Privacy Policy

1. Who is responsible

Patissiers Ltd, a Bulgarian single-member limited liability company (EOOD), is the operator of Pastry and the controller responsible for the personal data described in this policy. Our Unified Identification Code is 208773054 and VAT number is BG208773054.

Contact support@pastry.com for privacy questions, complaints or requests. The company handles these requests.

This policy covers the Pastry website, iOS and Android apps, guest access and related services. Apple, Google and your sign-in provider also process information for their own services under their own privacy notices.

As a Bulgarian company, we process personal data under the EU General Data Protection Regulation (GDPR) and Bulgaria's Personal Data Protection Act. This policy also preserves any additional rights and protections that apply to you under local law.

2. Information we collect

Guest activity can be linked to a persistent guest identifier. When a guest upgrades to an account, existing guest records may be linked to that account. Activity associated with an identifier is personal data even if it does not contain your name.

There are no public user profiles or user-to-user conversations. Private chats are nevertheless processed by Pastry and its service providers to operate the feature; they are not confidential exchanges with a human professional.

Please do not submit sensitive personal information, identifying documents, payment credentials or another person's private information. If you put personal or sensitive information into a message or image, it can be included in the content processed to respond and address safety issues. We do not ask you to disclose health, sexuality or other sensitive information to use chat.

3. Why we use information

The following table explains why we use information and the legal bases under GDPR. Describing a use here does not replace consent where it is required.

We do not use private chats or uploaded images to train our own models, produce dramas, advertise to you, or conduct general human quality review. Access for support, safety or legal investigations is limited to the people who need it for those purposes. AI providers' separate processing and retention must also be considered, as described below.

4. AI processing and personalization

To generate a character reply, we process your current message, relevant conversation history and any image submitted for that response, together with character context. These inputs are sent to the AI provider used for the chat. AI systems may also assess content for safety restrictions.

Your viewing, likes, follows, surveys and interactions can be used to infer preferences and select characters or follow-up messages. This is profiling for entertainment and engagement. The Service does not use that profiling to make decisions with legal or similarly significant effects on you. Automated safety checks may flag or refuse a message; you can contact support to contest an error.

Human review of our published dramas is separate from processing your private conversations. We do not publish your chats or uploaded images to other users.

5. Tracking, storage and your choices

The website uses browser session storage to remember your sound preference. Requests for pages, trailers and media also expose technical information, such as an IP address, to the servers delivering them. The legal pages themselves do not embed analytics scripts, external fonts or advertising pixels.

The mobile apps use service identifiers and analytics software to record the activities described above. This includes activity from guests. Some analytics records can be linked to accounts, emails or device information; they should not be described as anonymous.

We will request consent before optional tracking where the law requires it. Where a lawful analytics exception allows collection without prior consent, we will provide the required information and objection mechanism. Where processing relies on legitimate interests, you may object on grounds relating to your situation. Necessary account, purchase and security records are handled separately.

You may withdraw consent without affecting processing lawfully performed before withdrawal. Refusing optional analytics will not remove access to the core service. Device permissions, such as notification or photo access, are not a substitute for any separate consent required for a particular use of data.

6. Service providers and disclosures

We use providers for hosting and content delivery, AI generation and safety processing, analytics and diagnostics, authentication, payments, email and push delivery. They receive the data needed for their role. We require appropriate data-protection arrangements where a provider acts on our behalf.

Processing locations and international-transfer safeguards are described in Where information is processed. You can use the privacy request route to ask which recipients have received or will receive your personal data; we will identify them as required by applicable law.

We do not sell personal data or share it for cross-context behavioral advertising. We do not supply advertising audiences or allow providers to use our users' data for those purposes under this policy.

We may disclose information to professional advisers, authorities or others where reasonably necessary to meet legal obligations, protect rights or address fraud and safety. If the business is reorganized or sold, relevant information may be transferred subject to applicable safeguards and any required notice; it does not become unrestricted marketing data.

7. Where information is processed

Our primary systems store personal data within the European Union (EU). We use content-delivery networks (CDNs) to distribute videos and other content across different regions. Service providers, including AI, app-store, communications and CDN providers, or authorized support personnel may process information outside the EU or European Economic Area (EEA).

Transfers outside the EEA must meet GDPR's international-transfer requirements, for example through an applicable adequacy decision or approved contractual safeguards with any necessary additional measures. We also apply any additional safeguards required by other applicable law. You can ask support about the destinations and safeguards for your data, including a copy of relevant safeguards where available by law.

8. How long information is kept

Account and chat records: We keep these while your account is in use, or until a valid deletion request is acted on, subject to the limited exceptions below. Records needed to preserve unspent purchased credits are limited to what is necessary for that purpose.

Uploaded chat images: Images are temporary inputs for generating a response. They are removed from our active storage when response processing and any necessary retry have finished, and excluded from long-term logs and backups. AI-provider retention is assessed separately.

