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The method below is designed for a current app review. Policies and settings change, and a policy is a statement of intended practice rather than an independent technical audit. Treat every conclusion as limited to the policy version, region and account settings you can verify.
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What “private chats” can mean
Before reading a privacy policy, define the claim you want to test. “Private” can refer to several different outcomes that are not interchangeable.
| Privacy claim | Question to ask | What the claim does not establish |
|---|---|---|
| Hidden from other users | Can another customer, follower or shared-device user see the conversation? | It does not show that the provider, contractors or vendors cannot access it. |
| Not used for advertising | Is message content excluded from ad targeting and marketing? | It does not rule out service delivery, safety analysis, personalization or model improvement. |
| Not used for model training | Are chats excluded from training or tuning generative models? | Other systems, such as search, recommendations or safety classifiers, may still use some data. |
| Deleted after removal | Does deleting a chat or account remove server copies, backups and vendor copies? | A disappearing item in the app is not proof of immediate or complete erasure. |
| Inaccessible to the provider | Does the provider lack the technical ability to read the content? | Encryption in transit or at rest is not end-to-end encryption. |
Write down the exact protection you need. Someone seeking a private role-play conversation has a different risk tolerance from someone considering disclosure of a medical condition, an access credential or a client secret.
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Gather the documents and settings that apply to you
Use the current privacy policy, any regional privacy notice, cookie policy, terms of service and the controls shown in the app or web account. A help article written for another country or an old app version can describe a setting you do not have.
- Record the policy’s “last updated” date and the country or legal region associated with your account.
- Open the privacy or data settings from the signed-in app, then repeat the check on the web version if both exist. Note the exact labels and whether a control is enabled.
- Read the terms for definitions of “content,” “user data,” “de-identified data,” “service providers” and “improvement.” A broad definition can cover more than the visible chat transcript.
- Check the cookie and advertising disclosures separately. They often describe website identifiers and advertising partners that are not explained in the chat section.
- Save a dated copy or screenshot of the relevant language. If a policy changes later, you need to know which terms covered the messages you already sent.
If the policy sends you to a regional disclosure, read that document rather than assuming the global policy is complete. Age limits, legal bases, rights and opt-outs can differ by location.
1. Identify everything the app collects
Message and media content
Look for explicit references to text, voice recordings, photos, video, files, prompts, replies and reactions. “Conversation data” may include attachments and metadata, not just the words in a chat. Voice or image features can introduce additional copies, transcripts, thumbnails or biometric-related information.
Profile, device and network information
Policies commonly distinguish account details, profile fields, interests and preferences, device identifiers, IP address, browser or operating-system data, approximate location and usage events. Mark each item as required for basic operation, optional for a feature, or collected automatically. An app may need an account identifier to deliver a reply but not a precise location for that purpose.
Inferences from interaction
Read for language such as “derive,” “infer,” “predict” or “create profiles.” The service may infer interests, mood, preferences, likely age or engagement patterns from what you say and how you use the companion. Inferred information can be personal data even when you never entered it as a profile field.
Separate collection from access
A policy can say content is collected when you submit it, while a feature may also permit live microphone access, contact access or camera access. Check the operating system’s permissions and revoke any capability the companion does not need. The policy should explain whether optional permissions are required for a particular feature or for the whole service.
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2. Separate the purposes for processing
Do not accept a single sentence such as “we use your data to improve the service” as an answer. Map each purpose to the data it covers and the legal or contractual reason given.
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|---|---|
| Generating a reply | Whether the message and relevant context are sent to the app’s systems or a third-party language-model provider. |
| Personalizing the companion | Whether memories, preferences or past conversations are retained to shape future replies, and whether you can disable that feature. |
| Safety and abuse prevention | Whether automated classifiers or human reviewers may inspect content, and how long safety records remain. |
| Analytics and product improvement | Whether usage events, transcripts or de-identified samples are analyzed, and whether an opt-out covers them. |
| Training or tuning models | Which models, data types, users and regions are included, and when an opt-out takes effect. |
| Recommendations and advertising | Whether chat content, profile data or website identifiers influence recommendations or ads. “No chat advertising” is narrower than “no processing.” |
| Legal and security requirements | What may be retained for fraud prevention, disputes, law-enforcement requests, accounting or other legal duties. |
For each purpose, look for an affirmative statement, not an assumption. Processing a message to generate a response does not by itself authorize model training, advertising or personalization; those are separate uses that should be described.
