Privacy Policy for PapaNoel.chat

1. Data we collect

1.1 Account data (adult)

When you create an account we collect:

• Your email
• Your user ID
• Account settings (PIN, preferences)
• Available minutes and related operations

1.2 Child profiles (created by adult)

The adult can enter:

• Child's name
• Age
• Likes, hobbies, achievements, behavior and Christmas wishes
• Additional information that the adult decides to include

We do not request or recommend including sensitive data (health, religion, etc.).

1.3 Usage data

We collect:

• Call history (date, duration, minutes used)
• Basic interactions within the App
• IP address, device model, operating system, error logs
• Aggregate performance and usage metrics

1.4 Video call data

We do not record or store the audio or video content of calls.

We only keep technical metadata, such as start, end, duration and call status.

If you record or share a video call from your device, that recording is yours and you are responsible for its storage and dissemination.

2. How we use your data

We use your data to:

• Manage the account and usage minutes
• Enable video calls with the Santa avatar
• Personalize the child's interaction according to their profile
• Send transactional notifications (for example, about minutes or account changes)
• Improve App performance and stability
• Prevent abuse and maintain security
• Comply with legal obligations

We never sell personal data.

We never use minor data for advertising.

3. Use of external artificial intelligence services

To generate the personalized video call experience, we use external artificial intelligence technology providers.

We share with these providers only the information strictly necessary to offer the functionality (for example, the child's profile configured by the adult and the context essential for the conversation).

These providers act as data processors in accordance with GDPR and are contractually obligated to:

• use the data only to provide the requested service,
• process it following our instructions,
• apply appropriate security measures,
• and not use it for their own commercial purposes.

4. Recording and sharing video calls

You can record or share a video call from your own device if you wish.

By doing so you accept that:

• The App does not access, process or store the recording.
• You are solely responsible for the use, editing and dissemination of that content.
• The avatar is generated by AI and does not represent a real person.
• We recommend not sharing sensitive information about the minor.

5. Minors and supervision

• Only an adult can create the account and child profiles.
• Use by minors must always be done under direct adult supervision.
• The adult can exercise all privacy rights on behalf of the minor.
• We do not offer interactions with other users or social functionalities.

6. Legal bases for processing

According to GDPR, we process personal data under these legal bases:

• Contract execution: provide the service (account, minutes, video calls).
• Explicit consent of the adult: processing of minor's data.
• Legitimate interest: security, fraud prevention, aggregate App improvements.
• Legal obligation: tax, accounting or regulatory requirements.

7. Data retention

• Account data: while the account remains active.
• Child profiles: until the adult deletes them or closes their account.
• Call history and usage: for the time necessary for service functionality and internal audit.
• Tax and billing data: according to applicable legal deadlines.

When you delete your account, we delete your data within a maximum of 30 days, except for legal obligation.

8. Who we share your data with

We share data only with essential providers who act as data processors, such as:

• Authentication and account management
• Database and storage
• Technology services for video calls and AI
• Payment processors (if applicable)
• Monitoring and analytics tools

All of them are subject to data protection agreements and comply with GDPR or equivalent guarantees.

9. International transfers

Some providers may be located outside the European Economic Area.

We only transfer data when appropriate safeguards are applied in accordance with GDPR, such as standard contractual clauses or additional security measures.

10. Security

We apply technical and organizational measures such as:

• Encryption in transit and at rest
• Internal access control
• Anomalous activity detection
• Secure backups
• Strict minimization of minor's data

We work continuously to improve security, although no digital service is 100% infallible.

11. Your rights

You can exercise at any time the rights of:

• Access
• Rectification
• Deletion
• Portability
• Limitation or opposition
• Withdrawal of consent for minor's data

To do so, contact us at: help@papanoel.chat help@papanoel.chat

If you are not satisfied, you can contact the Spanish Data Protection Agency (AEPD).

12. Changes to this policy

We will update this Policy when we incorporate improvements or new functionalities.

We will notify you of relevant changes through the App or by email.

13. Contact

If you have questions about privacy or data processing, you can contact us at:

Operator: Alfredo Artiles (Independent Developer)

Email: help@papanoel.chat

Location: Spain

14. Cookies and tracking technologies

We use cookies and similar technologies to improve your experience and analyze application usage.

14.1 What are cookies?

Cookies are small text files that are stored on your device when you visit a website. They help us remember your preferences and understand how you use the application.

14.2 Cookies we use

We currently use only analytics cookies to improve the application:

• Analytics cookies (PostHog): We use PostHog, an analytics tool hosted in the European Union, to collect aggregate information about how users interact with the application. This helps us identify technical problems, understand which functionalities are most used and improve the overall experience.

Data collected by PostHog: Usage events (such as clicks, navigation, errors), technical device information (browser type, operating system, screen resolution), and performance metrics. We do not collect personally identifiable information through these cookies, and all data is processed in aggregate and anonymous form.

14.3 Consent and control

In accordance with the General Data Protection Regulation (GDPR), we only load analytics cookies after obtaining your explicit consent. You can:

• Accept all cookies: You allow the use of analytics cookies to improve the application.
• Reject all cookies: We do not load analytics cookies. The application will work normally, but we will not collect usage data.

You can change your preference at any time by deleting cookies from your browser or contacting us at help@papanoel.chat.

14.4 Essential cookies

We do not use essential cookies that require consent. Session cookies necessary for authentication and basic application operation are managed automatically and do not require consent according to GDPR.

14.5 Analytics provider

We use PostHog as our analytics provider. PostHog is hosted in the European Union and complies with GDPR. You can learn more about their privacy policy at posthog.com/privacy.

Data collected by PostHog is used exclusively to improve PapaNoel.chat and is not shared with third parties for advertising purposes.