1. Who we are (data controller)

The data controller for personal data processed through the Service is:

• LIPITT SAS, a French simplified joint-stock company

• Registered office: 7 avenue de Laponie, 91940 Les Ulis, France

• SIREN/SIRET: 980 765 531 00010

• Privacy contact: privacy-mentors@equos.ai

• Data protection point of contact: Antoine Ménager, CEO

For any question concerning your personal data or the exercise of your rights, please contact us at the email address above.

2. What data we collect

2.1 Account data (collected when you sign up)

You create an account using one of the following methods:

• Sign in with Apple: we receive your email address (which may be a private relay address provided by Apple if you choose to hide your real email) and a unique Apple user identifier specific to our app.

• Phone number authentication: we receive your mobile phone number, verified via a one-time SMS code.

2.2 Profile data (collected during onboarding)

To personalise your experience with the avatars, we ask you to provide:

• Your first name;

• Your areas of interest (used to recommend relevant avatars and adapt conversational content).

2.3 Conversation data

• Text messages exchanged with the avatars;

• Voice (audio): streamed in real time during audio and video calls with the avatars;

• Video (camera): only if you choose to enable the camera during a video call; used to give the avatar contextual feedback on your facial expressions;

• Conversation memory summaries: short text summaries that we generate per avatar, so each avatar can maintain continuity across your sessions with them (e.g., topics discussed, preferences you have shared). The full audio and video of your calls are never stored by Lipitt.

See Section 3 for important details on how voice, video and conversation data are processed.

2.4 Technical and usage data

When you use the App, we automatically collect:

• Device information: device model, iOS version, language and region settings, time zone;

• App-specific identifiers (Apple's IDFV — Identifier for Vendors);

• Usage analytics: screens viewed, features used, session duration, avatars selected, conversation initiation events;

• Attribution data (via Adjust): a signal enabling us to understand how you discovered the App (e.g. through which marketing channel), without cross-app tracking;

• Crash and performance logs (when the App crashes or encounters an error);

• IP address (used transiently for connection routing and abuse prevention).

We do not use Apple's IDFA, do not request App Tracking Transparency permission, and do not track you across other apps or websites. The App does not contain any advertising.

2.5 Communications

If you contact us by email or interact with us, we keep a record of that correspondence.

3. Voice, video and conversation data — special notice

Important. Audio and (optional) video data may qualify as "biometric data" under GDPR when processed in certain ways. We process your voice and camera input solely to enable conversations with the avatars, and never to uniquely identify you as an individual. We do not perform voice cloning, face recognition, or speaker identification.

3.1 How real-time conversations work

Depending on the modality you choose (text, audio call, or video call):

1. For text chat: your messages are sent to our backend and then to Google's Gemini API for the avatar's response to be generated.

2. For audio and video calls: your microphone audio (and, only if you have enabled the camera on a video call, your video frames) are streamed in real time from your device to Google's Gemini Live API (operated by Google Ireland Limited, processing region: europe-west).

3. Gemini processes the input, generates a response, and streams the synthesised speech (and text) back to your device in real time.

4. The avatar is rendered by our on-device engine (running locally on your iPhone) to animate the avatar's lip movements and facial expressions. No video of the avatar leaves your device.

3.2 Storage by Lipitt

Lipitt does not record, store or archive the raw audio or video of your calls on its own servers. We store:

• The text messages you exchange with an avatar (so you can find them again in your chat history);

• Short memory summaries per avatar (used to provide continuity across sessions with that avatar).

You can clear the history and memory of any avatar at any time from within the App.

3.3 Storage by Google

Google processes the streams and prompts as our sub-processor under its Cloud Data Processing Addendum. Based on Google's published policies:

• We have opted out of using your data for model training. Google does not use your prompts or responses to train its AI models.

• Google may temporarily log prompts and responses for a limited period for the sole purpose of detecting abuse and violations of its acceptable use policy.

For full details, see Google's Cloud Data Processing Addendum.

3.4 Camera and microphone are revocable

The camera permission is not required to use Mentors — it is only requested when you initiate a video call. You can grant it, refuse it, or revoke it at any time in iOS Settings → Mentors → Camera. The microphone is required for the audio and video call features; you can disable it in iOS Settings → Mentors → Microphone, but this will prevent audio and video calls from working. You can still use text chat with the microphone disabled.

4. How we use your data and legal bases

Under the GDPR, we must rely on a "legal basis" to process your personal data. The table below sets out our processing purposes and the corresponding legal basis.