Privacy Policy

Effective Date: January 20, 2026

This Privacy Policy describes how Melochora LLC ("Company," "we," "us," or "our") collects, uses, and shares information about you when you use the Expert Avatar platform and our website, mobile applications, and related services (collectively, the "Services").

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By using the Services, you consent to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services.

1. Information We Collect

We collect information about you in the following ways:

1.1 Information You Provide Directly

When you use the Services, you may provide us with:

Account Information

• Name
• Email address
• Password
• Profile information

Voice Recordings

• Audio recordings of your voice during interviews
• Voice samples used to create your Cloned Voice
• Any audio messages you send through the Services

Images and Photographs

• Photographs you upload for avatar creation
• Profile pictures
• Any other images you submit

Interview and Chat Content

• Transcripts of your interview sessions
• Responses and information you share during interviews
• Chat messages between Seekers and Expert avatars
• Messages sent between Experts and Seekers

Payment Information

• Billing name and address
• Payment card information (processed by our payment processors)
• Transaction history

Communications

• Emails or messages you send to us
• Customer support inquiries
• Feedback and suggestions

1.2 Information We Collect Automatically

When you use the Services, we automatically collect:

Device and Usage Information

• Device type, operating system, and browser type
• IP address
• Unique device identifiers
• Pages viewed and features used
• Time spent on the Services
• Referring and exit pages
• Date and time of access

Usage Metrics

• Session duration and frequency
• Chat usage minutes
• Avatar interaction data

Location Information

• General location based on IP address (city, state, country)

1.3 Information from Third Parties

We may receive information about you from:

• Authentication providers when you sign in using third-party accounts (e.g., Google)
• Payment processors regarding transaction status
• Analytics providers

1.4 Biometric Information Notice

In connection with providing the Services, we collect voice recordings that we use to create a synthetic clone of your voice ("Cloned Voice") and process photographs to create your avatar image. This process may involve creating a "voiceprint" or other biometric identifier.

What We Collect: Audio recordings of your voice during interviews and any voice samples you provide, as well as photographs you upload for avatar creation.

How We Use It: We use your voice recordings solely to create and operate your Cloned Voice for the purpose of generating avatar responses. We use your photographs solely to create your avatar image. We do not use your voice recordings, voiceprints, or photographs for identification, surveillance, or any purpose other than providing the Services.

Consent Requirement: Voice cloning and image use for avatar creation occur only after you provide explicit, affirmative consent. Each time you initiate voice cloning, you must affirmatively consent to the collection and use of your voice recordings for voice cloning (for example, by checking a required consent checkbox). We maintain consent logs (including timestamp, clone id, and consent version) for compliance and recordkeeping. This biometric consent is separate from your general acceptance of the Terms of Service.

Revoking Consent: You may revoke your consent at any time by deleting your account. Upon account deletion, your voice recordings, Cloned Voice data, photographs, and avatar images will be deleted as described in the Account Deletion section of this Privacy Policy.

Retention: We retain your voice recordings, Cloned Voice data, photographs, and avatar images for as long as your account is active. When you delete your account, we delete this data as described in the Account Deletion section of this Privacy Policy. For additional details, see our Biometric Information Retention & Destruction Policy at https://expertavatar.com/biometric, which is incorporated by reference.

Sharing: We share your voice recordings with our voice synthesis service providers and your photographs with our avatar generation service providers to create your Cloned Voice and avatar image and to operate the Services. We seek to use providers with appropriate security measures and contractual protections. However, some providers may, under their own terms, retain and/or use data processed through their services to improve their services or models. See Section 3 (AI Model Training) for more information.

2. How We Use Your Information

We use the information we collect to:

2.1 Provide and Operate the Services

• Create and manage your account
• Conduct interview sessions and record your responses
• Create your Cloned Voice using voice synthesis technology
• Create your Avatar Image by processing your photographs
• Generate AI-powered avatar responses based on your interview content
• Facilitate conversations between Seekers and Expert avatars
• Process payments and manage billing
• Provide customer support

2.2 Improve and Develop the Services

• Analyze usage patterns and trends
• Identify and fix bugs and errors
• Develop new features and functionality
• Monitor and improve service performance

2.3 Communicate with You

• Send account-related notifications
• Provide customer support
• Send service updates and announcements
• Respond to your inquiries

2.4 Safety and Security

• Detect, prevent, and respond to fraud or abuse
• Enforce our Terms of Service
• Protect the rights, property, and safety of Expert Avatar, our users, and others
• Comply with legal obligations

3. AI Model Training

Expert Avatar does not train or develop its own artificial intelligence or machine learning models using your voice recordings, interview transcripts, chat content, or other personal information.

