PRIVACY POLICY

INTRODUCTION

Rulta OÜ (“Company”, “Rulta”, “Rulta Mate”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your privacy and personal data, in accordance with applicable data protection laws, including the European Union General Data Protection Regulation (“GDPR”) and, where applicable, other relevant privacy laws.

Rulta OÜ is the controller of the personal data described in this Privacy Policy, unless otherwise stated.

This Privacy Policy explains how we collect, use, store, share, disclose, and otherwise safeguard your personal information when you access, visit, or use our website https://rultamate.com (the “Site”), desktop and mobile application, and other related Services (collectively, the “Services”), as well as what information we collect and why we collect it, the legal bases on which we process it, how long we retain it, and the rights available to you regarding your personal data.

Please read this policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Site and discontinue your use of the Services. By using our Site and Services, you acknowledge that you have read this policy carefully and have agreed to the terms of the policy.

INFORMATION WE COLLECT

Personal Data

The personal data we collect depends on how you interact with our Services. We may collect personally identifiable information that you voluntarily provide to us when you register on the Site, make a purchase, or contact us, under the following categories:

1. Account Information

When you create an account, we may collect:

• Name and username
• Email address
• Account credentials (password) and preferences (settings)

2. Subscription, Payment and Billing Information (processed by our payment provider, Paddle)

When you purchase a subscription, Paddle processes information necessary to manage your subscription and billing, in accordance with its own privacy practices, which includes:

• Subscription plan
• Billing status
• Transaction identifiers
• Other payment related information provided by you.

Please note that we do not store your full payment card details.

3. Connected Platform Information

When you connect a supported third-party platform (currently OnlyFans) to the Services, we may collect and process information that is made available to us through your connected account and that is necessary to provide, operate, maintain, improve, secure, and support the features and functionality of the Services, in accordance with your authorization, this Privacy Policy, and other applicable laws and regulations. Such information is processed only to the extent necessary for providing the features you choose to use. This may include information required to enable the features described below.

Depending on the features you use, this information may include:

• Account identifiers and profile information,
• Earnings, revenue, payout and other financial performance information made available through the connected platform,
• Subscriber, fan and follower statistics and information,
• Account analytics and content performance metrics,
• Transaction and purchase information relevant to you,
• Messaging and conversation information that you choose to use through AI-powered or messaging features,
• Content identifiers and other necessary data for watermarking, content tracking, and related protection features,
• Chargeback related information and account activity information used for fraud prevention and risky user detection, and
• other data and information that you choose to make available to us through the connected platform.

4. Communication Data

When you contact us, we may collect:

• Customer support requests and messages
• Emails
• Chat conversations
• Feedback
• Survey responses

5. Usage Information

We may collect certain information about how you use the Services, which includes:

• Features used
• Pages viewed and times spent on pages
• Click patterns
• Session activity
• Time spent using the Services
• Interaction events
• Error reports
• Diagnostic information

Automatically Collected Device Data and Technical Information

When you visit the Site or use the Services, we automatically collect certain information about your device and usage, including:

• IP address and approximate geographic location
• Browser type and version
• Operating system
• Referring URLs and exit pages
• Device identifiers
• UTM parameters and campaign source data
• Log files

AI FEATURES AND PERSONALIZATION

If you choose to use AI-powered features, we may process information that you voluntarily submit, including prompts, messages, notes, templates, and other content necessary to generate AI-assisted responses or recommendations.

Certain AI features allow you to create a personalized communication profile (“Personal Traits”). Where you use features such as “Copy Me”, manually upload example conversations, or select predefined communication templates, we may process the submitted content solely to generate and maintain your Personal Traits. We do not retain the original conversation content after it has been processed for this purpose, unless otherwise stated or retention is necessary for troubleshooting, legal compliance, or security reasons, or where otherwise required by applicable law. We retain only the resulting Personal Traits necessary to provide personalized AI functionality.

We may also collect limited usage information regarding AI features (such as the number of times a feature is used) to analyze product usage, improve the Services, and measure feature adoption.

HOW WE USE YOUR INFORMATION

We process your personal data where we have a valid legal basis for doing so. Depending on the circumstances, we rely on one or more of the following legal bases:

• Performance of a contract
• Compliance with a legal obligation
• Our legitimate interests
• Your consent, where required by applicable law

We use the information we collect for the following purposes:

• To create, maintain and manage your account
• To authenticate your identity and provide access to the Services
• To provide, operate, maintain, and improve the Services
• To provide account management features, analytics, revenue tracking, subscriber and fan management, chargeback protection, risky user detection, watermarking, content tracking, and other functionality based on information from connected third-party platforms
• To provide AI-powered features, including AI-assisted messaging, note generation, templates, and such personalized content
• To analyze feature usage and improve our AI-powered functionality
• To process subscriptions, payments, transactions and related information through our payment provider Paddle
• To communicate administrative information to you, such as updates, security alerts, and support messages
• To respond to your comments, enquiries, questions, customer service requests, and feedback
• To personalize and improve your experience when using the Services
• To generate and maintain personalized communication profiles based on information you choose to submit
• To monitor and analyze trends, usage, and activities in connection with our Services in order to improve functionality, reliability, and security
• To send marketing communications and promotional materials (with your consent, where required)
• To detect, investigate, prevent, and address fraud, abuse, unauthorized access, security incidents, and other technical issues
• To maintain system integrity and ensure the proper operation of the Services
• To comply with applicable legal obligations and enforce our Terms of Service and other legal rights

We do not use your personal data to make decisions based solely on automated processing that produce legal or similarly significant effects concerning you within the meaning of Article 22 of GDPR.

COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to operate, secure, and improve our Services, collect and track information about user activity to understand how users interact with our website and applications, remember user preferences, and measure the effectiveness of our marketing activities.

Cookies are small data files placed on your device. We use session cookies (which expire when you close your browser), persistent cookies (which remain on your device until deleted or expired), essential cookies (which are required for our Site to work) and non-essential cookies. Where required by applicable law, we will obtain your consent before placing non-essential cookies or similar technologies on your device. You may manage your cookie preferences at any time through Cookie Settings or your browser settings.

For detailed information about the cookies we use and your choices regarding cookies, please see our Cookie Policy.

THIRD-PARTY SERVICES

We use trusted third-party service providers to help us operate, provide, and improve our Services. These providers process personal data on our behalf or, where applicable, as independent controllers in accordance with their own privacy policies. We may share your information with these third-party service providers that helps them perform certain services on our behalf. Our third-party service providers may include:

• Payment Processing: Paddle.com Inc. processes payments, subscriptions and related billing information on our behalf. Their use of your personal information is governed by their own privacy policy.
• Authentication: We use Firebase Authentication to securely authenticate users and manage user accounts.
• Analytics: We use Google Tag Manager, Sentry and Microsoft Clarity to understand how visitors use and interact with our Services.
• Customer Support: We use Crisp for live chat and customer support.
• Cloud Infrastructure: We use Google Cloud Platform and Firebase to host our Services and securely store and process data.
• AI Services: Certain AI-powered features are provided using third-party AI models. Information submitted through AI features may be processed by these providers solely for the purpose of generating the requested output and improving the functionality of our Services.

We may update the third-party providers we use from time to time as our Services evolve. Any such providers will process personal data only for the purposes described in this Privacy Policy and subject to appropriate contractual and legal safeguards where required.

DATA RETENTION

We retain your personal data for as long as your account is active or for as long as needed for the purposes for which it was collected, including providing you our Services and maintaining your account. We may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The length of time we retain personal data depends on the nature of the information and the purpose for which it is processed. For example, we generally retain account information for as long as your account remains active, while certain transaction and billing records may be retained for longer where required by applicable law.

Unless otherwise required for the provision of the Services, content submitted to AI-powered features is processed only for the purpose of generating the requested output. Where applicable, we retain only the resulting Personal Traits and other profile information necessary to provide personalized AI functionality.

When your data is no longer needed, we will securely delete, anonymize, mask, or otherwise dispose of it in accordance with applicable law.

DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of your residence, including countries that may not provide the same level of data protection as your own jurisdiction, such as the United States. These countries may have data protection laws that are different from the laws of your country. By continuing to access or use the Services after reviewing this Privacy Policy, you acknowledge and understand that your personal data may be transferred and processed internationally as described in this Policy.

Where we transfer personal data outside the European Economic Area (“EEA”), the United Kingdom, or other jurisdictions with applicable data transfer restrictions, we take appropriate safeguards to ensure that your personal data remains protected in accordance with this Privacy Policy and as required by applicable law.

You may contact us if you would like more information regarding the safeguards applicable to international transfers.

YOUR RIGHTS

Depending on your location and applicable law, you may have the following rights regarding your personal data:

• Access: You have the right to request a copy of the personal data we hold about you.
• Rectification: You have the right to request correction of inaccurate or incomplete data.
• Erasure: You have the right to request deletion of your personal data, subject to certain conditions.
• Restriction: You have the right to request that we restrict the processing of your personal data.
• Data Portability: You have the right to receive your personal data in a structured, commonly used format.
• Objection: You have the right to object to the processing of your personal data for direct marketing purposes.
• Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time.
• Lodge a Complaint: You have the right to lodge a complaint with the competent data protection authority if you believe that we have processed your personal data unlawfully.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the reasonable time period required by applicable law (for example, within a month according to GDPR).

CHILDREN'S PRIVACY

Our Site and Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from anyone under the age of 18. If you believe that a child has provided us with personal data, please contact us. If we become aware that we have collected personal data from a person under the age of 18 without parental consent or in violation of applicable law, we will take reasonable steps to dispose of that information without undue delay.

SECURITY

We implement appropriate and commercially reasonable administrative, technical, organizational and physical security measures that are designed to protect both your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or any unauthorized access, and your content processed through the Services against fraudulent behavior and risky users. However, no method of transmission of data over the Internet or method of electronic storage is completely secure. While we strive to protect your personal information, and implement measures appropriate to the nature of the personal data that we process and the risks involved, we cannot guarantee its absolute security.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our Services, applicable laws, or our data processing practices. We will notify you of any changes by updating the “Last updated” date at the top of this policy. Where required by applicable law, we will provide additional notice before the changes take effect. We encourage you to review this Privacy Policy periodically to stay updated on how we protect your personal data, or any changes. Your continued use of the Site after any modifications indicates your acceptance of the updated Privacy Policy.

CONTACT US

If you have any questions or concerns about this Privacy Policy, or our data practices, please contact us at: