Privacy Policy

Last updated: February 3, 2026

1. Introduction

Welcome to REFLX ("we," "our," or "us"). We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect, use, disclose, and safeguard your information when you use our AI clone creation service, including our website, mobile applications, and related services (collectively, the "Service").

By using REFLX, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our Service.

2. Information We Collect

2.1 Information You Provide

  • Account Information: Name, email address, password, profile picture, and contact details
  • Profile Data: Biographical information, interests, personality traits, communication style, and preferences you provide to create your AI clone
  • Training Content: Text, messages, documents, audio, video, and other content you upload to train your AI clone
  • Communication Data: Messages, conversations, and interactions with your AI clone and other users
  • Payment Information: Billing details, payment card information (processed securely through third-party payment processors)

2.2 Automatically Collected Information

  • Usage Data: Pages visited, features used, time spent, click patterns, and interaction history
  • Device Information: IP address, browser type, operating system, device identifiers, and mobile network information
  • Location Data: Approximate geographic location based on IP address (precise location only with your consent)
  • Cookies and Tracking: We use cookies, pixels, and similar technologies to track activity and enhance user experience

2.3 Information from Third Parties

We may receive information from social media platforms, analytics providers, advertising networks, and publicly available sources to supplement the information you provide and improve our Service.

3. How We Use Your Information

We use your information to:

  • Create and Train Your AI Clone: Process your profile data and training content to build an AI representation that mimics your communication style, knowledge, and personality
  • Provide and Improve Service: Deliver, maintain, and enhance our Service features and functionality
  • AI Model Development: Train, fine-tune, and improve our AI models and algorithms (using anonymized and aggregated data where possible)
  • Personalization: Customize your experience and provide personalized recommendations
  • Communication: Send service updates, security alerts, support messages, and marketing communications (with your consent)
  • Analytics: Analyze usage patterns, measure effectiveness, and conduct research
  • Security: Detect, prevent, and address fraud, abuse, security incidents, and technical issues
  • Legal Compliance: Comply with legal obligations, enforce our terms, and protect rights and safety

4. AI Training and Processing

Important Notice: Content you provide to train your AI clone will be processed by our AI systems. This includes:

  • Analysis of your communication patterns, vocabulary, tone, and style
  • Processing of factual information, preferences, and knowledge you share
  • Storage and indexing of training data to enable your AI clone's responses
  • Use of aggregated, anonymized data to improve our AI models generally

You retain ownership of your original content. We do not use your private conversations or personally identifiable training data to train AI clones for other users without explicit consent.

5. Data Sharing and Disclosure

We may share your information with:

5.1 Service Providers

Third-party vendors who perform services on our behalf, including hosting, AI processing, payment processing, analytics, customer support, and marketing (under strict confidentiality agreements).

5.2 AI Model Providers

We may use third-party AI services (such as OpenAI, Anthropic, or similar) to power certain features. Your data shared with these providers is subject to their privacy policies and our data processing agreements.

5.3 Business Transfers

In connection with mergers, acquisitions, bankruptcy, or sale of assets, your information may be transferred to successor entities.

5.4 Legal Requirements

When required by law, legal process, government request, or to protect rights, property, safety, or comply with legal obligations.

5.5 With Your Consent

We may share information with your explicit consent, such as when you choose to make your AI clone publicly accessible or share it with specific users.

6. Data Security

We implement industry-standard security measures to protect your data, including:

  • Encryption in transit (TLS/SSL) and at rest
  • Regular security audits and vulnerability assessments
  • Access controls and authentication mechanisms
  • Employee training on data protection and confidentiality
  • Incident response procedures

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Data Retention

We retain your information for as long as necessary to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements. When you delete your account, we will delete or anonymize your personal data within 90 days, except where retention is required by law. AI training data may be retained in anonymized form for model improvement purposes.

8. Your Rights and Choices

Depending on your location, you may have the following rights:

  • Access: Request a copy of your personal data
  • Correction: Update or correct inaccurate information
  • Deletion: Request deletion of your data (subject to legal exceptions)
  • Portability: Receive your data in a structured, machine-readable format
  • Opt-Out: Unsubscribe from marketing communications
  • Restrict Processing: Limit how we use your data
  • Object: Object to certain processing activities
  • Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, contact us at privacy@reflx.me. We will respond within 30 days.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. We ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission and other lawful transfer mechanisms.

10. Children's Privacy

Our Service is not intended for children under 13 (or 16 in the EEA). We do not knowingly collect information from children. If you believe a child has provided us with personal data, please contact us immediately, and we will delete such information.

11. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to enhance your experience, analyze usage, and deliver personalized content. You can control cookies through your browser settings, but disabling them may affect Service functionality.

Types of cookies we use: Essential (required for Service operation), Analytics (usage statistics), Functional (remember preferences), and Marketing (personalized advertising with consent).

12. Third-Party Links and Services

Our Service may contain links to third-party websites or integrate with third-party services. We are not responsible for their privacy practices. We encourage you to review their privacy policies before providing any information.

13. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

  • Right to know what personal information is collected, used, shared, or sold
  • Right to delete personal information
  • Right to opt-out of sale of personal information (we do not sell your data)
  • Right to non-discrimination for exercising privacy rights

To exercise these rights, email privacy@reflx.me with "CCPA Request" in the subject line.

14. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR), including those listed in Section 8. Our legal basis for processing includes:

  • Contract Performance: To provide the Service you requested
  • Legitimate Interests: To improve and secure our Service
  • Consent: Where you have given explicit consent
  • Legal Obligation: To comply with applicable laws

You have the right to lodge a complaint with your local data protection authority.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or prominent notice within the Service. Your continued use of the Service after changes constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: privacy@reflx.me

Data Protection Officer: dpo@reflx.me

Address: REFLX Privacy Team, [Your Company Address]