Developer:Naiara AI SL
Contact email: info@naiara.com
NAIARA AI is committed to respecting the privacy of users and protecting and securing their personal data. Therefore, we inform you about how personal data provided through our Application is collected, processed, and protected. As a User, you should carefully read this privacy policy, which is written in a clear and simple manner, and freely and voluntarily determine whether you wish to provide your personal data to NAIARA AI. NAIARA AI complies with the data protection regulations of the countries in which it operates or provides its services, mainly Spain, EU/EEA countries, the United Kingdom, the United States, Brazil, Argentina, Colombia, Mexico, and Chile. There may be specific amendments by jurisdiction; in the event of a conflict, the specific amendment will prevail. IF YOU RESIDE IN A U.S. STATE WITH COMPREHENSIVE PRIVACY LAWS (CCPA, VCDPA, CPA, TDPSA, CTDPA, AND OTHERS), PLEASE REFER TO SECTION 6 OF THIS POLICY.
Data processing is carried out by NAIARA AI, S.L. (hereinafter, "NAIARA AI"), with Tax ID number B70751045 and registered address at C/ Historiador Joan Mari Cardona 6, Esc. 2, Pl. 0, Pta. D, 07800 Eivissa (Balearic Islands), Spain. For any questions regarding this privacy policy, you can contact us or our Data Protection Officer by email at: info@naiara.com.
a) Account details
Email address and/or phone number, user ID, authentication data (Google, Apple), date of birth for age verification, and IP address for service personalization. We use your account information to communicate with you, resolve issues, and provide updates. This processing is necessary to fulfill our contractual obligations.
NAIARA AI stores the content of your conversations with virtual assistants, including text, transcribed voice, images, and documents you share. These conversations are shared with the AI model providers that power the assistants (currently Google via Gemini API and OpenAI via ChatGPT API) to generate responses. Your account data (email, username) is NOT shared with these providers. We recommend that you do not provide confidential personal information (bank details, passwords, social security numbers) to the assistants.
The Application allows voice input. Voice data is processed for real-time transcription. NAIARA AI does not store voice recordings permanently, unless you expressly consent otherwise.
When you make purchases through NAIARA AI's affiliate links, we may receive information about the transaction (amount, product category, purchase confirmation) from third-party providers in order to improve recommendations, calculate affiliate commissions, and assign reward tokens. NAIARA AI does NOT have access to your payment details (credit card, bank details), which are managed directly by the third-party provider or app store.
When you use the Application, we automatically collect: device information (type, operating system, version, screen), connection information (IP, operator, network type, timestamp, and session duration), essential cookies, in-app events (login, opening assistants, sending messages), and application information.
NAIARA AI collects the preferences you share with assistants (travel preferences, fashion style, budget, favorite brands, etc.) to personalize future recommendations. This data can be viewed and deleted from the "Profile" section of the Application.
We collect information when you interact with ads or promotions in the Application: IP address, advertising ID, and ad interaction information. We may share your encrypted email address with advertising platform partners for our advertising activities. If necessary, we will obtain your consent before initiating this processing.
If you upload images containing human faces to the Application, NAIARA AI will not use such data for identification, authentication, or facial recognition. Facial data is processed solely to generate the requested response; no separate databases are maintained, and no data is sold to third parties.
If you contact us via info@naiara.com, we will process the data you voluntarily provide in order to respond to your request.
3.1. Registration and management of your personal account. Legal basis: Art. 6(1)(b) of the GDPR (contractual performance). Retention: until you cancel your account. 3.2. Provision of the service: to allow you to interact with virtual assistants, manage purchases within the app, and ensure proper functioning. Legal basis: Art. 6(1)(b) of the GDPR. 3.3. Improvement of the Application: processing of pseudonymized or anonymized data to improve assistants and optimize your experience. Legal basis: Art. 6(1)(f) of the GDPR (legitimate interest). 3.4. Contextual analysis of conversations: NAIARA AI may analyze the content of conversations to identify interests, needs, or relevant topics in order to display recommendations, content, or contextual advertising within the Application, including products or services from third-party partners (such as Amazon, Expedia, Booking, and others). The aim is to improve the user experience and display relevant commercial information. Legal basis: Art. 6(1)(f) of the GDPR (legitimate interest). Retention: time necessary to fulfill this purpose. 3.5. Commercial intermediation and personalized recommendations for third-party products and services. Legal basis: Art. 6(1)(a) and Art. 6(1)(b) of the GDPR. 3.6. Marketing and commercial communications about our services. Legal basis: Art. 6(1)(a) of the GDPR (consent). You can object at any time. 3.7. Management of contests and promotions. Legal basis: Art. 6(1)(a) of the GDPR (express consent). 3.8. Legal compliance, protection of rights, and fraud prevention. Legal basis: Art. 6(1)(c) and Art. 6(1)(f) of the GDPR. Your consent to the use of your personal data is always revocable, without retroactive effect. To revoke consent: info@naiara.com.
