Smirk

Privacy Policy

Last updated November 5, 2026

Smirk is an iPhone app where every match is an AI character. It is operated by Grayfalls LLC ("we", "us"). This policy explains what we collect, why, who helps us run the service, and the choices you have. Smirk is for adults 18 and over.

The short version. We collect what you give the app (your answers, photos and messages) to run your conversations. Your messages are processed by AI providers to write the characters' replies. We don't sell your data. Your conversations and photos are never shared with advertisers. If you allow tracking, we share install and purchase events with ad platforms to measure our ads. You can delete your account and data at any time in the app.

What we collect

What you give us

What we collect automatically

How we use it

AI and who processes your data

Every character is an AI. To write their replies, your recent messages, what you've shared in your profile, a summary of your conversation, and any photo you just sent in the chat are sent to the AI models we use. We share data only with service providers that help us run Smirk, under contracts that limit their use of it to providing their service to us:

We do not sell or share your personal information for advertising, and we do not track you across other companies' apps or websites. We never send your conversations or photos to advertisers, and Smirk shows no ads. Apple may tell us, without identifying you, which ad campaign led to an install (AdAttributionKit / SKAdNetwork).

How long we keep it

We keep your data while your account exists, including your chat history, so characters can remember your conversations. When you delete your account, we delete your profile, matches, messages, uploaded and received photos, purchase records and wallet right away. Copies in our database backups expire within 30 days. Our AI model provider and OpenAI may keep the requests we send them for up to 30 days to monitor for abuse, then delete them. Some technical logs (for example, the cost and success of an AI request, or a safety event with no message text) may be kept without your identity attached. Apple keeps its own records of App Store purchases.

Refund requests

If you ask Apple for a refund of a purchase, Apple may ask us about it. We may tell Apple how much of the purchase you used (for example, whether Sparks were spent), whether it was delivered, how long you've had your account, and how much you have bought and been refunded before. We never tell Apple what you wrote or who you chatted with.

Your choices and rights

If you're outside the United States

Smirk is run from the United States. Wherever you use it, Grayfalls LLC is responsible for your data (the "controller"), and your data is stored and processed in the United States and by the service providers listed above. Where the law of your country requires it, we rely on safeguards such as the European Commission's Standard Contractual Clauses (and the UK addendum to them) or a provider's certification under the EU-U.S. Data Privacy Framework.

If laws like the EU or UK GDPR apply to you, these are our legal reasons for using your data:

What you tell characters about yourself may include sensitive details (for example about your health or love life). You choose what to share; we use it only to write the characters' replies and to keep you safe, never for advertising.

You can ask us to access, correct, delete or export your data, to restrict or object to how we use it, and to withdraw consent, by emailing support@smirkapp.com. We answer within one month. You also have the right to complain to your local data protection authority (in the UK, the Information Commissioner's Office; in the EU, the authority in your country).

Age

Smirk is only for adults 18 and over. We don't knowingly collect data from anyone under 18. If we learn that someone under 18 is using Smirk, we delete their account.

Security

Data is encrypted in transit, access is limited to people and systems that need it, and photos and conversations are stored privately. No system is perfectly secure, but we work to protect your information.

Changes

If we change this policy in a meaningful way, we'll update the date above and tell you in the app.

Contact

Grayfalls LLC · support@smirkapp.com