Privacy Policy

1. Introduction

SMARTPATH AI LLC("we", "our", or "us"), a limited liability company registered in the State of Montana, United States, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use the SMARTPATH AI service at smartpathavatar.online ("the Service"). By using the Service, you acknowledge that you have read and understood this Policy.

2. Data Controller

The data controller responsible for your personal information is:

3. Data We Collect

We collect only the data strictly necessary to operate the Service:

4. How We Use Your Data

• —To provide and operate the Service (process AI avatar requests, enforce quotas)
• —To manage your account and authenticate your identity
• —To process and confirm purchases and deliver license access
• —To send transactional emails (purchase confirmations, account notices)
• —To detect, prevent, and investigate fraud, abuse, or unauthorized access
• —To comply with applicable legal and regulatory obligations

We do not sell, rent, trade, or otherwise share your personal data with third parties for advertising, marketing, or any commercial purpose unrelated to the Service.

5. Third-Party Service Providers

We engage the following sub-processors to operate the Service. Each provider operates under its own privacy policy and applicable data processing agreements:

We only share the minimum data necessary for each provider to fulfill their designated function.

6. Data Retention

We retain your account data and generated avatar outputs for as long as your account remains active. Input images (uploaded portraits) are stored for a maximum of 30 days following upload, after which they are automatically and permanently deleted from our storage systems. Subscription and transaction records are retained for 7 years for accounting and legal compliance purposes.

Upon account deletion, all personal data and associated files are permanently purged within 30 days, except where retention is required by applicable law.

7. Your Rights

Subject to applicable law, you have the following rights regarding your personal data:

• —Right of access — request a copy of the personal data we hold about you
• —Right to rectification — request correction of inaccurate or incomplete data
• —Right to erasure — request deletion of your personal data
• —Right to data portability — receive your data in a structured, machine-readable format
• —Right to object — object to processing based on legitimate interests
• —Right to withdraw consent — where processing is based on your consent

To exercise any of these rights, contact us at contact@smartpathavatar.online. We will respond within 30 days of receiving your request.

8. Security

SMARTPATH AI LLC implements industry-standard security measures to protect your data, including TLS/HTTPS encryption for all data in transit, row-level security (RLS) on all database tables, and private encrypted cloud storage for uploaded images that is inaccessible to other users. Despite these measures, no system can guarantee absolute security. We encourage you to use a strong, unique password and to notify us immediately of any suspected unauthorized access to your account.

9. Cookies

We use only strictly necessary session cookies for authentication purposes, managed by our authentication provider (Supabase). We do not use tracking, advertising, analytics, or third-party marketing cookies. No cookie consent banner is required as we do not deploy non-essential cookies.

10. International Data Transfers

Your data may be processed in data centers located in the United States and/or the European Union by our service providers. We ensure that appropriate contractual and technical safeguards are in place for any international transfers of personal data, in accordance with applicable privacy laws.

11. Children's Privacy

The Service is not directed to individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a minor has provided us with personal data, please contact us immediately and we will take steps to delete such information.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. When we make material changes, we will notify you by email or via a notice on the platform. The "Last updated" date at the top of this page reflects the most recent revision.

13. Contact

For any privacy-related inquiries or to exercise your rights, contact the data controller: