Privacy Policy

Last Updated: March 1, 2026

Privacy Policy of SIA Sigmatics

MyVirtual.Love (the “APP”) is owned and operated by SIA Sigmatics, registered at Ganību dambis 24D, Rīga, Latvia, LV-1050, duly incorporated in Latvia, having its address registered with the Latvian Business Registry under the number 40203671732.

MyVirtual.Love is an online chat application that uses artificial intelligence algorithms to generate virtual and fictional characters (the “AI Companions”). The APP also generates images and messages, allowing you to chat with the AI Companions. Some of the Services offered by the APP may require you to create a user account. For purposes of this Privacy Policy, “you” and “your” means you as the user of the APP.

GDPR

If you are a resident of the European Union, you are protected by and enjoy additional rights under the European Union’s General Data Protection Regulation 2016/679, also known as GDPR.

Definitions

As we are committed to respecting your privacy, such Services will always be provided with your consent. This document provides clear information on how your data is processed when you visit the Website and use our Services. The following definitions apply:

  • “Content” means the information that you provide to us for registration as a User and the information you upload on our Platform, including your Personal Data and discussions with the AI Companions.
  • “Consent” means any freely given, specific, informed, and unambiguous indication of your wishes by which you, by a statement or a clear affirmative action, signify agreement to the Processing of Personal Data relating to you.
  • “Performance of our Services” refers to the actions necessary for us to provide our Services.
  • “Personal Data” means any information relating to you as an identified person, directly or indirectly, such as your name, address, marital status, date of birth, gender, office location, position, company name, spoken languages, photos, your identification number, location data, or factors specific to your physical, physiological, genetic, mental, economic, cultural, or social identity, your networks, and connections made available to us, or obtained on your behalf, and any personal information you provide us with.
  • “Platform” refers to the APP.
  • “Processing” means any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction.
  • “Services” refers to all the steps for enabling you to chat with the AI Companions.
  • “Subscription” refers to an arrangement between SIA Sigmatics and you to enable you to benefit from and/or use the Services.
  • “User,” “you,” and “your” collectively mean a person or company that has visited or is using the APP and/or the Services.
  • “Visitor” refers to anyone who is browsing the Website without a valid Subscription.
  • “Website” refers to MyVirtual.Love.

Purpose of Personal Data Processing

When Visiting the Website

When you visit the Website, we will collect information for the following purposes:

  1. analyzing and understanding your behavior on the Website;
  2. performing our Services;
  3. making improvements to the Website and Services;
  4. enabling us to enhance, customize, or modify our communications;
  5. improving data security;
  6. determining whether marketing campaigns are effective.

When Registering and Using Our Services

After a free test of a few messages, you will be asked to register so we can identify you. At this stage, we receive and store any information you enter on the Website or provide us with in any other way. The types of Personal Data collected may include (but are not limited to) your name, date of birth, usage information regarding your use of our Services, and browser information.

The Personal Data you provide is used for purposes such as allowing you to set up a User account and profile that can be used to interact with the AI Companions. We may also draw upon this Personal Data to adapt the Services to your needs and to develop new tools.

When you use the Platform, we automatically receive and record information on our server logs from your browser or mobile, including your location, IP address, cookie information, and the page you requested. We treat this data as non-Personal Data, except where required otherwise under applicable law. We only use this data in aggregate form. We may provide this information to our partners to understand how our customers, collectively, use our site, so that our partners may also understand how often people use the Website and the Platform.

If you fail to provide your Personal Data, we may not be able to perform the Services pursuant to the Subscription. In this case, we may have to cancel the Service, provided that we will notify you if this is the case at the time.

You give your Consent to the Processing of your Personal Data for the following specific purposes: Processing is necessary for the performance of the Services pursuant to a Subscription. We Process your Personal Data because it is necessary:

  1. for the Performance of our Services;
  2. to provide you with a confirmation regarding the Subscription;
  3. to deal with any complaint or request you may have;
  4. for any other purpose for which you provide us with your Personal Data;
  5. for the administration and management of our business; and
  6. to perform marketing analysis and to conduct market research.

