Privacy Policy

HAARO PRIVACY POLICY Last updated: August 2026 1. INTRODUCTION This Privacy Policy explains how Haaro collects, uses, stores, shares and protects users’ personal data. Haaro is a communication assistance platform that uses artificial intelligence to generate replies, suggestions, transcriptions and contextual support for personal and professional relationships. The purpose of this Policy is to provide users with clear information about how their personal data is processed and about the rights they may exercise. 2. DATA CONTROLLER The controller responsible for the personal data processed through Haaro is: Salvador de Haro López Haaro Spain Privacy contact: privacy@haaro.app Additional official contact channels may also be made available within the app or on Haaro’s official website. 3. DATA HAARO MAY PROCESS Haaro may process the following categories of data: - Account data, such as email address, sign-in method, user identifiers and information required to authenticate and maintain a session. - Personalization data provided by the user, such as Basic Information, Professional Profile, Favorite Relationships, preferred tones, example messages associated with relationships and other preferences configured within Haaro. - Usage data, such as number of generations, selected language, subscription plan, available balance, usage limits, purchased packs and basic activity necessary to provide and manage the service. - Technical data, such as device type, operating system, app version, error logs and information required to maintain the security, stability and proper functioning of Haaro. - Content voluntarily entered or shared by the user, including text, messages and audio files used to generate replies, start conversations, receive suggestions or obtain transcriptions. Haaro does not intend to collect special categories of personal data. However, users may voluntarily include such information in the text or content they submit. Users are advised not to provide particularly sensitive information when it is not necessary to use the service. 4. PURPOSES OF PROCESSING Haaro may use data for the following purposes: - To create, authenticate and maintain the user’s account. - To provide the features requested by the user. - To generate replies, suggestions and assistance using artificial intelligence. - To transcribe audio files when the user chooses to use this feature. - To personalize communication replies and suggestions. - To maintain and synchronize the user’s settings and preferences across devices. - To manage plans, subscriptions, packs, balances and usage limits. - To manage purchases and purchase restoration. - To prevent fraudulent or abusive use. - To maintain the security, stability and technical operation of the service. - To analyze the operation and use of Haaro in aggregated form in order to improve the product. - To comply with legal obligations or requests from competent authorities where necessary. 5. LEGAL BASES FOR PROCESSING Depending on the circumstances, the processing of personal data may be based on: - The performance of the contractual relationship or provision of the service requested by the user, including account creation and the operation of Haaro’s features. - The user’s consent where required, for example for certain optional features or processing activities that require specific authorization. - Haaro’s legitimate interest in maintaining security, preventing fraud, correcting errors, ensuring technical stability and improving the operation of the service, provided that such interests are not overridden by the user’s rights and freedoms. - Compliance with legal obligations applicable to Haaro. Where processing is based on consent, the user may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal. 6. USER PERSONALIZATION AND SETTINGS Haaro uses information configured by the user within the app to better adapt replies, suggestions and communication proposals. This configuration may include, among other elements: - Basic Information. - Professional Profile. - Favorite Relationships. - Communication tones and preferences. - Example messages associated with specific relationships. - Language and app usage preferences. In the current version of Haaro, these personalization features do not imply the existence of a general conversation history or an automatic relational memory covering all user conversations. Users may modify or reset their configuration using the tools available within the app. 7. ARTIFICIAL INTELLIGENCE AND CONTENT PROCESSING To provide certain features, Haaro uses external artificial intelligence and content-processing services. When a user requests a generation, transcription or another feature based on artificial intelligence, the content strictly necessary to process that request may be sent to the relevant provider. This may include: - Text entered or shared by the user. - Audio files or audio fragments when a transcription is requested. - Contextual and personalization information required to adapt the response. - Language, relationship, tone, intention or other selected preferences. This data will be used for the purpose of processing the request made by the user. Haaro does not use the content of users’ conversations to train its own models without their consent. Haaro may use different technology or artificial intelligence providers over time. Such providers will act in accordance with their respective contractual and data protection obligations. 