Privacy Policy

Last updated: 11/22/2024

1. Introduction

This Privacy Policy describes how we collect, use, and protect personal data of users of our Santa Claus Call application (hereinafter "the App"). The protection of personal data, particularly that of minors, is our highest priority.

2. Data Controller

  • Worksdem SRL
  • Via Concordia, 124 (CT)
  • info@worksdem.com

3. Data Collected

3.1 Adult Data

  • Email
  • Payment data (managed through Apple and Google stores)

3.2 Minor Data

  • Name
  • Date of birth
  • City of residence
  • Gender
  • Spoken language
  • Additional notes provided by parents
  • Audio recordings of interactions with AI

4. Purpose of Processing

Data is collected and processed to:

  • Provide the simulated Santa Claus call service
  • Personalize the child's experience
  • Manage in-app purchases
  • Ensure service security
  • Improve the service and AI algorithm

5. Legal Basis for Processing

  • Consent of parent or legal guardian for processing minor's data
  • Contract execution for service provision
  • Legitimate interest for service improvement

6. Data Retention

Data is retained for the duration of the account and for a maximum period of 12 months after its deactivation.

7. Data Sharing

We do not share personal data with third parties, except:

  • Payment service providers
  • Cloud hosting service providers
  • Competent authorities if required by law

8. Data Security

We implement technical and organizational security measures to protect personal data.

9. User Rights

Users have the right to:

  • Access their data
  • Rectify data
  • Delete data
  • Limit processing
  • Data portability
  • Object to processing

10. Contacts

To exercise your rights or for privacy questions:

  • Email: info@worksdem.com