Roxie Privacy Policy

1. Who we are

Roxie is an AI-powered conversational companion available through the Telegram bot, with this website as the entry point. The same operator runs both the website and the Telegram bot. The service is established in Spain and is offered internationally.

If you have any privacy question or want to exercise your data protection rights, you can contact us at hello@roxietee.com.

2. What this policy covers and what data we process

This policy applies to personal data processed when you:

visit meet.roxietee.com;
chat with Roxie on Telegram;
receive AI-generated messages from Roxie; or
contact us for support, privacy requests, or access issues.

This policy does not govern data practices of third-party platforms acting under their own policies, such as Telegram, except to the extent we receive or process data from those platforms in connection with providing the Roxie service.

Website and contact data

basic technical request data such as IP address, browser information, and server logs;
messages you send to us by email or other support channels;
local browser storage used to remember age verification, if enabled on your device.

Telegram account and interaction data

your Telegram username, Telegram user ID, display name, and profile information made available to the bot;
messages, prompts, and other text content you send to Roxie;
service usage details such as timestamps, delivery state, and daily message counts used to apply the usage limit.

Conversation memory and user profile data

A core feature of Roxie is persistent conversational memory. We therefore store relevant aspects of your conversations, such as preferences, recurring themes, personal context, and other profile signals derived from your interactions, so Roxie can respond consistently over time.

Purchase data

Getting into Roxie is free and requires no payment details. If you choose to make an optional purchase inside Telegram using Telegram Stars, payment is handled by Telegram: we never see or process card details and no payment gateway of ours is involved.

For each purchase we only keep a record with the transaction identifier, the product bought, the amount in Stars and the date, so we can grant the access you paid for, prevent duplicate charges, and handle any claims.

AI output-related data

Roxie is a text-only service: she does not send images or voice notes. We process the request data and delivery metadata for text replies through our infrastructure and service providers.

3. Why we process your data and legal bases

We process personal data for the following purposes:

To provide the Roxie service, including access, AI messaging, memory, personalization, and delivery of content. Legal basis: performance of a contract or pre-contractual steps.
To personalize the experience by maintaining conversation memory and a user profile based on relevant interactions. Legal basis: performance of the service and, where appropriate, your express instructions and acknowledgements.
To operate, secure, and moderate the service, including fraud prevention, abuse handling, access control, incident investigation, and service stability. Legal basis: legitimate interests and legal obligations where applicable.
To manage access and customer support, including handling access issues, disputes, and communications. Legal basis: contract and legitimate interests.
To comply with legal and regulatory obligations. Legal basis: legal obligation.

4. Profiling, memory, and AI transparency

Roxie builds and maintains a user profile from relevant conversation history to remember details and personalize future interactions. This is an intentional and central feature of the service.

We do not use your conversation data to train models, ours or anyone else's. With every request we technically require the AI providers not to retain your messages or reuse them for training. We do not sell your data. Roxie is an AI system, not a human being, and users should understand that they are interacting with software.

At this stage, Roxie's memory and personalization are not intended to produce decisions with legal effects or similarly significant effects within the meaning of Article 22 GDPR. If that changes, we will update this policy and the service flow accordingly.

5. Who we share data with

We share data only where reasonably necessary to operate the service:

Hetzner, where the bot runs, in the European Union (Helsinki, Finland).
Supabase, which hosts the service database, in the European Union (Frankfurt, Germany).
Telegram, because the bot runs on Telegram and your interactions depend on that platform.
AI model providers, to process your messages and generate Roxie's replies. Inference takes place in the United States.
Cloudflare, to serve this website and to measure visits in aggregate, without cookies.
Other infrastructure providers, where needed to run the bot, load the website, or serve content.
Authorities, courts, advisors, or insurers, where required by law or reasonably necessary to protect rights, safety, or the service.

International transfers

The service database is hosted in the European Union. Even so, some providers operate outside the European Economic Area: in particular Telegram, Cloudflare, and the AI model providers, whose inference takes place in the United States.

Where required, we rely on available lawful transfer mechanisms such as adequacy decisions, standard contractual clauses, or other safeguards made available by the relevant provider. Because provider configurations can change, we recommend reviewing the providers' own privacy materials in addition to this policy.

6. Data retention, rights, and safeguards

We keep data only for as long as reasonably necessary for the purposes described in this policy. Our current retention approach is:

Website server logs: generally up to 30 days, unless needed longer for security or incident response.
Support communications: generally up to 24 months after the last contact.
Telegram account identifiers and access records: while your access is active and for a limited period afterwards to manage reactivation, abuse prevention, and support.
Conversation memory and profile data: while you keep using the service, or until you request deletion, subject to limited backup and legal retention constraints.
Purchase records: for the period required by applicable law, so we can evidence the access you bought and handle claims.
Compliance records: for the period required by applicable law.

Subject to applicable law, you may have the right to access, rectify, erase, restrict, object to, or port your personal data, and to object to certain profiling activities. You may also lodge a complaint with the competent supervisory authority, including in Spain with the Agencia Española de Protección de Datos (AEPD).

Roxie is intended only for adults aged 18 or over. We do not knowingly offer the service to children or minors. We use reasonable technical and organizational measures to protect data, including secure hosting and access controls. Conversations are processed inside confidential computing environments (TEE) with hardware-encrypted memory, so the inference provider cannot access the content of the messages. Even so, no system can be guaranteed to be fully secure.

Roxie does not use advertising cookies or cookie-based analytics. The website does use Cloudflare Web Analytics, a measurement tool that counts page visits without setting cookies and without building a profile of you. We may use limited browser-side storage for strictly functional purposes, such as remembering that you passed the age gate. See Cookies & Storage for details.