Privacy Policy

CLIPO, Inc. | 1225 4th Street, Unit 119, San Francisco, CA 94158

Effective: March 5, 2026 | info@burnchat.ai | burnchat.ai/privacy

1. Introduction and Data Controller

This Privacy Policy describes how CLIPO, Inc. ("CLIPO," "we," "us," or "our") collects, uses, stores, discloses, and protects information when you use BurnChat ("Service") at burnchat.ai. BurnChat is designed with privacy as a core architectural principle: our Privacy Shield is built to reduce personally identifiable information in messages transmitted to AI model providers. This policy explains honestly and precisely what we do and do not collect.

Data Controller. CLIPO, Inc., 1225 4th Street, Unit 119, San Francisco, CA 94158, United States. Email: info@burnchat.ai.

EU/EEA Representative (GDPR Art. 27). To be designated. CLIPO will appoint and publish an EU representative before August 2, 2026. Until then, CLIPO directly handles EU data subject requests at info@burnchat.ai.

UK Representative (UK GDPR Art. 27). To be designated. CLIPO will appoint and publish a UK representative before August 2, 2026. Until then, contact info@burnchat.ai.

Data Protection Officer. CLIPO does not currently employ a DPO; info@burnchat.ai handles all data protection matters.

2. Summary of Our Core Privacy Architecture

Before we describe individual categories of data, we want to be specific and honest about how BurnChat's core architecture handles your messages:

  • Your chat messages are processed through Privacy Shield on your device before being sent to AI model providers. Privacy Shield replaces detected personally identifiable information with anonymized placeholders.
  • Privacy Shield is not perfect. It may miss PII (false negatives) or incorrectly replace non-PII content. On mobile, a lighter-weight NLP pipeline is used.
  • De-identified messages (after Privacy Shield processing) are transmitted to AI model providers via OpenRouter. OpenRouter and the underlying AI model providers process these messages under their own terms and privacy policies.
  • CLIPO does not use your messages to train AI foundation models.
  • "De-identified" in this policy means we have taken reasonable technical and organizational measures to prevent re-identification; it does not mean it is technically impossible to re-identify information in all circumstances.
  • We retain certain account and usage data described below. We do not sell your personal information.

3. Information We Collect

3.1 Information You Provide Directly

Account registration data: email address, name (optional), and password hash. You are not required to provide your phone number or government-issued identification.

Payment information: billing name, payment card data (processed and stored by Stripe, Inc. — CLIPO never stores full card numbers or CVV codes).

Support communications: email content you send to us for support or legal purposes.

3.2 Information Generated by Your Use of the Service

Usage data: the AI model selected, number of messages sent, credits and subscription tier, timestamps, and feature usage patterns (e.g., whether Privacy Shield was active).

Account metadata: account creation date, last login, authentication provider (e.g., Google OAuth token reference).

Technical data: IP address at login (stored for fraud prevention and security purposes; not linked to message content), browser/device type, operating system, and crash reports.

3.3 Information About Your Messages

CLIPO does not store the content of your chat messages on our servers in association with your identity. Your messages are processed through Privacy Shield on your device and the de-identified version is transmitted to AI model providers to generate responses. We do not retain the de-identified message content on our servers after the session.

Please note: AI model providers (accessed via OpenRouter) may process, log, or temporarily retain transmitted content under their own policies. Review OpenRouter's privacy policy and the applicable AI model provider's privacy policy for their practices.

3.4 Information from Third Parties

If you sign in with Google, we receive your Google account email address and a unique identifier from Google to authenticate your account. We do not receive your Google password or access to your Google data.

3.5 Sensitive Personal Information

We do not intentionally collect sensitive personal information ("SPI") as defined under the California Privacy Rights Act (Cal. Civ. Code § 1798.140(ae)), including Social Security numbers, financial account details beyond payment processing, health information, racial or ethnic origin, religious beliefs, sexual orientation, biometric data, or neural data. If you include such information in your chat messages, Privacy Shield is designed to detect and anonymize some categories of SPI, but this is not guaranteed. Do not include SPI in your messages if you do not wish it transmitted to third-party AI providers.

