers are subject to confidentiality agreements and data protection obligations equivalent to those described in this Policy.

### 11. MINORS

The application is intended exclusively for persons over 18 years of age.

We do NOT knowingly collect data from minors.

If we detect that data from a minor has been provided, we will immediately delete it and suspend the account.

If you are a parent/guardian and believe your child has provided personal data, contact us at: info@movilive.com

### 12. GOOGLE PLAY AND APP STORE REQUIREMENTS

**Declaration of use of sensitive permissions:**
- Microphone: for voice conversation mode (optional)
- Camera: for interactive video mode (optional)
- Storage: to save local preferences

These permissions are requested at runtime and the user can deny them. The application works in limited mode without these permissions.

**Accessible policy:**

This Privacy Policy is available:
- Within the application (Menu > Privacy)
- In the application listing on Google Play Store and Apple App Store
- On the official website

### 13. COMPLIANCE WITH INTERNATIONAL REGULATIONS

**European Union (GDPR):**
- Right to be forgotten, portability, access, rectification
- Explicit and revocable consent
- International transfers with adequate guarantees

**United States (CCPA - California):**
- Right to know what data is collected
- Right to request deletion
- Right to opt out of data sales (we do not sell data)

**Brazil (LGPD):**
- Transparency in processing
- Specific consent
- Rights of access, rectification and deletion

**Mexico (Federal Law on Protection of Personal Data):**
- Clear privacy notice
- ARCO rights (Access, Rectification, Cancellation, Opposition)

**Other countries:**

The user is responsible for verifying compliance with local laws in their jurisdiction.

### 14. CHANGES TO THE POLICY

We reserve the right to modify this Privacy Policy at any time.

The updated version will be available in:
- The mobile application
- The official website
- Application stores (Google Play and App Store)

**Change notification:**
- Minor changes: publication in the app and website
- Substantial changes: email notification (if available) and/or in-app notification

Continued use of the application after publication of changes implies acceptance of the new Policy.

### 15. JURISDICTION AND APPLICABLE LAW

This Policy is governed by Spanish and European legislation.

In case of conflict or claim, the parties submit to:
- The courts of Barcelona, Spain
- The competent data protection authorities (Spanish Data Protection Agency - AEPD)

**Supervisory authority:**  
Spanish Data Protection Agency (AEPD)  
C/ Jorge Juan, 6, 28001 Madrid, Spain  
www.aepd.es

### 16. CONTACT AND EXERCISE OF RIGHTS

For any questions about this Privacy Policy or to exercise your data protection rights, you can contact us at:

📧 **Email:** info@movilive.com

📬 **Postal address:**  
CENTRO DE EMISIÓN DE CONTENIDOS SL  
Privacy Department  
Diputació 188, mezzanine 116  
08015 Barcelona, Spain

**Include in your request:**
- Full name
- Device identifier (if known)
- Description of the right you wish to exercise
- Copy of identity document (for verification)
- Email address for response

We will respond to your request within the maximum period established by applicable legislation (generally 30 days).

---

**Last updated:** November 2025  
**Version:** 2.0