Privacy Policy

Phase Pal Privacy Policy

Effective Date: November 1, 2025

Introduction

Consistency AI LLC (“Consistency AI”, “we,” “us,” or “our”) has created this Privacy Policy to explain how we collect, use, and disclose personal information about you in connection with our website phasepal.com, the Phase Pal desktop application, and related software, services, and properties displaying or referencing this Privacy Policy (collectively, the “Services”). Consistency AI LLC is the data controller for the processing of your personal data under this Privacy Policy.

By using our Services, you agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy and in accordance with our Terms of Service.

1. Personal data we collect
We collect only the personal information necessary to provide and improve our services. The data points below are gathered directly or indirectly through your interactions with Phase Pal.

A. Information you provide to us

  • Account Information. When you create an account through our Unity application or website, we may collect your name, contact details, account credentials, date of birth, and payment information. If you sign in with Steam, we receive your Steam ID, profile information, and depending on your Steam privacy settings, your linked email address.
  • User-Generated Content. When you upload content to the Website Backend we collect and securely store each 3D model together with any metadata you provide. For voice-cloning services we collect and securely store your audio files along with metadata such as filename, display name, content type, duration, file size, voice characteristics (gender, category, language), and any custom tags you assign. The audio file is then deleted after a voice clone has been made.
  • Communications. If you contact support through the Desktop App we collect your steam username, and the content of your message. Our website contact forms collect your name, email address, message content, the page on which you submitted the form, and timestamps. When you file an authenticated issue report we also collect your user ID, email, username, the page where the issue occurred, additional diagnostic information such as file details, and timestamps so we can troubleshoot and resolve your concern.
  • Chat Data. In our desktop application, text and prompts you input when interacting with the pal are processed to generate responses, with this data typically processed locally or through third-party AI services without being stored long-term on our servers. Through our memory features, we process and store your conversation data, messages, and interaction history to provide personalized responses and maintain conversation context across sessions. This stored data includes your message content, conversation threads, and associated metadata to enhance your experience.
  • Payment Information. We collect and process payment information when you purchase or subscribe to any paid Phase Pal products or services.


B. Personal Information We Collect When You Use the Services

  • Usage Information. In the desktop app we record how you interact with the Services so we can maintain, protect and improve them. This includes feature usage metrics, crash logs, error reports, login attempts, and session-management activities that we log for security monitoring.
  • Device Information. When you visit our websites we collect browser type, IP address and time-zone information for operational and security purposes only. To ensure compatibility and to debug issues we collect your operating-system version and the HTTP User-Agent string supplied by your browser (containing browser type, version and operating system). We do not collect personally identifying details such as device name.
  • Location Information. We may infer your country or region from your IP address or Steam account data so we can enforce regional compliance requirements and content restrictions.
  • Cookies and Similar Technologies. We use cookies and browser storage for essential site functions, including authentication sessions, language preferences, cookie banner settings, Steam integration, and temporary caching to improve performance. We do not use marketing analytics, advertising, or tracking cookies.
  • Information We Receive from Third Parties. We receive data from platforms such as Steam and from payment processors that handle transactions on our behalf. When you sign in with Steam we collect the identifiers and profile data necessary to authenticate your account.
  • User Feedback. Users may provide ratings or reviews of other users content. We collect and process this feedback to display aggregate ratings and share relevant review information with creators to help them understand user sentiment and improve their content.

C. Information We Do Not Collect

Phase Pal does not knowingly collect sensitive or special category personal information, such as genetic data, biometric identifiers, health information, or religious beliefs. We also do not knowingly collect information from, or direct our Services to, individuals under the age of 18. If we discover or have reason to believe that a user is under 18, we will take appropriate steps to investigate and, where necessary, delete the associated personal data and/or account.

2. How We Use Your Personal Information
We use the data we collect for the following purposes:

  • To provide, maintain, and improve the Services.
  • To authenticate and manage your Steam-linked account.
  • To enable AI chat and voice features.
  • To process payments for premium features.
  • To communicate with you (service messages, support).
  • To prevent fraud prevention, compliance, and safety.
  • To enforce our Terms of Service and other applicable agreements.
  • To generate anonymized or aggregated data.

Regional Modes of Operation
Default (Cloud-First Mode): Outside certain GDPR contexts, the application connects to cloud APIs (e.g., OpenAI, Groq, OpenRouter) to deliver AI chat and voice features.
EEA Users: Chat histories are always stored locally on your device. Storing chat memory on our U.S.-based 3rd party servers for syncing requires your explicit opt-in consent.

3. How We Disclose Your Personal Information
We share personal information only as described below:

  • Vendors and Service Providers. We engage third-party providers for hosting, cloud storage, payment processing, email delivery, unity operational analytics, and other information-technology services. These parties access, process, or store personal data solely on our instructions and under confidentiality obligations.
  • Third-Party AI Providers. When cloud mode is enabled, chat inputs and related data are transmitted securely to pre-trained AI models to generate responses. No user data is used to train these models.
  • Legal and Compliance. We may disclose personal information to comply with applicable law, respond to lawful requests from public authorities, or protect our rights and the safety of our users.
  • Business Transfers. In the event of a merger, acquisition, financing, or sale of all or part of our assets, personal information may be transferred to the new entity, subject to standard confidentiality arrangements.
  • With Your Consent. We may share personal information for any other purpose disclosed to you and with your explicit permission.

