Privacy Policy
Last updated: June 25, 2026
This is not legal advice.
1. Who We Are
Silmari ("Silmari," "we," "us") is a narrative-driven AI entertainment service — persona-based fictional character chat, not an AI companion or relationship-substitute service — operated by FunnelLabs Inc., 401ho, 2652, Nambusunhwan-ro, Seocho-gu, Seoul, Republic of Korea 06739. This Policy explains what personal data we collect, how we use it, and the rights you have. For payment processing, see Section 9.
2. Information We Collect
Account data: email, username, hashed password, authentication identifiers.
Conversation data: messages you exchange with our AI characters and the content we generate for you.
Transaction data: purchase records and subscription status (full payment-card data is handled by our payment provider — see §9).
Device & usage data: IP address, device/OS, app interactions, approximate region, cookies/SDK identifiers.
We do not knowingly collect data from anyone under 18 (see §11).
3. How We Use Your Information
To provide the Service: generate AI character chats. To maintain accounts, process purchases, and deliver purchased results. To improve, secure, and troubleshoot the Service. To detect fraud, abuse, and safety risks (including self-harm signals — see §12). To comply with legal obligations.
Legal bases (GDPR/EEA users): performance of contract; your consent; legitimate interests (security, improvement); and legal obligation.
4. Sensitive Information
We do not intentionally collect special categories of sensitive personal data. Please do not share sensitive information (such as health, religious beliefs, or precise location) in your conversations. If you voluntarily provide such information, you consent to our processing it to operate the Service, and you may withdraw that consent at any time.
5. We Do Not Sell Your Data
We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising as defined under the CCPA/CPRA. We do not use your conversation data to train third-party machine-learning models without your consent.
6. How We Share Information (Processors)
We share data only with service providers acting on our instructions — such as cloud hosting, analytics, customer support, AI model providers, and our payment provider. We require them to protect your data and use it only to provide services to us. We may disclose data where required by law or to protect safety and rights.
7. International Data Transfers
We are based in Korea and use providers located in the United States and other countries. Where we transfer personal data internationally, we rely on appropriate safeguards (e.g., your consent, Standard Contractual Clauses, or adequacy decisions). For Korean users, we obtain separate consent for overseas transfer as required by the Personal Information Protection Act (PIPA), disclosing the recipient, items, country, purpose, and retention period.
8. Data Retention & Security
We keep personal data while your account is active and delete it within 30 days of account deletion, except where law requires longer retention (e.g., transaction/tax records). We protect data with encryption in transit (TLS) and at rest, access controls, and other safeguards.
9. Payments
Payments are processed by our merchant-of-record payment provider (Creem), which acts as the seller of record and an independent controller of your checkout/payment data under its own privacy policy. We receive transaction confirmations but do not store full card numbers.
10. Your Rights
EEA/UK (GDPR): access, rectification, erasure, restriction, portability, objection, and withdrawal of consent; the right to lodge a complaint with a supervisory authority.
California (CCPA/CPRA): know, delete, correct, opt out of sale/sharing, limit the use of sensitive personal information, and non-discrimination. You may exercise "Do Not Sell or Share My Personal Information" — we honor this even though we do not sell.
Korea (PIPA): access, correction, deletion, suspension of processing, and withdrawal of consent.
To exercise your rights, email support@funnellabs.app. We verify requests before acting.
11. Children
The Service is for users 18 and older. We do not knowingly collect data from anyone under 18. If we learn that we have, we delete it.
12. Safety
Our AI applies safeguards against harmful content. If we detect indications of self-harm or suicide, we may surface crisis resources (e.g., the 988 Suicide & Crisis Lifeline in the US, and Korea's 109 line). The Service is for entertainment and is not a crisis, medical, or counseling service. See our AI Disclosure & Safety Notice for the full protocol.
13. Contact
Privacy inquiries: support@funnellabs.app · FunnelLabs Inc., 401ho, 2652, Nambusunhwan-ro, Seocho-gu, Seoul, Republic of Korea 06739.