Privacy Policy

Last updated: October 2026 – Version 1.0

This Privacy Policy explains how AI Psychologist collects, uses, keeps and protects users' personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD). Please read it carefully before using our services. It applies to the website https://za.psychologistai.ai and all its services.

1. Data controller

ControllerCEDIA Investigación y Desarrollo, S.L. (trading as AI Psychologist)
NIF / VAT numberB93806404
AddressAv. Aragón 30, 46021 Valencia, Spain
ActivityAI-based virtual assistant for emotional well-being
Emailsupport@psicologoia.ai
Websitehttps://za.psychologistai.ai
Applicable lawGDPR (EU) 2016/679 · LOPDGDD 3/2018

2. Data we collect and why

We collect different categories of data depending on how the user interacts with the platform:

2.1. Registration and account data

  • Name or username.
  • Email address.
  • Password (stored encrypted, never in plain text).
  • Date of registration and last login.

2.2. Usage and conversation data

  • Content of the conversations with the AI assistant.
  • History of interactions on the platform.
  • Technical session data (IP address, device type, browser, operating system).
  • Behavioural data on the platform (pages visited, session time).

Special category data – health data (art. 9 GDPR): conversations on the platform may contain information about the user's emotional, psychological or mental health. The GDPR classifies this data as a special category, which requires a higher level of protection.

The legal basis for processing it is the user's explicit consent (art. 9.2.a GDPR), given through a separate checkbox at registration. Users may withdraw this consent at any time without affecting the lawfulness of previous processing.

AI Psychologist does not use this data to make clinical decisions or diagnoses, and does not share it with health systems, insurers, employers or any unauthorised third party.

2.3. Billing and payment data

  • Data needed to manage the subscription (processed by Stripe – AI Psychologist does not store card numbers).
  • Payment and invoice history.

2.4. Browsing data and cookies

  • Own and third-party cookies (see section 7 and the Cookie Policy).
  • Meta Pixel for measuring advertising campaigns (see section 5).
  • Web analytics data.

2.5. Data we do NOT collect

  • We do not knowingly collect data from people under 18.
  • We do not store credit card data (handled entirely by Stripe).
  • We do not collect biometric data or precise geolocation data.

3. Purposes and legal bases

Each processing activity has a specific purpose and a specific legal basis under article 6 GDPR:

PurposeDataLegal basis (art. 6 GDPR)
Managing registration and account accessEmail, password, usernamePerformance of a contract (art. 6.1.b)
Providing the AI assistant serviceConversations, session dataPerformance of a contract (art. 6.1.b) + explicit consent for health data (art. 9.2.a)
Managing subscriptions and paymentsBilling data, payment historyPerformance of a contract (art. 6.1.b) + legal obligation (art. 6.1.c)
Transactional communications (registration confirmation, payment notices, etc.)EmailPerformance of a contract (art. 6.1.b)
Commercial communications and newsletterEmail, nameConsent (art. 6.1.a) + art. 21 LSSI
Analysing and improving the serviceAnonymised usage dataLegitimate interest (art. 6.1.f)
Personalised advertising on Meta (Facebook/Instagram)Browsing data, Meta Pixel, audience listsConsent (art. 6.1.a) through cookie management
Compliance with legal obligations (tax, accounting)Billing dataLegal obligation (art. 6.1.c)
Security, fraud prevention and abuse detectionIP, session data, logsLegitimate interest (art. 6.1.f)

4. Data processors and international transfers

To provide the service, AI Psychologist works with the following providers, which act as processors under article 28 GDPR:

ProviderFunctionCountry / seatGDPR safeguards
Anthropic, PBCProcessing of conversations (Claude AI model)USA / multi-regionDPA + Standard Contractual Clauses (SCCs), modules 2 and 3
Hostinger International Ltd.Hosting of the platform and web infrastructureLithuania (EU)Within the EEA – no international transfer
Stripe, Inc.Payment processing and subscription managementUSA / EU office in IrelandDPA + SCCs + PCI-DSS certification
Brevo (Sendinblue SAS)Transactional emails and commercial communicationsFrance (EU)Within the EEA – no international transfer
Meta Platforms Ireland Ltd.Advertising on Facebook and Instagram (Meta Pixel, audiences)Ireland (EU) / USADPA + SCCs + EU-US Data Privacy Framework

4.1. International data transfers

Some of these providers involve transfers of data outside the European Economic Area (EEA), mainly to the United States. These transfers are based on the Standard Contractual Clauses adopted by the European Commission (Implementing Decision 2021/914) and, in Meta's case, also on the EU-US Data Privacy Framework, adopted by European Commission adequacy decision of July 2023.

