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Privacy Policy

Last updated: 2 April 2026

1. Data Controller

MODERN LUXURY CARPETS SARL, 12 Rue de Strasbourg, L-2560 Luxembourg City, Luxembourg. RCS: B174835. VAT: LU25933881. For data protection inquiries, contact: [email protected].

2. Data We Collect

We collect the following categories of data:

Account data: Name, email address, region, authentication provider (Google, Apple, or email).

Conversation data: Messages exchanged with AI personas, including text and transcripts from voice interactions. Voice recordings are processed for transcription and immediately discarded — only transcripts are stored.

Wellness data (special category): Mood indicators, assessment results, and coaching context shared during sessions. This data is collected only with your separate explicit consent (see Section 4).

Usage data: Session timestamps, feature usage, and device information.

Payment data: Subscription tier and billing dates. Payment processing is handled by Stripe — we do not store credit card numbers or bank details.

3. How We Use Your Data

We use your data to: (a) provide and personalize the Selavi service; (b) maintain conversation context across sessions; (c) process payments; (d) improve the service through aggregated, anonymized analytics; (e) communicate with you about your account.

4. Legal Basis (GDPR)

Consent: Wellness and mood data (GDPR Article 9 special category). You provide separate explicit consent during onboarding. You may withdraw consent at any time.

Contract performance: Account data and conversation data, necessary to provide the service you signed up for.

Legitimate interest: Usage analytics, security monitoring, fraud prevention.

5. Third Parties

We share data with the following service providers:

Stripe (payments) — processes subscription payments under their own privacy policy.

LLM Provider (AI processing) — conversation content is sent to our AI provider for response generation. No permanent storage by the provider.

Hetzner (hosting) — EU-based infrastructure provider, GDPR compliant.

Cloudflare R2 (CDN) — media and asset delivery.

We do not sell your personal data to third parties.

6. International Transfers

AI processing may involve data transfers to the United States. These transfers are covered by the EU-US Data Privacy Framework and Standard Contractual Clauses where applicable.

7. Data Retention

Active accounts: Data retained while your account is active.

Paused accounts: Data retained indefinitely until you reactivate or delete your account.

Deleted accounts: 90-day soft-delete by default (recoverable), or immediate deletion by request. After the retention period, all data is permanently and irreversibly deleted.

8. Cookies

Selavi uses only essential cookies required for the service to function: session tokens, authentication state, and region preference. We do not use tracking cookies, advertising cookies, or third-party analytics cookies.

9. Your Rights (GDPR — EU Users)

If you reside in the EU, you have the right to: (a) access your personal data; (b) rectify inaccurate data; (c) erase your data ("right to be forgotten"); (d) port your data to another service; (e) restrict processing; (f) object to processing; (g) withdraw consent at any time.

You can exercise most of these rights directly through your account settings (data export, account deletion). For other requests, contact [email protected].

You also have the right to lodge a complaint with the Commission nationale pour la protection des données (CNPD), 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg. Website: https://cnpd.public.lu.

10. Your Rights (CCPA — US/California Users)

If you reside in California, you have the right to: (a) know what personal information we collect; (b) delete your personal information; (c) opt out of the sale of personal information (Selavi does not sell personal data); (d) non-discrimination for exercising your rights.

11. Children

Selavi does not knowingly collect personal data from children under 16 (EU) or under 13 (US). If you believe a child has provided data to Selavi, contact [email protected].

12. Data Export

You can download all your personal data at any time through Settings > Your Data > Download My Data. The export includes your profile, conversations, memory context, assessments, and billing history.

MODERN LUXURY CARPETS SARL · 12 Rue de Strasbourg, L-2560 Luxembourg City, Luxembourg · RCS B174835 · VAT LU25933881