Effective date: April 27, 2026 Replyca is operated by Visaneer LLC ("Visaneer", "Replyca", "we", "us"). Visaneer LLC 3422 Old Capitol Trl, STE 4026 Wilmington, DE 19808-6124 United States Contact: support@replyca.ai 1. Scope This Privacy Policy explains how we collect, use, store, disclose, and protect personal data when you use Replyca, including our website, Telegram bots, creator onboarding, AI clone features, payments, subscriptions, and related services. Replyca is intended for users who are at least 18 years old. Do not use Replyca if you are under 18. 2. Personal data we collect We may collect and process the following categories of data: - Telegram identifiers and profile data: Telegram user ID, username, display name, bot IDs, bot usernames, and chat metadata needed to operate the service. - Messages and conversations: messages sent to platform bots, creator bots, AI clones, onboarding flows, moderation queues, support conversations, and related conversation history. - Creator content: posts, channel exports, documents, links, videos, transcripts, interviews, style examples, prompt settings, pricing settings, uploaded materials, and other content provided by creators to configure an AI clone. - Voice and audio data: voice messages, audio or video content, transcripts, and voice-related settings if a voice feature is enabled. - Payment and subscription data: purchase amount, package or subscription type, payment status, transaction identifiers, payout data, refunds, chargebacks, commissions, and provider metadata. We do not store full card numbers. - Account and operational data: account status, plan settings, usage counters, logs, diagnostics, security events, abuse reports, moderation decisions, and support requests. - Technical data: IP address, user agent, timestamps, request metadata, device/browser information, and server logs needed for security, debugging, fraud prevention, and service reliability. We do not currently use cookies or website analytics tools. 3. How we use personal data We use personal data to: - provide, maintain, and improve Replyca; - create, configure, and operate AI clones and Telegram bots; - generate, validate, moderate, and deliver AI responses; - personalize AI responses based on creator-approved content and settings; - process payments, subscriptions, refunds, commissions, and creator payouts; - enforce age restrictions, usage limits, safety rules, and legal terms; - detect abuse, fraud, security incidents, and policy violations; - provide support and respond to data requests; - comply with accounting, tax, legal, and regulatory obligations. 4. Legal bases Depending on your location and how you use Replyca, we process personal data on one or more of the following legal bases: - performance of a contract, where processing is needed to provide Replyca; - legitimate interests, including service security, fraud prevention, product improvement, moderation, and support; - consent, where required for optional features or communications; - legal obligation, where processing is needed for accounting, tax, compliance, dispute, or law enforcement requirements. 5. AI processing and automated features Replyca uses AI systems to generate and validate responses. AI output may be inaccurate, incomplete, delayed, or inappropriate. Creators are responsible for the content, settings, source materials, and commercial use of their AI clones. We may process messages, creator content, and conversation context through third-party provider categories such as AI generation providers, AI validation providers, transcription providers, voice feature providers, payment processors, messaging platforms, hosting providers, infrastructure providers, and email/support providers. 6. Third-party provider categories We may share personal data with provider categories that help us operate Replyca, including: - messaging platforms and bot APIs; - AI model, generation, validation, transcription, and voice feature providers; - payment processors, subscription providers, payout providers, and fraud-prevention providers; - cloud hosting, database, infrastructure, monitoring, logging, and security providers; - email, support, legal, accounting, and compliance service providers. These providers may process data in countries other than your country of residence. We use them only as needed to provide the service, protect the service, process payments, or comply with legal obligations. 7. Hosting and international transfers Replyca infrastructure is currently hosted in Germany on Hetzner infrastructure. Visaneer LLC is a United States company and Replyca is available worldwide. This means personal data may be processed in Germany, the United States, Cyprus, and other countries where our provider categories operate. Where required, we use appropriate safeguards for international transfers, such as contractual protections and provider data-processing terms. 8. Retention We keep personal data only for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required by law. As a general rule: - account, creator, bot, content, and conversation data are kept until the account is deleted or a deletion request is completed, unless we need to retain limited records for legal, security, abuse-prevention, or dispute purposes; - payment, payout, accounting, tax, refund, and chargeback records may be kept for 5-7 years or longer where required by law; - server logs and security records are kept for a limited period needed for security, debugging, fraud prevention, and service reliability; - backups may retain deleted data for a limited time until backup rotation removes it. 9. Your rights Depending on where you live, you may have rights to access, correct, delete, restrict, object to, or receive a copy of your personal data. You may also have the right to withdraw consent where processing is based on consent. To make a request, email support@replyca.ai. We may need to verify your identity before acting on a request. We will respond within the time required by applicable law. 10. Deletion requests You can request deletion of your account and personal data by emailing support@replyca.ai. Deletion may not remove records that we must keep for legal, accounting, tax, security, fraud-prevention, chargeback, or dispute-resolution purposes. Where full deletion is not possible, we will limit retained data to what is necessary. 11. Security We use technical and organizational measures designed to protect personal data, including access controls, encryption for selected secrets, limited access to production systems, and operational monitoring. No system is perfectly secure, and we cannot guarantee absolute security. 12. Children Replyca is only for users who are 18 or older. We do not knowingly collect data from children or permit children to use Replyca. 13. Changes to this Policy We may update this Privacy Policy from time to time. If we make material changes, we will update the effective date and may provide notice through the website, bot, email, or other reasonable means. 14. Contact For privacy questions, data requests, or deletion requests, contact: support@replyca.ai © 2025 Visaneer LLC. All rights reserved.