Privacy Policy

Last Updated: August 17, 2025

1. Introduction

Welcome! This Privacy Policy explains how Soul AI LLC ("we," "us," or "our") collects, uses, and shares information when you use Newsletter AI, including our website and web application (the "App" or "Service").

Your privacy and your subscribers' privacy are fundamental to our newsletter management service. This policy outlines our practices and your rights concerning your information. By using our services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

Information You Provide Directly

When you register for Newsletter AI, we collect information that you voluntarily provide, including:

• Account Information: Name, email address, profile photo (via Google or Apple Sign-In)
• Newsletter Content: Text, images, and formatting of newsletters you create
• Subscriber Lists: Email addresses and names of subscribers you manage
• Campaign Settings: Scheduling, targeting, and delivery preferences
• Import Data: Subscriber lists and contact information you upload
• Communications: Messages you send us through contact forms or support

Subscriber Information

Subscriber Data You Manage: As a newsletter platform, we process subscriber data on your behalf:

• Contact Information: Email addresses, first names, last names of your subscribers
• Subscription Data: Subscription status, preferences, subscription source
• Engagement Data: Email opens, clicks, bounces, unsubscribes
• Subscription History: When subscribers joined, unsubscribed, or updated preferences
• List Segmentation: Any categories or tags you assign to subscribers

Email Analytics and Tracking

Email Performance Data: To provide analytics, we automatically collect:

• Delivery Statistics: Successful deliveries, bounces, spam complaints
• Engagement Metrics: Email opens, link clicks, time spent reading
• Device and Location Data: General location and device information from email interactions
• Email Client Data: Which email clients your subscribers use
• Campaign Performance: Overall campaign success rates and trends

Information We Collect Automatically

When you visit our website or use our App, we may automatically collect:

• Usage Data: Features used, newsletter creation activity, sending frequency
• Device Information: Browser type, operating system, screen resolution, device type
• Location Data: General geographic location based on IP address
• IP Address: For security, diagnostics, and basic analytics
• Usage Limits: Tracking of your email sending usage against beta limits
• Error Reports: Anonymized data about app errors for debugging and improvements

Third-Party Authentication

Firebase Authentication: We use Firebase Authentication for secure login via Google and Apple Sign-In. Firebase processes your authentication credentials according to Google's privacy policies.

3. How We Use Your Information

We use the information we collect for the following specific purposes:

• Provide Our Service: Create, manage, and send newsletters to your subscriber lists
• Email Delivery: Process and send newsletters through our email delivery infrastructure
• Analytics and Reporting: Track email performance, engagement rates, and campaign success
• Subscriber Management: Help you organize and segment your subscriber lists
• Email Compliance: Ensure proper unsubscribe handling and CAN-SPAM compliance
• Usage Monitoring: Track your usage against beta testing limits and prevent abuse
• Improve Our Platform: Analyze usage patterns to enhance user experience and develop new features
• Communicate With You: Send service updates, respond to inquiries, provide customer support
• Security and Protection: Monitor for suspicious activity and protect against spam and abuse
• Legal Compliance: Meet legal obligations and anti-spam regulations

Legal Basis for Processing (GDPR)

• Processing your account information is based on the Performance of a Contract
• Processing subscriber data for email delivery is based on the Performance of a Contract
• Processing email analytics data is based on our Legitimate Interest in providing service insights
• Processing technical data for functionality, security, and improvement is based on our Legitimate Interest
• Marketing communications are based on your Consent (where required)

4. Information Sharing and Disclosure

We may share your information only in these limited circumstances:

• Email Delivery Services: Subscriber email addresses and newsletter content are processed by our email delivery infrastructure to send newsletters
• Firebase/Google: For authentication services as described above
• Analytics Providers: Anonymized email performance data may be processed by email analytics services
• Service Providers: Trusted third parties who help us operate our service (hosting, analytics, customer support) under strict confidentiality agreements
• Legal Requirements: When required by law, court order, or to protect our rights and safety
• Business Transfers: In the event of a merger, acquisition, or sale of assets (with user notification)
• With Your Consent: When you explicitly agree to share information for a specific purpose

5. Data Security

Given the sensitive nature of email marketing data, we implement robust security measures:

• Encryption: All data is encrypted in transit and at rest using industry-standard encryption
• Secure Email Delivery: All newsletter sending uses secure, authenticated email delivery services
• Access Controls: Strict access controls with need-to-know basis for any data access
• Data Isolation: Each user's subscriber lists and newsletters are isolated from other users
• Regular Audits: Periodic security assessments and vulnerability testing
• Spam Protection: Anti-spam measures to protect our sending reputation and your deliverability

