The provisions of this Privacy Policy extend to all interactions with the App, irrespective of the User’s status or method of access. Particular attention is given to the protection of personal information belonging to minors, with specific protocols established for users aged 13 to 17 and those under 13, as mandated by Sections 1 Terms. These protocols are designed to align with international standards for data privacy and child protection, ensuring that the App’s operations adhere to the legal frameworks governing the collection and handling of sensitive data.

Sthirah engages in the collection of various categories of information to facilitate the provision and enhancement of the App’s services. This includes, but is not limited to, the following types of data:

a) Personal Information: Sthirah may gather identifiable details such as your full name, email address, date of birth or age verification, and other contact information provided during the registration process or account setup. For Users opting into subscription plans, one-time purchases, or discounted purchases, payment-related data, including credit card details, is collected and processed securely through Stripe, Inc. (“Stripe”), our third-party payment processor, as detailed in Section 7.1 of the Terms. Sthirah does not store or process payment data directly, and all transactions are subject to Stripe’s Terms and Conditions (https://stripe.com/legal) and Privacy Policy (https://stripe.com/privacy). For Users under the age of 18, supplementary data may be obtained, such as parental consent forms or government-issued identification from legal guardians, to comply with the age verification requirements outlined in Sections 1.1 and 1.2 of the Terms.

b) User-Generated Content: The App permits Users to submit, post, or display a wide array of materials, collectively referred to as “Content” under Section 6 of the Terms. This encompasses text, images, audio, video, or any other data uploaded by Users, including prompts submitted to the App’s artificial intelligence features (“AI Features”) and the resulting AI-generated outputs, which may contain personal or sensitive information subject to the terms of this Policy. You acknowledge that AI-generated outputs are based on statistical models and may contain errors, biases, or unintended content, as stated in Section 6.3 of the Terms, and that such outputs are not professional psychological, counseling, or mental health advice, as clarified in Section 6.4 of the Terms.

c) Technical Data: In the course of your interaction with the App, technical information is automatically collected, including your device’s IP address, browser type, operating system, and other metadata. Usage patterns, such as session duration and features accessed, are tracked using cookies, analytics tools, and similar technologies integrated into the App’s technology stack, as detailed in Section 3 of the Terms. Furthermore, if you have enabled location services, geolocation data may be gathered to personalize AI-driven features or optimize service delivery.

d) Children’s Data (Under 13): For Users under the age of 13, Sthirah restricts data collection to the minimum necessary to provide access to the App and ensure compliance with COPPA. This may include a username, email address, and documentation verifying parental consent. Sthirah expressly undertakes not to knowingly collect or retain additional personal information from such Users beyond what is strictly required, unless explicit authorization is provided by a parent or legal guardian in accordance with Section 1.2 of the Terms.

The collection of information by Sthirah occurs through multiple channels to support the App’s functionality and legal obligations. This includes direct submission by Users during registration, subscription purchases, or the uploading of Content. Additionally, technical data is gathered automatically through the App’s underlying infrastructure, which incorporates technologies such as Amazon CloudWatch and Redis Cache, as outlined in Section 3 of the Terms. Information may also be obtained from third-party service providers, such as Stripe for payment processing or providers facilitating parental consent verification. For Users under 18, the consent process involves the submission of verifiable documentation—such as email confirmations or signed forms—directed to info@sherpalai.com, as stipulated in Sections 1.1 and 1.2 of the Terms.

Sthirah utilizes the collected information for a variety of operational and legal purposes, including the provision, maintenance, and continuous improvement of the App. This encompasses the deployment of AI Features, such as content generation and personalization, as described in Section 3.1 of the Terms, with reasonable technical controls and guardrails to prevent abuse, as outlined in Section 6.3 of the Terms. The information is also employed to process subscription payments, one-time purchases, and discounted purchases through Stripe, Inc., and manage account-related transactions under Section 7 of the Terms, as well as to verify the age and parental consent of Users under 18 to ensure adherence to COPPA and similar regulations. Communication with Users, including the delivery of notices or updates as required under Section 19 of the Terms, relies on the collected data. Sthirah may use this information to safeguard the App’s security, investigate potential violations of the Terms, and enforce its legal rights as delineated in Section 22 of the Terms. Analytical use of the data to enhance user experience is conducted, with User consent obtained where mandated by applicable law. You acknowledge that AI-generated outputs are not professional psychological, counseling, or mental health advice, as stated in Section 6.4 of the Terms, and Sthirah disclaims liability for any reliance on such outputs.