Your data is used solely to:

• Create and operate your personal Expert avatar
• Provide the Services as described in our Terms of Service
• Improve the technical operation of the Services (e.g., bug fixes, performance)

Third-Party Service Providers: We use third-party providers to support features such as speech-to-text, text-to-speech, voice synthesis, avatar generation, and AI-powered conversations. When you use these features, your content (including audio and transcripts) may be processed by those providers on our behalf. Some providers may retain and/or use data processed through their services to improve or develop their own services or models, subject to their terms and privacy policies. We do not control these providers’ independent practices, and we cannot guarantee that they will not use data to improve their services.

We may use aggregated, anonymized data that cannot reasonably be linked back to you for analytics and service improvement purposes.

4. How We Share Your Information

We share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Payment processing providers to process transactions
• Cloud hosting and infrastructure providers to store and process data
• Voice synthesis providers to create Cloned Voices
• Avatar generation providers to create visual avatars
• AI and language model providers to power avatar conversations
• Email and communication providers to send notifications
• Analytics providers to understand service usage
• Customer support providers to assist with inquiries

These service providers are contractually obligated to use your information only for the purposes of providing services to us and to maintain appropriate security measures. Service providers may process data outside the United States, and data transfers occur only to providers under contractual confidentiality and security obligations. See the International Data Transfers section of this Privacy Policy for more information.

4.2 Other Users

Certain information is shared with other users as part of the Services:

• Experts: Your avatar, including your Avatar Image and Cloned Voice, is made available to Seekers
• Seekers: Your messages and questions may be shared with the Expert whose avatar you interact with

Seeker Content Handling: Seeker messages and audio are processed to facilitate conversations with Expert avatars. Seeker audio recordings and transcripts may be retained by Expert Avatar and our service providers for the purpose of providing and improving the Services. Experts may view and reference Seeker messages and questions (text only) and may reuse them outside the Services, including verbatim excerpts, but Experts must not publish a Seeker's contact information, must not doxx or attempt to identify a Seeker without the Seeker's consent, and must comply with applicable law. Experts do not have access to Seeker audio recordings through the Services.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in good faith belief that such disclosure is necessary to:

• Comply with legal process, such as a court order or subpoena
• Respond to requests from government authorities
• Enforce our Terms of Service
• Protect our rights, property, or safety, or that of our users or others
• Investigate fraud or security issues

4.4 Business Transfers

If Expert Avatar is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change via email or prominent notice on the Services.

4.5 With Your Consent

We may share your information with third parties when you direct us to do so or provide your consent.

5. Data Storage and International Transfer

5.1 Location of Data

The Services are operated from the United States. Your information is primarily stored and processed on servers located in the United States.

5.2 International Data Transfers

By using the Services, you consent to the transfer of your information to the United States and to the processing of your information in the United States, which may have different data protection laws than your country of residence.

Our third-party service providers may process data outside the United States. When your data is transferred to service providers located in other countries, such transfers occur only to providers that are under contractual confidentiality and security obligations with us.

5.3 Geographic Scope and International Users

The Services are operated from and intended for users located in the United States. We do not intentionally target or market to users outside the United States, including individuals located in the European Union, European Economic Area, United Kingdom, or Switzerland.

Expert Avatar does not represent compliance with the General Data Protection Regulation (GDPR), UK GDPR, EU consumer protection directives, or any other non-U.S. data protection or consumer protection law. If you access the Services from the European Union, European Economic Area, United Kingdom, or any other jurisdiction outside the United States, you do so at your own initiative. Your information may be transferred to and processed in the United States (and potentially other countries where our service providers operate), and you may not have the same rights or protections that you would have under the laws of your jurisdiction.

6. Data Retention

6.1 Retention Period

We retain your information for as long as your account is active or as needed to provide the Services. We may also retain information as necessary to:

• Comply with legal obligations
• Resolve disputes
• Enforce our agreements
• Protect our legal rights

6.2 Account Deletion

When you delete your account, we delete your personal information from our active systems, including:

• Your account information and profile data
• Your voice recordings and Cloned Voice
• Your photographs and Avatar Images
• Your interview transcripts and chat content
• Messages between you and other users

Upon deletion of an Expert account, the associated avatar will be immediately deactivated and will no longer be accessible to Seekers. Any license granted to Expert Avatar to use your voice, image, or avatar will terminate following the backup retention period described below. See the Avatar IP Licensing and Termination section below for more information.