4.2. Data retention by Anthropic (API)

AI Psychologist uses the Anthropic API under commercial terms (not a consumer account). Under these terms, Anthropic deletes conversation inputs and outputs within a maximum of 7 days of receipt or generation and does not use API data to train its AI models. Exceptionally, if a conversation is flagged by abuse detection systems, retention may be extended to up to 2 years under Anthropic's acceptable use policy.

5. Social media advertising – Meta Ads

AI Psychologist uses Meta Ads (Facebook Ads and Instagram Ads) to promote its services. This involves the following technologies:

5.1. Meta Pixel

The Meta Pixel is a piece of JavaScript code that AI Psychologist installs on its website. When a user visits the site and has accepted marketing cookies, the pixel collects information about their behaviour (pages visited, actions taken, conversions) and sends it to Meta Platforms for the following purposes:

  • Measuring the effectiveness of advertising campaigns (conversions, cost per acquisition).
  • Creating Custom Audiences to show ads to users who have already visited the site.
  • Creating Lookalike Audiences to reach new users with profiles similar to current ones.
  • Optimising ad delivery towards users more likely to convert.

Important: the Meta Pixel should only be activated if the user has given prior consent to marketing cookies. If the user rejects marketing cookies, the pixel must not run and no data will be sent to Meta. Users can withdraw their consent at any time.

5.2. Custom audiences and remarketing

AI Psychologist may share with Meta, in encrypted form (SHA-256 hash), lists of email addresses of users who have given express consent to receive commercial communications. This practice is called Custom Audiences from Customer List and allows specific ads to be shown to those users on Facebook and Instagram.

Users can object to this practice at any time by writing to support@psicologoia.ai or directly from the ad settings of their Facebook account.

5.3. Joint controllership with Meta

In relation to the use of the Meta Pixel, AI Psychologist and Meta Platforms Ireland Ltd. act as joint controllers under article 26 GDPR, in accordance with the Controller Addendum signed with Meta. For more information on how Meta processes data, see Meta's Privacy Policy.

5.4. Express restriction: health data and advertising

AI Psychologist does not use or share with Meta any data from the conversations held on the platform, or any data that could reveal the user's mental or emotional health. The Meta Pixel works only at the level of browsing behaviour (visits, clicks, conversions) and never accesses the content of conversations. This restriction is absolute.

6. Commercial communications and email marketing

AI Psychologist uses Brevo (Sendinblue SAS), a company based in France (EU), to send electronic communications to its users. Brevo acts as processor and has a GDPR-compliant DPA.

6.1. Types of communications

  • Transactional communications: registration confirmation, account verification, payment notices, subscription renewal notices and password resets. These are necessary for the performance of the contract and do not require additional consent.
  • Commercial communications: newsletters, promotions, service news and useful content on emotional well-being. These require the user's prior, express consent (art. 21 LSSI) and can be cancelled at any time through the unsubscribe link in each email or by writing to support@psicologoia.ai.

6.2. Data processed by Brevo

To send emails, Brevo receives and processes the email address, the user's name and technical delivery metadata (open rate, clicks, bounces). No conversation data is sent to Brevo.

6.3. Opting out of commercial communications

Users can unsubscribe from commercial communications at any time without giving a reason, through:

  • The "Unsubscribe" link at the bottom of every commercial email.
  • A direct request to support@psicologoia.ai.
  • The preference settings in their account.

