Privacy Policy

1. Overview

GBFCIP team LLC (“we”, “us”) operates ActsLala. This Privacy Policy explains what information we process when you use gbfcip.net and how we use it. We design chat to minimize retention; member and payment data are processed only as needed to provide the Service.

GBFCIP team LLC (“we”, “us”) operates ActsLala. This Privacy Policy explains what information we process when you use actslala.com and how we use it. We design chat to minimize retention; member and payment data are processed only as needed to provide the Service.

2. What we collect

2.1 Casual chat (no member account)

• Temporary session identifier and nickname you choose
• Chat messages and metadata for delivery, subject to short TTL deletion (see PolicyTech)
• Technical data: IP address, browser/device type, timestamps (for abuse prevention and operations)

2.2 Member account (recharge / wallet)

• Email address or phone number and hashed PIN
• lala balance, expiry, and transaction history tied to your member record

2.3 Invite email address book (room owner)

• Room owners may store invitee email addresses solely to send an ActsLala room invite link
• Invitee emails are stored in plaintext on our server only for SMTP delivery; owner-only list/add/remove, rate limits, and ResidualCleanup TTL (about 90 days) apply
• Invite address books are keyed by the logged-in member account (not by chat room). The same owner keeps one list across rooms. Member signup/login is required; paying for a recharge is optional
• If the room owner opts in (checkbox next to My email), that owner email may be shown in the invite message as “Inviter.” If unchecked, the owner email is not shown in the invite body
• Room invite emails are sent through our email delivery provider (Brevo) from the ActsLala sender address of the site you are using: invite@gbfcip.netactslala@actslala.com. Our hosting provider’s mail server (poc@actslala.com) is used only for the contact form, sign-up verification codes and recharge notices — not for bulk room invites. Only if the owner has connected Google and separately allowed sending mail (gmail.send), invites are sent first from the owner’s own Gmail account and only to the addresses the owner confirmed; if Gmail’s daily limit is reached or a send fails, the remaining invites go through the delivery provider above

2.3.1 Google Contacts import (optional)

This section is the product-specific disclosure for Google user data obtained through OAuth / the Google People API. App: ActsLala (https://actslala.com/). Operator: GBFCIP team LLC.

This section is the product-specific disclosure for Google user data obtained through OAuth / the Google People API. App: ActsLala (https://gbfcip.net/). Operator: GBFCIP team LLC.

• Owners may connect their Google account via OAuth to import email addresses from Google Contacts
• We request only the Google scope https://www.googleapis.com/auth/contacts.readonly (read-only access to the owner’s contacts). The contacts import feature itself uses no other Google scope; the optional AI Secretary mail permissions are described separately in §2.3.2. Sending invites from the owner’s own Gmail is a separate, optional permission (gmail.send) used only to send the invitations the owner confirmed
• After Google authorization, contact names and email addresses are loaded temporarily into a selection UI in ActsLala for the room owner. We do not silently copy the entire Google address book into long-term storage
• Only emails the owner explicitly confirms (and, for select-all, only after an additional confirmation prompt) are saved to the invite address book described in §2.3
• Google OAuth tokens are stored on our Cafe24-hosted application server, linked to the owner’s session/member context (hashed session identifier), solely to call Google’s People API for this import feature; owners can disconnect Google from the invite Contacts modal (Disconnect Google), which deletes stored tokens and best-effort revokes them at Google. Unused token records are also pruned after about 7 days
• We do not sell Google user data. We do not use Google Contacts or other Google user data for advertising, retargeting, or interest-based ads
• We do not use Google user data to develop, improve, or train AI and/or ML models (including non-personalized models). Google user data from this scope is not used for AI/ML training
• Google user data from contacts.readonly is used only to provide the owner-facing invite picker described here (Limited Use: providing a user-facing feature in ActsLala)

Sharing / transfer / disclosure of Google user data

This clause states with whom we share, transfer, or disclose Google user data. We do not transfer or disclose your information to third parties for purposes other than the ones provided.