4. Legal Bases for Processing (GDPR / UK GDPR)

For users in the European Economic Area, United Kingdom, and other jurisdictions requiring a legal basis for processing, CLIPO processes personal data under the following bases:

  • Contract performance (GDPR Art. 6(1)(b)): Processing your account data, managing subscriptions and Credits, and providing the Service is necessary to perform our contract with you.
  • Legitimate interests (GDPR Art. 6(1)(f)): We process technical and usage data to improve the Service, detect fraud, maintain security, and operate our business. We have conducted a legitimate interest assessment (LIA) balancing our interests against your rights and freedoms; a summary is available on request from info@burnchat.ai.
  • Legal obligation (GDPR Art. 6(1)(c)): We may process data where required by applicable law, including responding to valid legal process.
  • Consent (GDPR Art. 6(1)(a)): Where we rely on consent (e.g., optional analytics, marketing communications), we will seek your explicit consent and you may withdraw it at any time without affecting the lawfulness of prior processing.

We do not use your data for AI model training. We do not process SPI without your explicit consent except where required by law.

5. How We Use Your Information

We use personal information to:

  • Create and maintain your account, authenticate your identity, and manage your subscription and credits;
  • Process payments and prevent fraud;
  • Provide, operate, and improve the Service;
  • Send transactional communications (account confirmations, receipts, security alerts, subscription notices);
  • Respond to your support inquiries;
  • Comply with applicable law, respond to legal process, and enforce our Terms of Service;
  • Detect, investigate, and prevent fraud, abuse, and security incidents;
  • Maintain the integrity and security of the Service.

We do not use your personal information to: sell advertising; profile you for targeted advertising; train AI models; or make fully automated decisions that produce legal or similarly significant effects without a human review option.

6. Automated Decision-Making and AI Processing

The Service generates AI responses through a process of automated decision-making. Responses are generated by AI systems and are probabilistic in nature. CLIPO does not use the Service to make legally significant decisions about individuals (such as credit decisions, employment decisions, or healthcare decisions). The AI output is provided as a tool to assist you, and all consequential decisions remain yours.

Consistent with GDPR Article 22, GDPR Recital 71, the EDPB's guidance on AI systems (Opinion 28/2024), the EU AI Act Article 50, and California's CPRA ADMT regulations (effective January 1, 2027), CLIPO discloses: BurnChat uses AI to generate conversational responses. AI outputs are probabilistic, may reflect training data biases, and may be factually incorrect. You should evaluate AI outputs critically and not rely on them as authoritative.

California residents: The California Privacy Protection Agency's ADMT regulations (effective January 1, 2027) will give you the right to opt out of ADMT and to access information about the logic involved. We will update this policy when those regulations take effect. In the meantime, you may contact info@burnchat.ai with questions about our use of automated decision-making.

7. Data Sharing and Disclosure

7.1 AI Model Providers

De-identified message content is transmitted to AI model providers via OpenRouter, Inc. OpenRouter routes requests to various underlying AI model providers. CLIPO takes reasonable contractual measures with OpenRouter to limit use of transmitted data. By using the Service, you acknowledge that de-identified messages are processed by these third parties.

7.2 Payment Processors

Payment information is processed by Stripe, Inc., subject to Stripe's privacy policy. CLIPO does not store full payment card data.

7.3 Authentication Providers

If you use Google Sign-In, authentication is handled by Google LLC, subject to Google's privacy policy.

7.4 Infrastructure

The Service is hosted on Vercel, Inc. (frontend) and Railway Corp. (backend), and uses Supabase for database services. These providers process data as described in their respective data processing agreements.

