Version 2026.10.2 · Effective 11 September 2026 · Last updated 11 September 2026 · Chap.AI by Chap.Club
Operated by Elliott James Chapman (Individual / Sole Trader) trading as Chap.Club, ABN 57 434 518 597.
This summary is for orientation only. The numbered sections below are the policy that actually applies.
This document has been prepared for clarity and is intended for review by qualified legal counsel before it is relied upon. It is not legal advice and is not a guarantee of compliance with the law of every jurisdiction.
1.1 Chap.AI is an AI companion application operated under the registered business name Chap.Club. The entity responsible for the personal information described here — the data controller for the purposes of the UK and EU GDPR, and the entity accountable under the Australian Privacy Act 1988 (Cth) — is Elliott James Chapman (Individual / Sole Trader) trading as Chap.Club, ABN 57 434 518 597.
1.2 Our registered place of business is Queensland, Australia. We do not publish a street address; legal and privacy notices should be sent to the email addresses in section 31. [REQUIRES CONFIRMATION] — whether a service address for formal legal notice must be published in any market we distribute to.
1.3 This policy applies to the Chap.AI mobile and web applications, the website at https://project--8e014427-4596-4442-b2fb-c089faf96799.lovable.app, and the support and billing correspondence connected with them (together, the Service). It does not apply to third-party services you choose to reach from within the Service, which are governed by their own policies.
1.4 We have not appointed a Data Protection Officer and have not appointed an EU or UK Article 27 representative. [REQUIRES CONFIRMATION] — whether the volume and nature of our EEA or UK processing makes either appointment mandatory. Privacy enquiries are handled by the operator directly at privacy@chap.club.
3.1 We collect the following categories.
3.2 Device permissions. The microphone is used only while you hold the dictation control; the camera and photo library only when you choose to attach a photo; notifications only if you enable them. Each permission is requested by your device at the moment of first use and may be withdrawn in your device settings at any time.
3.3 Sensitive information. We do not ask for sensitive information (such as health, biometric, racial, religious, political or sexual-orientation data). Because Chap is an open-ended conversational product, you may nevertheless volunteer such information in a message. Where you do, you are consenting to us handling it as described in this policy for the purpose of providing the Service. Please do not send us information you would not want stored, and never rely on Chap for safety-critical details.
4.1 We use personal information to: create and operate your account; generate and deliver AI replies, images and games; maintain conversation history and, where enabled, memory; apply plan quotas and entitlements; process payments, subscriptions and refunds; operate ChapPoints, ChapPacks and streaks; send the notifications you have chosen; detect, prevent and investigate abuse, fraud and security incidents; respond to support requests; meet legal, tax and accounting obligations; and understand aggregate product usage where analytics are enabled.
4.2 Where the EU or UK GDPR applies, we rely on the following legal bases.
4.3 We do not sell personal information, we do not share it for cross-context behavioural advertising, and we do not use your conversations to target advertising.
5.1 Chap generates replies automatically using large language models supplied by third-party providers and reached through an AI gateway. To answer you, the content needed for that request — typically your message and a limited slice of recent conversation, plus any relevant memories, uploaded image or prompt — is transmitted to the model provider.
5.2 Chap selects a model for each request. Which model answers may vary with the complexity of the request, provider availability and our own running-cost safeguards, so quality and speed can differ between requests.
5.3 AI output can be wrong. Replies are generated statistically, not retrieved from a verified source, and may be inaccurate, incomplete, outdated or misleading. Chap does not give financial, medical, legal or other professional advice. See the Acceptable Use Policy and AI notice.
5.4 Market data, web look-ups and image look-ups send only the query or symbol involved to the relevant data provider, without an account identifier.
6.1 Memory is an optional feature you control in Settings. When it is on, Chap may write short notes about your stated preferences, interests and context so later conversations feel continuous and personalised. Those notes are stored against your account and may be supplied to the model with a later request.
6.2 Memory is limited and fades. Only a small number of notes are kept, and less-used notes are displaced automatically as newer ones arrive. Chap does not remember everything you say, nothing is guaranteed to be retained for any period, and memory must never be used as the only record of anything important — in particular allergies, medical, financial or other safety-critical details.
6.3 You can view every stored memory on the Memories page, delete any of them individually, and switch memory off entirely in Settings. Switching memory off stops new memories being created; deleting a memory removes it.
7.1 Chap Finds surfaces potentially useful information — such as an openly licensed photo or a web look-up — related to what you are discussing. It runs only in response to your interaction, and only the query terms involved are sent to the search or image provider. No account identifier is sent with the query.
