Privacy Policy

Last updated: July 21, 2026

This Privacy Policy (“Policy”) explains how Cortex Innova Ltd. (registration number HE 484658), a Cyprus private limited company with its registered office at Naxou, 1, 1st floor, Flat/Office 103, Strovolos, 2043, Nicosia, Cyprus (“Cortex”, “MyPlayBoo”, “we”, “us”, “our”), collects, uses, shares, and protects personal data when you use the MyPlayBoo website, apps, and related services (collectively, the “Service”).

MyPlayBoo is an adults-only (18+) AI entertainment platform. By using the Service, you acknowledge that you have read and understood this Policy. If you do not agree, please do not use the Service.

If a capitalized term is not defined here, it may be defined in our Terms of Service.

1. Who We Are and Our Role

For purposes of the EU General Data Protection Regulation (“GDPR”) and applicable Cyprus data protection law, Cortex Innova Ltd. is the data controller for the personal data described in this Policy.

2. Personal Data We Collect

We collect personal data in three ways: (A) information you provide, (B) information collected automatically, and (C) information from third parties.

A. Information You Provide to Us

Depending on how you use the Service, you may provide:

  • Account information (e.g., email address, login method, account ID, and basic profile settings).

  • Support communications (messages you send to customer support).

  • User Inputs (prompts and messages you type in chats) and any related preferences used to generate AI content.

  • Sharing choices (whether you mark content private or public, and what you choose to share with other users).

  • Age confirmation (we require users to confirm they are 18+; we may request additional verification where needed).

B. Information We Collect Automatically

When you use the Service, we may automatically collect:

  • Device and usage data: device type, browser type, operating system, app version, timestamps, pages/screens viewed, clicks, session data, and general interactions.

  • Identifiers and technical data: IP address, cookie identifiers, and similar device identifiers.

  • Approximate location: general location inferred from IP address (not precise GPS unless we explicitly request it).

We use cookies and similar technologies for essential functionality and analytics (see Section 6).

C. Information from Third Parties

We may receive limited data from:

  • Login provider (Google) if you choose Google sign-in (such as a Google account identifier and email address), depending on your permissions.

  • Payment processor (Finby and Coingate) for payment confirmation, subscription status, transaction identifiers, and billing signals. We do not store full payment card details (these are handled by the processor).

3. Adult Content and Sensitive Data

MyPlayBoo may generate adult content. We do not require users to provide sensitive personal data (e.g., health data, political opinions). Please do not include sensitive personal data in chats or uploads.

Because the Service is adults-only, we take steps designed to prevent minors from using the Service. If we learn a user is under 18, we will take action to restrict access and delete data where required by law.

4. How We Use Personal Data

We use personal data for the following purposes:

A. To Provide and Operate the Service

  • Create and manage accounts.

  • Authenticate users (email login and Google sign-in).

  • Provide subscriptions, PlayCoins usage, and purchases.

  • Generate AI content and enable user features (e.g., creating characters, saving content, sharing).

B. To Maintain Safety, Prevent Abuse, and Enforce Rules

  • Detect fraud, misuse, and security incidents.

  • Investigate reports and enforce our Terms.

  • Protect users and the Service.

C. To Communicate with You

  • Send transactional messages (account, security, billing, service updates).

  • Send marketing emails where allowed, and according to your settings (see Section 7).

D. To Improve and Develop the Service

  • Debug, analyze performance, and improve user experience.

  • Understand feature usage and improve product design.

AI Improvement Note (Important):  

We may use some interactions, User Inputs, and/or generated Outputs to improve and develop the Service (including quality and safety improvements). Where feasible, we aim to use aggregated or de-identified data. If you have questions about this in your jurisdiction, contact us (Section 13).

E. Legal and Compliance

  • Comply with legal obligations and lawful requests.

  • Establish, exercise, or defend legal claims.

5. Legal Bases for Processing (EEA/UK Users)

Where GDPR applies, we rely on these legal bases:

  • Contract: to provide the Service you request (account, chat functionality, subscriptions).