Lawful Basis for Processing

Under GDPR Article 6, we process your Personal Data on the following legal bases:

| Processing Purpose | Lawful Basis | GDPR Article | |--------------------|-------------|--------------| | Account creation and management | Performance of contract | Art. 6(1)(b) | | Providing AI Companion chat services | Performance of contract | Art. 6(1)(b) | | Processing chat content involving adult/sexual themes | Explicit consent | Art. 9(2)(a) | | Age verification | Legal obligation / Legitimate interest | Art. 6(1)(c) / Art. 6(1)(f) | | Content moderation and safety | Legal obligation / Legitimate interest | Art. 6(1)(c) / Art. 6(1)(f) | | Payment processing | Performance of contract | Art. 6(1)(b) | | Website analytics | Legitimate interest (with consent for cookies) | Art. 6(1)(f) | | Marketing communications | Consent | Art. 6(1)(a) | | Fraud prevention and security | Legitimate interest | Art. 6(1)(f) | | Compliance with legal requests | Legal obligation | Art. 6(1)(c) |

Where we rely on legitimate interest, we have conducted a balancing test to ensure your rights and freedoms are not overridden. You may request details of these assessments by contacting our Data Protection Officer.

Special Category Data

Our platform processes data that may relate to your sexual preferences and interactions with AI Companions. This constitutes special category data under GDPR Article 9 (data concerning sex life or sexual orientation).

We process this data on the basis of your explicit consent (Article 9(2)(a)), which you provide when you:

  • Accept these terms and create an account;
  • Complete age verification; and
  • Actively engage with adult content features.

You may withdraw this consent at any time by deleting your account through Settings > Delete Account, or by contacting support@myvirtual.love. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

We have conducted a Data Protection Impact Assessment (DPIA) in accordance with GDPR Article 35 for our processing of special category data, given the high-risk nature of this processing (automated processing of intimate/sexual data at scale).

Personal Data Collection

Personal Data Collection for Visitors

The Website can be visited anonymously. The Website may process anonymous metadata through cookies, such as the URL of the requested file, the amount of data transferred, the date and time of the request from the User, Internet browser information, operating system type, the IP address of the used device, the Internet service provider, and reference links such as user clicks on certain links. This metadata cannot be used by the Website to obtain personally identifiable information. This information is only used for general purposes, such as technical improvements, statistical and marketing analysis.

When you visit the Website, we may automatically receive some information that identifies, for each page accessed:

  1. the type of browser and operating system you have used;
  2. the IP (Internet Protocol) address of the device which has accessed it (e.g., PC, tablet);
  3. the date and time of your visit to the Website;
  4. the address of your server;
  5. the previous website visited;
  6. the average duration of page view;
  7. the navigation behavior and preferences of the user.

Personal Data Collection for Users

We use different methods to collect Personal Data from and about you, including through:

  1. Information you provide to us when you register for Subscription.
  2. Content you provide to us via your personal account on the Website.
  3. Communication with us in writing, by telephone, fax, website registration, email, or other forms of electronic communication. We may monitor, record, and store any such communication.
  4. Automated technologies or interactions. As you interact with the AI Companions, we may automatically collect technical data about your equipment, browsing actions, and patterns. Our moderation team checks that you comply with the law, and we collect this Personal Data using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
  5. Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources, as set out below, technical data from the following parties:
    1. Analytics providers such as Google Analytics.
    2. Advertising networks/agencies.
    3. Search information providers.

Personal Data Processing for Age Verification

To comply with applicable age verification laws, we use a third-party age verification provider to confirm that users are 18 years of age or older before accessing adult content.

During age verification:

  • The third-party provider may collect biometric data (facial image for age estimation) or identity document data, depending on the method chosen.
  • SIA Sigmatics does NOT receive, process, or store any biometric data, facial images, or identity documents. We receive only a binary confirmation (verified/not verified) and a timestamp.
  • The third-party provider processes verification data in accordance with their own privacy policy and deletes biometric data immediately after the age check is completed.
  • No verification data is shared with any other party.

Our age verification provider is [Provider Name], whose privacy policy is available at [URL].

Personal Data Collection for Volt Payments

In connection with Volt Payments, the following personal information is shared with the Payment Service Provider strictly for security and payment purposes:

  1. Email Address
  2. IP Address
  3. Country Location
  4. Document ID for Brazilian users when paying with Pix

This information is provided to ensure that your transactions are processed safely and in compliance with applicable regulations. Volt Payments is obligated to protect your personal data in accordance with data protection laws and to use this information solely for the purpose of processing payments.

Children's Data

Our Services are not directed at individuals under 18 years of age. We do not knowingly collect Personal Data from anyone under 18. We employ age verification measures to prevent minors from accessing the APP's adult content.