Recognizing the vulnerability of minors, Sthirah implements heightened protections for Users under the age of 18, with distinct measures for those aged 13 to 17 and those under 13.

a) Users Aged 13-17: Access to the App by individuals within this age range is contingent upon the verifiable consent of a parent or legal guardian, to be provided through methods such as email verification or the submission of a signed consent form to info@sherpalai.com, as specified in Section 1.1 of the Terms. Parents or guardians, as included in the definition of “You” under Section 2 of the Terms, bear joint and several responsibility for supervising the minor’s use of the App, ensuring compliance with the Terms, and monitoring the Content accessed or submitted. Sthirah reserves the right to request proof of age and consent at any time, and failure to provide such documentation within a reasonable timeframe may result in account suspension or termination under Section 13 of the Terms. Parents or guardians may submit a written request to info@sherpalai.com to terminate their child’s account and request the deletion of associated personal data, subject to the data retention obligations outlined in this Policy and applicable laws.

b) Users Under 13: The use of the App by children under 13 is permitted exclusively with the express, verifiable consent of a parent or legal guardian, in strict accordance with COPPA and other child protection statutes, as detailed in Section 1.2 of the Terms. This consent must be obtained through a designated process, which may include the submission of a signed consent form, completion of an online registration, or other electronic verification methods that Sthirah may implement or modify without prior notice. Parents or guardians, as included in the definition of “You” under Section 2.3 of the Terms, consenting on behalf of a child under 13 are required to review this Policy in its entirety, agree to supervise the child’s activities, and accept joint and several liability for the child’s actions within the App. To comply with legal and safety standards, Sthirah may impose restrictions on the features, functionality, or Content available to such Users. Sthirah further commits to collecting, processing, or retaining only the personal information strictly necessary to provide the App and meet COPPA requirements, unless otherwise authorized by the parent or guardian. Parents retain the right to revoke consent and request the deletion of their child’s data at any time by contacting info@sherpalai.com, subject to applicable legal retention periods. Sthirah reserves the authority to terminate access for Users under 13 if consent is not verified, is withdrawn, or if the child’s use contravenes the Terms or relevant laws.

Sthirah adheres to a strict policy of not selling personal information to third parties. However, the sharing of information may occur under the following circumstances: with service providers, such as third-party vendors listed in Section 3 of the Terms (e.g., Amazon S3, MS SQL Server) and Stripe, Inc. (“Stripe”), which processes payment-related data for subscriptions, one-time purchases, and discounted purchases as detailed in Section 7.1 of the Terms, who assist in operating the App and are bound by confidentiality agreements; for legal compliance, where disclosure is mandated by law enforcement, regulatory authorities, or pursuant to a court order, or to protect Sthirah’s rights and interests as outlined in Section 22 of the Terms; with the express consent of the User or, in the case of Users under 13, with the approval of their parent or legal guardian for specific purposes; and in the event of a business transfer, such as a merger or acquisition, where your data may be transferred to a successor entity, provided that such entity agrees to be bound by the terms of this Policy. Any sharing of information is conducted with due diligence to safeguard your privacy and comply with applicable legal standards.

Sthirah is committed to protecting the confidentiality and integrity of your personal information by implementing reasonable technical and organizational measures, consistent with industry standards and the requirements of Section 22 of the Terms. These measures include, but are not limited to, encryption protocols, access controls, and regular security assessments to mitigate risks of unauthorized access or data breaches, as part of the controls and guardrails outlined in Section 6.3 of the Terms. Notwithstanding these efforts, Sthirah acknowledges that no electronic system can be rendered entirely impervious to security threats. Accordingly, Sthirah expressly disclaims liability for any unauthorized access, data breaches, or losses resulting from circumstances beyond its reasonable control, including acts of third parties or unforeseen technical failures, to the fullest extent permitted by Texas law, including the Texas Business and Commerce Code. In the event of a data breach that compromises your personal information, Sthirah undertakes to notify affected Users in accordance with applicable laws, such as within 72 hours as required under the GDPR or as mandated by state-specific regulations like the CCPA. Such notifications will be delivered via email or through the App interface, provided Sthirah maintains current contact information for the affected User. Users are further responsible for maintaining the confidentiality of their account credentials and are obligated to promptly notify Sthirah at info@sherpalai.com of any suspected unauthorized access or security incidents.