AI Data Processing and Training Policy. When you use AI-based features such as voice cloning or text generation, we transmit your data securely to third-party processors solely to fulfill your request. We do not train our own models on user data. Voice files uploaded for cloning are stored temporarily in secure cloud storage, processed by Replicate’s voice-cloning service, and then deleted. Comments posted on 3D models are stored in our database and may be visible to other users. No opt-out is required because we do not engage in model training using your data. Phase Pal involves cloud-based processing and data sharing between users through public voice models and comments.

4. Your Choices
You have the following options to control your data:

  • Manage account linkage via Steam.
  • Delete your account and all associated data at any time.
  • Delete uploaded voices, AI models, comments, and saved content.
  • Delete individual memories and conversation data.
  • Opt out of promotional emails at any time.
  • Adjust Steam privacy settings to control what information we receive.
  • Request a complete export of your personal data through the export tool on the website, which includes profile information, voice uploads, clone history, purchase records, and third-party service usage data.

China-Specific Data Management. Users in China cannot disable local chat file creation, but you may delete your chat history at any time from settings, and no cloud sync or external transfers occur.

5. Purposes and Legal Basis of Processing (GDPR)

  • Steam Account Data: To authenticate your identity and manage accounts.
  • Chat Data: To provide AI responses. Local storage is default; cloud sync requires consent in the EEA.
  • 3D Models: Used locally for personalization.
  • Analytics: Collected in Unity anonymized form to improve performance.
  • Payments: Processed by Stripe or Steam.

6. Data Retention

  • Chat Data: Always retained locally; storing chat history on our U.S.-based servers requires explicit consent (EEA users only).
  • Account Information: Kept while your account is active and deleted when you close it.
  • Analytics: Stored for up to 24 months in anonymized form.
  • Payments: Retained by Stripe; we do not store credit card data.

7. Children’s Privacy
Our Services are not designed for or aimed at children under 13, and we do not knowingly collect personal data from them. Users under 13 are not permitted to use our Services. Those between 13 and the legal age of consent in their jurisdiction may use the Services only with the consent of a parent or guardian. If you believe a child under 13 has provided personal data to Consistency AI through our Services, please contact us at hello@consistencyai.net. We will review the report and, if necessary, remove the personal data from our systems. Users under 18 must obtain parental or guardian permission to use our Services.

8. Security
We use industry-standard encryption and storage practices designed to prevent data loss. Our cloud infrastructure features automated security updates, continuous monitoring, and detailed security logs to detect and respond to threats, though no online service can guarantee absolute security. We implement reasonable technical, administrative, and organizational measures to protect your data, but you should exercise caution when sharing information, as we are not responsible for circumvention of privacy settings or third-party website security.

9. International Data Transfers
EEA Users: Transfers to the U.S. rely on Standard Contractual Clauses (SCCs) and technical safeguards. Your data is processed and stored in the U.S. as part of our service operations. When you use our platform, your personal information and uploaded content may be transferred to and processed by our trusted third-party service providers, primarily located in the United States, to provide you with our voice cloning services. For users located in the European Economic Area (EEA), transfers of personal data to the United States are conducted in compliance with applicable data protection laws. We rely on Standard Contractual Clauses (SCCs) approved by the European Commission, along with technical and organizational safeguards, to ensure adequate protection of your data during international transfers. Before these transfers, we conduct a Transfer Impact Assessment (TIA) to evaluate the laws and practices of the destination country and confirm that they do not undermine the effectiveness of the SCCs. You may request a summary of our Transfer Impact Assessment or a copy of the SCCs by contacting us at hello@consistencyai.net.

10. Data Protection by Design and Default
Our Services are cloud-first to provide AI features. In the EEA, storing chat history on U.S.-based servers requires explicit opt-in consent. In China, the app runs in local-only offline mode.

11. Amendments
We may update this Privacy Policy periodically. Significant changes will be announced through the app or email 30 days before they take effect.

12. Data Breach Notification
We notify supervisory authorities within 72 hours of a breach and affected users without undue delay where required.

13. China-Specific Privacy Policy

  • Offline Operation: No AI service connectivity.
  • No Data Transmission: All data remains on the device.
  • Compliant Local Models: Only Qwen, DeepSeek, Alibaba models.
  • Consent Screen: Chinese users see a localized consent box explaining local processing and deletion rights.
  • Data Management: Chat files are created locally by default but may be deleted by the user.

14. International Scope

Our Services are operated and hosted in the United States and are intended for users located in the United States.

We do not market or offer our Services to individuals located in the European Economic Area (EEA), the United Kingdom, or other jurisdictions with comprehensive data-protection laws.

If you access the Services from outside the United States, you do so at your own initiative and are responsible for compliance with local laws.

Contact Information
📧 hello@consistencyai.net
Ekene Obiesie
PO box 831034
Richardson, TX 75080