Privacy Policy

Privacy Policy

This privacy policy is applicable to the NextPaycheck app for mobile devices, together with any related services operated by Arai Tech L.L.C-FZ (collectively, the "Application"). Arai Tech L.L.C-FZ is hereinafter referred to as the "Service Provider".

Data Controller Information

Arai Tech L.L.C-FZ acts as the Data Controller responsible for the processing of your personal data.

Name: Arai Tech L.L.C-FZ
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Email: admin@arai-tech.com

For data protection inquiries and to exercise your GDPR rights, please contact the Data Controller using the contact information above.

EU Representative: Oaca Stefanita Cornel, oacastefanita@gmail.com

What information does the Application obtain and how is it used?

The Application does not require you to create an account or register. The information it processes is the information you choose to enter, which may include: your income or paycheck amount and schedule, recurring financial obligations you add, the purchase questions or descriptions you type, your chosen settings, and the decisions you record in the Application. This information is stored locally on your device to provide the Application's budgeting and decision features.

When you use the AI verdict feature, some of this information (your purchase question and related budget context) is transmitted to a third-party AI provider to generate your response, as detailed in the AI section below. The Service Provider may also use information you provide to send important information and required notices and, where permitted by law and with your consent, marketing communications.

Legal basis for processing your personal data

Where the GDPR applies, the Service Provider relies on one or more lawful bases to process your personal data, including:

Contract performance: processing necessary to provide the Application or fulfil a contract with you.
Consent: where you have given explicit consent to processing, including for marketing, analytics, or optional features. You may withdraw consent at any time without affecting processing that occurred before withdrawal.
Legitimate interests: where processing is necessary for the Service Provider's specific legitimate interests, such as maintaining network and information security, preventing fraud and abuse, or improving the Application's core functionality through analytics, provided those interests are not overridden by your data protection rights or fundamental freedoms.
Legal obligation: to comply with laws or government requests.

Cookies and similar technologies

The Application or its third-party SDKs may use cookies, SDKs, pixels, and similar technologies to support functionality, analytics, and service delivery. Where required by law, the Service Provider will obtain your consent before using non-essential tracking technologies.

Automated decision-making and profiling

If the Application uses automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you, you have the right to request human review, express your point of view, and contest the decision. Information about the logic involved and the likely consequences of that processing will be provided where required by law.

What information does the Application collect automatically?

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.

Does the Application collect precise real time location information of the device?

This Application does not gather precise information about the location of your mobile device.

Does the Application use Artificial Intelligence (AI) technologies?

Yes. A core feature of the Application lets you describe a purchase you are considering and receive a humorous, character-based "verdict" in response. This response is generated using a third-party AI provider, DeepSeek, an AI service operated from the People's Republic of China (the "AI Provider").

Each time you use this feature, the following information is transmitted to the AI Provider in order to generate the response:

The text you type describing the purchase or question (please do not enter sensitive personal information in this field);
Budget context you have entered in the Application, such as your remaining budget amount, currency, and the number of days until your next paycheck;
A short summary of your recent in-app decisions (the item, amount, and whether you proceeded), used to keep the character's responses consistent.

This information is sent to the AI Provider to generate the in-app response you requested. Arai Tech does not itself use your inputs to train any AI models. However, the AI Provider (DeepSeek) acts as an independent controller of the data it receives and, under its own privacy policy, may use your inputs to train and improve its machine-learning models, algorithms, and technologies. DeepSeek stores the data it receives in the People's Republic of China. DeepSeek offers its own opt-out for the use of your data to train its models, which you must exercise with DeepSeek directly; the Service Provider does not control DeepSeek's processing and cannot exercise that opt-out on your behalf. Once your inputs are transmitted to the AI Provider, their retention and deletion are governed by DeepSeek's policies and are outside the Service Provider's control. We strongly encourage you to review the AI Provider's own terms and privacy policy at DeepSeek's Terms of Use and DeepSeek's Privacy Policy. Because the AI Provider is located outside the European Economic Area, this involves an international data transfer, as described in the "International Data Transfers" section below.

Responses are automatically generated for entertainment purposes, may be inaccurate, and do not constitute financial, investment, tax, or other professional advice. Using this feature is optional: your inputs are sent to the AI Provider only after you give explicit consent on the Application's in-app AI consent screen, and you can withdraw that consent at any time in the Application's Settings, under the AI section. If you do not consent, or if you do not submit a purchase question, no inputs are sent to the AI Provider.

Does the Application use analytics or crash reporting services?

Yes. The Application uses Google Firebase Analytics and Google Firebase Crashlytics, services provided by Google LLC and its affiliates ("Google"), to understand how the Application is used, to measure the performance of features such as onboarding and subscriptions, to diagnose crashes and technical problems, and to improve the Application. Google processes this information as the Service Provider's data processor under Google's data processing terms.

