Last updated: 30 October 2026.
Controller: Techbuddie Solutions, Travessa D. Frei Diogo de Melo Pereira, 145, 4465-614 Matosinhos, Porto, Portugal, https://techbuddie.org.
Contact: info@techbuddie.org.
AI Girlfriend ("the app") lets adults talk by voice and text with an AI companion. You are talking to an AI, not a person. This policy explains what we collect, why, who processes it for us, how long we keep it, and your rights.
1. What we collect
| Data | Examples | Why | Legal basis (GDPR) |
|---|---|---|---|
| Device identifier | A random ID the app creates on first launch | To recognise your account without a sign-up | Contract (Art. 6(1)(b)) |
| Consent records | Time you confirmed you're 18+ and accepted the AI disclosure; app version; locale | To prove the age gate and disclosure happened | Legal obligation and legitimate interest (Art. 6(1)(c), (f)) |
| Voice recordings | Audio you record while holding the talk button. Streamed to our speech-to-text provider and never stored by us | To transcribe what you said | Contract; your consent to AI processing |
| Reply audio | The companion's spoken replies | So you can replay them | Contract |
| Conversation text | Transcripts, typed messages and the companion's replies | To generate replies and show your history | Contract; your consent to AI processing |
| Memories | Short notes the companion keeps about things you said (e.g. "has a dog named Biscuit") | So she remembers you; included in your data export | Contract; consent |
| Companion settings | Name, chosen look, personality, voice, your custom instructions | To build the companion you asked for | Contract |
| Generated images | Photos of your companion | To deliver the photos you request | Contract |
| Purchases | Subscription status, product, price, renewal date (from the App Store / Google Play via RevenueCat) | To give you the credits you paid for | Contract |
| Country and language | From your device settings | Language, local crisis resources, regional prices | Legitimate interest |
| Usage and cost events | That a turn happened, its provider cost, language and avatar expression; never its content | To run the service and keep it affordable | Legitimate interest |
| Crash reports | Error type and stack trace, without request bodies, headers or conversation content | To fix bugs | Legitimate interest |
| Push token | Firebase Cloud Messaging token, only if you turn on daily check-ins | To send the one daily check-in you opted into | Consent |
We do not collect your name, email, contacts, location, photos from your device, or advertising identifiers. You can't upload a face. We don't sell personal data or use it for advertising.
Before your first conversation the app asks you to agree that your voice and text are processed by the AI providers below.
2. Who processes your data for us
Each provider processes data only to provide its service to us, under its data processing terms.
| Provider | What it does | Data it receives | Location |
|---|---|---|---|
| Deepgram | Speech-to-text | Voice recordings | USA |
| Google (Gemini API / Vertex AI) | Generates replies, memory notes and summaries; image generation and image safety checks | Conversation text, memories, companion settings (not your instructions in image prompts), generated images | USA / global |
| ElevenLabs (or Cartesia as a fallback) | Text-to-speech | The companion's reply text | USA |
| OpenAI (only if we switch image models) | Image generation | Image prompts built from your chosen look; never your messages | USA |
| Cloudflare R2 | Storage of reply audio and images | Reply audio clips, generated images | USA (western North America) |
| RevenueCat | Subscription management | Device user ID, purchase receipts | USA |
| Apple / Google | Payments, push notifications | As covered by their own policies | — |
| Sentry | Crash reporting | Error details, no conversation content | USA |
| PostHog | Product analytics | User ID and event metadata, no conversation content | USA |
| PrivateSystems Networks | Hosts our API server and database | All of the above at rest | USA |
We are based in Portugal and our providers process data in the USA. Transfers outside the EEA rely on the EU-US Data Privacy Framework where the provider is certified, otherwise on Standard Contractual Clauses.
3. How long we keep it
- Your voice recordings: not stored; they are only streamed for transcription.
- The companion's reply audio: deleted after 30 days.
- Transcripts, memories, companion settings and images: kept while your account exists. You can ask us by email to delete specific memories or photos sooner.
- When you delete your account, everything above is deleted immediately, and in any case within 72 hours. Purchase records needed for tax or accounting are kept as the law requires.
- Analytics events: up to 12 months. Crash reports: up to 90 days.
4. Your rights
You can, in the app's Settings:
- Access / portability: export all your data as a file.
- Erasure: delete your account and all its data. Without the app, see https://techbuddie.org/ai-girlfriend-delete-account/.
- Rectification: change your companion's settings and instructions at any time. To correct or delete specific memories, email us.
- Withdraw consent: stop using the app and delete your account; turn off notifications at any time.
You can also object to processing based on legitimate interest, or ask for restriction, by emailing info@techbuddie.org. You can complain to the Portuguese data protection authority (CNPD, www.cnpd.pt) or the authority where you live.
5. Age
The app is for adults 18 and over only. We ask you to confirm your age before you start. If we learn that a user is under 18, we delete the account.
6. Safety and moderation
Messages are checked automatically for harmful content. If you mention self-harm, the companion steps out of character and points you to local help. Reports you send about messages or images are kept with the reported item so we can review them.
7. Changes
We'll update this page and the date at the top when anything changes, and tell you in the app if a change is significant.