7. Cookies and tracking technologies

The website uses its own and third-party cookies. The main categories are:

CategoryPurposeExamplesConsent
Technical / necessaryBasic operation of the site, user session, securitySession cookie, CSRF tokenNot required (art. 22.2 LSSI)
AnalyticsAggregated analysis of traffic and user behaviourGoogle Analytics / own analytics toolRequired
Marketing / advertisingConversion measurement, remarketing, custom audiencesMeta Pixel (_fbp, _fbc)Required
PreferencesRemembering user settings (language, interface preferences)Interface settings cookiesRequired

For detailed information on the cookies used, their duration and the third parties involved, please see our Cookie Policy.

8. Retention periods

DataRetention periodReason
Account data (email, name)Duration of the contractual relationship + 5 years after closing the accountLegal obligation (limitation period for civil actions)
Conversation history (platform)While the account is active, or until deletion is requestedProvision of the service
Conversations on Anthropic's serversMaximum 7 days (commercial API)Anthropic's retention policy for API customers
Billing data5 years from the date of the invoiceTax obligation (Spanish General Tax Law 58/2003)
Security and access logs12 monthsLegitimate interest in security + art. 12 LSSI
Email marketing data (subscribers)Until consent is withdrawn or the user unsubscribesConsent (revocable)
Marketing cookie data (Meta Pixel)Maximum 90 days for _fbp / _fbc cookiesMeta Platforms policy

9. Your rights

Users may exercise the following rights against AI Psychologist as controller at any time:

RightWhat it means
AccessConfirmation of whether your data is being processed, and access to it.
RectificationCorrection of inaccurate or incomplete data.
ErasureDeletion of your data when it is no longer necessary or you withdraw consent.
RestrictionSuspension of processing in certain cases.
PortabilityReceiving your data in a structured, commonly used format to send it to another controller.
ObjectionObjecting to processing based on legitimate interest or for direct marketing.
Withdrawal of consentWithdrawing your consent at any time without affecting previous processing.
Not to be subject to automated decisionsRequesting human intervention in decisions taken solely by automated systems that significantly affect you.

How to exercise your rights: send an email to support@psicologoia.ai stating the right you wish to exercise and attaching a copy of your identity document. We will reply within a maximum of 30 days of receiving the request.

Complaint to the AEPD: if you consider that the processing of your data does not comply with the law, you have the right to lodge a complaint with the Spanish Data Protection Agency: www.aepd.es.

10. Security measures

AI Psychologist applies appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in accordance with article 32 GDPR:

  • Encryption of data in transit with TLS 1.2 or higher (HTTPS).
  • Encryption of data at rest (databases and backups).
  • Passwords stored with secure hash functions (bcrypt or equivalent).
  • Access to data restricted to staff with a justified need to know.
  • Two-factor authentication for administrative access.
  • Regular security audits and vulnerability management.
  • A documented procedure for responding to security breaches.

If a security breach poses a risk to users' rights and freedoms, AI Psychologist will notify the AEPD within a maximum of 72 hours of becoming aware of it and will inform the affected users without undue delay, in accordance with article 34 GDPR.

11. Minors

The service is intended exclusively for people aged 18 or over. By registering, users expressly declare that they are of legal age. AI Psychologist does not knowingly collect data from minors. If a user is found to be under 18, the account will be closed immediately and the data deleted.

Under article 7 of the LOPDGDD, processing the data of children under 14 requires the consent of their parents or legal guardians.

12. Changes to this Privacy Policy

AI Psychologist reserves the right to modify this Privacy Policy to adapt it to new legislation, case law or changes in the services provided. Any substantial change will be communicated to users by email at least 15 days before it takes effect. The updated version will always be available on the website, showing the date of the last update.

13. Applicable law and jurisdiction

This Privacy Policy is governed by Spanish law and by European data protection rules. For the resolution of any dispute relating to it, the parties submit to the jurisdiction of the courts and tribunals corresponding to the user's domicile in Spain, without prejudice to the user's right to lodge a complaint with the AEPD.

© AI Psychologist – CEDIA Investigación y Desarrollo, S.L. All rights reserved.