Residual Data: Following account deletion, residual copies of your data may persist for up to thirty (30) days in:

• Encrypted backup systems
• Disaster recovery systems
• System logs

These residual copies are access-restricted, automatically overwritten or deleted within thirty (30) days, and are not used for any purpose other than backup integrity and system recovery. We do not restore deleted accounts from backup data. The licenses you granted to Expert Avatar survive during this backup retention period solely for the purpose of maintaining backup integrity and legal compliance.

Exceptions: We may retain certain information as necessary to:

• Comply with legal obligations (such as tax and financial records)
• Resolve disputes and enforce our agreements
• Prevent fraud and abuse

Aggregated or anonymized data that cannot reasonably be linked back to you may be retained for analytics purposes.

To delete your account, contact us at support@melochora.com or use the account deletion option in your account settings.

6.3 Deletion Requests

You may request deletion of your account and personal information by contacting us at support@melochora.com. We will process your request in accordance with applicable law, subject to the retention exceptions described above.

6.4 Complete Deletion Confirmation

Upon account deletion, Expert Avatar deletes all personal data associated with your account from active systems. Only limited residual technical data may remain temporarily in backup and disaster recovery systems as described in the Account Deletion section above, and such data is automatically purged within thirty (30) days.

6.5 Avatar IP Licensing and Termination

Any license granted to Expert Avatar to use an Expert's voice, image, or avatar exists while the Expert's account is active and survives for up to thirty (30) days following account deletion solely to the extent required for backup retention and legal compliance. Upon account deletion:

• Your avatar will be immediately deactivated and will no longer be accessible to Seekers
• All associated data, including voice recordings, Cloned Voice, photographs, and avatar images, are deleted from active systems immediately and from backup systems within thirty (30) days as described in this section
• All licenses terminate upon completion of the backup retention period

For detailed information about intellectual property rights and licenses, please refer to our Terms of Service.

7. Security

We implement reasonable technical and organizational security measures to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication
• Regular security assessments
• Employee training on data protection

However, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee the absolute security of your information, and you provide information to us at your own risk.

8. Data Breach Notification

In the event of a data breach involving your personal information, we will notify affected users without unreasonable delay. Notification may be provided via email to the address associated with your account, in-app notice, or other lawful means.

The timing of notification may be delayed if required by law enforcement or if necessary to determine the scope of the breach and restore the security of our systems.

9. Children's Privacy

The Services are intended for users who are at least eighteen (18) years of age. We do not knowingly collect personal information from anyone under 18 years old.

If we become aware that we have collected personal information from a person under 18, we will take steps to delete that information as quickly as possible. If you believe we have inadvertently collected information from a person under 18, please contact us at support@melochora.com.

10. Your Rights and Choices

10.1 Account Information

You can access, update, or delete certain account information through your account settings or by contacting us at support@melochora.com.

10.2 Communications

You can opt out of marketing communications by following the unsubscribe instructions in those messages. You will continue to receive transactional and account-related communications.

10.3 Cookies and Tracking

Most web browsers allow you to control cookies through their settings. Please note that disabling cookies may affect the functionality of the Services.

10.4 Data Requests

Depending on your jurisdiction, you may have the right to:

• Request access to your personal information
• Request correction of inaccurate information
• Request deletion of your information
• Request a copy of your information in a portable format
• Object to or restrict certain processing of your information

Data Portability: Upon request, we can provide your personal data in the following formats:

• Profile and text data: JSON format
• Audio recordings: wav audio files

To exercise these rights, please contact us at support@melochora.com with the subject line "Privacy Request." We will acknowledge your request within ten (10) business days and respond to verifiable requests within forty-five (45) days. If we require additional time (up to an additional 45 days), we will inform you of the reason and extension period.

We may need to verify your identity before processing your request. Verification may require you to confirm information associated with your account or provide additional documentation.

10.5 California Privacy Rights

If you are a California resident, the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA") provide you with specific rights regarding your personal information. This section describes your rights and how to exercise them.

