Privacy Policy

Privacy Policy

Tyrell Inc. ("we", "us", or "our") values the privacy of all users and is committed to respecting and protecting your personal data. This Privacy Policy outlines how we collect, store, use, and share information when you use our services.

We are committed to safeguarding your personal data. When you engage with the Cochi AI Companion, the information you provide is processed strictly in accordance with this Privacy Policy. Our goal is to ensure that your interactions with the AI Companion are personalized, secure, and meaningful. We may analyze and learn from your feedback, inputs, and interactions to improve future conversations and enhance personalization.

Please note: while we may use data such as website visit information to improve and promote our services, conversations with the AI Companion will never be used for marketing or advertising purposes.

By using our app, website, or any related services (collectively, the "Services"), you agree to the terms of this Privacy Policy.

Unless otherwise defined herein, capitalized terms shall have the meaning assigned to them in our Terms of Service. If you have any questions, please contact us at official@tyrell.kr.

1. Overview of This Privacy Policy

When you visit our website or use our app, you may provide various types of personal data based on your activity. The same applies when using Cochi. It is important that you understand the applicable privacy policy before providing personal data. If one is not readily available, you should request it.

We only use your personal data as described in this policy. Unless otherwise specified, we do not share your data with third parties, except as described in this Privacy Policy and/or our Terms of Service.

2. Types of Personal Data Collected, Usage, and Sharing

We do not rent or sell your personal information to anyone.

Your conversations with the AI Companion are not shared with any other companies. They may be shared only with our affiliates, legal representatives, or service providers strictly as necessary.

We collect information you intentionally provide, as well as certain technical information collected from your device or browser.

Below is a list of personal data that may be collected and stored while using Cochi. Some of this data may be shared with service providers who support the functionality of Cochi.

Fields marked with an asterisk (*) are required; others are optional.

Data Type	Purpose	Retention Period
Email Address (*)	Account identification, login, user verification	5 years after account deletion
Device Time Zone (*)	To provide accurate reminders and time-based features	5 years after account deletion
Device Push Token (*)	For push notifications and device identification	5 years after account deletion
Conversation Data	For AI learning and personalization purposes	5 years after account deletion

3. Device Information

We collect information from the devices you use to access Cochi, such as computers, phones, and other web-connected devices. This information may be combined across devices.

Device information helps us conduct user research related to demographics, interests, and behavior. This information does not personally identify you. We may share aggregated user statistics with business partners or third parties for legitimate business purposes.

4. Cookies

We use trusted third-party analytics and advertising services to enhance your browsing experience. These partners may place cookies on your device. Please review their respective privacy policies to ensure you are comfortable with how your data is used.

• Google Analytics, Google DoubleClick: subject to Google’s Privacy Policy

• Facebook Pixel: subject to Facebook’s Privacy Policy

• Adroll: subject to Adroll’s Privacy Notice

• Criteo: subject to Criteo’s Privacy Policy

• Yahoo: subject to Yahoo’s Privacy Policy

• Microsoft Bing Ads: subject to Microsoft’s Privacy Policy

• MGID: subject to MGID’s Privacy Policy

5. Data Processing Methods

The data controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of your personal data.

6. Data Retention and Deletion

You have the right to delete your account at any time through the app, which will also initiate the deletion of your personal data.

You may also contact our support team to request deletion or modification of your personal data. Please note that deletion requests may take some time to process.

Data is retained only for as long as necessary to provide services. Once deleted, your data may still persist in cached or archived versions beyond our control, such as in internet archives or search engine caches.

Even after account deletion, we may retain certain data as required by law or for legitimate business purposes.

7. Changes to This Privacy Policy

We reserve the right to update or revise this Privacy Policy at any time. You are responsible for reviewing this page periodically. The "Last Updated" date at the top of this policy indicates the most recent changes.

8. Rights of Users in the European Union (EU)

If you are located in the EU, you have specific rights under the General Data Protection Regulation (GDPR), including:

• Right of Access: You have the right to know whether we are processing your personal data, and if so, to access it and obtain a copy, along with details of how it is being used (commonly known as a Subject Access Request).

• Right to Rectification: You may request correction or completion of any inaccurate or incomplete personal data we hold about you. If you cannot update it directly via the Service, contact us and we will update it as soon as possible.