7.5 Legal Process and Law Enforcement

CLIPO may disclose information in response to valid legal process, including court orders, subpoenas, and other legally binding demands. Our ability to resist such requests is limited by applicable law. BurnChat's Privacy Shield architecture is designed to minimize the personal data we hold, thereby limiting our exposure to legal process. However, CLIPO will comply with valid legal process as required.

We will notify you of legal process demands where legally permitted. We will not provide access to data based on voluntary requests without legal compulsion unless required for immediate threats to safety.

7.6 Business Transfers

If CLIPO is acquired or merges with another company, your personal information may be transferred as part of the transaction. We will notify you of any such transfer and give you the opportunity to delete your account before your data is subject to a materially different privacy policy.

7.7 No Sale of Personal Information

CLIPO does not sell, rent, or trade your personal information to third parties for their commercial purposes. CLIPO does not share personal information with third parties for cross-context behavioral advertising.

8. International Data Transfers

CLIPO is based in the United States. Your personal data may be transferred to and processed in the US and other countries that may not have the same data protection laws as your country of residence.

EU/EEA users (GDPR Chapter V): We transfer personal data to the US relying on the EU-US Data Privacy Framework, Standard Contractual Clauses (SCCs) approved by the European Commission, or other approved mechanisms. A copy of applicable SCCs is available on request from info@burnchat.ai.

UK users: We rely on the UK International Data Transfer Agreement (IDTA) or UK Addendum to EU SCCs for transfers to the US.

Brazilian users (LGPD Art. 33): We transfer data to the US pursuant to standard contractual clauses approved by the ANPD, or other mechanisms permitted by the LGPD.

9. Data Retention

We retain personal information only as long as necessary for the purposes described in this policy, subject to longer retention required by applicable law.

  • Account data (email, name): Retained for the life of your account plus 3 years after account deletion for legal compliance and fraud prevention.
  • Payment records: Retained for 7 years from the date of transaction as required by applicable tax and financial regulations.
  • Usage/technical logs (IP address, session metadata): Retained for 90 days for security and fraud detection purposes.
  • Support communications: Retained for 3 years from the date of last communication.
  • De-identified message content: Not retained by CLIPO on our servers after session completion.

When retention periods expire, we delete or irreversibly anonymize data using industry-standard methods.

10. Your Rights and How to Exercise Them

10.1 Rights for California Residents (CCPA/CPRA)

Under the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended by the CPRA, you have the right to:

  • Know and access the categories and specific pieces of personal information we collect, use, disclose, and sell about you;
  • Delete personal information we hold about you, subject to certain exceptions;
  • Correct inaccurate personal information;
  • Opt out of the sale or sharing of personal information (CLIPO does not sell or share personal information);
  • Limit the use and disclosure of sensitive personal information to purposes necessary to provide the Service;
  • Not be discriminated against for exercising your privacy rights;
  • Opt out of automated decision-making technology (effective when CPPA ADMT regulations take effect January 1, 2027);
  • Data portability: receive your personal information in a machine-readable format.

To exercise these rights, submit a verifiable consumer request to info@burnchat.ai or use the in-app account settings. We will respond within 45 days (extendable by 45 additional days with notice).

Global Privacy Control (GPC): CLIPO's Service is designed to detect and honor GPC signals as opt-out-of-sale requests. If you enable GPC in your browser, CLIPO will treat your visit as an opt-out of sale and sharing of personal information.

Authorized Agent: You may designate an authorized agent to submit requests on your behalf by providing written authorization or a power of attorney.

10.2 Rights for EU / EEA Residents (GDPR)

Under the General Data Protection Regulation (Regulation (EU) 2016/679), you have the following rights:

  • Right of access (Art. 15): Obtain a copy of your personal data and information about how it is processed.
  • Right to rectification (Art. 16): Correct inaccurate or incomplete personal data.
  • Right to erasure (Art. 17): Request deletion of your data under certain conditions.
  • Right to restriction of processing (Art. 18): Restrict how we use your data in certain circumstances.
  • Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.
  • Right to object (Art. 21): Object to processing based on legitimate interests or for direct marketing.
  • Rights regarding automated decision-making (Art. 22): Not be subject to solely automated decisions producing legal or significant effects without human intervention.
  • Right to lodge a complaint: You may lodge a complaint with your local supervisory authority (e.g., the German BfDI, French CNIL, Irish DPC, or the supervisory authority in your EU member state).

