Eirwe Privacy Policy

Effective Date: April 23, 2026 (Updated for AI transparency requirements)

This Privacy Policy explains how Eirwe ("Eirwe," "we," "us," or "our") collects, uses, stores, shares, and protects personal data when you use the Eirwe mobile application, related services, user-generated content features, AI coaching features, recharge or in-app purchase features, report and block tools, and any associated support channels (collectively, the "Service").

Eirwe is intended only for users who are 18 years of age or older. By using Eirwe, you confirm that you are at least 18 years old and that you have the legal capacity to agree to this Privacy Policy and the applicable EULA and Terms of Service.

1. Who We Are

If you have questions about privacy, data protection, moderation, or your rights, you may contact us at eirweinfo@eirwehq.com.

2. Personal Data We Collect

2.1 Data You Provide Directly

• Profile information, such as nickname, avatar, biography, and membership display details.
• User-generated content ("UGC"), including guide titles, notes, arrangement descriptions, images, feedback, and other text or media you choose to submit or store in the app.
• AI Coach inputs, including text you type and text produced from your speech after you confirm sending it.
• Support, safety, report, feedback, and moderation-related submissions.
• Block-list and report choices you make inside the app.

2.2 In-App Purchase and Recharge Data

• Purchase state, recharge selections, virtual balance information, and transaction-related status data.
• We do not receive your full payment card number from Apple. Payment processing is handled by Apple and its payment partners.
• We may receive limited transaction information needed to deliver purchased content, restore balances, comply with law, or handle support requests.

2.3 Device and Usage Data

• Basic device and app interaction information necessary to operate the Service, maintain session state, remember saved content, and preserve your in-app preferences.
• App safety and integrity information used to troubleshoot failures, enforce content rules, and respond to abuse or misuse.

2.4 Permissions and Related Data

We only describe permissions that are actually used by the current app build:

• Camera: to let you capture photos for profile images and floral setup or guide content.
• Photo Library: to let you choose images for profile images, saved guides, and floral setup content.
• Photo Library Add Access: to save, prepare, or reuse relevant images within your workflow where supported.
• Microphone: to capture voice for speech-to-text input before you send an AI Coach message.
• Speech Recognition: to convert your spoken words into text so you can review and send them.

Eirwe does not currently request or describe unused permissions such as location, contacts, calendars, Bluetooth, health, or advertising tracking in this policy.

3. How We Use Personal Data

• To provide the Service, maintain your profile, and display your saved cards, guides, balances, and settings.
• To operate AI Coach and generate responses to floral arrangement questions.
• To process and reflect recharges, balances, purchase states, and purchase restorations.
• To enable speech-to-text input and associated microphone workflows.
• To moderate user-generated content and enforce our zero-tolerance safety rules for objectionable content or abusive conduct.
• To review reports, process blocks, limit exposure to content you do not want to see, and take enforcement action where necessary.
• To respond to support and feedback requests.
• To detect, investigate, document, and prevent fraud, misuse, harassment, manipulation, illegal activity, and security issues.
• To comply with legal obligations and defend our rights, users, and platform.

4. Legal Bases Under GDPR

If GDPR, UK GDPR, or similar privacy laws apply, we rely on one or more of the following legal bases:

• Performance of a contract: to provide the features you request, including saved content, AI interactions, and purchase delivery.
• Legitimate interests: to protect the Service, moderate content, improve safety, investigate abuse, and maintain app integrity.
• Consent: where required, including access to camera, microphone, speech recognition, and photo library permissions.
• Legal obligation: where we must retain, disclose, or process data to comply with law, lawful requests, or regulatory duties.

5. AI Features and Third-Party Processing

Eirwe includes AI chat functionality powered by a third-party AI service. This section explains what data is sent, who receives it, and how it is protected.

5.1 What Data Is Sent to the AI Service

When you choose to send a message to AI Coach, the following data is transmitted:

• Your message content: The text of your question or prompt about floral design, arrangement techniques, or related topics.
• Recent conversation context: A limited history of your recent AI Coach conversation (typically the last few messages) to maintain conversation continuity and provide relevant responses.
• Session information: Basic technical data required to process your request and return a response.

Important: Speech input is converted to text locally on your device first. You have full control to review and edit this text before choosing to send it to AI Coach. Only the text you explicitly choose to send is transmitted to the AI service.

5.2 Who Receives Your AI Data

AI Coach messages are sent to DeepSeek, our third-party AI service provider, for processing and response generation. DeepSeek operates AI language models that analyze your input and generate relevant responses about floral design and arrangement topics.

