1. Introduction

Welcome to Commenter.ai.

MConsultants LTD (“us”, “we”, or “our”) operates https://commenter.ai (hereinafter referred to as the “Service”).

This Privacy Policy governs your visit to https://commenter.ai and explains how we collect, safeguard, and disclose information that results from your use of the Service.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, the terms used here have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Service and, together with this Privacy Policy, constitute your agreement with us (“Agreement”).

2. Definitions

SERVICE means the https://commenter.ai website operated by MConsultants LTD.

PERSONAL DATA means data about a living individual who can be identified from that data (or from that data and other information in our possession or likely to come into our possession).

USAGE DATA is data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who determines the purposes for which and the manner in which any Personal Data is processed. For the purposes of this Privacy Policy, we are the Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes data on behalf of the Data Controller.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service, corresponding to the Data Subject.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4. Types of Data Collected

Personal Data: While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you, such as your email address, as well as Cookies and Usage Data. We may use this Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of such communications by following the unsubscribe link.

Usage Data: We may collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device, including your IP address, browser type and version, the pages you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the Service with a mobile device, Usage Data may also include information such as the type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data.

Tracking Cookies Data: We use cookies and similar tracking technologies (such as beacons, tags, and scripts) to track activity on our Service and hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent, but if you do not accept cookies, some portions of the Service may not function properly.

Examples of Cookies we use include: Session Cookies to operate our Service, Preference Cookies to remember your preferences and settings, Security Cookies for security purposes, and Advertising Cookies to serve advertisements that may be relevant to you and your interests.

Other Data: While using our Service, we may also collect additional information such as sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone numbers, details of documents on education, qualification, professional training, employment agreements, non-disclosure agreements, information on bonuses and compensation, marital status, family members, social security (or other taxpayer identification) number, office location, and other similar data, where relevant.

Mobile App Data: If you use our mobile application, we may collect session tokens stored locally on your device to maintain login sessions (encrypted and automatically expiring after 7 days), post and comment data and engagement metadata securely fetched via our backend APIs from your connected professional network account, and data used for AI-based comment generation, where only the relevant post text and your preferred tone are sent to our secure backend for processing using third-party AI services. No personal identifiers or account credentials are shared in this process.

Report Data: If you choose to report AI-generated content within the mobile app, we may collect the AI-generated content being reported, the reason or category for reporting, a timestamp, and non-identifiable metadata such as device type or session ID (unless already part of the session token). This data is not linked to your personal identity, is used solely to review flagged content and improve comment quality, and is not shared with third parties.

5. Use of Data

MConsultants LTD uses the collected data to provide and maintain our Service and to notify you about changes to the Service.

We use data to allow you to participate in interactive features of our Service when you choose to do so, to provide customer support, and to gather analysis or valuable information so that we can improve our Service.

We use data to monitor the usage of our Service, to detect, prevent, and address technical issues, and to fulfill any other purpose for which you provide it.

We may use data to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, and to provide you with notices about your account or subscription, such as expiration and renewal notices and email instructions.

We may provide you with news, special offers, and general information about goods, services, and events we offer that are similar to those you have already purchased or enquired about, unless you have opted not to receive such information.

We may use data in any other way we describe when you provide the information or for any other purpose with your consent.

We do not sell, rent, or share your Personal Data with third parties for marketing or advertising purposes. All post, comment, and AI-related processing is performed securely via our backend APIs and used only to provide app functionality.

We may also use data to process, investigate, and improve the quality of AI-generated content based on user-submitted reports, while ensuring the anonymity of the reporting user.

6. Retention of Data

We retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

We retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Usage Data is generally retained for a shorter period, except where it is used to strengthen the security or improve the functionality of our Service or when we are legally obligated to retain it for longer periods.

7. Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside your state, province, country, or other governmental jurisdiction where data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

MConsultants LTD takes all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place, including the security of your data and other personal information.

8. Disclosure of Data

We may disclose Personal Data if required to do so by law or in response to valid requests by public authorities.

If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred as part of that transaction.

We may also disclose your information to our subsidiaries and affiliates, to contractors, service providers, and other third parties we use to support our business, to fulfill the purpose for which you provide it, or for any other purpose disclosed by us when you provide the information.

9. Security of Data

The security of your data is important to us, and we strive to use commercially acceptable means to protect your Personal Data.

However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee its absolute security.

10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) or European Economic Area (EEA), you have certain data protection rights under the GDPR.

You may request access to, update, rectify, or delete the Personal Data we hold about you, object to or request restriction of processing, and request data portability.

You may withdraw your consent at any time where we rely on your consent to process your personal information, and you can make such requests by contacting support@commenter.ai.

We may ask you to verify your identity before responding to such requests, and some data may be necessary for us to provide the Service.

You also have the right to lodge a complaint with your local data protection authority. For mobile app users, mobile session data is stored only locally on your device, automatically expires after 7 days, and you must scan a new QR code to continue using the app after expiration. You may request complete data deletion, including any data processed via our backend, by contacting support@commenter.ai.

11. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

Under the California Online Privacy Protection Act (CalOPPA), users can visit our site anonymously.

Our Privacy Policy link includes the word “Privacy” and can easily be found on the home page of our website.

Users will be notified of any privacy policy changes on our Privacy Policy page and can request changes to their personal information by emailing support@commenter.ai.

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser.

12. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect about you, to request deletion of your personal information, and to request that we do not sell (or share) your personal information.

Upon request, we will provide you with information such as the categories of personal information we have collected, the categories of sources, the business or commercial purpose for collecting or selling it, the categories of third parties with whom we share it, and the specific pieces of personal information we have collected about you, subject to legal limits.

You may request that we delete the personal information we hold about you, subject to certain exceptions, and we will also direct our service providers to delete it where appropriate.

We do not sell your personal information for monetary consideration, but certain transfers without monetary consideration may be considered a “sale” under California law; you may opt out of such transfers by submitting a Do Not Sell My Personal Information request.

To exercise your CCPA rights, you can send your request by email to support@commenter.ai. We will not discriminate against you for exercising your rights, although certain features or services may not be available if you choose to delete or restrict use of your data.

13. Service Providers

We may employ third-party companies and individuals to facilitate our Service, provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used.

These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

For mobile services, we use secure backend APIs that may interact with third-party services to fetch posts and generate AI-powered comments. These third-party services act strictly as data processors and do not store or reuse your data for any other purpose.

14. Analytics

We may use third-party Service Providers to monitor and analyze the use of https://commenter.ai.