PRIVACY POLICY

1. Introduction

Baba Magic LLC ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our "baba" mobile and web application ("App").

Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE APP.

1.1 Key Points Summary

• We collect translation data, device information, and usage data
• We use your data to provide translation services and improve our AI models
• Your translations and uploaded images are used to train our AI systems
• We use third-party services including AI providers, cloud services, and analytics
• We do not sell your personal information to third parties
• You have rights to access, correct, and delete your data subject to certain limitations
• We comply with GDPR, CCPA, Israeli Privacy Protection Law, and other applicable privacy laws

1.2 Changes to This Policy

We may update our Privacy Policy from time to time. We will notify you of any material changes by email, a prominent notice within the App, or push notification. The "Last Updated" date at the top of this Privacy Policy indicates when it was last revised. Your continued use of the App following the posting of changes constitutes your acceptance of such changes.

2. Information We Collect

We collect several types of information from and about users of our App, including:

2.1 Information You Provide to Us

2.2 Information We Collect Automatically

3. How We Use Your Information

We use the information we collect for various purposes, including:

3.1 To Provide and Maintain the App

• Operating, maintaining, and improving the App
• Providing translation services to you
• Processing and completing transactions and subscriptions
• Sending you service-related communications
• Responding to your comments, questions, and customer service requests
• Providing technical support and troubleshooting

3.3 To Personalize Your Experience

• Personalizing your experience and customizing the content we display
• Remembering your preferences and settings
• Providing translation history and saved translations
• Offering relevant features and recommendations

3.4 To Communicate with You

• Sending you marketing communications about our products and services (you can opt out at any time)
• Informing you about new features, updates, and improvements
• Requesting feedback or participation in surveys
• Sending push notifications (you can disable these in your device settings)
• Responding to your inquiries and providing customer support

3.5 To Ensure Security and Prevent Fraud

• Monitoring and analyzing for security threats
• Detecting, preventing, and responding to fraud, abuse, or illegal activity
• Enforcing our Terms of Service
• Protecting the security and integrity of the App
• Verifying user identity and preventing unauthorized access

5. How We Share Your Information

We do not sell your personal information to third parties. However, we may share your information in the following circumstances:

5.1 With Your Consent

We may share your information with third parties when we have your explicit consent to do so.

5.2 With Service Providers

We share your information with third-party vendors, service providers, contractors, and agents who perform services on our behalf, including:

• AI and LLM Providers: We share translation requests with AI service providers (such as OpenAI, Anthropic, Google, or other LLM providers) to generate translations.
• Cloud Infrastructure Providers: We use cloud services (such as Supabase, AWS, Google Cloud) to host and store data.
• Subscription Management: We use RevenueCat to manage subscriptions and in-app purchases.
• Analytics Services: We use analytics providers (such as Google Analytics) to understand App usage.
• Customer Support Tools: We may use customer support platforms for communications.
• Email Services: We use email service providers to send transactional and marketing emails.

All service providers are authorized to use your information only as necessary to provide services to us and are contractually obligated to protect your information.

5.3 For Legal Reasons

We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to: comply with a legal obligation, protect and defend our rights or property, prevent or investigate possible wrongdoing in connection with the App, protect the personal safety of users of the App or the public, or protect against legal liability.

5.4 In Connection with a Business Transaction

We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on our App of any change in ownership or uses of your information.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

6.2 Specific Retention Periods

• Account Information: We retain your account information for as long as your account is active, plus 90 days after account deletion for backup and legal compliance.
• Translation Data and Uploaded Images: We retain your translation history and uploaded images for as long as your account is active. After account deletion, we may retain this data for up to 90 days for backup purposes.
• Usage and Log Data: We typically retain usage and log data for 12-24 months for analytics and security purposes.
• Financial Records: We retain payment and transaction records for 7 years as required by law.

7. Your Data Rights and Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information:

7.1 General Rights (All Users)

• Access: You can request a copy of the personal information we hold about you by contacting privacy@itsbaba.com.
• Correction: You can update your account information directly in the App settings, or contact us to correct inaccurate information.
• Deletion: You can request deletion of your account and personal information by contacting privacy@itsbaba.com. Please note the limitations regarding AI training data.
• Marketing Opt-Out: You can opt out of receiving marketing emails by clicking the "unsubscribe" link or adjusting preferences in the App.

7.2 GDPR Rights (EEA, UK, and Switzerland Users)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have additional rights under the GDPR:

• Right of Access: Request access to the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete personal data
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data, subject to certain exceptions
• Right to Restriction of Processing: Request restriction of processing under certain circumstances
• Right to Data Portability: Receive a copy of your personal data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Withdraw consent at any time (note: withdrawing consent for AI training may not be possible once data is incorporated into trained models)
• Right to Lodge a Complaint: Lodge a complaint with a supervisory authority in your country

7.3 CCPA Rights (California Users)

If you are a California resident, you have specific rights under the CCPA and CPRA:

• Right to Know: Request disclosure of categories and specific pieces of personal information we collected
• Right to Delete: Request deletion of your personal information, subject to certain exceptions
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out of Sale: We do NOT sell your personal information
• Right to Non-Discrimination: You will not receive discriminatory treatment for exercising your CCPA rights

7.4 Israeli Privacy Rights

If you are located in Israel, you have rights under the Protection of Privacy Law (PPL), as amended by Amendment 13 (effective August 2024):

• Right of Access
• Right to Correction
• Right to Deletion
• Right to Object
• Right to Lodge a Complaint with the Israeli Privacy Protection Authority

8. International Data Transfers

Your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

8.1 Primary Operations

We primarily operate in the United States, with the founder based in Israel and development team members located globally. Your information may be transferred to and processed in the United States, Israel, and countries where our service providers or partners are located. We will take steps to ensure that your information receives an adequate level of protection in these jurisdictions.

8.2 European Economic Area (EEA) Data Transfers

If you are a resident of the EEA, United Kingdom, or Switzerland, we will only transfer your personal data outside of the EEA under one of the following mechanisms: Adequacy Decisions, Standard Contractual Clauses (SCCs), Other Approved Mechanisms, or when Necessary for Contract Performance.

9. Security

We take reasonable measures to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Our security measures include:

9.1 Technical Safeguards

• Encryption: We use encryption to protect sensitive information transmitted online (TLS/SSL for data in transit)
• Data Encryption at Rest: Sensitive data is encrypted when stored in our databases
• Secure Authentication: We use secure authentication mechanisms and password hashing (e.g., bcrypt)
• Access Controls: We implement role-based access controls and the principle of least privilege
• Firewalls and Network Security: We use firewalls and network segmentation to protect our systems

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

9.5 Data Breach Notification

In the event of a data breach that affects your personal information, we will notify you without undue delay as required by applicable law, notify relevant data protection authorities as required, and provide information about the breach and steps you can take to protect yourself.

10. Children's Privacy

Our App is intended for general audiences. While we do not specifically target children, we recognize that users of various ages may use translation services.

We do not knowingly collect personal information from children under the age of 13 (or the applicable age of digital consent in your jurisdiction, which may be 16 in certain countries) without verifiable parental consent.

If you are a parent or guardian and believe that your child under the applicable age has provided us with personal information without your consent, please contact us at privacy@itsbaba.com.

20. Questions, Concerns, and Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact us at:

20.2 Supervisory Authorities

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates data protection laws.

If you are located in Israel, you may contact the Israeli Privacy Protection Authority at privacy@justice.gov.il