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Privacy Policy

Last updated: 10 November 2026

This Privacy Policy explains how TREVEN MEDIA, radijska dejavnost, d.o.o. (“Treven Media”, “we”, “us”) processes personal data when you use RevAIved: this website (revaived.ai), our Telegram bot, the RevAIved app and the backend service behind it, and our main website, the RevAIved app & company site (together, the “Service”). RevAIved is a service of Treven Media d.o.o. It lets you describe someone you have lost and chat with an AI persona inspired by them. You are always talking to an AI, never to the real person. RevAIved is not therapy, medical care or a crisis service.

We process personal data in line with the EU General Data Protection Regulation (GDPR) and the Slovenian Personal Data Protection Act (ZVOP-2).

1. Summary

  • On this website, analytics and advertising tools (Google Analytics, Microsoft Clarity, Meta Pixel) only run if you click “Accept all”. If you reject, nothing is tracked.
  • In the app, we store your account, personas, chats (including images) and short “memories” extracted from chats, because the Service needs them.
  • AI replies are generated by OpenAI in the USA. Chats are encrypted in transit and at rest, but not end-to-end encrypted: our servers and OpenAI process them in readable form.
  • We never sell your data and never use it to train AI models. No one on our team routinely reads your conversations.
  • You can delete your account and its content from inside the app at any time.
  • RevAIved is for adults (18+) only.

2. Who is responsible for your data

  • Controller: TREVEN MEDIA, radijska dejavnost, d.o.o. (Treven Media d.o.o.), Obrtna cona Logatec 22, 1370 Logatec, Slovenia
  • Registration no. 7579799000 · Tax no. 64090701 (not registered for VAT)
  • Privacy requests: privacy@revaived.com · Support: support@revaived.com · Legal: legal@revaived.com

We have not appointed a data protection officer, as we are not required to. Please send privacy questions to privacy@revaived.com.

3. This website, the Telegram bot & cookies

Without your consent

Our server processes technical data needed to show you the site (IP address, browser, requested page, time) and keeps server logs for 30 days. We store your cookie choice. If you click a “Begin in Telegram” button and have not accepted cookies, our /go link only redirects you to Telegram. Nothing about you is stored.

With your consent (“Accept all”)

  • Google Analytics 4 (Google Ireland Ltd / Google LLC): page views and interactions, with IP truncation and Consent Mode. Cookies: _ga, _ga_* (up to 2 years).
  • Microsoft Clarity (Microsoft Ireland Operations Ltd / Microsoft Corp.): heatmaps and session recordings of how you use the page (clicks, scrolls, mouse movement). Cookies: _clck (up to 1 year), _clsk (1 day).
  • Meta Pixel (Meta Platforms Ireland Ltd): measures our ads on Facebook and Instagram. Cookies: _fbp (90 days) and, if you arrived from a Meta ad, _fbc (90 days), which we set only after you consent.
  • Ad attribution via our /go link. When you click through to Telegram, we store your _fbc/_fbp values, IP address, browser user agent, an event ID and which button you clicked in Upstash (Redis), under a random one-time key, for at most 48 hours. If you then start our Telegram bot, we send this data to Meta’s Conversions API (Meta Platforms Ireland Ltd) to record a “Lead” and immediately delete the stored entry. Otherwise it expires automatically after 48 hours.

Your choice is stored in the cc-consent cookie (12 months) and in your browser’s local storage (cookie-consent). Legal basis: your consent (Art. 6(1)(a) GDPR and Art. 225 of the Slovenian Electronic Communications Act, ZEKOM-2). You can withdraw it at any time with the “Cookie settings” link in the footer. Withdrawal does not affect processing that took place before. Google, Microsoft and Meta may process data in the USA (see §10). Data in these tools is pseudonymous, not anonymous. Google Analytics data is kept for no more than 14 months, Clarity data for up to 1 year, and Meta processes data under its own terms.

Telegram

Our bot runs on Telegram. Your messages to the bot and your Telegram account are processed by Telegram under Telegram’s own privacy policy. Our bot reads the /start message to match the one-time key above and replies with a link to the app. We do not store your Telegram ID or chat ID.

4. What we collect in the app

  • Account data: email address and login credentials (passwords are stored only in hashed form by our authentication provider). If you sign in with Google or Apple, we receive an identifier and your email address; Apple may also share your name.
  • Persona details: name, nickname, relationship, language, year of birth, age at death, origin, personality, speaking style, catchphrases, hobbies, optional avatar photo.
  • Chat content: your messages, attached images and the AI’s replies.
  • Memories: short facts extracted automatically from your chats so the persona can remember them.
  • Subscription status: purchase and renewal events from Apple or Google, received through RevenueCat. We never see your card details.
  • Security and audit logs: IP address, user agent, request path, timestamps and the safety-check result for each request. These logs never contain message text.
  • Messages to us: emails you send us and our replies.