Categories of Personal Information We Collect:

Sources of Personal Information:

• Directly from you when you register, participate in interviews, or use the Services
• Automatically when you use the Services (device data, usage data)
• From third-party authentication providers (Google, etc.)
• From payment processors

Purposes for Collection:

• Providing and operating the Services, including creating your avatar and cloned voice
• Processing payments and managing your account
• Communicating with you about the Services
• Analyzing and improving the Services
• Detecting and preventing fraud and abuse
• Complying with legal obligations

Categories Disclosed to Service Providers:

• Identifiers: to cloud hosting, email, and customer support providers
• Biometric Information: to voice synthesis providers
• Audio/Visual Information: to avatar generation and AI providers
• Payment Information: to payment processors
• Internet/Network Activity: to analytics providers

Your California Rights:

• Right to Know: Request information about the personal information we collect, use, and disclose about you
• Right to Access: Request a copy of the personal information we have collected about you
• Right to Delete: Request deletion of your personal information, subject to certain exceptions
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: We do not sell your personal information or share it for cross-context behavioral advertising
• Right to Limit Use of Sensitive Personal Information: Request that we limit our use of sensitive personal information to purposes necessary to provide the Services
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

Exercising Your Rights: To exercise any of these rights, contact us at support@melochora.com or by mail at:

Melochora LLC
2108 N ST #7813
Sacramento, CA 95816

We will verify your identity before processing your request by confirming information associated with your account. You may designate an authorized agent to submit requests on your behalf by providing written authorization.

We do not sell your personal information.

Retention: We retain personal information for as long as your account is active or as needed to provide Services, comply with legal obligations, resolve disputes, and enforce our agreements.

10.6 Other U.S. State Privacy Rights

If you are a resident of Colorado, Connecticut, Utah, or Virginia, similar state privacy laws may provide you with additional rights regarding your personal information.

Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act (UCPA), and Virginia Consumer Data Protection Act (VCDPA):

These laws generally provide residents with rights to:

• Access: Request access to the personal data we have collected about you
• Correction: Request correction of inaccurate personal data
• Deletion: Request deletion of your personal data
• Data Portability: Obtain a copy of your personal data in a portable format
• Opt-Out of Sale: We do not sell your personal data
• Opt-Out of Targeted Advertising: We do not use your personal data for targeted advertising based on cross-context behavioral data
• Opt-Out of Profiling: We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects

Sensitive Data: Under these laws, biometric data and certain other categories are considered "sensitive data." We process sensitive data only with your consent, as described in the Biometric Information Notice section of this Privacy Policy.

Exercising Your Rights: To exercise any of these rights, contact us at support@melochora.com with the subject line "State Privacy Request." We will verify your identity and respond within the timeframes required by applicable law (generally 45 days, with possible extensions).

Appeals: If we decline to take action on your request, you may appeal our decision by contacting us at support@melochora.com with the subject line "Privacy Appeal." We will respond to appeals within the timeframes required by applicable law. If your appeal is denied, you may contact your state's Attorney General to submit a complaint.

11. Third-Party Links and Services

The Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party websites you visit.

12. Relationship Between Privacy Policy and Terms of Service

This Privacy Policy governs how we collect, use, and share your personal information. Our Terms of Service govern your use of the Services, including intellectual property ownership, avatar usage licenses, and platform rules.

In the event of a conflict between this Privacy Policy and the Terms of Service regarding intellectual property rights or license terms, the Terms of Service shall govern.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you at least seven (7) days before the changes take effect by:

• Posting the updated Privacy Policy on the Services with a new effective date
• Sending you an email notification (for material changes)

Your continued use of the Services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

14. Contact Us

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

Email: support@melochora.com

Mail:
Melochora LLC
2108 N ST #7813
Sacramento, CA 95816
USA

15. Additional Disclosures

15.1 Do Not Track

Some browsers include a "Do Not Track" (DNT) feature that signals to websites that you do not want your online activity tracked. The Services do not currently respond to DNT signals.

15.2 Cookies We Use

We use the following types of cookies and similar technologies:

15.3 Data Protection Contact

For data protection inquiries, please contact:

Email: support@melochora.com
Subject Line: Data Protection Inquiry

15.4 Managing Cookies and Opting Out

You can control cookies through the following methods:

Browser Settings: Most web browsers allow you to manage cookies through browser settings. You can set your browser to refuse cookies or delete certain cookies. Please note that disabling cookies may affect the functionality of the Services.

Opt-Out Tools: You can opt out of interest-based advertising from participating companies through:

• Network Advertising Initiative (NAI): https://optout.networkadvertising.org/
• Digital Advertising Alliance (DAA): https://optout.aboutads.info/
• Google Ads Settings: https://adssettings.google.com/

Mobile Device Settings: Your mobile device may provide options to limit ad tracking. On iOS, go to Settings > Privacy > Tracking. On Android, go to Settings > Privacy > Ads.

Please note that opting out of interest-based advertising does not mean you will stop seeing ads; you will still see ads, but they may be less relevant to your interests.