As a User of the App, you are endowed with certain rights and options regarding the management of your personal information, which are designed to empower you and, where applicable, your parents or legal guardians. You may submit a written request to info@sherpalai.com to access the personal information Sthirah holds about you or to request corrections to inaccurate data, and Sthirah will endeavor to respond within a reasonable timeframe in accordance with applicable law. Similarly, you may request the deletion of your personal information, subject to legal retention obligations or the need to fulfill contractual commitments under the Terms. For non-essential data collection activities, such as analytics or marketing, you may opt out where required by law, though this may impact the functionality or personalization of the App. In the case of Users under 18, parents or legal guardians possess the authority to review, modify, or delete their child’s personal data and may revoke previously granted consent at any time by contacting info@sherpalai.com, with such requests processed subject to the data retention requirements stipulated herein and by applicable regulations. Sthirah reserves the right to verify the identity of individuals making such requests to ensure the security and accuracy of data handling.

Given the global nature of the App’s cloud-based infrastructure, personal information may be stored, processed, or transferred to servers located in the United States or other jurisdictions through services such as Amazon ECS, as detailed in Section 3 of the Terms. For Users accessing the App from outside the United States, Sthirah ensures compliance with the GDPR and other local privacy laws by implementing appropriate safeguards, including the use of Standard Contractual Clauses or other legally recognized mechanisms for cross-border data transfers. Users are advised that the data protection laws in the United States or other countries may differ from those in their home jurisdiction, and by using the App, they consent to such transfers, subject to the protections outlined in this Policy.

Sthirah adheres to a policy of retaining personal information only for the duration necessary to achieve the purposes for which it was collected, as described in this Policy, or as required to comply with legal, regulatory, or contractual obligations. This includes the fulfillment of subscription services, the enforcement of the Terms, and the resolution of disputes. For Users under the age of 13, data will be deleted promptly upon the revocation of parental consent, unless retention is mandated by law, such as for compliance with COPPA or other child protection statutes. Sthirah maintains internal policies to periodically review and purge data that no longer serves a legitimate purpose, ensuring alignment with privacy best practices.

The App employs cookies, web beacons, and similar tracking technologies to enhance its functionality, personalize user experiences, and analyze usage patterns. These technologies, integrated into the App’s frontend and cloud infrastructure as noted in Section 3 of the Terms, may collect data such as session identifiers, page views, and device information. Users retain the ability to manage their cookie preferences through their browser settings or by following opt-out instructions provided within the App, where applicable. However, disabling cookies may result in reduced functionality or an impaired user experience, and Sthirah disclaims liability for any such limitations arising from User choices.

Sthirah reserves the right to amend this Privacy Policy at its sole discretion to reflect changes in its data practices, technological advancements, or evolving legal requirements. Any such modifications will be communicated to Users through email notifications or prominent updates within the App interface, as permitted under Section 19 of the Terms. Continued use of the App following the effective date of any amendment shall constitute your binding acceptance of the revised Policy. Users are encouraged to review this Policy periodically to remain informed of current practices.

This Privacy Policy, including the collection, use, storage, processing, and disclosure of your personal information, shall be governed by and construed in accordance with the laws of the State of Texas, without regard to its conflict of law principles. You agree that any dispute, claim, or legal action arising out of or relating to this Policy, the App, or your personal information, including but not limited to data privacy or security issues, shall be brought exclusively in the state or federal courts located in Harris County, Texas. You irrevocably consent to the personal jurisdiction and venue of such courts and waive any objection based on inconvenient forum or improper venue. Notwithstanding the foregoing, payment-related disputes processed through Stripe, Inc. (“Stripe”) shall be subject to Stripe’s Terms and Conditions, available at https://stripe.com/legal, as provided in Section 7.1 of the Terms. Sthirah, Inc. (“Sthirah”, “we”, “us”, or “our”) reserves the right to seek injunctive or equitable relief in any court of competent jurisdiction to protect its intellectual property, confidential information, or other rights under this Policy. If you are a minor, your parent or legal guardian, as included in the definition of “You” under Section 2 of the Terms, is jointly and severally bound by this jurisdiction clause. This Section shall apply to the fullest extent permitted by Texas law, including the Texas Business and Commerce Code and Texas Civil Practice and Remedies Code.

For any inquiries, concerns, or to exercise your rights under this Policy, please direct your correspondence to Sthirah, Inc. at the following address: 3903 Garnet Fls, Sugar Land, TX 77479, Houston, Texas, or via email at info@sherpalai.com. Sthirah is committed to addressing your requests promptly and in accordance with applicable privacy laws, and we welcome the opportunity to assist you in safeguarding your personal information.