6. Email Marketing and Compliance

Compliance Features:

• Automatic unsubscribe links in all emails
• Subscriber preference management
• Bounce and complaint handling
• Suppression list management
• Subscription source tracking

Your Compliance Responsibilities:

• Obtaining proper consent before adding subscribers to your lists
• Providing clear information about what subscribers are signing up for
• Honoring unsubscribe requests promptly
• Ensuring your content complies with applicable laws
• Maintaining records of subscriber consent

7. Your Privacy Rights

You have several rights regarding your personal information:

• Access: Request a copy of the personal information we have about you
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your personal information and all associated data
• Portability: Export your subscriber lists and newsletters in portable formats
• Subscriber Management: Add, edit, or remove subscribers from your lists at any time
• Opt-Out: Unsubscribe from marketing communications
• Object (GDPR): Object to processing based on legitimate interests
• Restrict Processing (GDPR): Request restriction of processing under certain conditions

To exercise these rights, please contact us using the information provided below.

8. Subscriber Rights

Your subscribers have rights regarding their personal information:

• Unsubscribe: Easy one-click unsubscribe from your newsletters
• Preference Management: Update their email preferences and subscription settings
• Data Access: Request information about how their data is being used
• Data Deletion: Request removal from your subscriber lists
• Complaint Process: Report spam or privacy concerns

9. Data Retention

We retain your information based on the following principles:

• Account Data: Retained while your account is active
• Subscriber Lists: Retained until you delete them or close your account
• Newsletter Content: Retained for service functionality and analytics
• Email Analytics: Aggregated analytics data retained for service improvement
• Unsubscribe Records: Maintained to honor unsubscribe requests and prevent re-addition
• Support Communications: Retained for customer service purposes

Upon account deletion, we will delete your personal information and subscriber data within 30 days, subject to backup retention cycles and legal requirements.

10. Beta Service Limitations

Newsletter AI is currently in beta testing with the following limitations:

• Email Quota: Limited to 100 emails per user during beta period
• Feature Availability: Some features may be incomplete or subject to change
• Service Stability: Service availability may be inconsistent
• Data Migration: Beta data may need to be migrated during service updates

11. Third-Party Email Services

Newsletter AI integrates with email delivery services to send your newsletters:

• Email Delivery Providers: Your newsletters are sent through third-party email services
• Tracking and Analytics: Email opens and clicks are tracked through these services
• Deliverability Management: Email reputation and deliverability are managed by these providers
• Compliance: These services help ensure compliance with email marketing regulations

These services have their own privacy policies that govern how they handle your newsletter data during delivery.

12. International Data Transfers

Your information may be processed and stored in countries other than your own, including the United States. We ensure appropriate safeguards are in place to protect your information in accordance with this privacy policy and applicable data protection laws.

13. Changes to This Privacy Policy

We may update this privacy policy from time to time. We will notify you of significant changes by:

• Posting the updated policy on our website
• Sending you an email notification (for material changes)
• Updating the "Last Updated" date at the top of this policy

14. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information we collect and how it's used
• Right to delete personal information (with certain exceptions)
• Right to opt-out of the sale of personal information (we don't sell data)
• Right to non-discrimination for exercising your privacy rights

15. European Privacy Rights

If you are in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR):

• Legal basis for processing your data as outlined above
• Right to object to certain types of processing
• Right to restrict processing in certain circumstances
• Right to lodge a complaint with your local data protection authority

16. Limitation of Liability

EMAIL MARKETING LIABILITY LIMITATION: SOUL AI LLC SHALL NOT BE LIABLE FOR ANY DAMAGES, LOSSES, OR HARM ARISING FROM:

• Email delivery failures, delays, or spam filtering
• Subscriber data breaches or unauthorized access to subscriber lists
• Email marketing compliance violations or legal issues
• Unsubscribe processing errors or subscriber preference management
• Third-party email service provider issues or changes
• Analytics data inaccuracies or email tracking problems
• Subscriber list corruption, loss, or import/export issues

MAXIMUM LIABILITY: NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HEREIN, SOUL AI LLC'S LIABILITY TO YOU FOR ANY PRIVACY-RELATED CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION, WILL AT ALL TIMES BE LIMITED TO THE AMOUNT PAID, IF ANY, BY YOU TO US DURING THE SIX (6) MONTH PERIOD PRIOR TO ANY CAUSE OF ACTION ARISING.

17. Contact Information