7.2 Where Chap Finds draws on your stated interests or memory to decide what is relevant, it does so on our own servers, using only information you have already provided in the Service. Turning memory off, or clearing your memories, limits what it can draw on. Results returned by third-party sources are not vetted by us and are provided as-is.
8.1 Uploads and Chap Vision. When you attach a photo, it is stored privately against your account and transmitted to the model provider so Chap Vision can analyse it and answer your question about it. Only images you choose to attach are processed. We do not run facial recognition, and we do not use your photos to identify you or anyone else.
8.2 Generation. When you ask Chap for a picture, your prompt is sent to the image model and the result is stored against your account so you can view and download it.
8.3 Retention. Generated pictures are kept for 7 days from creation and are then deleted automatically, including the stored file. You can delete any picture sooner using the delete control beneath it; deletion is permanent and the content cannot be recovered. Uploaded photos are retained with the conversation they belong to and are removed when you clear that conversation or delete your account.
8.4 Safety. Prompts and uploads pass automated safety checks before generation or analysis. See section 15.
9.1 When you ask Chap to build a playable game, your request and a limited slice of recent conversation are sent to the model provider, and the resulting game definition is stored against your account so you can play it again.
9.2 Games run inside a restricted sandbox in the app. Game requests and outputs pass automated checks, including checks intended to prevent the reproduction of third-party copyrighted characters, worlds and assets; refused requests may be recorded as described in section 15.
9.3 You can change a game you have just been given by describing the change in plain words (for example a colour or a size). Those follow-up requests are handled on our servers against the supported settings of that game; unsupported changes are declined and no new game is created.
9.4 Generated games are kept for 7 days from creation and then deleted automatically, and can be deleted sooner using the delete control.
10.1 If you dictate a message, the audio clip you record is sent to a speech-to-text provider and converted to text. The transcribed text is then treated exactly like a typed message.
10.2 We do not retain the audio. The recording is discarded once transcription completes or fails; only the resulting text, and a duration figure used for quota and cost metering, are kept. We cannot recover a recording after the fact, for you or for anyone else.
11.1 Premium is currently offered at A$24.99 per month or A$229.99 per year. Prices are in Australian dollars. Chap.Club is not currently registered for GST, so no GST is charged on purchases billed by us. Apple and Google convert and tax prices for your storefront, so the amount you are charged may differ from the Australian dollar list price shown here.
11.2 Payments on the web are processed by Stripe. Purchases made inside the native apps are processed by Apple and by Google under their own store rules. We use no other payment providers.
11.3 We never receive or store your full card number, CVC or equivalent payment credentials. Those are collected and processed directly by the payment provider under its own privacy policy. What we receive and store is the outcome: plan, status, transaction and receipt identifiers, amounts, currency and period dates, together with the email address associated with the purchase.
11.4 We use those records to grant and maintain your entitlements, to reconcile purchases, to handle refunds and disputes, to prevent payment fraud, and to satisfy tax and accounting obligations.
11.5 Billing enquiries: billing@chap.club. See also the Subscription & Billing Terms.
12.1 ChapPoints are a loyalty balance and ChapPacks are collectible reward packs, both held against your account. Operating them involves records of your balance, the events that earned or spent points, the packs you have opened, the cards and feature credits you hold, and their expiry.
12.2 ChapPoints and ChapPacks are not money, not a cryptocurrency, not a security and not redeemable for cash. They have no value outside the Service and are governed by the ChapPacks & Rewards Disclosure.
13.1 If you enable notifications, we store a push token for your device together with your preferences. We use these to deliver reminders you have set, streak and reward prompts, replies that finish while the app is in the background, and essential account, security and billing messages.
13.2 Promotional notifications are off by default and are sent only to people who explicitly switch them on. Recipient selection uses only your opt-in setting and whether your account is Free or Premium. Draft wording may be prepared with an internal AI tool, but every campaign is reviewed, approved and sent by a person. You can turn promotional notifications off at any time in Settings, and you can revoke notification permission entirely in your device settings. We do not send marketing email.
14.1 Chap personalises its replies and parts of the interface using information you provide (your display name, preferences, settings and stated interests) and information generated by your use of the Service (recent conversation, memories where enabled, entitlement state and streak progress).
14.2 Personalisation is not used to make decisions with a legal or similarly significant effect on you. Automated systems do apply quotas, safety checks and abuse limits; those decisions can be reviewed by a person if you contact us at support@chap.club.