Through these services, the following categories of information are collected:

Usage events describing your interaction with the Application, such as the onboarding steps you reach, whether you grant or decline the in-app AI consent, when a subscription offer is shown and which plan you select, the outcome of a purchase attempt (for example completed, cancelled, or failed — never your card or payment details), when you change settings such as the response style, and when you share a verdict;
Aggregate, app-level attributes derived from your on-device data, such as the total number of purchase questions you have recorded and how many you resolved each way, your current streak, whether you have an active subscription, and your notification and reminder settings;
Information collected automatically by the analytics software, such as a pseudonymous app-instance identifier, your device model and operating system version, general diagnostic and performance data, and an approximate region derived from your IP address (Google does not log the full IP address for Analytics).

These services do not receive the purchase descriptions you type, your income or paycheck amounts, your obligation details, or the AI-generated verdict text; that information remains on your device or, for the AI feature only, is handled as described in the AI section above. The analytics information is used in aggregate to improve the Application, and the Service Provider does not sell your personal data. Depending on your region and applicable law, the Service Provider relies on your consent and/or its legitimate interest in securing and improving the Application as the legal basis for this processing; where consent is required, it will be obtained and you may withdraw it as described in this Policy. Google may process this information in the United States and other countries, as described in the "International Data Transfers" section below. For more information about how Google uses data from apps that use its services, see Firebase Privacy and Security and Google's Privacy Policy.

Do third parties see and/or have access to information obtained by the Application?

The Application shares information with third parties only as described in this privacy statement. Specifically:

AI Provider: When you use the AI verdict feature, the purchase text you enter and the related budget context are transmitted to our third-party AI provider (DeepSeek) to generate your response, as described in the "Does the Application use Artificial Intelligence (AI) technologies?" section above. Unlike the Service Provider's other service providers, DeepSeek is an independent controller and may use your inputs for its own purposes, including training and improving its AI models.
Apple: Purchases and subscriptions are processed by Apple through the App Store. Your payment details are handled by Apple and are not collected or received by the Service Provider.
Analytics and crash-reporting provider (Google): Aggregate usage events, app-level attributes, and diagnostic data are shared with Google (Firebase Analytics and Crashlytics) to help the Service Provider understand usage, diagnose crashes, and improve the Application, as described in the "Does the Application use analytics or crash reporting services?" section above. Google acts as the Service Provider's data processor for this information and does not receive the purchase text, income, budget, or obligation details you enter.

The budget, income, obligation, and decision information you enter is otherwise stored locally on your device and is not transmitted to the Service Provider's own servers. The Service Provider does not sell your personal data.

International Data Transfers

The Service Provider or its third-party service providers may transfer personal data outside the European Economic Area (EEA). Where such transfers occur, the Service Provider will use an appropriate transfer mechanism required by GDPR Chapter V.

Adequacy decisions by the European Commission
Standard Contractual Clauses (SCCs) approved by the European Commission
Other safeguards or derogations recognized under GDPR Chapter V, including consent where legally permitted

Countries outside the EEA may not provide the same level of data protection as the EEA. In particular, when you use the AI verdict feature, your input and related budget context are transferred to the AI Provider's infrastructure in the People's Republic of China, which is not the subject of a European Commission adequacy decision. Because the AI Provider is an independent controller that does not enter into Standard Contractual Clauses with the Service Provider, this transfer is made in reliance on your explicit consent under Article 49(1)(a) of the GDPR. You provide this consent through the Application's in-app AI consent screen before any data is sent, and you may withdraw it at any time in the Application's Settings, under the AI section. If you do not consent, your inputs are not transmitted to the AI Provider.

When you use the Application's analytics and crash-reporting services, information may be processed by Google on servers located in the United States and other countries. Google is certified under the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) and also offers Standard Contractual Clauses approved by the European Commission; the Service Provider relies on these mechanisms for transfers of analytics data outside the EEA. Unlike the transfer to the AI Provider, this transfer to Google as a processor does not rely on your Article 49 consent.

The Service Provider may disclose User Provided and Automatically Collected Information:

as required by law, such as to comply with a subpoena, or similar legal process;
when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with their trusted services providers who work on their behalf, do not have an independent use of the information the Service Provider discloses to them, and have agreed to adhere to the rules set forth in this privacy statement.

Where the GDPR applies, the Service Provider enters into Data Processing Agreements (DPAs) with third-party service providers that process personal data on its behalf, as required by Article 28 of the GDPR. These DPAs impose the same data protection obligations on those service providers as described in this Privacy Policy. The AI Provider (DeepSeek) is not a processor acting under an Article 28 DPA: it determines its own purposes for the data it receives, including training and improving its own models, and therefore acts as an independent controller. Sharing with the AI Provider is based on your explicit consent rather than on a DPA.

What are my opt-out rights?

You can stop further collection of information from your mobile device by uninstalling the Application. Uninstalling will stop the Application from collecting data from your device, but it does not automatically delete information that has already been transmitted to the Service Provider or to third parties.