• Google — required to complete OAuth (token exchange / refresh / revoke) and to read the owner’s contacts via the People API under contacts.readonly. See Google’s Privacy Policy.
• Cafe24 (hosting) — ActsLala is hosted on Cafe24. Application data on that server, including OAuth tokens and the owner’s invite address book, is processed on Cafe24’s hosting infrastructure as needed to run the website. Cafe24 is not given a separate dump of the owner’s Google Contacts. Cafe24 SMTP from poc@actslala.com is used for the public contact form, sign-up verification codes and recharge notices, not for bulk Google-contact invites.
• Selected invite recipients only — if (and only if) the owner chooses specific emails and sends the invite (via our email delivery provider, Brevo, from invite@gbfcip.netactslala@actslala.com), an invite may be delivered to those addresses. The recipient sees the invite (room link and, if the owner opted in, the inviter’s email). Recipients do not receive the owner’s full Google contact list, unselected contacts, or OAuth tokens. Chat participants cannot access Google Contacts import (owner-only).
• No other third parties. We do not sell, rent, or transfer Google user data to advertising platforms, data brokers, information resellers, or analytics/ads vendors. Payment processors (for example Lemon Squeezy) do not receive Google Contacts or Google OAuth tokens. We do not share Google contact dumps with our email delivery provider (Brevo); it receives only the selected recipient address plus the invite message, not the owner’s full Contacts list.
• Google user data never leaves ActsLala + Cafe24 except: (1) the OAuth/API calls back to Google needed to import contacts, and (2) the invite email sent to a recipient the owner selected. That is the complete list of sharing, transfer, and disclosure.
• We may disclose data if required by applicable law, or if needed to investigate abuse of the Service. We do not otherwise allow humans to browse owners’ Google contact lists.

Data protection mechanisms for sensitive data

This clause specifies data protection mechanisms for sensitive data (Google OAuth tokens and contact data obtained under contacts.readonly). Security procedures are in place to protect the confidentiality of your data. We use encryption to protect your information in transit (HTTPS/TLS between the user’s browser and ActsLala, and TLS when our server talks to Google).

• Access control: Google Contacts import, contact list load, token disconnect, and invite-address-book changes require an authenticated room-owner session and a logged-in member account. Participants cannot call these APIs.
• OAuth token storage: Access and refresh tokens are stored server-side only (not in the browser as the system of record). Tokens live in a server data directory that is blocked from public HTTP access (web-server deny rules / .htaccess). Client secrets in *.local.php are likewise blocked from HTTP. Tokens are keyed to a hashed session identifier, not published at a public URL, and are not kept longer than needed for the owner’s import sessions (disconnect deletes them; unused records are pruned after about 7 days).
• No public contact dump: Unselected people from Google Contacts are not written into the long-term invite address book. Contact JSON and token files are not exposed as public website pages.
• Retention / deletion: Confirmed invite emails follow §2.3 and §4 (owner remove, ResidualCleanup TTL about 90 days, and room/TTL cleanup of related session context). Disconnect Google removes stored tokens and attempts revocation at Google.
• Logging: We do not publish contact lists in public logs. Operational error logs may contain technical messages; they are not a public contacts directory.
• We do not claim disk encryption-at-rest as a Cafe24 standard, and we do not claim SOC 2 or similar third-party certifications. Protections above are the mechanisms we actually operate.

2.3.2 AI Secretary — Gmail access (optional, separate consent)

The “Secretary” screen of the Mobi app can help the owner read and answer their own email. It works only if the owner connects Google from that screen and explicitly allows the extra permissions below. Contacts import and invite sending (§2.3.1) work without them.

• Scopes: https://www.googleapis.com/auth/gmail.readonly (read the owner’s mail), https://www.googleapis.com/auth/gmail.send (send a reply the owner approved) and https://www.googleapis.com/auth/gmail.labels (unread count only), plus the account email address. We do not request gmail.modify, so we cannot delete or change the owner’s mail
• What it does: (1) shows the unread count; (2) lists up to 10 unread inbox messages (sender, subject and a short preview); (3) when the owner taps one message, reads that message so a reply draft can be written; (4) sends the reply only after the owner presses Send, and only to the original sender of that message
• Not stored: Mail text is returned to the owner’s browser and is not saved on our server. We keep only usage counters needed to limit abuse
• Gemini / AI: Our server does not call any AI service on mail content, except for the optional important-mail summary described under “actslala key” below (only after the owner answers “yes”). If the owner has entered their own Gemini API key, the owner’s browser sends the selected message to Google’s Gemini directly with that key to draft the reply; by default the key stays in the owner’s browser. However, if the owner chooses to (a “store on server” checkbox, off by default), an encrypted copy of the key is kept on our server so it can be restored on another device; it is never shown in lists or logs and is deleted when the owner deletes the key. The same applies to optional chat translation, voice-to-text and photo captions. Lala is charged only for answers actually received
• Optional “actslala key” (company key): If the owner chooses this subscription option instead of their own key, the owner’s chat text (and, for voice consultation, the owner’s voice from their browser using a short-lived token) is sent to Google Gemini using our company key. Google processes it under its Gemini API terms; Google Search is used only when a question needs current information, and a more capable model only for detailed requests. We do not store the conversation; we keep only usage counters, Lala charges and subscription status (subscription payments are handled by Lemon Squeezy). Important-mail summary (optional): once a day the app may check, by simple rules and without AI, which of your recent Gmail messages look important (payments, warnings, replies to mail you sent, contacts, business or project proposals; ads and spam are excluded) and ask whether you want a summary. Only if you answer “yes” are the sender, subject and the first part of up to 5 of those messages sent to Google Gemini (through our company key with the actslala key, or from your browser with your own paid key) to write the summary. The mail content is not stored on our server, is not used for advertising or sale, and is not used to train AI models
• Device ID lock: While an AI key is saved on a device, that device’s login screen is fixed to the ID that saved it; deleting all saved keys releases the lock. This is stored only in the browser
• Limited Use: Google user data from these scopes is used only to provide these user-facing features. It is not sold, not used for advertising, not used to train AI/ML models, and not read by our staff except as required for security, legal compliance, or with the owner’s explicit consent
• Sharing: Only with Google (Gmail API, and Gemini when the owner uses their own key) and Cafe24 hosting for the OAuth tokens described in §2.3.1. Nothing is passed to other third parties
• Control: The owner can disconnect Google at any time on the Secretary screen (stored tokens are deleted and revoked at Google) or at myaccount.google.com/permissions