15.1 Automated checks run on prompts, uploads and generated output to enforce our Acceptable Use Policy, protect users, and prevent misuse of paid capacity. Where a request is blocked, rate-limited or otherwise refused, we may record the request text or prompt, the reason, the time, the account, the endpoint and the originating IP address.
15.2 You can report a message from inside the app. Reports are reviewed by a person and are retained with the reported content and your account reference.
15.3 We do not review every conversation. Human review is limited to reported content, investigations into suspected abuse or fraud, support requests you raise, and legal obligations. Repeated or serious breaches may lead to restriction or closure of an account.
16.1 We do not train any model of our own on your Content, and we do not provide your conversations, images, prompts or audio to third parties for the purpose of training their foundation models. Content is sent to model providers only to serve the request in front of you.
16.2 Model providers process that content under the terms that apply to our commercial API access, which we have configured for service delivery rather than training contribution. Providers may retain request data briefly for their own abuse-monitoring purposes under their own policies. [REQUIRES CONFIRMATION] — the current zero-retention and no-training terms of each downstream model provider should be confirmed in writing and this section updated if any of them change.
16.3 We do use aggregated, non-identifying operational metrics (such as counts of requests, failures and feature usage) to improve reliability and cost. Those metrics contain no message content.
17.1 Premium is entirely ad-free. Premium accounts see no sponsorships at all.
17.2 Free accounts may occasionally see a clearly labelled first-party sponsor card. These placements are sold by us directly. There are no third-party advertising networks, no advertising SDKs, no tracking pixels and no advertising cookies in the Service. We never share your messages, memories, images, email address or any identifier with a sponsor, and sponsors cannot target you. Whether a card appears is decided on our own servers using only a count of how many you have already seen. Tapping a sponsor routes through a link on our own domain with the referrer stripped, so the sponsor learns only that someone arrived from Chap.AI.
17.3 You may be offered the optional choice to view a sponsor briefly in exchange for an extra message when your allowance runs out. That choice is always yours and never automatic.
17.4 Advertising never influences Chap. Sponsorships do not affect the content of replies, memory, recommendations, search results, moderation outcomes or any safety decision, and sponsors have no input into them.
18.1 Essential technologies. We use cookies and browser local storage that are strictly necessary to run the Service: keeping you signed in, remembering your interface preferences, holding an unsent draft, and enabling offline and installed-app behaviour. These cannot be switched off without breaking the Service.
18.2 Optional technologies. Product analytics are optional and gated behind your consent in Settings; when off, no analytics events are recorded. We use no advertising or cross-site tracking technologies, and no third-party analytics SDK that identifies you personally.
18.3 Font files are requested by your browser directly from Google Fonts, which exposes your IP address and browser details to Google as part of that request. No account identifier is sent.
18.4 You can clear cookies and local storage in your browser or device settings; doing so signs you out and resets local preferences.
19.1 We rely on third parties for hosting, database and storage, authentication, AI model access, payments, email delivery, push delivery and market and search data. Each receives only what it needs for the task described and is required to process it on our instructions. The current list is below; it is maintained as part of this policy and changes to it are published here.
19.2 We may also disclose personal information: to professional advisers under confidentiality; where required by law, regulation, court order or a valid request from a public authority; where necessary to establish, exercise or defend legal claims or to protect the rights, safety or property of users, the public or us; and, in the event of a restructure, merger or sale of the business, to the acquiring party, subject to this policy continuing to apply to the information transferred.
19.3 We do not sell personal information and we do not disclose it to data brokers.
20.1 Chap.AI is available internationally. Our infrastructure and AI providers process and store data outside your country of residence, including in the United States, and in other regions operated by our cloud provider.
20.2 Where personal information is transferred out of the EEA, the United Kingdom or Switzerland, we rely on the transfer mechanisms made available by the provider concerned, which for our principal providers are the European Commission Standard Contractual Clauses and the UK Addendum, incorporated into our agreements with them, together with the technical measures described in section 24. [REQUIRES CONFIRMATION] — the specific transfer mechanism in force with each provider, and whether a transfer impact assessment is required for our processing volumes.
20.3 Australian users should note that, by using the Service, personal information will be disclosed to overseas recipients as described in section 19, principally in the United States.
21.1 We keep personal information only as long as needed for the purpose it was collected for, or as long as the law requires. The schedule below reflects how the Service is actually configured.