• Right to Erasure (Right to be Forgotten): You may request the deletion of your personal data where it is no longer necessary, where you have withdrawn consent, where you object to processing and no overriding legitimate interest exists, where data was unlawfully processed, or where deletion is required by law. Please note this right is not absolute and may be limited by legal obligations or the need to establish, exercise, or defend legal claims.

• Right to Restrict Processing: You may request the restriction of processing in certain circumstances—such as when you contest the accuracy of the data (for a verification period), when processing is unlawful but you oppose deletion, or when you need the data for legal claims even if we would otherwise delete it. When processing is restricted, we will only process your data with your consent or for lawful reasons.

• Right to Data Portability: You may request to receive the personal data you provided to us in a structured, commonly used, machine-readable format, and to have that data transmitted to another controller where technically feasible. This right applies where processing is based on your consent or a contract and is carried out by automated means.

• Right to Object: You may object to our processing of your data when it is based on our legitimate interests (Article 6(1)(f) GDPR). We will assess your objection and determine if our interests override your rights. However, if your data is used for direct marketing purposes, you have an absolute right to object at any time, and we will stop such processing immediately.

• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing. For example, you can withdraw your consent to receive marketing messages, or remove optional personal data you previously provided.

• Right Not to be Subject to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which significantly affects you, unless it is necessary for a contract, authorized by law, or you have given explicit consent. We currently do not use automated decision-making in this way, but will comply with GDPR Article 22 if implemented in the future.

• Right to Lodge a Complaint: You have the right to lodge a complaint with a data protection authority in your habitual residence, place of work, or where you believe a breach of data protection law has occurred.

9. Rights of California Residents (CCPA/CPRA)

Residents of California have specific rights and notices under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) as outlined below.

• Notice Regarding the Sale of Personal Information
  • No Sale of Personal Information: We do not sell your personal information to third parties for monetary compensation.
  • No Sales in the Past 12 Months: In the past 12 months, we have not sold any personal information of California residents, including minors.
  • No Cross-Context Behavioral Advertising: We do not share your personal information for cross-context behavioral advertising without your consent.
  • Data Sharing for Analytics/Advertising Purposes: If we share data with third-party analytics or advertising partners, it is either in aggregated or anonymized form, or under contractual terms that do not constitute a “sale” under the CCPA.
  • Future Policy Changes: If we change our business practices to include the sale of personal information, we will update this policy accordingly and provide a “Do Not Sell or Share My Personal Information” link to allow you to opt out.

• Your Rights as a California Consumer
  • Right to Know: You may request that we disclose the following information collected about you in the past 12 months:
    • Specific pieces of personal information collected
    • Categories of personal information
    • Categories of sources from which the personal information was collected
    • Business or commercial purposes for collecting, selling, or sharing the information
    • Categories of third parties with whom the information was shared
  • Right to Delete: You may request the deletion of personal information we have collected and retained about you. Once we verify your identity and confirm the request, we will delete your personal data (and instruct our service providers to do the same), unless an exception applies. Deletion of your data may result in the termination of your account and loss of access to the service. Exceptions may include:
    • To complete a transaction initiated by you
    • To detect and prevent security incidents
    • To comply with legal obligations
    • Other exceptions permitted under the CCPA
  • Right to Correct: You may request the correction of inaccurate personal information that we hold about you. If you find any errors, you may request correction, and upon verification, we will make the necessary updates. Some information can also be updated directly through your account settings.
  • Right to Opt-Out of Sale or Sharing: You have the right to direct us not to sell or share your personal information with third parties. As we do not currently engage in “sales” or “sharing” as defined under the CCPA, we do not provide an opt-out link at this time. If such activities are introduced in the future, we will notify you and provide an appropriate opt-out mechanism.

• Non-Discrimination Policy
  • We do not discriminate against users for exercising their privacy rights.
  • If you request account deletion, access to the service may be restricted. However, no discrimination beyond what is permitted by law will occur.
  • In accordance with CPRA’s consumer rights requirements, we provide equal service without discrimination in pricing or service quality.

10. Acceptance of This Policy

Your use of our website, app, and related services constitutes your agreement to this Privacy Policy and the accompanying Terms of Service.

Use of Cochi and our services is contingent upon acceptance of this Privacy Policy and applicable terms.