Last Updated: March 2026

CONTACT US

If you have questions about data protection or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the support features within the App, so we can reply to you more quickly. Alternatively, you may contact:

Name of the controller: Ventura Brands Oy

Address: Vanha talvitie 19, FI-00580 Helsinki, Finland

Email: support@mysilvery.com

I. INTRODUCTION. REGIONAL NOTICE (CALIFORNIA)

This Privacy Policy ("Privacy Policy") outlines our data protection practices and describes the types of information we may process when you use our mobile application (the "App").

Our App is a free AI-powered sleep chat assistant. You do not need to create an account or log in to use our App. We do not collect or store your personal information in our own systems beyond what is necessary to operate the App, and we do not sell your personal information. However, certain data, including your chat messages and any optional personal details you choose to share (such as your name, age, or gender), is transmitted to OpenAI, our third-party AI service provider, to generate responses. Please see Section II and Section IV for full details

When we refer to "personal data" (or "personal information"), we mean any information that relates to an identified or identifiable natural person.

This Privacy Policy applies to all users who access our App ("Users"). PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW YOUR INFORMATION MAY BE PROCESSED. BY USING OUR APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE READ THE FOLLOWING IMPORTANT NOTICE.

Under the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request the following information regarding their personal information:

• The categories of personal information that we process;
• The categories of sources from which personal information is obtained;
• The purposes for which we process user personal data;
• The list and categories of third parties with whom we may share your personal information;
• The specific pieces of personal information that we may have collected about you, provided that the information submitted in the request is sufficient to identify you.

Please note that the only third party engaged in processing user data through our App is OpenAI, which acts as a service provider processing data based on contractual agreements and as necessary for the delivery of our chat service.

Opt-Out Options

Since we do not collect personal information in our own systems, there is no personal data stored with us to opt out of. However, if you wish to stop your chat messages from being processed by OpenAI, you may simply discontinue use of the App. If you have further questions, please contact us at support@mysilvery.com

Requests

If you would like to submit a verifiable request regarding your personal data — whether for access, portability, or deletion — please reach out to us at support@mysilvery.com When contacting us, please include the phrase "Your rights to maintain confidentiality in the state of California" in your request.

We aim to respond to all verifiable consumer requests within 45 days of receipt. If additional time is needed, we will notify you in writing. Per legal requirements, we are obligated to respond to a maximum of two requests per individual each year.

Equal Rights Policy

We are committed to upholding equal rights and ensuring non-discrimination in the handling of your requests. Regardless of your choices regarding your personal information, we will maintain consistent service quality for all users. Our App is free and requires no registration, so exercising your privacy rights will not affect your access to the App.

Data Sales Policy

We do not sell, trade, or otherwise transfer your personal information to any third parties. Your data is used solely for the purposes outlined in this Privacy Policy.

II. INFORMATION WE PROCESS

1. Information You Choose to Share

Our AI sleep assistant may optionally ask for your name, age, and gender to personalize your conversation. Providing this information is entirely voluntary. You may use the App without sharing any of this. Any information you choose to provide is transmitted to OpenAI as part of your chat session.

We also collect information you provide if you contact us via email or a support form, including your name, email address, and message content, solely to respond to your inquiry.

2. Chat Conversation Data

The content of your chat conversations with the sleep assistant is transmitted to and processed by OpenAI to generate responses. Conversation logs are also saved in our back-end systems for the purpose of maintaining session continuity and improving the App experience. These logs are not linked to any registered account, as no accounts or logins are required.

3. What We Do Not Collect

We do not collect or store the following in our own systems:

• Email addresses, or contact information (unless you contact us directly for support)
• Dates of birth, physical characteristics, or health records
• Payment or financial information
• Device identifiers or advertising IDs
• Precise or approximate location data
• Usage analytics or behavioral tracking data

We do not display advertisements in our App.

4. Third-Party AI Processing (OpenAI)

Our App is powered by OpenAI. When you use the chat assistant, your messages are transmitted to and processed by OpenAI's servers. This includes any optional personal details you choose to share during the conversation.