21.2 Exceptions that survive deletion. Billing, tax and payment records are retained for seven years as required by Australian tax law, and records of legal-document acceptance and age eligibility are retained for the life of the account plus seven years, so that we can show the account was eligible and had accepted the applicable terms. These records are separated from your account when it is deleted and are not used for any other purpose. The retention archive contains only those billing and legal-acceptance records; moderation and content-report records, individual AI usage or spend records, and security or rate-limit logs are destroyed or anonymised when your account is deleted.
21.3 We may also retain information for longer where necessary to resolve a dispute, to investigate or prevent fraud or abuse, to enforce our agreements, or to comply with a legal hold or lawful request.
21.4 Backups. Deleted data may persist for a limited period in encrypted infrastructure backups until those backups age out on their normal cycle. Backup copies are not used to restore deleted individual records and are not accessible to ordinary operations. We cannot promise instantaneous erasure from every backup.
22.1 You can delete individual items yourself: clear a conversation, delete a memory on the Memories page, or delete a generated picture or game with the delete control beneath it.
22.2 You can delete your entire account from Settings, or without signing in to the app at /delete-account. Deletion is permanent. It removes your profile, conversations, uploaded and generated content, memories, preferences, reminders, saved items, usage counters, balances, inventory, notification tokens and any connected integration.
22.3 What survives deletion is limited to the records described in section 21.2, plus the limited period described in section 21.4 for backups. Records held by a payment provider or app store are governed by that provider and must be pursued with them.
22.4 If you cannot use the in-app controls, email privacy@chap.club from the address on the account and we will action the request. We may need to verify your identity before doing so.
23.1 A self-service export is available in Settings. It produces a machine-readable copy of your profile, messages, memories, references to your uploaded and generated content, preferences, usage counters, credit and ChapPoints balances, streak history, ChapPack and card inventory, purchase and subscription records, support submissions, reminders, saved items, wallpaper settings, reports you have submitted, notification settings, legal acceptances and age-eligibility record.
23.2 You can correct your display name and preferences directly in Settings. For any other correction, or for a copy of information not covered by the export, email privacy@chap.club.
23.3 We respond to access and correction requests without undue delay and, where a jurisdiction sets a deadline, within that deadline. We may ask you to verify your identity, and we may decline or partly decline a request where the law permits, giving reasons.
24.1 We apply security measures appropriate to the risk, including encryption in transit and at rest provided by our infrastructure, per-account access rules enforced on the server, private storage for uploaded content, server-side resolution of entitlements so they cannot be altered from a device, encrypted storage of any third-party connection tokens, rate limiting and abuse detection, and restricted administrative access.
24.2 We deliberately do not publish the details of these controls.
24.3 No method of transmission or storage is completely secure. We cannot and do not guarantee absolute security. You are responsible for keeping your sign-in credentials and device secure. If we become aware of a data breach that is likely to result in serious harm, we will notify affected individuals and the relevant regulator as required by applicable law, including the Notifiable Data Breaches scheme in Australia and Articles 33 and 34 of the GDPR where they apply.
25.1 Depending on where you live and which law applies to you, you may have rights to: access the personal information we hold about you; have it corrected; have it deleted; obtain a portable copy; object to certain processing; ask us to restrict processing; withdraw a consent you have given; opt out of certain disclosures; and complain to a regulator.
25.2 Not every right applies to every user. Which rights you have, and their limits, depend on your jurisdiction and the applicable law. Sections 26 to 28 give jurisdiction-specific detail.
25.3 To exercise a right, email privacy@chap.club from the address on your account, or use the in-app controls where they achieve the same result faster. We do not charge for a first request, we do not discriminate against you for making one, and we will tell you if we need more time or more information.
26.1 We are based in Queensland, Australia and handle the personal information of Australian users in a manner consistent with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth). [REQUIRES CONFIRMATION] — whether the operator meets the definition of an APP entity, which turns on turnover and the nature of the business. Where it does not, we nonetheless apply the standards described here as a matter of policy.
26.2 We collect personal information only where it is reasonably necessary for the functions of the Service (APP 3), we tell you what we collect and why in section 3 (APP 5), we use and disclose it for the purposes described in section 4 (APP 6), and we take reasonable steps to keep it accurate and secure (APPs 10 and 11).
26.3 We do not use personal information for direct marketing except with your explicit opt-in (section 13), and every promotional notification can be switched off in Settings (APP 7).
26.4 We disclose personal information to overseas recipients as described in sections 19 and 20, principally in the United States (APP 8).
