Privacy Policy
Last Updated: March 12, 2025
1. Introduction
Welcome to SmokeFree[X] ("we," "our," or "us"). We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website and services.
2. Data Controller
SmokeFree[X] is the data controller responsible for your personal data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at: privacy@smokefreex.com
3. Information We Collect
We collect several types of information from and about users of our website, including:
- Personal identifiers (name, email address)
- Usage data (how you interact with our service)
- Device information (browser type, IP address)
- Cookies and similar technologies
- Information about your smoking habits and quitting journey (when provided)
- Conversation data from interactions with our AI therapist
- Health-related information you share during therapy sessions
4. How We Collect Your Data
We collect data through:
- Direct interactions (when you sign up, fill out forms, or communicate with us)
- Automated technologies (cookies, server logs)
- Third parties (analytics providers, advertising networks)
5. How We Use Your Data
We use your data for the following purposes:
- To provide and maintain our service
- To personalize your experience
- To improve our website and services
- To communicate with you
- To comply with legal obligations
5.1 AI Conversation Data Processing
When you interact with our AI therapist, we process your conversation data for the following purposes:
- To provide personalized therapy and support for smoking cessation
- To improve our AI models and enhance the quality of our service
- To analyze patterns and trends in smoking cessation journeys
- To ensure the safety and appropriateness of our AI responses
With your explicit consent, we may use anonymized conversation data to train and improve our AI systems. Before being used for training, all data is processed to remove personally identifiable information.
A limited number of authorized personnel may review conversations between users and our AI therapist for quality assurance purposes. These reviewers are bound by strict confidentiality agreements.
6. Legal Basis for Processing
We process your personal data on the following legal grounds:
- Your consent
- Performance of a contract
- Legitimate interests
- Compliance with legal obligations
For special category data (such as health information related to smoking habits), we process this data based on:
- Your explicit consent
- Necessity for the provision of health or social care
7. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
For conversation data with our AI therapist, we retain this information for 24 months after your last interaction with our service. After this period, personally identifiable aspects of the data are permanently deleted, though anonymized insights may be retained for ongoing model improvement.
8. Your Data Protection Rights
Under the GDPR, you have the following rights:
- Right to access - You have the right to request copies of your personal data.
- Right to rectification - You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
- Right to erasure - You have the right to request that we erase your personal data, under certain conditions.
- Right to restrict processing - You have the right to request that we restrict the processing of your personal data, under certain conditions.
- Right to object to processing - You have the right to object to our processing of your personal data, under certain conditions.
- Right to data portability - You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
- Right to withdraw consent - You have the right to withdraw your consent at any time where we relied on your consent to process your personal data.
To exercise any of these rights, please contact us at privacy@smokefreex.com. We may need to request specific information from you to help us confirm your identity.
9. Cookies
We use cookies and similar tracking technologies to track activity on our website and store certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
We use the following types of cookies:
- Essential cookies - Necessary for the website to function properly
- Analytics cookies - Help us understand how visitors interact with our website
- Marketing cookies - Used to track visitors across websites for advertising purposes
- Preference cookies - Allow the website to remember choices you make
10. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.
For conversation data with our AI therapist, we implement advanced encryption and security measures. All conversations are encrypted in transit and at rest, and access to raw conversation data is strictly limited to essential personnel.
11. Third-Party Disclosure
We may share your personal data with:
- Service providers who perform services on our behalf
- Business partners with your consent
- Law enforcement or regulatory agencies when required by law
We do not sell, trade, or otherwise transfer your conversation data with our AI therapist to third parties unless we have your explicit consent or are required by law to do so.
12. International Transfers
Your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
When transferring personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission.
13. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.
14. Contact Us
If you have any questions about this Privacy Policy, please contact us at:
Email: privacy@smokefreex.com
Address: 123 Smoke Free Street, Health City, 12345
Data Protection Officer: dpo@smokefreex.com