2.3.3 Mobi (friends and chat list)

• Nickname, optional profile picture (an emoji face or a small photo you choose) and a personal friend code
• Friend list, chat-list entries (which rooms you belong to) and unread counters
• Finding friends from your own address book is optional: your device sends one-way hashed email addresses, which we compare with member records and do not keep after matching
• AI Secretary personalization (such as how you like to be addressed) and your own Gemini API key stay in your browser and are not stored on our server — however, if you choose to, your key can be stored encrypted on our server (see §2.3.2)
• Chat message content follows the short-retention rules in §4

2.4 Payments

• Order IDs, amounts, payment method type, fulfillment status
• For card payments: Lemon Squeezy processes card data; we receive transaction references and custom order metadata, not full card numbers
• For bank transfer: deposit memo, amount, and confirmation records

3. How we use information

• Provide chat, translation, video, and lala wallet features
• Allow room owners to store invite emails and send room invite links (including optional Google Contacts pick-list import)
• Process purchases and prevent duplicate or fraudulent fulfillment
• Respond to support requests and legal obligations
• Enforce Terms, block abuse (e.g. session/fingerprint blocks), and maintain security

4. Retention/Deleted

• Chat messages: Deleted per ephemeral policy (e.g. after read timeout, room idle destruction, link expiry).
• Invite email address book: Each stored invite email is deleted after about 90 days (ResidualCleanup TTL), or earlier when the room owner removes it.
• Google OAuth tokens (Contacts import): Kept only while needed to refresh access for the owner’s import sessions; removed when the owner disconnects or when associated session/token records are purged.
• Member and payment records: Retained as long as needed for accounting, disputes, chargebacks, and legal requirements.

5. Third-party processors

• Google — OAuth and Google People API when an owner imports contacts (Google Privacy Policy). See §2.3.1 for sharing and protection of Google user data
• Cafe24 — website hosting and contact-form / sign-up code / recharge SMTP from poc@actslala.com
• Brevo — transactional email delivery for room invites, sent only to recipients the owner selected (Brevo Privacy Policy). Brevo does not receive Google OAuth tokens
• Lemon Squeezy — payment processing and Merchant of Record (Lemon Squeezy Privacy). Lemon Squeezy does not receive Google Contacts or Google OAuth tokens

6. Your rights

Depending on your jurisdiction, you may request access, correction, or deletion of personal data we hold about you, or object to certain processing. Contact us through the contact form. We may need to verify your identity via your registered contact.

Deleting a member account may not erase records we must keep for legal or payment dispute purposes.

7. International transfers

Our servers and processors may be located in the Republic of Korea and other countries. By using the Service, you acknowledge that data may be processed in those locations with appropriate safeguards where required.

8. Children

The Service is not directed at children under 14 (or the minimum age in your country). We do not knowingly collect data from children. Contact us to request deletion if you believe a child has provided data.

9. Use in your country and local laws

ActsLala is offered to a global audience, and the legality of online chat, translation, video, email-sending, AI features and similar services differs from country to country. We do not guarantee that the Service is lawful or available in every country. If the laws of your country or region restrict or prohibit use of the Service, or impose requirements on it, you are solely responsible for deciding whether to use ActsLala and for complying with those laws. Where local law requires a different level of data protection for you, we will honor the rights described in §6 to the extent we are legally required to do so.

10. Changes and contact

We may update this Policy. The “Last updated” date will change when we do. Material changes may be announced in the app.

Data controller: GBFCIP team LLC · 340-15-02889 · Registered address and contact form