26.5 Complaints. Please contact us first at privacy@chap.club. We will acknowledge your complaint and respond within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
27.1 Controller. Elliott James Chapman (Individual / Sole Trader) trading as Chap.Club, ABN 57 434 518 597 is the controller of the personal data described in this policy. Contact: privacy@chap.club.
27.2 Purposes and legal bases. Set out in section 4.2.
27.3 Your rights. Subject to the conditions in the GDPR and UK GDPR, you have the rights of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), objection including to processing based on legitimate interests (Art. 21), and withdrawal of consent (Art. 7(3)).
27.4 Automated decision-making. We do not carry out decision-making producing legal or similarly significant effects that is based solely on automated processing within the meaning of Art. 22. Automated quota, safety and abuse controls can be reviewed by a person on request.
27.5 Transfers. See section 20.
27.6 Complaints. You may lodge a complaint with your local supervisory authority, or with the UK Information Commissioner's Office (ico.org.uk) if you are in the United Kingdom. We would appreciate the chance to address your concern first at privacy@chap.club.
27.7 We have not appointed a Data Protection Officer or an Art. 27 representative; see section 1.4.
28.1 US state privacy laws such as the California Consumer Privacy Act as amended by the CPRA, and comparable laws in other states, apply only to businesses that meet statutory thresholds (for example revenue or volume of consumer data). [REQUIRES CONFIRMATION] — whether the operator currently meets those thresholds. We do not assert that we are a covered business.
28.2 Regardless of whether those laws currently apply to us, we extend the following to US users as a matter of policy: you may request to know the categories and specific pieces of personal information we hold about you, request deletion, request correction, and obtain a portable copy, by emailing privacy@chap.club or using the in-app export and deletion controls. We will not discriminate against you for exercising these choices.
28.3 We do not sell personal information and we do not share it for cross-context behavioural advertising, as those terms are used in California law. We have not sold or shared personal information in the preceding twelve months. We do not knowingly collect or sell the personal information of minors.
28.4 The categories we collect, the purposes, the sources (you, your device, and our payment and infrastructure providers) and the categories of recipient are described in sections 3, 4 and 19. Retention is described in section 21.
28.5 An authorised agent may submit a request on your behalf with written proof of authority; we may still verify the request with you directly.
29.1 Chap.AI is intended only for people aged 16 and over. We chose this minimum because the Service keeps long-term memory about the person using it, accepts uploaded photos, and produces open-ended AI content, and because we operate no parental-consent mechanism.
29.2 You confirm your age bracket after signing in. We store the bracket only, never a date of birth. Accounts that indicate they are under 16 are blocked from the Service.
29.3 We do not knowingly collect personal information from anyone under 16. If we learn that an account belongs to someone under that age, we close it and delete the associated data. A parent or guardian who believes a child has provided us with personal information should contact privacy@chap.club and we will act promptly.
29.4 App-store age ratings are set separately in the relevant store console and may differ from the minimum age above.
30.1 We may update this policy as the Service, our providers or the law change. Every version carries a version number, an effective date and a last-updated date at the top of this page.
30.2 For a material change — for example a new category of information, a new purpose, a new class of recipient, a materially longer retention period, or any change to the AI-training position in section 16 — we bump the version number and ask you to review and accept the updated documents the next time you use the app. Your acceptance is recorded against your account with the document, version and time. Where we hold your consent for a purpose and that purpose changes materially, we will ask for consent again rather than assume it.
30.3 Non-material changes, such as clarifications or typographical corrections, may be made without a re-acceptance prompt, but the last-updated date will still change.
30.4 If we ever propose to use personal information in a way materially different from what was described when it was collected, we will give notice in the app before doing so, and where consent is required we will obtain it first.
30.5 Continuing to use the Service after an update takes effect, and after any required acceptance, means the updated policy applies to you.
These addresses all deliver to the single Chap.Club mailbox operated by us, and mail sent to them is handled under this policy.
Operator / controller: Elliott James Chapman (Individual / Sole Trader) trading as Chap.Club, ABN 57 434 518 597. Postal address: not published; use the addresses above for notices. [REQUIRES CONFIRMATION]
Version: 2026.10.2 · Effective date: 11 September 2026 · Last updated: 11 September 2026.
This service is provided by Chap.AI by Chap.Club. This document is intended to be reviewed by qualified legal counsel before publication and is not legal advice.
These documents are drafted for clarity and are pending review by qualified Australian legal counsel, and United States counsel where applicable. They are not legal advice and do not constitute a guarantee of compliance in any jurisdiction.
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Chap.AI
by Chap.Club