8. PROVIDERS AND THIRD PARTIES To provide the service, Haaro uses or may use specialized external providers. The main categories of providers include: - Authentication, infrastructure and database services, such as Supabase. - Artificial intelligence and language or audio processing services. - Subscription and purchase management services, such as RevenueCat. - App stores and payment platforms, such as Apple App Store and Google Play. - Hosting, web infrastructure and distribution services. - Technical services required for security, stability, monitoring or error resolution. Haaro will only provide these providers with the data necessary to deliver the relevant functionality. Some providers may process data from countries other than the user’s country of residence. 9. INTERNATIONAL DATA TRANSFERS Some of the providers used by Haaro may be established in or provide services from countries outside the European Economic Area. Where applicable, Haaro will seek to ensure that such international transfers are carried out using mechanisms recognized under applicable data protection law, such as adequacy decisions, Standard Contractual Clauses or other legally recognized safeguards. 10. SUBSCRIPTIONS, PURCHASES AND PAYMENTS Haaro offers a free plan and may offer paid subscription plans as well as additional purchases. Purchases made through the mobile applications may be managed by Apple App Store or Google Play. Haaro uses specialized services, such as RevenueCat, to manage subscription status, access rights, purchase restoration and other information necessary to correctly provide purchased plans. Haaro may process information such as: - Purchased plan. - Subscription status. - Identifier of the purchased product. - Renewal date or renewal status. - Packs or available balance. - Information required to restore or verify a purchase. Haaro does not directly receive or store complete payment card details used for purchases made through Apple or Google. 11. DATA RETENTION Data associated with the user’s account, settings and personalization may be retained for as long as the account remains active and the data is necessary to provide the service. Data relating to purchases, billing or transactions may be retained for the periods required under applicable law. Technical or security logs will only be retained for the period reasonably necessary to maintain security, investigate incidents or ensure proper operation of the service. When a user deletes their account, associated personal data will be deleted or anonymized, except where certain data must be retained for an additional period due to legal obligations, fraud prevention, dispute resolution or other legitimate reasons permitted by law. 12. ACCOUNT AND DATA DELETION Users may request the deletion of their account and associated personal data. Haaro will provide a mechanism to initiate account deletion from within the app. A web-based mechanism will also be provided through Haaro’s official website to request deletion of the account and associated data. Deleting the app from a device does not by itself delete the user’s account. When a deletion request is processed, Haaro will delete or anonymize personal data linked to the account, except where retention is legally required. Deleting a Haaro account does not necessarily cancel a subscription managed through Apple App Store or Google Play. Where applicable, users must manage cancellation of those subscriptions through the relevant store. 13. USER RIGHTS Under applicable law, users may exercise the following rights where relevant: - Access to their personal data. - Rectification of inaccurate data. - Erasure of their data. - Restriction of processing. - Objection to processing. - Data portability. - Withdrawal of consent where processing is based on consent. Requests may be sent to: privacy@haaro.app Haaro may request information reasonably necessary to verify the identity of the requester before fulfilling certain rights. Users also have the right to lodge a complaint with the competent data protection authority. In Spain, users may contact the Spanish Data Protection Agency (AEPD). 14. SECURITY Haaro applies reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, alteration, disclosure or misuse. These measures may include access controls, authentication systems, encrypted communications and other safeguards proportionate to the nature of the service and the data being processed. However, no digital system can guarantee absolute security. 15. MINORS Haaro is intended for users aged 16 or over. Use of Haaro by persons under the age of 16 is not permitted. If Haaro becomes aware that data relating to a person under this age has been processed without the required authorization, reasonable steps will be taken to delete such data. 16. AUTOMATED DECISION-MAKING Haaro uses artificial intelligence to generate proposals, suggestions and content requested by the user. These features are not intended to make legal decisions or decisions producing significant effects on users solely through automated processing. Content generated by Haaro is provided as assistance, and users always remain responsible for deciding whether they wish to use it. 17. CHANGES TO THIS PRIVACY POLICY Haaro may update this Privacy Policy due to legal, technical or provider-related changes, or changes related to the evolution of the product. Where changes are significant, users will be informed through the app, the website or other reasonable means. Where required by law, user consent will be requested again. 18. CONTACT For any questions relating to this Privacy Policy or the processing of personal data: Haaro Salvador de Haro López Spain Email: privacy@haaro.app Updated contact information will also be available on Haaro’s official website. 19. ADDITIONAL INFORMATION This Privacy Policy should be read together with Haaro’s Terms and Conditions and any additional privacy information displayed within the app or in app stores.