4.1. NAIARA AI retains conversations for: (a) service provision and improvement; (b) training and optimization of AI models; (c) generation of anonymized data for market analysis and monetization. Legal basis for (c): Art. 6(1)(a) of the GDPR (explicit and separate consent). 4.2. Before any sharing or sale of data to third parties, NAIARA AI applies a rigorous anonymization process in accordance with the AEPD Guidelines and Opinion 05/2014 of the Article 29 Working Party, including the removal of direct and indirect identifiers, k-anonymity techniques, l-diversity and/or differential privacy, and periodic assessment of the risk of re-identification. 4.3. NAIARA AI may share or sell completely anonymized and aggregated data to third parties for the purposes of market analysis, consumer trends, statistical reports, and research. As this data is genuinely anonymized, it falls outside the scope of the GDPR. 4.4. Contributing to the generation of anonymized data for monetization requires specific, informed, free, and unambiguous consent, given separately through an active opt-in mechanism (no pre-checked boxes). This consent is revocable at any time from the "Privacy and Data" section of the Application or by contacting us, without affecting the provision of the basic service. 4.5. Anonymized data may be shared with: market research companies, advertising and marketing agencies, strategic consulting firms, academic and research institutions, and other business partners. NAIARA AI will not share personally identifiable data with third parties for monetization purposes under any circumstances. 4.6. NAIARA AI has conducted and maintains an up-to-date Data Protection Impact Assessment (in accordance with Article 35 of the GDPR). The summary is available upon request. 4.7. NAIARA AI may use data, after dissociating it, to prepare statistical studies with the aim of improving the functionality of the Application.
Your personal data may be processed by third parties contracted by NAIARA AI, solely for the purposes described and following precise instructions, with data processing agreements (Art. 28 of the GDPR):
Personal data is hosted on Amazon Web Services servers within the European Economic Area whenever possible. For transfers outside the EEA (United States and India), Standard Contractual Clauses (Art. 46 of the GDPR) are used and, where applicable, the EU-US Data Privacy Framework (DPF). Your data may also be disclosed to comply with legal obligations and/or requests from competent authorities, or in the event of a merger, acquisition, or sale of assets (with prior notification).
6.1. Europe (EU/EEA) You have the right to: access, rectification, erasure, restriction of processing, portability, objection, withdrawal of consent, and to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es). Specific right to opt out of monetization: revocable from "Privacy and Data" without affecting the service. Response time: one month. 6.2. California (USA) – CCPA/CPRA Right to: know the categories of information collected, its sources and purpose; know if your information has been sold or disclosed; object to the sale of your personal information; access and delete your information; rectify inaccuracies; limit the use of sensitive data; equal service and price. NAIARA AI recognizes and will respect Universal Opt-Out Mechanisms (UOOM) signals, including Global Privacy Control (GPC). Link "Do Not Sell or Share My Personal Information" visible in the Application. NAIARA AI does not sell personal information. Response time: 45 days. 6.3. Brazil – LGPD Right to: confirm processing, access, rectify, request anonymization/blocking/deletion, portability, deletion, information about sharing, information about the consequences of refusing consent, and revoke consent. Competent authorities: ANPD and PROCON. 6.4. Colombia, Argentina, Mexico, and Chile Right of access, rectification, and deletion in accordance with applicable local legislation (Law 25.326 Argentina, LFPDPPP Mexico, Law 1581 Colombia, Law 19.628 Chile). 6.5. United Kingdom Same rights as European citizens under the UK GDPR and the Data Protection Act 2018. Competent authority: Information Commissioner's Office (ICO). 6.6. India – DPDP Act Verifiable consent, withdrawal of consent, notification of breaches within 72 hours, encryption. To exercise your rights, send an email to info@naiara.com indicating: your first and last names, contact email address, the right you wish to exercise, and the data to which your request relates.
The data is kept for as long as the account is active and for as long as necessary to comply with our legal obligations. After deletion, the data is blocked and cannot be accessed, remaining available only at the request of the competent authorities (law enforcement agencies, judges, and courts) during the limitation period for any actions that may arise. Once this period has elapsed, the data is completely deleted.
NAIARA AI implements appropriate technical and organizational measures in accordance with Article 32 of the GDPR: encryption of data in transit and at rest, role-based access controls, regular security audits, and incident response plans. In the event of a security breach: notification to the AEPD within 72 hours (Article 33 of the GDPR) and communication to the user without undue delay when there is a high risk (Article 34 of the GDPR). However, no security measure on the Internet is impregnable.
As a user, you must be at least 14 years old if you reside in Europe, and at least 13 years old if you reside in Latin America, the US, or the UK. If you do not have full legal capacity to consent, your parents or legal guardians must accept these Terms on your behalf. NAIARA AI does not intentionally collect data from minors under the applicable minimum age. If we detect data from a minor without parental consent, we will proceed to delete it immediately. If you believe we have collected data from a minor, please contact us immediately at info@naiara.com.
The Application uses essential cookies that are strictly necessary for its operation. For non-essential cookies (analytics, advertising), prior consent will be requested in accordance with the LSSI-CE and the ePrivacy Directive. You can manage your cookie preferences from the Application's "Privacy Settings."
In accordance with Article 22 of the GDPR, virtual assistants use artificial intelligence systems to generate personalized recommendations based on your preferences, interaction history, and profile data. You have the right to: obtain meaningful information about the logic applied, express your point of view, challenge the decision, and request human intervention. NAIARA AI does not make solely automated decisions that produce legal effects or significantly affect the user without consent.
NAIARA AI reserves the right to modify this Privacy Policy by publishing the updated version in the Application and on our website. For substantial changes that affect data monetization or introduce new categories of processing, renewed consent will be requested from the user. We suggest you review this Policy periodically. Simplified summary Your privacy matters: We respect your privacy and protect your personal data. Why we collect data: To manage your account, provide virtual assistance, improve our assistants, and show you relevant recommendations. Security: We comply with the GDPR and the LOPDGDD (Spanish Data Protection Law) and use encryption and advanced security measures. Your control: You can access, correct, delete, or export your data at any time. You can revoke your consent to monetization without affecting the service. Who sees your data: Only necessary contracted providers. Your personal data is never sold. Contact: info@naiara.com © NAIARA AI, S.L. CIF B70751045. All rights reserved.
