Privacy Policy

This Privacy Policy explains how The Leo King, Inc. ("SpiritDial," "we," "us," or "our") collects, uses, discloses, and retains personal information when you use SpiritDial.ai, Lady Avalon Live, our mobile and ChatGPT applications, subscriptions, credits, generated media, and related services (the "Services"). It also explains choices and rights that may apply to you. Please also read our Terms of Service.

1. Scope and Roles

This Policy applies to information SpiritDial controls. Third-party platforms may separately control information they collect. For example, when you use SpiritDial through ChatGPT, OpenAI controls your ChatGPT account and may process prompts, app interactions, device information, and related data under OpenAI’s own privacy policy. App stores, identity providers, and payment providers also process information under their own policies.

2. Information We Collect

• Account and contact information: name, email address, account and user identifiers, authentication status, support communications, and preferences.
• Age and eligibility information: date of birth or age-related confirmation when provided or reasonably required to apply age restrictions or legal protections.
• Spiritual and reading information: prompts, messages, questions, chat history, tarot selections, reading results, optional birth date, birth time, birth city, coordinates derived from a selected birth location, astrological information, relationship context, and other details you choose to provide.
• Voice, image, and video information: audio, transcripts, photographs or other uploads, generated images and audio, live-avatar session media, and associated metadata when you use those features.
• Payment and entitlement information: subscription tier, purchase and renewal status, product identifiers, credits, included minutes, transaction and fulfillment identifiers, billing-provider customer identifiers, amounts, currency, refunds, and charge status. SpiritDial does not store full payment-card numbers.
• Device, network, and usage information: browser or device type, IP-derived information, user agent, timestamps, pages and features used, clicks, session and queue status, crash and diagnostic data, model and provider telemetry, token counts, latency, safety events, and approximate location inferred from IP where providers make it available.
• Support and safety information: support tickets, messages, receipt identifiers, issue classifications, fraud or abuse signals, reports, and records needed to investigate security, billing, safety, or legal issues.

3. How We Collect Information

• directly from you when you create an account, enter a prompt, speak, upload content, purchase, contact support, or configure a reading;
• automatically from the website, app, device, and use of the Services;
• from platforms and providers such as ChatGPT/OpenAI, Clerk, Stripe, Apple, Tavus, Daily, Vercel, Convex, and communications providers; and
• from safety reports, public sources, and other users when reasonably necessary to investigate misuse or protect the Services.

4. How We Use Information

• provide, personalize, and maintain chat, voice, avatar, tarot, astrology, image, support, billing, and sharing features;
• authenticate users, maintain accounts, fulfill purchases, meter usage, prevent duplicate charges, and provide customer support;
• send prompts and necessary context to AI and feature providers to generate requested outputs;
• monitor performance, evaluate output quality, troubleshoot errors, develop and improve features, and understand aggregate usage;
• moderate content, enforce age and safety restrictions, detect fraud or abuse, protect users and systems, and investigate incidents;
• communicate service, security, transactional, policy, and—with permission where required—marketing messages;
• comply with legal obligations, respond to lawful requests, establish or defend legal claims, and enforce our agreements; and
• create aggregated or de-identified information that is not reasonably linkable to an individual.

5. AI Processing and Sensitive Content

Your prompts and uploads may reveal sensitive or deeply personal information, including beliefs, relationships, emotional concerns, birth information, voice, or images. Do not provide information you do not want processed. We and our providers may analyze content to generate responses, apply safety protections, prevent abuse, troubleshoot, and evaluate or improve the Services. SpiritDial does not claim that a spiritual or AI-generated inference is true. We do not use sensitive personal information to determine eligibility for employment, housing, credit, insurance, healthcare, education, or another high-impact service.

6. Voice, Video, and Biometric Boundary

Voice and live-avatar features may transmit audio, video, transcripts, and session signals to voice, avatar, media, and AI providers so the feature can operate. SpiritDial does not use these features to enroll a biometric identifier, identify you through facial recognition, or match your face or voice against an identity database. Providers may process technical face, voice, or presence signals to render media, reduce noise, detect speech, or operate their services under their own policies. Do not use these features in a place where others can be recorded without notice or consent.

7. How We Disclose Information

• Service providers: companies that provide AI generation, hosting, databases, authentication, analytics, payments, email, customer support, voice, video, avatar, search, astrology calculations, security, and related infrastructure. Depending on the feature, these may include OpenAI, Clerk, Convex, Vercel, Stripe, Apple, Tavus, Daily, ElevenLabs, Resend, Brave, and astrology-service providers.
• At your direction: recipients, platforms, or members of the public when you choose to share, publish, export, or connect content.
• Legal and safety recipients: courts, regulators, law enforcement, advisers, or affected parties when we reasonably believe disclosure is required by law or necessary to protect rights, safety, property, users, or the Services.
• Business transfers: actual or prospective parties and advisers involved in a merger, financing, acquisition, reorganization, bankruptcy, or sale of assets, subject to appropriate protections.
• Affiliates: controlled affiliates that support the Services and follow protections consistent with this Policy.

We do not sell personal information for money. We do not sell or share personal information for cross-context behavioral advertising, and we do not knowingly sell or share the personal information of users under 16. If our practices change, we will provide legally required notice and choices before the change applies.