To exercise GDPR rights, contact info@burnchat.ai. We will respond within 30 days (extendable to 60 days for complex requests with notice).

10.3 Rights for UK Residents (UK GDPR / DUA Act 2025)

UK residents have substantially equivalent rights under UK GDPR and the Data (Use and Access) Act 2025, including the rights listed in Section 10.2. You may also lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk. The DUA Act 2025 provides a right to lodge complaints electronically, which we facilitate through info@burnchat.ai.

10.4 Rights for Other Jurisdictions

Australian residents: Under the Privacy and Other Legislation Amendment Act 2024 (effective December 10, 2024), you have a right to a statutory tort action for serious privacy invasions. Australian residents may also request access, correction, and deletion of personal data under the Privacy Act 1988.

Canadian residents: Under PIPEDA (and Quebec's Law 25), you have rights to access, correction, and deletion. Quebec's Law 25 also provides rights regarding automated decision-making. Contact info@burnchat.ai to exercise these rights.

Brazilian residents: Under the LGPD (Lei No. 13.709/2018), you have rights of confirmation, access, correction, anonymization, portability, deletion, information about sharing, and human review of automated decisions (Art. 20). Contact info@burnchat.ai to exercise LGPD rights.

Indian residents: Under the Digital Personal Data Protection Act 2023 (DPDPA, with compliance required by May 2027), you will have rights to access, correction, erasure, and grievance redressal. We will update this policy as DPDPA implementing rules are finalized.

South Korean residents: Under the AI Basic Act (effective January 22, 2026) and the Personal Information Protection Act (PIPA), you have rights to access, correction, deletion, and portability. To exercise these rights, contact info@burnchat.ai.

11. Children's Privacy

The Service is not directed to children under 13. We do not knowingly collect personal information from children under 13 without verifiable parental consent. If we discover that a child under 13 has provided personal information without parental consent, we will delete it promptly.

COPPA Compliance (amended 2025 rule, effective April 22, 2026): CLIPO has implemented an age-neutral registration gate. We do not target the Service to children. We do not use personal information of users under 13 for targeted advertising or share it for commercial purposes. We do not condition a child's participation on disclosing more personal information than is necessary to use the Service.

If you are a parent or guardian and believe your child under 13 has created an account, contact info@burnchat.ai immediately.

12. Security

CLIPO implements technical and organizational security measures designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS), encrypted password storage, access controls, and regular security assessments.

No system is completely secure. In the event of a data breach affecting your rights and freedoms, CLIPO will notify applicable supervisory authorities within 72 hours (as required by GDPR Art. 33) and notify affected users without undue delay as required by applicable law. We will also notify you at your registered email address of breaches that pose a high risk to your rights.

13. Cookies and Tracking Technologies

BurnChat uses essential cookies necessary to operate the Service (authentication, session management, security). We do not use third-party advertising cookies or cross-context behavioral tracking.

EU/EEA users: Under the ePrivacy Directive, we obtain consent for any non-essential cookies before placing them. Essential cookies do not require consent under applicable law.

UK users: Under the Data (Use and Access) Act 2025 and the Privacy and Electronic Communications Regulations, functional cookies (analytics, preferences, security) no longer require opt-in consent; opt-out mechanisms are available in your account settings.

California users: We honor Global Privacy Control (GPC) signals. You may opt out of any sale or sharing of personal information via the in-app privacy settings or by emailing info@burnchat.ai.