3. Trace third-party recipients
Find the categories of organizations that receive chat content or related identifiers. They may include cloud hosting companies, analytics providers, customer-support or moderation teams and language-model vendors. The important questions are:
- What exact purpose does each recipient serve?
- May the recipient retain the data after the immediate request?
- Is the recipient prohibited from using it to train its own models?
- Does the app require deletion or return of data when the relationship ends?
- Can the provider move data to another country, and are additional safeguards described?
Third-party processing is not automatically unsafe. It does mean that the app’s privacy promise depends on contracts, configuration and the vendor’s actual controls. A policy that names only “trusted partners” without purposes or restrictions leaves a material uncertainty.
4. Check whether training controls really apply
Training controls are often narrower than their labels. Verify the geographic scope, the kinds of content covered, the date the setting takes effect and the uses that remain allowed after opting out.
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How to inspect an opt-out
- Open the current privacy or data-control page while signed in.
- Record the exact switch name and its initial state.
- Read the explanatory text for “new content,” previously collected content, human review, analytics, safety systems and recommendations.
- Change the setting, save it, then confirm that the account shows the new state.
- Keep the confirmation date. If the control is regional, record the country associated with the account.
Character.AI example
Character.AI’s official “About our Model Training” page says it retains certain user-shared data to help train and improve its models and takes steps to reduce personal information in training datasets. For users in the European Economic Area and the United Kingdom, it describes an opt-out in the app at Settings → Data & Privacy → “Improve the Model for Everyone”. On the web, the route is Settings → Account → Manage Account & Data → Model Improvement → turn off “Improve the Model for Everyone.”
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That page says new content will not be used to train generative AI models after opting out. It also says content may still be used to improve other service components, including search, recommendations and safety classifiers. This is a regional, purpose-specific control, not a promise that all processing stops for every user. Character.AI’s policy-update notice said changes to its Privacy Policy and Terms of Service were scheduled to take effect on August 27, 2025, and directed users to regional disclosures and a cookie policy. Check the currently applicable documents rather than relying on that notice indefinitely.
5. Read retention and deletion by data category
Retention is rarely one number. Make a separate row for chat content, account identifiers, application logs, backups, safety or abuse records, analytics, payment records and information kept for legal obligations.
Questions that reveal the real deletion process
- Does deleting a visible conversation delete the server-side record or only remove it from the interface?
- When does account deletion begin, and how long can operational backups persist?
- Are copies held by language-model or hosting vendors included in the deletion request?
- Which records must remain for fraud prevention, disputes, tax, payment or legal compliance?
- Can the company retain aggregated or de-identified information after deleting the account?
Do not infer complete erasure from a disappearing chat bubble. Look for the company’s stated timeline and exceptions, then decide whether that residual risk is acceptable before sharing sensitive details.
Replika example
Replika’s privacy policy, last updated May 27, 2026, describes different periods for different categories. It says messages and other content may be processed for up to 60 days after contract termination for contract-performance purposes. It separately says account information, financial records and automatically collected personal data are retained for a minimum of 10 years after termination because of legal retention requirements. The policy also says analysis data is deleted within one year from collection after the relevant analysis and anonymization process. These are not one universal “chat retention” period.
The same policy says users can delete an account in settings and that deletion requests extend to service-provider data under contractual arrangements, while noting that legal obligations or other lawful grounds can limit some choices. Treat those statements as the provider’s published policy, not proof that every operational, backup or vendor copy has been independently verified.
6. Distinguish security protections
Encryption in transit
Encryption during transmission protects data as it travels between your device and a server. It does not prevent the service from reading the message after it arrives.
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Encryption at rest and access controls
Stored-data encryption, firewalls, role-based access controls and strong authentication reduce exposure if storage or accounts are attacked. Ask whether access is logged, limited to a need-to-know basis and reviewed. A general phrase such as “industry-standard security” provides less detail than a description of these controls.
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End-to-end encryption
End-to-end encryption means only the communicating endpoints hold the keys needed to read the content. If the provider must process your message to generate an AI response, it normally has access to plaintext at some stage unless a specific technical design says otherwise. Never infer end-to-end encryption from a statement that data are encrypted in transit.