We encourage you to review OpenAI's Privacy Policy to understand how they handle your data:

• OpenAI Privacy Policy (US): https://openai.com/policies/us-privacy-policy
• OpenAI Privacy Policy (General): https://openai.com/privacy

III. PURPOSES OF PROCESSING YOUR DATA

We process information for the following purposes:

• To make the App available. We use your chat content to deliver AI-generated sleep assistant responses via OpenAI.
• To improve and monitor the App. We use anonymized conversation data to refine the quality and accuracy of the assistant.
• To communicate with you. If you contact us, we use your contact information to respond to your inquiry.
• To prevent fraud and enforce the law. We may use information to detect and prevent fraudulent, harmful, or unlawful activity and to enforce our Terms of Use.

Should any new purposes for processing arise, we will update this Privacy Policy accordingly.

 

IV. SHARING OF YOUR INFORMATION

We share your information with third parties only as described in this Privacy Policy. We do not rent or sell your personal data.

The only third-party service provider we engage in connection with the App's core functionality is:

We may also disclose your information in the following limited circumstances:

• Legal compliance — if required by law, court order, or government request;
• Safety — if disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud;
• Business transactions — in the event of a merger, acquisition, or sale of assets, you will be notified of any changes to how your information is handled.

V. USER CONSENT FOR THIRD-PARTY DATA SHARING

Before your data is transmitted to OpenAI for the first time, we will ask for your explicit consent within the App. You will be presented with a clear notice explaining:

• What data will be sent - your chat messages and any optional personal details you choose to provide, such as your name, age, or gender
• Who it will be sent to - OpenAI, L.L.C.
• The purpose of the transfer - to generate AI-powered sleep assistant responses

You may choose to decline, in which case the AI chat features will not be available. If you have previously given consent and wish to withdraw it, you may do so by discontinuing use of the App and contacting us at support@mysilvery.com.

 

VI. DATA TRANSFERS

Our App is operated from the United States. When you use the chat assistant, your messages are processed by OpenAI, which operates in the United States. If you are located outside the US, please be aware that your data may be transferred to and processed in the US, where privacy laws may differ from those in your jurisdiction.

VII. DURATION OF DATA RETENTION

Chat conversation logs saved in our back-end are retained for as long as necessary to provide and improve the App's services. Since we do not maintain user accounts, there is no account data to delete. If you wish to request deletion of any conversation data associated with your session, please contact us at support@mysilvery.com

Certain data may be retained for a limited period if required to comply with legal obligations or to prevent fraud or malicious activity.

VIII. YOUR RIGHTS

You have the following rights regarding your personal data:

• Right to Access — You may request information about what data we hold about you.
• Right to Deletion — You may request that we delete personal data we hold.
• Right to Portability — You may request a copy of your data in a commonly used format.
• Right to Object — You may object to certain types of data processing.

To exercise any of these rights, please contact us at support@mysilvery.com. Please note that we can only fulfill requests related to information we physically access and store. For data processed by OpenAI, please contact them directly via the links in Section II or Section IV.

IX. HOW TO OPT OUT

Since we do not use advertising or behavioral tracking, there are no ad-tracking permissions to manage within our App. To stop your chat messages from being sent to OpenAI, simply discontinue use of the App.

If you contact us and wish to have your support correspondence deleted, please reach out to support@mysilvery.com

X. SECURITY

We take reasonable technical and organizational measures to protect information processed through our App. We endeavor to ensure that data transmitted to third-party services such as OpenAI is handled securely.

However, no method of transmission over the Internet is 100% secure. We cannot guarantee the absolute security of data once it is transmitted to third-party services. In the event of a security breach affecting your information, we will notify you promptly in accordance with applicable laws.

If you have security-related questions, please contact us at support@mysilvery.com

XI. MEDICAL DISCLAIMER

Our App is designed exclusively for general informational conversations about sleep and wellness habits. The AI sleep assistant is not a medical professional and will not provide medical advice, diagnoses, treatment recommendations, or any other form of medical instruction. Nothing in this App should be interpreted as medical advice. If you have health or sleep concerns, please consult a qualified healthcare professional.

XII. CHILDREN'S PRIVACY

Our App is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has shared personal information through the App, please contact us at support@mysilvery.com, and we will take immediate steps to address it.

Users between the ages of 13 and 18 should use the App with parental or guardian awareness and consent.

XIII. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to periodic updates. In the event of any material changes, we will post the revised version within the App with an updated "Last Modified" date. We encourage you to review this policy periodically.

Our App is free to use and requires no registration. Our goal is to provide helpful, safe, and private conversations about sleep - nothing more.