Roxie Privacy Policy

1. Who we are

Roxie is an AI-powered conversational companion made available through a website, Telegram, and selected third-party providers. 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

This policy applies to personal data processed when you:

visit meet.roxietee.com;
purchase or manage a Roxie subscription through Whop;
chat with Roxie on Telegram;
receive AI-generated messages, images, or voice outputs from Roxie; or
contact us for support, privacy requests, or account issues.

This policy does not govern data practices of third-party platforms acting under their own policies, such as Telegram or Whop, 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, uploads, and other content you send to Roxie;
service usage details such as timestamps, delivery state, and subscription-linked access status.

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.

Subscription and transaction data

Payments are handled by Whop. We do not receive full payment card numbers. We may receive subscription metadata from Whop such as plan, purchase status, start date, renewal state, cancellation state, and identifiers needed to grant or revoke access.

AI media and output-related data

If your plan includes media outputs such as images or voice notes, we may process the related request data and delivery metadata 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 account 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 subscriptions and customer support, including handling access issues, disputes, and communications. Legal basis: contract and legitimate interests.
To comply with legal, tax, accounting, 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 our own AI models. 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, our hosting infrastructure provider in Europe, for server and data hosting.
Telegram, because the bot runs on Telegram and your interactions depend on that platform.
Whop, for subscription and payment workflow management.
Anthropic, to process prompts and generate AI outputs.
ElevenLabs, if voice generation is used in your plan or interaction flow.
Web infrastructure and delivery providers, where needed to 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

Some of our providers operate outside the European Economic Area or may remotely access data from outside the EEA. In particular, Telegram, Whop, Anthropic, ElevenLabs, and some web infrastructure providers may involve international data transfers.

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 your account remains active, or until you request deletion, subject to limited backup and legal retention constraints.
Billing and compliance records: for the period required by applicable tax, accounting, or legal obligations.

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, but no system can be guaranteed to be fully secure.

Roxie does not currently use analytics or advertising cookies. 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.