Scarlett: Virtual AI Lover

Privacy Policy and Personal Data Text

Date: 27.12.2023


1. TOON TECH LTD (“TOON TECH” or “Company”) aims to process users’ personal data in strict adherence to fundamental principles of privacy and in compliance with applicable data protection laws, particularly the laws and regulations relevant to personal data protection in the United Kingdom. Additionally, this policy encompasses the rights of individuals where General Data Protection Regulation (European Union) 2016/679 is applicable.

2.Your personal data, provided to or obtained by TOON TECH, may be processed by the Company as the “Data Controller” under the following objectives:

3. With a focused intent on processing personal data and aligned with the specific purpose outlined, ensuring its limited and measured utilization.

4. Upholding the accuracy and currency of the personal data shared or communicated to TOON TECH.

5. The personal data may be recorded, stored, preserved, reorganized, and potentially transferred to authorized institutions in compliance with legal requirements. They may also be transferred, categorized, and shared with third parties within or outside the country, conforming to legislative conditions and requiring explicit consent where necessary. These data might be processed by other means specified in the legislation and subject to procedures outlined in the legal framework.

6. This Privacy Policy is adopted to sustain and enhance TOON TECH’s operations in accordance with the principles delineated in the relevant data protection laws.

7. This Privacy Policy delineates the data collected, the intended methods of use, storage, protection, and sharing of collected data, the procedure to withdraw consent for data processing, and mechanisms for data correction and revision.

8. Terms capitalized in this Policy carry the definitions specified in the Terms and Conditions, unless separately defined in this Privacy Policy

Collection of Personal Data and Method

At TOON TECH LTD, we gather and process various user-specific data as part of our commitment outlined in this Privacy Policy. The information we collect includes your name, surname, email address, and phone number, which are obtained when you interact with TOON TECH. Additionally, we may collect order information pertaining to in-app purchases, user-generated content shared within our Scarlett: Virtual AI Lover app, and identifiers associated with your device, such as the Identifier for Advertisers (IDFA), Identifier for Vendors/Developers (IDVF), and Internet Protocol Address (IP Address). These data types are instrumental in enhancing the user experience, ensuring compliance with legal obligations, and maintaining the integrity of our services while aligning with the principles stipulated in our Privacy Policy.

Data Categories and Data Types

Identity Information Name and surname
Contact Information Phone number, e-mail address
Process Security Internet traffic data (network movements, IP address, visit data, time and date information), device name, In-app purchase history, Token ID (when you allow notifications through your device), identifier for advertisers designated in your mobile device used in accessing our services (if you give a permission, the Identifier for Advertisers-IDFA), identifier for vendors/developers Designated your mobile device (The identifier for Vendors-IDVF)
User Content messages, posts, communication, statements, information, phrases, entries, text, questions, answers, materials, images, photos, visual records, graphics, and any content, record, or data that you provide, upload, transmit, create, store, use, edit, or share within or through our app, Scarlett: Virtual AI Lover by TOON TECH
Customer Transaction Order information
Marketing Data IDFA , IDVF

We may collect your abovementioned data directly from you through electronic or physical mediums, your mobile device, third party applications or third party sources which you can access our application through these mediums such as Apple App Store, Google Play App Store (similar platforms together with “App Stores”), for the purposes of compliance with legal obligations, enhancing our services, administering your use of our services, as well as enabling you to enjoy and easily navigate our services.

We may collect your log data generated while you are using our services/applications (through our products or third party products). This log data may include information such as your device’s Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our service/application, the time/date of your use of the service/application, and other statistics.