Behavioral history: We retain identifiable events for a rolling maximum of 24 months from each event where necessary for the stated purpose, subject to earlier deletion or withdrawal/objection requirements. We then delete them or convert them to genuinely anonymous aggregate statistics, which may be kept longer for trend analysis.

Support, diagnostics and security: Retention is assessed separately for resolving your support request, investigating a technical fault, and handling a specific security or safety incident. A case requiring further retention must have a documented reason, such as an unresolved dispute or legal duty. Chat and image content is avoided in diagnostic traces by default.

Financial and compliance records: Retention depends on the applicable accounting and tax requirements, legal-claim periods, and the records needed to demonstrate consent or honor an unsubscribe choice. These purposes do not justify keeping unrelated chats or activity history.

Backups: Deleted records may remain in restricted backups until those backups expire under the applicable rotation schedule. If a backup is restored, deletion controls prevent erased information from returning to active use.

Deleting names or replacing an email with an identifier does not necessarily anonymize data. Older statistics are treated as anonymous only where people can no longer reasonably be identified or linked back to accounts.

A specific legal duty or dispute may require limited records to be preserved after account deletion. Those records must be restricted to the relevant purpose. Where an exception applies to your request, we will explain it rather than treat all account data as exempt.

9. Privacy requests and account deletion

You can also initiate deletion through the app's Delete Profile flow. Signing out or uninstalling the app is not an account-deletion request. Closing a Pastry account does not automatically cancel a store subscription.

Under GDPR, you can request access and a copy, correction, deletion, restriction, or portability of your personal data; object to processing based on legitimate interests; and withdraw consent. You can object to direct marketing at any time. These rights have conditions and legal exceptions. Additional local rights may also apply.

We may verify your identity proportionately to protect your information. You can use an authorized representative where permitted; we may need evidence of authority. We will not require unnecessary information to process a request.

We respond without undue delay, normally within one month of receiving your request under GDPR. Where legally permitted, complex or numerous requests may take up to two additional months; we will explain the extension within the first month. Any adjustment for identity verification must be permitted by law. We also meet any additional local deadlines that apply. Requests are normally free, subject to limited legal exceptions.

10. Email and push notifications

We use contact and device delivery details for necessary account, security, purchase and service communications. Optional character-engagement or promotional communications are subject to applicable consent and marketing rules.

Marketing and engagement emails will contain an unsubscribe link. You can also contact support to object. Unsubscribing from marketing does not stop essential account or security messages. We retain the minimum suppression information needed to avoid contacting you again against your choice.

You can control push permission through your device settings. Turning off push delivery does not by itself delete in-app messages, remove your account or withdraw a separate analytics choice.

11. Adults only

Pastry is intended for adults aged 18 or older, including guest users. We do not seek to collect personal data from children or encourage them to use the Service.

If you believe someone under 18 is using Pastry, contact support. We will investigate and take appropriate steps to restrict access and delete personal data that should not be retained, subject to applicable law.

Our age restriction is not a claim that every user's age has been verified.

12. Additional information for US residents

The categories, sources, purposes and recipients of information are described above. There is no sale of personal information or sharing for cross-context behavioral advertising under this policy, and no targeted-advertising audience transfer.

Where a US state privacy law applies to our processing of your information, you may have rights to confirm processing, access or obtain a portable copy, correct or delete information, and opt out of sale, targeted advertising or certain profiling. Some laws also provide rights concerning sensitive information. Availability and exceptions depend on the law and our activities.

Make a request through support. Where an appeal right applies and we decline your request, reply asking for a privacy appeal; we will explain the decision, applicable timing and how to contact the relevant regulator. You may use an authorized agent where permitted. We will not unlawfully discriminate or retaliate against you for exercising your rights.

We do not use entertainment-preference profiling to make decisions with legal or similarly significant effects. We will honor legally applicable opt-out preference signals for processing to which they apply. A sale/sharing opt-out signal does not itself control unrelated, necessary service processing.

For California residents, where applicable, the rights include knowing the categories and specific pieces collected, correction, deletion, portability, opting out of sale/sharing and limiting qualifying uses of sensitive information. You can also ask about disclosures for third parties' own direct marketing; we do not make those disclosures under this policy.

13. Security

We use measures intended to protect personal information, including controls on access to service systems. Security measures must be appropriate to the information and risks involved. No internet service can guarantee absolute security.

Protect your account and contact support if you suspect unauthorized access or a privacy incident. We will assess incidents and make notifications where applicable law requires them.

14. Complaints and policy updates

Contact support@pastry.com with a privacy complaint so the company can investigate and respond. This does not limit your right to contact a regulator or seek a legal remedy.

You can complain to Bulgaria's Commission for Personal Data Protection. You may also complain to another competent data-protection authority, including in the country where you live or work, or where you believe an infringement occurred.

When this policy changes, we will publish an updated version and effective date. Material changes will receive an appropriate notice, and we will obtain fresh consent where a new use requires it. We will not treat a policy update alone as permission for an incompatible new use of your information.