To request deletion of your personal data, withdraw consent, or exercise any of your rights, contact the Service Provider at admin@arai-tech.com.

What is the data retention policy and how can you manage your information?

The Service Provider retains personal data based on its necessity for the stated purposes:

User Provided Data: Retained for the duration of your use of the Application plus 12 months thereafter, unless longer retention is required by law
Automatically Collected Data: Retained for up to 24 months from collection, unless longer retention is required for legal compliance or security purposes
Aggregated and Anonymized Data: Retained indefinitely as it no longer identifies you
Data required for legal compliance: Retained as long as required by applicable law

You have the right to request deletion of your personal data at any time, except where retention is required by law. If you'd like the Service Provider to delete User Provided Data that you have provided via the Application, please contact them at admin@arai-tech.com and they will respond within the time required by applicable law. Please note that some User Provided Data may be required in order for the Application to function properly.

How does the Application address children's privacy?

The Application is not intended for children under 16 years of age, or where a higher age of digital consent is established under applicable law. The Service Provider does not knowingly solicit data from children or market the Application to them.

The Service Provider does not knowingly collect personally identifiable information from children. The Service Provider encourages all children to never submit any personally identifiable information through the Application and/or Services. The Service Provider encourages parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide personally identifiable information through the Application and/or Services without their permission. If you have reason to believe that a child has provided personally identifiable information to the Service Provider through the Application and/or Services, please contact the Service Provider (admin@arai-tech.com) so that they will be able to take the necessary actions. If you are under 16 years of age, or where a higher age of digital consent is established by applicable law, your parent or guardian must provide consent on your behalf where permitted by law.

How is your information kept secure?

The Service Provider is committed to safeguarding the confidentiality of your information. The Service Provider implements physical, electronic, and procedural safeguards to protect information it processes and maintains. For example, access is limited to authorized employees and contractors who need to know that information to operate, develop, or improve the Application. However, no security system can prevent all potential security breaches.

Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, the Service Provider will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by applicable law. Where the breach is likely to result in a high risk to your rights and freedoms, the Service Provider will also notify you without undue delay, providing information about the nature of the breach, the categories of data affected, and the measures taken or proposed to address the breach.

How will you be informed of changes to this Privacy Policy?

The Service Provider may update this Privacy Policy from time to time. The Service Provider will notify you of material changes by posting the updated Privacy Policy with an effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect.

Previous versions of this Privacy Policy will be maintained and made available upon request by contacting the Service Provider at admin@arai-tech.com.

This privacy policy is effective as of 2026-07-17

What are your GDPR data protection rights?

Under the GDPR, you have the following rights:

Right of Access: You can request access to your personal data.
Right to Rectification: You can request correction of inaccurate data.
Right to Erasure: You can request deletion of your personal data (the "right to be forgotten").
Right to Restrict Processing: You can request that the Data Controller limits how they use your data.
Right to Data Portability: You can request a copy of your data in a structured, commonly used, machine-readable format.
Right to Object: You can object to processing based on legitimate interests. You have an absolute right to object to processing for direct marketing purposes at any time.
Right to Withdraw Consent: Where processing is based on your consent, you can withdraw it at any time. Withdrawal is as simple as toggling preferences in the Application's settings or contacting the Data Controller.
Rights Regarding Automated Decision-Making: You have rights related to automated decisions that affect you.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local Data Protection Authority. Contact details for each country's Data Protection Authority can be found at: https://edpb.ec.europa.eu/about-edpb/members_en

If you are located in the United Kingdom, you may contact the Information Commissioner's Office at https://ico.org.uk

What are your California privacy rights (CCPA/CPRA)?

If you are a resident of California, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information:

Right to Know: You can request disclosure of the categories and specific pieces of personal information the Service Provider has collected about you.
Right to Delete: You can request deletion of personal information the Service Provider has collected from you, subject to certain exceptions.
Right to Correct: You can request correction of inaccurate personal information.
Right to Opt-Out: You can opt out of the sale or sharing of your personal information for cross-context behavioral advertising.
Right to Limit Use of Sensitive Personal Information: You can limit the use of your sensitive personal information to essential purposes.
Right to Non-Discrimination: The Service Provider will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise any of these rights, please contact the Service Provider at admin@arai-tech.com. The Service Provider will verify your request using the information you provide and respond within the timeframes required by law. You may designate an authorized agent to make a request on your behalf.

How do you give your consent?

Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action. You may withdraw consent at any time without affecting processing carried out before withdrawal. Processing based on other lawful bases, including contract performance, legitimate interests, or legal obligations, is carried out as described above.

How can you contact the Data Controller?

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at admin@arai-tech.com.

To request deletion of your personal data or to exercise any of your rights, contact the Service Provider using the details provided above. The Service Provider will respond within one month of receiving your request, extendable by up to two months where necessary due to the complexity or volume of requests, as permitted by applicable law.

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