Independent evidence
Look for a named audit, certification, penetration-test summary or incident-disclosure process, and distinguish it from a policy promise. A privacy policy does not establish that live systems, employees, contractors or vendors behave exactly as described.
Replika’s policy says, “All transmitted data are encrypted during transmission.” It also describes secure servers, firewalls, role-based access controls and passwords, while warning that no technology, transmission or system can be guaranteed 100% secure. The policy does not establish end-to-end encryption, so it does not support a claim that the provider is technically unable to access conversations.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.7. Check user rights, geography and age scope
Identify whether you can access, correct, export or delete your information, object to processing, or withdraw consent. Note the identity-verification steps, response times and exceptions. Rights can depend on your location, the legal basis for processing and whether the account is used by a child or teenager.
Confirm the minimum age and whether parental-consent rules apply. A policy written for adults in one jurisdiction may not describe the protections or restrictions that apply elsewhere. Also check whether the app offers a data-download file and whether it includes conversation content, inferred profiles and media rather than only account basics.
What the current examples demonstrate
Replika: service processing, advertising and vendors
Replika’s policy describes account and profile information, messages and content including text, voice, photos and video, interests and preferences, device and network data, and usage data. It says third-party AI language-model providers generate replies and that conversation data, subject to data minimization and de-identification, is sent to them for that purpose. The policy says those providers may not use the data to train their own AI models and must provide security measures and delete or return data when the service relationship ends.
The policy also states that conversation content is not used for marketing or advertising and that advertising partners may receive limited information about website visitors. Those are separate statements: excluding chat content from advertising does not exclude it from reply generation, safety work, personalization or other disclosed processing.
Character.AI: training and regional controls
Character.AI’s model-training page openly describes retaining certain user-shared data for training and improvement, with steps intended to reduce personal information in training datasets. Its EEA and UK control excludes new content from training generative models after opt-out but leaves room for use in search, recommendations and safety classifiers. The practical lesson is to read the scope sentence after the attractive headline; the remaining uses often matter more than the switch name.
A repeatable comparison worksheet
When comparing apps, create one row per service and fill every column from the policy and the live settings. Record the policy date and your region beside the table.
| Axis | Record |
|---|---|
| Content collected | Text, voice, images, video, files, memories and inferred information. |
| Reply processing | In-house systems, named vendor categories and restrictions on retention or training. |
| Other purposes | Personalization, analytics, safety, model training, recommendations, advertising and legal/security processing. |
| Opt-outs | Exact path, geography, data covered, effective date and uses that remain. |
| Retention | Separate periods for chats, logs, backups, safety records, analytics, payment and legal records. |
| Deletion | What account or chat deletion removes, vendor instructions and documented exceptions. |
| Security | Transit and storage encryption, access controls, end-to-end encryption and independent evidence. |
| Rights and scope | Access, export, correction, deletion, objection, consent withdrawal, age limits and regional coverage. |
| Policy freshness | Last update, effective date of changes and whether the app’s labels match the document. |
If a cell cannot be established from the published material, write “not stated” and treat the omission as uncertainty. Do not convert missing information into a reassuring assumption.
Red flags and how to respond
- One broad purpose: “Improve the service” without explaining training, analytics or safety. Ask for the data categories and purposes separately.
- Marketing language without a scope: “Private,” “secure” or “confidential” with no retention, recipients or access explanation. Treat the claim as unsubstantiated until defined.
- Opt-out hidden behind a regional condition: Confirm that your account is in the covered region and that the switch affects new content, old content or both.
- Deletion described only in the interface: Look for server, backup and vendor timelines and legal exceptions.
- Vendor ambiguity: If language-model or analytics providers are not identified by category or restriction, assume you cannot assess their retention or training practices.
- Security conflated with encryption: Ask whether the statement concerns transit, storage or end-to-end protection.
- Stale help article: Follow the current in-app path and compare it with the policy’s date and effective date.
Decide what you can safely share
A policy review cannot certify that an app is safe or prove that implementation matches the document. It can show whether the provider gives you enough information to make a risk-based choice.
Do not enter passwords, recovery codes, payment-card numbers, confidential work material, government identifiers or highly sensitive personal details when a material uncertainty remains. Consider using a pseudonym, omitting identifying details and disabling optional memory, voice or location features. Those steps reduce exposure but do not turn an uncertain service into an anonymous one.
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