DeepSeek's contact information and privacy practices:

• Service provider: DeepSeek (operated by Hangzhou DeepSeek Artificial Intelligence Co., Ltd.)
• Website: https://www.deepseek.com
• Privacy Policy: https://www.deepseek.com/privacy-policy

5.3 How Your AI Data Is Protected

We require that DeepSeek provides data protection measures that are the same as or equal to the protections described in this Privacy Policy, including:

• Purpose limitation: Your data is used only to process your AI Coach requests and generate responses.
• Security measures: Industry-standard encryption and security protocols protect data in transit and at rest.
• Data retention limits: AI conversation data is retained only as long as necessary to provide the service and improve AI model performance, subject to applicable data protection requirements.
• No unauthorized sharing: DeepSeek does not sell your personal data or share it with third parties for their own marketing purposes.
• Compliance: DeepSeek maintains compliance with applicable data protection laws and regulations.

5.4 Your Control and Best Practices

• You control what you send: AI Coach only processes messages you explicitly choose to send. You can review and edit speech-to-text results before sending.
• Avoid sensitive information: Do not include sensitive personal information, payment card numbers, passwords, health data, or other confidential information in AI prompts.
• Review AI outputs: AI-generated responses may be inaccurate, incomplete, or unsuitable in some situations. Always review AI suggestions before relying on them for important decisions.
• Clear conversation history: You can start a new chat session at any time to clear your conversation context.

5.5 Consent and Opt-Out

Before using AI Coach for the first time, you will be presented with a clear notice explaining what data is collected and asking for your permission. You may decline to use AI Coach features at any time. If you choose not to use AI Coach, no data will be sent to DeepSeek, and you can continue using all other Eirwe features normally.

6. User-Generated Content, Safety, Reporting, and Blocking

Eirwe does not tolerate objectionable content, abusive behavior, or misuse. We may process UGC and related metadata to enforce this rule. Prohibited categories include, without limitation:

• pornographic, sexually explicit, or otherwise obscene content;
• content that is disturbing, graphic, gross, degrading, or reasonably likely to cause serious discomfort;
• gambling, betting, or unlawful gaming-related promotion or facilitation;
• illegal drugs, narcotics, controlled substances, or instructions for illegal drug activity;
• hate speech, discrimination, or content targeting people based on race, ethnicity, nationality, religion, sex, gender, sexual orientation, disability, or other protected characteristics;
• political extremism, manipulative political propaganda, coordinated influence abuse, or content intended to incite hostility or unlawful disruption;
• harassment, threats, bullying, stalking, impersonation, or exploitation;
• violent, abusive, illegal, fraudulent, or otherwise harmful material.

We provide report and block tools so users can flag or hide content. We may review reported material, block access, remove content, limit account functionality, retain evidence for safety or legal reasons, and take any other reasonable enforcement action.

7. How We Share Personal Data

We do not sell your personal data. We may share limited data only as necessary with:

• Apple: for App Store distribution, platform operations, and in-app purchase processing.
• DeepSeek (AI service provider): for AI Coach message processing after you submit AI prompts. DeepSeek receives your message content and limited conversation context to generate responses. DeepSeek is required to provide the same or equal data protection as described in this Privacy Policy.
• Speech recognition providers: for speech-to-text processing where enabled by your device and permissions. Speech is converted to text locally on your device before you choose whether to send it.
• Legal or safety authorities: where required by law or reasonably necessary to protect users, the public, our rights, or platform integrity.

All third-party service providers are contractually required to protect your data and use it only for the specific purposes for which it was shared. They may not use your data for their own independent purposes or share it with other parties without appropriate authorization.

8. International Transfers

Your data may be processed in countries other than your own, including countries whose data protection laws may differ from those in your jurisdiction. Where required, we take reasonable steps to use appropriate safeguards for such transfers.

9. Data Retention

• We retain profile data, saved cards, guides, balances, and settings while needed to provide the Service or until you delete them.
• We may retain reports, moderation records, and related evidence longer where needed for abuse prevention, legal compliance, dispute resolution, or enforcement.
• AI chat history may be stored locally or otherwise retained for continuity unless cleared, deleted, or removed under applicable law.

10. Your Privacy Rights

Depending on your location, you may have rights to request access, correction, deletion, restriction, objection, portability, or withdrawal of consent. If GDPR applies, you may also have the right to lodge a complaint with a supervisory authority.

To make a request, contact eirweinfo@eirwehq.com. We may ask for information to verify your identity before processing a request.

11. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. 18+ Policy

Eirwe is not intended for children. We do not knowingly seek or market the Service to users under 18. If you believe a person under 18 has provided personal data, please contact us so we can take appropriate steps.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The revised version will be posted with an updated effective date. Your continued use of the Service after the updated policy becomes effective means you acknowledge the revised policy.

14. Contact

Privacy, moderation, rights requests, and support: eirweinfo@eirwehq.com