This Privacy Policy describes how My Friend AI, SL ("Company", "we", "us", "our") collects, uses, stores, discloses, and protects your personal information when you use our TrendwatchAI service ("Service", "Services"). We also explain your rights regarding your personal information in accordance with the General Data Protection Regulation (GDPR) and applicable Spanish law.

By using the TrendwatchAI Services, you agree to the terms of this Privacy Policy.

1. Definitions

For the purposes of this Privacy Policy:

• Company (referred to as "My Friend AI, SL", "we", "us", or "our" in this Privacy Policy) refers to My Friend AI, SL, the legal entity providing the TrendwatchAI Services.

• Service refers to the TrendwatchAI service provided by the Company, including the web platform, analytical spreadsheets (Google Sheets, Excel, Airtable), and related functionalities.

• Personal Data means any information that relates to an identified or identifiable individual.

• Data Subject means the identified or identifiable natural person to whom the Personal Data refers.

• User ("you") means the individual accessing or using the Services.

• Usage Data refers to data collected automatically, either generated by the use of the Services or from the Service infrastructure itself (for example, the duration of a page visit).

• Data Controller means the natural or legal person who (alone or jointly with others) determines the purposes and means of the processing of Personal Data. For the purpose of this Privacy Policy, we are the Data Controller of your personal information.

• Data Processor means a natural or legal person who processes Personal Data on behalf of the Data Controller.

• GDPR means the General Data Protection Regulation (Regulation (EU) 2016/679).

2. Information We Collect

We collect various types of information to provide and improve our Services:

2.1. Personal Data Directly Provided by You:
* Contact and Account Information: When you register for our Services, create an account, or contact us, we collect information such as your name, email address, and possibly your phone number.
* Payment Information: If you purchase a subscription, we collect data necessary to process payments. This data may include credit or debit card information, which is processed by third-party payment systems (e.g., Stripe), and we do not store your full card number on our servers.

2.2. Usage Data Collected Automatically:
* When you access or use our Services, we may automatically collect certain information that is not always Personal Data but may be linked to you. This data may include: your IP address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

2.3. Social Media Information (Not User Personal Data):
* The TrendwatchAI Service is designed to analyze solely publicly available data from social media platforms (Instagram Reels, TikTok, YouTube Shorts) that you provide for tracking. We do not collect any personal data about the followers or visitors of the accounts you track. We also do not request or access your personal social media accounts, unless it is part of a direct request for support or debugging with your explicit consent.
* The data we collect from publicly available sources (e.g., view counts, likes, comments, video duration, text transcriptions of content, and other engagement metrics) is publicly available information and is not considered your personal data or the personal data of third parties under this Privacy Policy.

3. How We Use Your Information (Purposes and Legal Basis)

We use the collected information for the following purposes, relying on the relevant legal bases under GDPR:

3.1. Providing and Supporting Services (Legal basis: Performance of a contract – Art. 6(1)(b) GDPR):
* To manage your account and provide you with access to the Services.
* To process your subscriptions and payments.
* To provide access to analytical spreadsheets (Google Sheets, Excel, Airtable) with data.

3.2. Improving and Optimizing Services (Legal basis: Legitimate interest – Art. 6(1)(f) GDPR):
* To monitor the use of our Services and identify trends.
* To troubleshoot technical issues and enhance Service functionality.
* To develop new features and improve the user experience.

3.3. Communicating with You (Legal basis: Performance of a contract, Legitimate interest, Consent – Art. 6(1)(b), (f), (a) GDPR):
* To send you important notifications related to the Services (e.g., updates, changes to Terms or Policy).
* To respond to your support inquiries and provide assistance.
* With your consent, to send you marketing communications and offers that may be of interest to you. You may withdraw your consent at any time.

3.4. Complying with Legal Obligations (Legal basis: Legal obligation – Art. 6(1)(c) GDPR):
* To comply with applicable laws, rules, and regulations, including tax and accounting requirements.

3.5. Fraud Prevention and Security (Legal basis: Legitimate interest – Art. 6(1)(f) GDPR):
* To detect, prevent, and address fraud, security, or technical issues related to the Services.

4. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information only in the following cases:

4.1. With Service Providers: We may engage third-party companies and individuals to facilitate our Services, provide the Services on our behalf, perform Service-related services (e.g., payment processing, hosting, analytics), or to assist us in analyzing how our Services are used. These third parties have access to your personal information only to the extent necessary to perform their functions and are obligated not to disclose or use it for any other purpose.

4.2. With Affiliates: We may share your information with our affiliates, in which case we will require them to honor this Privacy Policy.

4.3. Business Transfers: In the event of a merger, sale of company assets, financing, or acquisition of all or a portion of our business, your personal information may be transferred. We will notify you before your personal information is transferred and becomes subject to a different Privacy Policy.

4.4. Law Enforcement: We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

4.5. For Other Legitimate Purposes: We may disclose your information when such disclosure is necessary to:
* Comply with a legal obligation.
* Protect and defend the rights or property of the Company.
* Prevent or investigate possible wrongdoing in connection with the Services.
* Protect the personal safety of Users of the Services or the public.
* Protect against legal liability.

5. Google Workspace APIs Data Usage

Since TrendwatchAI Services include providing data in Google Sheets, we explicitly affirm the following regarding any data obtained through Google Workspace APIs (including, but not limited to, Google Sheets):

• This data is NOT used to develop, improve, or train generalized artificial intelligence (AI) or machine learning (ML) models.

• This data is used solely for the specific purpose of providing our Service functionality, such as spreadsheet integration, analytics, and data delivery.

• This data is handled in strict accordance with the Google API Services User Data Policy and Google Workspace requirements.

• Access to this data is granted only with your explicit user consent and for the minimum scope necessary to provide the requested features.

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or when we are legally obligated to retain this data for longer time periods.

8. Your Data Protection Rights (GDPR)

In accordance with the GDPR, you have the following rights concerning your Personal Data:

8.1. Right to Access: You have the right to request copies of your Personal Data that we hold.
8.2. Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
8.3. Right to Erasure ("Right to be Forgotten"): You have the right to request that we erase your Personal Data under certain conditions.
8.4. Right to Restrict Processing: You have the right to request that we restrict the processing of your Personal Data under certain conditions.
8.5. Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions, in a structured, commonly used, and machine-readable format.
8.6. Right to Object to Processing: You have the right to object to our processing of your Personal Data under certain conditions, particularly when the processing is based on our legitimate interests.
8.7. Right to Withdraw Consent: Where we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
8.8. Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, in particular in Spain – the Agencia Española de Protección de Datos (AEPD), if you believe that we have violated your data protection rights.

To exercise any of these rights, please contact us at olewhale@gmail.com. We will respond to your request without undue delay and within one month of receipt of the request.

9. International Data Transfer

Your information, including Personal Data, may be stored and processed on computers located outside of your province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located in the EEA, and we transfer your Personal Data outside of the EEA, we ensure an adequate level of data protection by utilizing the following mechanisms:

• Adequacy Decisions: Transferring to countries that the European Commission has deemed to provide an adequate level of protection for Personal Data.

• Standard Contractual Clauses (SCCs): Entering into SCCs approved by the European Commission with the data recipients.

Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.

10. Children's Privacy

Our Services are not intended for individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under 16 without verification of parental consent, we will take steps to remove that information from our servers.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Services and store certain information. Cookies are small text files placed on your device that allow us to recognize your browser and collect information about your interaction with the Services.

• Types of Cookies: We use both "session" cookies (temporary, deleted after browser closure) and "persistent" cookies (remain on the device for a specified period).

• Purposes of Use: We use cookies to enable necessary functionality (e.g., authentication, session maintenance), for analytics (understanding Service usage), and to enhance your experience (remembering preferences).

• Your Choices: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Services.

12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will also notify you via email and/or a prominent notice on our Services before the change becomes effective, and update the "Effective Date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. Contact Information

If you have any questions regarding this Privacy Policy, please contact us at: olewhale@gmail.com.