8. ChatGPT App Privacy

• When you invoke the SpiritDial ChatGPT app, OpenAI may send SpiritDial the prompt, requested tool parameters, a pseudonymous or account-linked identifier, and other information needed to fulfill the request.
• SpiritDial returns requested results and operational metadata to ChatGPT so OpenAI can display the experience.
• Do not send SpiritDial information through ChatGPT that you would not want both OpenAI and SpiritDial to process.
• Your ChatGPT settings, OpenAI account type, parental controls, and OpenAI privacy choices are managed by OpenAI, not SpiritDial.

9. Public Sharing and Other People’s Information

Some features create share links for readings or generated media. A person with the link may be able to view, save, or redistribute the shared material. Review content carefully before sharing it and do not include private information. You are responsible for having permission before submitting another person’s image, voice, birth data, messages, or other information. Never upload intimate content or content depicting a minor.

10. Children and Teens

• The Services are not directed to children under 13, and we do not knowingly collect personal information directly from a child under 13. A person under 13 may not create an account or use the Services.
• Users ages 13 through 17 must have a parent or legal guardian’s permission and supervision. When used through ChatGPT, OpenAI’s teen requirements and protections also apply.
• Teen users should not disclose a home or school address, phone number, government identifier, payment information, precise real-time location, intimate content, or another person’s private information in prompts or uploads.
• We do not knowingly sell or share teen personal information for cross-context behavioral advertising or use it for targeted advertising.
• If we learn that we collected personal information directly from a child under 13 without legally valid authorization, we will take reasonable steps to disable access and delete the information as required by law. A parent or guardian may contact privacy@spiritdial.ai to report an underage account or request review or deletion. We may ask for information reasonably necessary to verify the requester’s identity and relationship to the child.

11. Cookies, Local Storage, and Analytics

We and our providers use cookies, local storage, pixels, SDKs, and similar technologies for authentication, security, preferences, payments, performance, and analytics. Some are necessary for the Services to function. Browser or device controls may limit optional technologies but may also affect features. Because we do not sell or share personal information for cross-context behavioral advertising, we do not currently respond differently to Global Privacy Control or "Do Not Track" signals for that purpose; we will honor legally required signals if our practices change.

12. Retention

We retain information only as long as reasonably necessary for the purposes described in this Policy, including to maintain an account, provide requested history and media, fulfill transactions, resolve disputes, enforce agreements, maintain safety and security, and meet legal, tax, accounting, and audit obligations. Retention varies by category. Short-lived webhook deduplication records may be kept for approximately 24 hours; account content and generated media may remain until deletion or account closure; and billing, fraud, security, and legal records may be kept longer where required or reasonably necessary. Backups and provider systems may take additional time to cycle out. We may retain aggregated or de-identified information where it can no longer reasonably identify you.

13. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information, including access controls, authenticated provider requests, payment-provider separation, and security monitoring. No internet service, transmission, model, or storage system is completely secure. You are responsible for protecting your credentials and device and for avoiding sensitive information that is not needed for a reading.

14. Your Choices and Privacy Rights

• You may update certain account information and manage subscriptions through the applicable account, billing portal, or app marketplace.
• You may ask to access, correct, delete, or obtain a copy of eligible personal information, or object to or restrict certain processing, by emailing privacy@spiritdial.ai.
• You may unsubscribe from marketing email using its unsubscribe link. We may still send transactional, security, legal, and service messages.
• Depending on where you live, you may have rights to know categories and specific pieces of personal information, request correction or deletion, obtain a portable copy, opt out of sale, sharing, targeted advertising, or certain profiling, limit certain uses of sensitive personal information, appeal a denied request, or complain to a regulator.
• We will not discriminate against you for exercising a privacy right. We may verify your identity and authority, deny or limit a request where permitted by law, and retain information subject to a legal exception. An authorized agent may submit a request where allowed, subject to verification.

15. California Notice at Collection

In the preceding 12 months, we may have collected the categories described in Section 2: identifiers; customer-record and commercial information; internet or electronic activity; approximate geolocation; audio, visual, and similar information; user content; sensitive personal information you choose to provide; and inferences generated to provide readings and personalize features. We collect, use, retain, and disclose these categories for the purposes in Sections 4 and 7. We do not use or disclose sensitive personal information to infer characteristics for purposes outside those permitted by California law. We do not offer financial incentives for personal information. California residents may exercise applicable rights using the contact in Section 20.

16. International Users

SpiritDial is based in the United States, and information may be processed in the United States and other countries where we or our providers operate. Those countries may have different privacy laws. Where required, we use appropriate transfer safeguards. For users in the EEA, United Kingdom, or similar jurisdictions, our legal bases may include performance of a contract, legitimate interests in operating and protecting the Services, consent where requested, and compliance with legal obligations. You may have a right to withdraw consent and complain to your local authority.

17. Third-Party Links and Features

The Services may link to or integrate third-party sites and services. We do not control their independent privacy or security practices. Review their policies before providing information or using their features.

18. Changes to This Policy

We may update this Policy as the Services, providers, or law change. We will post the revised date and provide additional notice or request consent when required. Material changes apply prospectively.

19. Nevada and Other State Notices

Nevada residents may submit a verified request regarding covered information under Nevada law. Residents of other states with comprehensive privacy laws may exercise applicable rights described in Section 14. SpiritDial does not currently sell covered information as "sale" is defined by Nevada law.

20. Contact Us

The Leo King, Inc.
Attn: Privacy
18650 MacArthur Blvd., Suite 360
Irvine, CA 92612
privacy@spiritdial.ai