  • Legitimate interests: to secure and improve the Service, prevent abuse, measure performance, and operate our business responsibly.

  • Consent: where required for certain cookies/marketing communications.

  • Legal obligation: to comply with applicable laws and lawful requests.

6. Cookies, Analytics, and Tag Management

We use cookies and similar technologies for:

  • Essential operation (security, sessions, core functionality).

  • Analytics to understand usage and improve the Service.

We currently use:

  • Google Tag Manager.

  • Google Analytics.

  • Microsoft Clarity.

You can control cookies through your browser settings. If you disable cookies, parts of the Service may not function properly. Google provides controls such as Google Analytics opt-out mechanisms and ad personalization settings.

7. Marketing Emails and Your Preferences

We may send marketing emails from [email protected] where permitted.

You can opt out of marketing emails by:

  • Changing settings in your profile page (turn off marketing emails); and/or

  • Using unsubscribe options included in marketing messages.

Even if you opt out of marketing emails, we may still send transactional/administrative messages (e.g., account security, billing, important service notices).

8. How We Share Personal Data

We do not sell your personal data. We may share personal data in the following situations:

A. Service Providers (Processors)

We share data with trusted providers that help us operate the Service, such as:

  • AWS (hosting/infrastructure).

  • FinBy and CoinGate (payments).

  • Google Analytics / Google Tag Manager / Microsoft Clarity (analytics).

  • Sentry (crash monitoring).

  • Cookiebot (cookies).

These providers process data only as needed and under contractual safeguards.

B. Public or Shared Content Within the Service

If you choose to make an AI character or generated content public or share it with other users, other users may see and interact with it as part of Service features. Default is private.

C. Legal, Safety, and Enforcement

We may disclose information when we believe it is necessary to:

  • Comply with law, regulation, or legal process.

  • Protect rights, safety, and security of users, the public, or the Service.

  • Investigate or prevent fraud and abuse.

D. Business Transactions

If we are involved in a merger, acquisition, restructuring, financing, or sale of assets, personal data may be transferred as part of that transaction subject to appropriate protections.

9. International Data Transfers

Our providers (such as AWS and Google) may process data in locations outside Cyprus/EEA depending on service configuration.

Where GDPR applies and personal data is transferred internationally, we use appropriate safeguards (such as Standard Contractual Clauses and recognized transfer mechanisms) to protect personal data.

10. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy, including legal, accounting, security, and dispute resolution needs.

Key retention points:

  • Account Deletion: Users can delete their account. After deletion, we may retain certain data where necessary for legal compliance, security, fraud prevention, backups, or system integrity.

  • Content After Deletion: Content may be flagged as deleted but remain stored in our databases (for example, for backup, integrity, audit, or security reasons). Access is restricted and content is treated as deleted within user-facing features.

  • Inactive Accounts: Accounts inactive for more than 6 months may be deleted.

  • Billing, Payment, and Accounting Records: We may retain transaction records and related billing/accounting information for up to 7 years to meet legal and accounting obligations.

11. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal data. However, no system is 100% secure, and we cannot guarantee absolute security.

12. Your Rights and Choices

Depending on your location (especially EEA/UK), you may have rights to:

  • Request access to your personal data.

  • Correct inaccurate data.

  • Request deletion.

  • Object to processing or request restriction.

  • Request data portability.

  • Withdraw consent (where processing is based on consent).

To exercise your rights, contact us at [email protected]. We may request verification to protect your account and privacy. You also have the right to lodge a complaint with your local data protection authority (e.g., the Office of the Commissioner for Personal Data Protection in Cyprus).

13. Contact Us

If you have questions or requests about this Policy or your personal data:  

Email: [email protected]  

Cortex Innova Ltd.  

Registration No: HE 484658  

Naxou, 1, 1st floor, Flat/Office 103  

Strovolos, 2043, Nicosia, Cyprus

14. Changes to This Policy

We may update this Policy to reflect changes to the Service, legal requirements, or our practices. We will update the “Last updated” date and provide additional notice where required by law. Continued use of the Service means you accept the updated Policy.