General Principles Regarding Personal Data Processing

In accordance with this Privacy Policy, personal data are processed by TOON TECH as a data controller in line with the basic principles named here: (i) being in accordance with law and good faith, (ii) being accurate and, where necessary, up-to-date, (iii) being processed for specific, explicit and legitimate purposes, (iv) being limited for the purpose for which they are processed and data minimization; and (v) being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Purposes of Processing Personal Data and Legal Reasons

Your personal data will be processed, utilizing both automatic and non-automatic means, for the outlined purposes, strictly in accordance with applicable legislation. This processing adheres to the provisions of articles 5 and 6 of the PDP Law, where permitted by explicit laws, and when establishing a contract or relating directly to the execution or performance of a contract. Moreover, your data may be processed for the legitimate interests of TOON TECH, ensuring that fundamental rights and freedoms are safeguarded throughout these operations. This approach ensures compliance with legal requirements and upholds the protection of your rights as per our commitment outlined in the Privacy Policy.

Purposes of Processing Personal Data

In accordance with this text, your personal data is processed for the following purposes in accordance with the above general conditions:

Identity Information Contact Information Customer Transaction execution of activities in compliance with legislationexecution of company/product/service commitment operationsexecution of communication activitiesexecution/auditing of business activitiesconducting after-sales support services for goods/servicesexecution of goods/services sales processesconducting storage and archive activitiesexecution of agreement processes
Process Security execution of information security processesconducting audit/ethical activitiesexecution/audit of business activitiesconducting activities to ensure business continuityproviding information to authorized persons, institutions and organizations
Customer Transaction execution/auditing of business activitiesconducting after-sales support services for goods/servicesexecution of goods/services sales processesconducting activities for customer satisfactionexecution of agreement processes
User Content operation of our product, e.g., to prepare edited user contentexecution of activitiesincompliance with legislationexecution of agreement processesconducting storage and archive activitiesexecution/auditing of business activitiesconducting activities to ensure business continuityexecution of activities for customer satisfactionimproving our services (including training AI models) (You can opt out of our use for your information to train AI models by filing a request through the “Data Subject Application Form” at support@toongamingllc.com)
Marketing Data conducting marketing analysis studiesexecution of advertising/ campaign/ promotion processes

Besides, the purposes of processing personal data may be updated in line with our obligations arising from our company policies and legislation; in particular,

    • Creating user accounts for the service recipients/application users,
    • Customizing our Services, understanding our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’ experience,
    • Informing about new products, services and applications and delivering you information regarding advertisements and promotions,
    • Carrying out a digital subscription and in-app purchase processes of service recipients,
    • Carrying out the auto-renewable subscriptions for giving users access to content, services, or premium features in our service,
    • Carrying out the processes of information security,
    • Conducting activities in accordance with legislation,
    • Fulfilling the demands of competent authorities,
    • Conducting the processes of finance and accounting transactions,
    • Conducting communication activities,
    • Conducting the processes of contracts,
    • Carrying out strategic planning activities,
    • Following up requests and complaints.

Legal Reasons

Identity Information Contact Information It is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract.We have to process data in order to establish a right for you, to exercise and protect this right
User Content execution of information security processesconducting audit/ethical activitiesexecution/audit of business activitiesconducting activities to ensure business continuity.providing information to authorized persons, institutions and organizations.
Process Security It is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract.We have to process data in order to establish a right for you, to exercise and protect this right.Processing is necessary for our legitimate interests, provided that your fundamental rights and freedoms of are not harmed
Marketing Data The law explicitly stipulates the process by which we process your personal dataConditions that are necessary in order to fulfill our legal obligationIt is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract
Marketing Data Your explicit consent (acquired via Apple and/or Google)

Third Party Websites and Applications

The Scarlett: Virtual AI Lover app may contain links to external websites or apps that are not affiliated with TOON TECH, and their content remains beyond our control. These linked websites or apps may have terms and conditions that differ from those outlined by TOON TECH. We do not assume responsibility for the use or disclosure of any information processed by these external websites or apps. Furthermore, any links from other sites or apps directed to the Scarlett: Virtual AI Lover app owned by TOON TECH are not within our liability.

We collect information through fair and lawful means, with your knowledge and consent, explicitly informing you about the purpose and usage of the data we gather. While you have the freedom to decline providing certain information, it’s important to note that refusal may limit some of the services we offer.