14. Third-Party AI Model Providers — Special Disclosure

This section is a required disclosure about the unique privacy architecture of BurnChat.

When you send a message, your input is processed by Privacy Shield on your device. The de-identified version of your message is then transmitted to OpenRouter, Inc., which routes it to an AI model provider (such as a provider of Claude, GPT-4o, Gemini, or other models you select). The AI model provider generates a response, which is routed back through OpenRouter to BurnChat.

CLIPO has contractual data processing arrangements with OpenRouter that include restrictions on use of transmitted data. However, CLIPO does not control and is not responsible for the data practices of underlying AI model providers once data passes to OpenRouter's infrastructure. You acknowledge this architecture by using the Service.

We recommend reviewing OpenRouter's Privacy Policy and the privacy policies of the AI model providers you select before transmitting sensitive information.

15. California-Specific Disclosures (CCPA/CPRA)

This section supplements other privacy policy disclosures for California residents.

15.1 Categories of Personal Information Collected (Cal. Civ. Code § 1798.140(v))

  • Identifiers: Email address, account ID.
  • Personal information categories listed in California Customer Records statute: Billing name, payment information (processed by Stripe).
  • Commercial information: Subscription and credit purchase history.
  • Internet or electronic network activity information: IP address at login, browser/device type, usage patterns.
  • Geolocation data: General geolocation inferred from IP address at login only (city/country level); not precise geolocation.
  • Professional or employment-related information: Not collected.
  • Inferences: CLIPO does not create consumer profiles or inferences about you.

15.2 Purposes for Collection

Personal information is collected to provide and improve the Service, process payments, prevent fraud, ensure security, and comply with applicable law, as further described in Section 5.

15.3 Sale and Sharing

CLIPO does not sell personal information and does not share personal information for cross-context behavioral advertising as defined under the CPRA.

15.4 Sensitive Personal Information

CLIPO does not use sensitive personal information for purposes other than those specified in Cal. Code Regs. tit. 11, § 7027(m). You may limit our use of SPI by contacting info@burnchat.ai.

15.5 Retention Periods

See Section 9 for retention periods by data category.

15.6 Your Privacy Choices

California residents may exercise their rights by: (a) using the in-app privacy settings; (b) emailing info@burnchat.ai; or (c) clicking the "Your Privacy Choices" link in the Service footer. CLIPO will verify your identity before processing requests. We do not discriminate against users for exercising privacy rights.

16. AI Training Data Transparency (Cal. Civ. Code § 3111 — AB 2013)

Effective January 1, 2026, California AB 2013 requires generative AI developers to post training data transparency information. CLIPO does not develop or train the foundation AI models used in BurnChat; it accesses pre-trained models via OpenRouter. Accordingly, CLIPO is not the developer of the AI models you interact with. Training data disclosures for the underlying models are the responsibility of their respective developers (e.g., Anthropic, OpenAI, Google).

If CLIPO develops or substantially modifies any AI model in the future, we will post the required AB 2013 disclosures at burnchat.ai/ai-transparency.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email to your registered address and post the updated policy at burnchat.ai/privacy at least 30 days before changes take effect, unless a shorter period is required by applicable law or exigent circumstances. Material changes will not apply retroactively to data collected before the change takes effect without your consent. Continued use after the effective date constitutes acceptance of the updated policy.

18. Contact and Complaints

  • Privacy requests and data subject rights: info@burnchat.ai
  • Data protection questions: info@burnchat.ai
  • Mailing address: CLIPO, Inc., Attn: Privacy, 1225 4th Street, Unit 119, San Francisco, CA 94158
  • EU supervisory authority: We will publish our lead EU supervisory authority designation upon appointment of our EU representative. In the interim, you may contact any EU member state supervisory authority.
  • UK supervisory authority: Information Commissioner's Office (ICO) — ico.org.uk
  • California: California Privacy Protection Agency (CPPA) — cppa.ca.gov
© 2026 CLIPO, Inc. All rights reserved.