PRIVACY POLICY

Last Updated: August 2026

This policy describes how DoaCam collects, uses, and protects your data, in compliance with the EU General Data Protection Regulation (GDPR) and the EU AI Act (Regulation 2024/1689).

1. Data Controller

DoaCam is an independent beta project. You can reach the data controller for any privacy request — access, rectification, erasure or any other right in Section 5 — through the Contact form in this application, or by post at:

DoaCam
Pere IV, 355
Barcelona, Spain

The controller's name and tax identification number are not yet published; see our Legal Notice. We have not appointed a Data Protection Officer, as we are not required to under GDPR Article 37.

2. What Data We Process

2.1. Data Processed Locally (Your Browser)

The following data is stored exclusively in your browser's LocalStorage / IndexedDB and never sent to our servers:

• UI preferences: microphone, camera, speaker, avatar and voice settings.
• Memory preferences and saved facts. (Saved facts are stored here, but a copy is sent to our backend at the start of each call so the avatar can use them — see 2.2.)
• Saved activity progress (for example an unfinished lesson or adventure), kept for 30 days so you can resume it.
• Age confirmation: the date of birth you enter at the age gate is stored in your browser. Only the derived age (a number) is sent to our backend, to set the session's content rules.
• A randomly generated, pseudonymous user identifier (doa_user_id) used to route your session to our backend. It is not linked to your identity and you can reset it at any time via Factory Reset.

2.2. Memory Feature

The "Local Memory" feature is part of the core companion experience and is enabled by default:

• The AI may save key facts about you (preferences, name, context) to your browser's IndexedDB.
• This data is sent to Google Gemini during active sessions to provide personalized responses.
• We process this data on the basis of our legitimate interest in providing the continuous companion experience the service is designed for (GDPR Art. 6.1.f). You can disable it at any time from Settings > Memory & Privacy > "Enable Local Memory" — this acts as an objection and stops all memory processing.
• You can also delete all stored memories at any time from the same settings panel, or perform a Factory Reset to wipe all data.

2.3. Data Sent to Google Gemini

During an active voice session, the following data is transmitted to Google's servers for AI processing:

• Audio from your microphone (real-time voice stream).
• Camera or screen images (if you enable video/screen sharing).
• Text messages (if you use the keyboard input).
• Memory context (only if the Memory feature is enabled).

The real-time conversation itself runs on the Google AI Studio API (free tier). Under that tier, your interactions may be used by Google to improve their AI models, per Google's API Terms of Service, and we have no control over that processing. Our background features — memory analysis, lore search and activity generation — run on a separate paid API key, under which Google does not use the content to train its models.

2.4. Data We Do NOT Collect

• We do not require an account: no registration, no password, no real name. The age gate asks for a date of birth, which stays in your browser — see 2.1.
• We do not use fingerprinting, advertising trackers, or sell data to third parties.
• The only case in which we receive your email address is if you voluntarily provide it through the Contact form (see Section 2.6).

2.5. Conversation and Operational Logs (Beta Phase)

DoaCam is currently in a beta phase. To debug issues, audit quality, and improve the product, our backend writes logs to Google Cloud. These logs include:

• Conversation transcriptions (your speech-to-text input and the AI's responses), associated with a per-session pseudonymous reference — not with your real identity, and not correlatable across sessions.
• Technical session events (connection, errors, tool usage).
• Client error reports (error message and stack trace) sent automatically when the app encounters a failure.

Because DoaCam is an adults-only companion service, a conversation may reveal information about your sex life or emotional state, which the GDPR treats as a special category of data (Art. 9). We therefore record conversation content only on the basis of your explicit consent (Art. 9.2.a), which you give at the age gate before your first call and can withdraw at any time by contacting us or by ceasing to use the service. Withdrawal does not affect processing carried out before it.

Logs are retained for a maximum of 30 days and then deleted automatically. They are used exclusively for debugging, quality auditing, and product improvement. They are never sold, and never shared with third parties beyond Google Cloud, which acts as our hosting processor.

2.6. Contact Form

If you use the Contact form, your email address and message are processed by Formspree (Formspree, Inc., USA), which acts as our form-processing provider, and are used solely to respond to your inquiry (GDPR Art. 6.1.b/f). We keep the correspondence for as long as needed to handle your request and up to one year afterwards. Because Formspree is based in the USA, this involves an international transfer — see Section 8. See Formspree's Privacy Policy.

2.7. Cookies, Local Storage and Analytics

DoaCam does not use cookies. We use Google Analytics 4 in a cookieless configuration: all browser storage is denied before the tag loads, so no analytics cookie (_ga or similar) is ever written and no persistent identifier is assigned to you. We receive only aggregate measurements — page views, session counts, approximate country — with no way to recognise you on a later visit. Because nothing is stored on or read from your device for this purpose, no cookie consent banner is required under Article 22.2 LSSI-CE.