When utilizing the Scarlett: Virtual AI Lover app, you might provide information via third-party websites and apps to TOON TECH. It’s essential to acknowledge that your responsibilities and obligations concerning third-party apps or websites persist, and TOON TECH cannot be held accountable for any terms, conditions, rules, or policies stipulated by these third parties.


Cookies, small text files, are stored on your computer or mobile device’s browser or hard drive when you visit a webpage or application. They optimize website performance and ensure the display of personalized web pages, offering a faster and more tailored browsing experience tailored to your specific needs. These cookies solely contain data related to your internet browsing history on the website, and they do not gather any information from personal files stored on your computer or mobile device. We may use cookies for essential operation of our services, enhancing service performance and functionality, and providing content, including ads relevant to your interests, on our sites or third-party sites. You have the option to delete existing cookies on your computer and prevent new ones from being stored through your internet explorer settings.

Most internet browsers are set to accept cookies automatically by default. As cookie management procedures differ across browsers, you can find detailed information in the help menu of your browser or application for specific instructions on managing cookies.

Push Notifications

Our Scarlett: Virtual AI Lover app may occasionally send push notifications concerning application upgrades or important service notifications. You have full control over these communications and notifications through your device settings, including the ability to opt-out of receiving such messages.

Regarding your data, we adhere to the duration specified in relevant legislation or retain it for a reasonable period until the purpose of processing concludes or during legally defined limitation periods. If you grant us consent for extended data storage, once this additional period expires or the purpose of processing ceases, we promptly delete, destroy, or anonymize the data as required.

Technical and Administrative Measures

TOON TECH securely stores the personal data it processes in accordance with the pertinent legislation for durations outlined in the relevant laws or as necessitated for the purpose of processing. TOON TECH is committed to implementing all requisite technical and administrative measures, exercising due diligence to ensure the confidentiality, integrity, and security of personal data. In this regard, specific measures are taken to prevent unlawful processing, unauthorized access, disclosure, alteration, or destruction of data. To ensure this, the following technical and administrative measures are implemented concerning the personal data processed by TOON TECH:

    • Anti-virus Application: All computers and servers within TOON TECH’s information technology infrastructure are equipped with regularly updated anti-virus applications.
    • Firewall: TOON TECH’s data center and disaster recovery centers hosting servers are shielded by periodically updated, software-loaded firewalls. These next-generation firewalls control internet connections and provide protection against viruses and similar threats.
    • VPN Access: Suppliers accessing TOON TECH’s servers or systems utilize SSL-VPN on Firewalls. Each supplier is allocated a distinct SSL-VPN identification, allowing access only to authorized systems.
    • User Identifications: Employee authorization to TOON TECH systems is restricted by job descriptions. Any changes in authority or responsibilities result in corresponding updates to systemic authorizations.
    • Information Security Threat and Event Management: TOON TECH utilizes a system to monitor events on servers and firewalls, immediately alerting responsible staff to security threats.
    • Encryption Measures: Sensitive data is stored using cryptographic methods and, if necessary, transmitted through encrypted environments. Cryptographic keys are stored securely.
    • Logging: All transaction records related to sensitive data are securely logged.
    • Two-factor Authentication: Remote access to sensitive data is permitted only through at least two-factor authentication.
    • Penetration Testing: Regular penetration tests are conducted on servers within the TOON TECH system, and identified security gaps are promptly addressed.
    • Information Security Management System (ISMS): Monthly audits of control forum topics within the ISMS are conducted to ensure information security management.
    • Employee Training: Regular employee training sessions are conducted to heighten awareness of information security and mitigate the human factor in security incidents.
    • Physical Data Security: Personal data on paper is stored securely and accessed only by authorized personnel. Suitable security measures are implemented based on the nature of the data storage environment.
    • Backup: TOON TECH performs periodic data backups utilizing cloud infrastructure providers and internally developed backup solutions, all in compliance with relevant legislation and this Policy.
    • Non-disclosure Agreement: Employees involved in sensitive personal data processing are bound by non-disclosure agreements.
    • Transfer of Sensitive Personal Data: Transfer of sensitive personal data via email is carried out either through encrypted corporate email or Registered E-mail.

In the unlikely event of personal data being compromised despite these measures, TOON TECH promptly informs Users and, if necessary, the relevant data protection authority, taking requisite actions to address the situation.

Transferring Personal Data to Third Parties

The procedures and principles governing the transfer of personal data are in accordance with the regulations specified in articles 8 and 9 of the relevant data protection laws. To facilitate these transfers, both personal and special categories of data related to our suppliers may be transferred to third parties, whether within the country or abroad, owing to the use of servers and cloud systems situated overseas.

Your personal data might be transferred internationally for various purposes including:

    • Facilitating storage and archiving activities
    • Conducting business operations
    • Providing after-sales support services for goods/services
    • Managing customer relationship management processes

Furthermore, with regard to the operation and enhancement of our services, TOON TECH may transfer your personal data to service providers associated with our Company. Additionally, your information might be shared with third-party entities such as Facebook SDK, Adjust, and Firebase Analytics embedded within our service. These transfers serve specific purposes:

    • Sharing identity, communication, and transaction security details with authorized public institutions and organizations to comply with legal requirements, monitor legal affairs, and inform relevant authorities.
    • Sharing identity and contact information to manage after-sales support services, conduct business activities, and maintain customer relationship management processes.

Your Rights as the Data Subject

Pursuant to Article 11 of the PDP Law, you may request the following regarding your personal data by applying to TOON TECH:

    • Determine if your personal data is being processed;
    • Request information regarding the processing of your personal data;
    • Understand the purpose of data processing and its alignment with the intended purpose;
    • Identify the third parties, both domestically and internationally, to whom your personal data has been transferred;
    • Request rectification or completion of inaccurately or incompletely processed personal data, along with the notification of such changes to third parties who received the data;
    • Ask for deletion, destruction, or anonymization of personal data if the reasons for processing cease to exist, also requesting notification of these actions to third parties;
    • Object to any detrimental outcomes resulting solely from automated processing of personal data;
    • Seek compensation for damages incurred due to unlawful processing of personal data.

In the case where the General Data Protection Regulation (GDPR) applies, data subjects possess additional rights:

    • Right of access: Verify if personal data is being processed and obtain information related to its processing by TOON TECH;
    • Right to rectification: Request correction of inaccurate or incomplete information by TOON TECH;
    • Right to erasure: Ask for deletion of personal data under the conditions stipulated in GDPR;
    • Right to restrict processing: Request limitations on the processing of personal data as per GDPR;
    • Right to object: Object to the processing of personal data as specified in GDPR;
    • Right to data portability: Request the transfer of data collected by TOON TECH to another organization under certain conditions;
    • Objection to solely automated processing: Object to decisions solely made by automated systems using processed data, including profiling.

To initiate any such requests, please provide explicit and comprehensible explanations regarding your rights as a data subject. If the request concerns another individual, proper authorization and documentation are required. You may file such requests through the “Data Subject Application Form” provided at support@toongamingllc.com. As per Article 13 of the PDP Law, our company will address your requests free of charge, within 30 days, depending on the nature of the request. If your request is declined, you will receive a written or electronic notification with the rationale behind the rejection.

Should you believe that your rights have been violated, you have the right to file a complaint with the data protection authority in your country or other relevant supervisory bodies.

This Privacy Policy may be subject to revisions by TOON TECH as necessary. By continuing to access or use the Scarlett: Virtual AI Lover App without availing services from TOON TECH after the notification period, you are deemed to have consented to the changes outlined in this Privacy Policy

Company Title: TOON TECH LTD

Address: 128 City Road, London, United Kingdom, EC1V 2NX

E-mail: support@toongamingllc.com

Tel: +44 7449 288503

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