If we become aware that we have collected Personal Data from a person under 18, we will take immediate steps to delete that data and terminate the associated account. If you believe we have inadvertently collected data from a minor, please contact us immediately at support@myvirtual.love.

Marketing

We may send you marketing about services we provide that may interest you, as well as other information in the form of alerts, newsletters, and invitations to events or functions which we believe might be of interest to you, or to update you with information (such as legal or commercial news) that may be relevant to you. We may communicate this to you in several ways, including by post, telephone, email, or other digital channels.

Third-Party Marketing

We will get your express opt-in consent before sharing your Personal Data with any company outside SIA Sigmatics for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website or third-party websites and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

Change of Purpose

We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

Disclosures of Personal Data

We may share your Personal Data with third parties we rely on to help provide our services. Third parties can include:

  • service providers who provide IT and system administration services;
  • professional advisers, including lawyers, bankers, auditors, and insurers, who provide consultancy, banking, legal, insurance, and accounting services;
  • regulators and other authorities who require reporting of processing activities in certain circumstances.

We may also share your Personal Data in the following situations:

  • when it is required by law;
  • when we are involved in a merger, acquisition, or sale of all or a portion of our assets.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected:

| Data Category | Retention Period | |--------------|------------------| | Account information (email, profile) | Duration of account + 30 days after deletion | | Chat logs and conversation history | Duration of account; deleted within 30 days of account deletion | | AI-generated images and media | Duration of account; deleted within 30 days of account deletion | | Payment records | 7 years after transaction (Latvian tax law requirement) | | Age verification status | Boolean (verified/not verified) retained with account; underlying verification data held and deleted by third-party provider per their policy | | Analytics and usage data | Anonymized after 26 months | | Content moderation logs | 12 months from event | | Cookie data | See Cookie Policy for individual cookie durations | | Support correspondence | 3 years from resolution |

When your account is deleted, we will erase or anonymize your Personal Data within the timeframes above, unless retention is required by law.

International Data Transfers

Your Personal Data is primarily processed within the European Economic Area (EEA). However, some of our service providers may process data outside the EEA:

| Service Provider | Purpose | Country | Transfer Safeguard | |-----------------|---------|---------|-------------------| | [Your hosting provider] | Infrastructure | [Country] | [SCCs / Adequacy decision / etc.] | | Google (Analytics) | Website analytics | United States | EU-US Data Privacy Framework | | [Payment processor] | Payment processing | [Country] | [SCCs / Adequacy decision] | | [Age verification provider] | Age assurance | [Country] | [SCCs / Adequacy decision] |

Where transfers rely on Standard Contractual Clauses (SCCs), we have assessed the adequacy of protection in the recipient country and implemented supplementary measures where necessary, in accordance with the EDPB's recommendations.

You may request a copy of the relevant transfer safeguards by contacting our Data Protection Officer.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data:

  • Request access to your Personal Data
  • Request correction of your Personal Data
  • Request erasure of your Personal Data
  • Object to processing of your Personal Data
  • Request restriction of processing your Personal Data
  • Request transfer of your Personal Data
  • Right to withdraw consent Right to withdraw consent: Given that our processing of special category data (sexual preferences and interactions) is based on explicit consent, you have the right to withdraw this consent at any time. To do so, delete your account via Settings or contact support@myvirtual.love. Upon withdrawal, we will cease processing your special category data, though this will result in inability to use the adult content features of the APP.

Automated decision-making: Our content moderation systems use automated processing to detect prohibited content. You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. If your account is suspended or content is restricted based on automated moderation, you may request human review by contacting support@myvirtual.love. If you wish to exercise any of the rights set out above, please get in touch with us using the contact details provided in this Privacy Policy.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made several requests. In such cases, we will notify you and keep you updated.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time in response to legal, technical, or business developments. We will take appropriate measures to inform you, consistent with the significance of our changes. You are encouraged to review this Privacy Policy periodically to stay informed about how we are protecting your information.

Contact Details

Data Protection Officer: Email: dpo@myvirtual.love

General inquiries: Email: support@myvirtual.love

Supervisory Authority: If you are unsatisfied with our response to a data protection concern, you have the right to lodge a complaint with the Latvian Data State Inspectorate (Datu valsts inspekcija): Website: www.dvi.gov.lv Email: pasts@dvi.gov.lv Address: Elijas iela 17, Rīga, LV-1050, Latvia

If you reside in another EU/EEA member state, you may also contact your local supervisory authority.