PRIVACY POLICY FOR ACCOUNTABLE AI

1. The Information We Collect

To provide our service, we collect the following categories of information:

2. How We Use Your Information

Your information is used for the following specific purposes:

• To Provide Core Services: To create and manage your account, track your goals, block selected apps using Apple's Screen Time API upon deadline failure, and process your proof submissions.
• To Verify Proof with AI: We send your proof (images, text) and its associated metadata to Google's Gemini AI for automated analysis to determine if the goal was completed.
• For Security and Fraud Prevention: We use photo metadata to detect and prevent submission of fraudulent, edited, or old proof. This is a legitimate interest to maintain the integrity of our accountability system.
• To Communicate With You: We use your push notification token to send you important updates about your goals, such as deadline reminders and verification results.
• To Process Subscriptions: We use RevenueCat to manage subscriptions and payments. We do not store your payment card information.

3. Automated Decision-Making (AI Verification)

Our service uses an automated process (AI analysis) to decide whether your proof of completion is valid. This decision has a direct effect on you, as it determines whether your selected apps are blocked.

Under GDPR Article 22, you have specific rights regarding this process:

• The Right to Human Intervention: You can request that a human review the AI's decision.
• The Right to Express Your Point of View: You have the right to provide feedback and context regarding your proof submission.
• The Right to Contest the Decision: If you believe the AI's decision was incorrect, you have the right to appeal it.

To exercise these rights, please contact us at privacy@accountableai.xyz. All AI decisions and reasons are available for your review within the app.

4. How We Share Your Information

We do not sell your personal data. We only share it with trusted third-party services that are essential to providing our app's functionality:

• Supabase: Our backend provider for secure database, storage, and authentication. All data is encrypted at rest and in transit.
• Google Gemini: Our AI provider for automated proof verification. Proof content and metadata are sent for analysis. Google does not use this data to train its models.
• RevenueCat: Our subscription and payment processing partner.
• Apple: We use Apple's services for push notifications and the on-device Screen Time API for app blocking.

5. Data Retention and Deletion

We believe in data minimization and only store your data for as long as necessary.

• Proof Content (Photos): Automatically and permanently deleted from our systems 30 days after submission.
• Proof Metadata: Anonymized or deleted after 30 days.
• Goal and Account Data: Retained as long as your account is active.
• Account Deletion: When you delete your account, all your personal data (account info, goals, etc.) is permanently deleted from our systems within 30 days.

6. Your Privacy Rights

You have control over your personal data. Depending on your location, you may have the following rights:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can correct any inaccurate data we have about you.
• Right to Erasure (Deletion): You can request that we delete your account and all associated data.
• Right to Restrict Processing: You can request that we limit the processing of your data under certain conditions.
• Right to Data Portability: You can request a copy of your data in a machine-readable format.
• Right to Object: You can object to our processing of your data for our legitimate interests.

To exercise any of these rights, please contact us at privacy@accountableai.xyz.

7. International Data Transfers

Our services operate globally, and your data may be transferred to and processed in countries outside of your own, including the United States. We ensure that all data transfers comply with legal requirements and are protected by appropriate safeguards, such as Standard Contractual Clauses for transfers from the EU/UK.

8. Children's Privacy

Our service is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have, we will take steps to delete such information promptly.

9. Changes to This Privacy Policy

We may update this policy from time to time. If we make material changes, we will notify you through the app or by email at least 30 days before the changes take effect.