The service does use your browser's LocalStorage and IndexedDB, but only for the data listed in Section 2.1 — the settings, memories and identifiers the application needs in order to work as you asked it to. These are not used for tracking or advertising, and you can erase all of them from Settings > Danger Zone > Factory Reset. Google Analytics still receives your IP address in order to deliver the measurement request; you can block it entirely with the Google Analytics Opt-out Browser Add-on.

3. AI Transparency (EU AI Act)

In accordance with EU AI Act Article 50 (Transparency obligations):

• AI Disclosure: A persistent badge informs you that you are interacting with an AI system during active sessions.
• Periodic Reminders: Hourly notifications remind you that the avatar is AI-generated.
• System Identification: DoaCam uses Google Gemini 3.1 Flash Live (a multimodal large language model with native audio capabilities) for real-time conversation, Google Gemini 3.1 Flash Lite for background memory analysis, Google Gemini 3.5 Flash for generating activity content, and Google Gemini Embedding 2 for character lore search.
• Limitations: The AI may produce inaccurate, biased, or fabricated information. It has no access to real-time data such as news or live web results, and no persistent awareness between sessions beyond the Memory feature.
• Synthetic Content: All avatar visuals, voice, and expressions are AI-generated. No real human is depicted or involved in the conversation.

4. Legal Basis for Processing

Under GDPR Article 6, we process your data based on:

• Performance of a service you requested (Art. 6.1.b): For audio and video processing during a call. Starting a call is the affirmative action that activates your microphone (and camera, only if you enable it); ending it stops the processing.
• Explicit consent (Art. 9.2.a): For recording conversation content during the beta phase, given at the age gate — see Section 2.5.
• Legitimate Interest (Art. 6.1.f): For the Memory feature (providing the continuous companion experience, with an opt-out in Settings), for technical logs and aggregate analytics, and for storing UI preferences locally to provide a functional experience.

5. Your Rights (GDPR)

You have the right to:

• Access: View what data is stored (Settings > Memory & Privacy), or ask us for a copy of anything we hold server-side.
• Rectification: Correct inaccurate facts the AI has saved about you, by editing or deleting them in Settings > Memory & Privacy.
• Erasure: Clear all memories (Settings > Memory & Privacy > WIPE) or all data (Settings > Danger Zone > Factory Reset), and request deletion of server-side logs.
• Restriction: Ask us to limit processing while a request of yours is being resolved.
• Withdraw Consent: Withdraw your consent to conversation recording, or disable the Memory feature, at any time.
• Portability: Your profile data is stored in your browser's local storage and can be exported.
• Object: Object to processing based on our legitimate interest. You may also stop using the service at any time — no account deletion is needed, as no account exists.

Since your profile data is stored locally in your browser, you have direct control over it — no request to us is needed for the rights above. For data we hold server-side (Section 2.5), use the Contact form; we will respond within one month. To let us locate your records, include the pseudonymous identifier shown in Settings.

If you believe we have mishandled your data, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD, C/ Jorge Juan 6, 28001 Madrid) or with the supervisory authority of your country of residence.

6. Age Restriction

DoaCam requires users to be at least 18 years old. By confirming your date of birth at the age gate you declare that you meet this requirement. Your date of birth is stored in your browser and never sent to us; only the age derived from it reaches our backend, where it sets the session's content rules and is held in memory for the duration of the call. No identity document is collected or processed. The service is not directed at minors and we do not knowingly process their data.

7. Data Retention

• Local data: Persists until you clear it manually or perform a Factory Reset. Saved activity progress expires after 30 days.
• Server-side sessions: Live session state is held in RAM only and destroyed on disconnect.
• Conversation and operational logs: Up to 30 days, then deleted automatically (see Section 2.5).
• Contact correspondence: Up to one year after your request is closed.
• Google Gemini: Session data is handled per Google's data retention policies.

8. International Data Transfers

Audio and video data is transmitted to Google's servers (located in the US and EU) during active sessions. Because the real-time conversation runs on the Google AI Studio API free tier, that processing is governed by Google's Gemini API Terms of Service rather than a dedicated data processing agreement, and Google may use the data as described in those terms (see Section 2.3). Operational logs are stored in Google Cloud (us-central1) under Google Cloud's data processing terms, which incorporate the European Commission's Standard Contractual Clauses. Contact-form submissions are processed by Formspree in the USA under its own terms. Transfers to the USA rely on the EU-US Data Privacy Framework and/or Standard Contractual Clauses, depending on the provider.

9. Changes to This Policy

We may update this policy to reflect changes in the service or legal requirements. Material changes will be communicated through the application.