5. How the AI uses your data

For each reply, our server sends OpenAI’s API the persona profile, about the last 50 messages, the stored memories and any attached image. We also use OpenAI to extract new memories and to run the text of your messages through a moderation check for self-harm and similar risks. If such signs are detected, the persona steps out of character and points you to findahelpline.com. No one is alerted.

Under OpenAI’s API terms, API data is not used to train OpenAI’s models by default. OpenAI may keep it for up to 30 days for abuse monitoring.

6. Purposes & legal bases

  • Providing the Service (account, personas, chats, memories, AI replies, subscriptions): contract, Art. 6(1)(b) GDPR.
  • Sensitive information in chats, such as information about your health or mental health: your explicit consent, Art. 9(2)(a) GDPR, which we ask for in the app before you start chatting. You can withdraw it by deleting your chats or account.
  • Safety moderation, security, abuse prevention, server and audit logs: legitimate interest, Art. 6(1)(f), plus explicit consent for any sensitive information.
  • Analytics, ads measurement and attribution on revaived.ai: consent, Art. 6(1)(a) GDPR and Art. 225 ZEKOM-2.
  • Accounting, tax and handling your rights requests: legal obligation, Art. 6(1)(c).
  • Legal claims: legitimate interest, Art. 6(1)(f), and Art. 9(2)(f).

7. Data about deceased persons & other people

The GDPR does not apply to the data of deceased persons, but Slovenian law does. Article 9 of ZVOP-2 says such data may only be processed in accordance with the law. Close family members (a spouse, partner, child, parent or heir) have a recognised position regarding it, unless the deceased prohibited this. The protection lasts for 20 years after death. By creating a persona, you confirm that you are such a relative or otherwise have a legitimate right to use the information, and that, to your knowledge, the person did not object. We process it on your behalf, only to provide the Service.

Please don’t upload other people’s private information or photos unless you have a right to. Relatives who object to a persona can contact legal@revaived.com.

8. Who we share data with

  • DigitalOcean, LLC: hosts our websites and API on servers in Frankfurt, Germany.
  • Supabase, Inc.: database, sign-in and file storage, EU (Frankfurt) region.
  • OpenAI: AI replies, memory extraction and moderation (USA).
  • RevenueCat, Inc.: subscription status (USA).
  • Apple and Google: sign-in and app store payments, under their own privacy policies.
  • Upstash: temporary attribution storage (max. 48 hours, with consent only).
  • Google, Microsoft, Meta: analytics and ads measurement on revaived.ai, with consent only.
  • Telegram: the bot channel, under Telegram’s own policy.

Processors work under data processing terms and only on our instructions. We may also disclose data to authorities where the law requires it. We never sell personal data.

9. How long we keep data

  • Account, personas, chats, images, memories: until you delete them or your account.
  • Security and audit logs: up to 12 months.
  • Server logs: 30 days.
  • Provider backups: deleted data disappears from our providers’ backups as they roll over, within up to 30 days.
  • Attribution data in Upstash: deleted on use or after at most 48 hours.
  • Website analytics: see §3.
  • Billing and tax records: as Slovenian law requires (up to 10 years under ZDavP-2 and ZGD-1).

“Delete account” in the app deletes your account, personas, chats, memories and images from our live systems. This cannot be undone.

10. Transfers outside the EU

Our servers and database are in the EU, but some providers are based in the USA or process data there, most importantly OpenAI. For these transfers we rely on the EU–US Data Privacy Framework where the provider is certified, and/or the European Commission’s Standard Contractual Clauses in the provider’s data processing terms (for OpenAI: OpenAI’s Data Processing Addendum).

11. Your rights

You have the right to access your data, rectify it, have it erased, restrict processing, receive it in a portable format, object to processing based on legitimate interest, and withdraw consent at any time. There is no in-app export yet. To request a copy, an export or anything else, email privacy@revaived.com from your account email address. We reply within one month. This can be extended by two months for complex requests, and we will tell you if it is.

12. Security

Data is encrypted in transit (TLS) and at rest by our hosting and database providers, and database access rules keep each user’s data separate. Chats are not end-to-end encrypted. Our policy is that no one on our team reads conversations, except where needed for security, to comply with the law, or to handle a support request you make. If a breach puts your rights at risk, we will notify the Information Commissioner within 72 hours, and we will also tell you if the risk to you is high.

13. Age limit

RevAIved is only for people aged 18 or over. If you believe a minor is using it, contact privacy@revaived.com and we will delete the data.

14. AI transparency

In line with Article 50 of the EU AI Act, we make clear that you are interacting with an AI, not with the deceased person. We make no decisions about you based solely on automated processing that have legal or similarly significant effects. The Service currently does not use voice. If we add voice features, we will explain how they work and ask for your separate consent first.

15. Changes

We will update this Policy when our processing changes and show the date at the top. We will announce significant changes in the app or by email before they take effect.

16. Complaints

Contact us first at privacy@revaived.com. You also have the right to complain to the Slovenian supervisory authority, Informacijski pooblaščenec Republike Slovenije (Information Commissioner), Dunajska cesta 22, 1000 Ljubljana (ip-rs.si), or to the authority in the EU country where you live or work.

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