Special Occasion: Privacy Policy

Effective date: November 1, 2026 · Last updated: November 5, 2026

This Privacy Policy explains what Special Occasion, Inc. ("Special Occasion," "we," "us") collects when you use specialoccasion.ai and our text-message gifting agent (the "Service"), how we use it, who we share it with, how long we keep it, and the choices you have. It also covers the information you share with us about the people you send gifts to. It doesn't cover the websites or services of retailers, florists, or other third parties, which have their own policies.

The short version:

• We collect what we need to remember your people and dates, propose gifts, and deliver the ones you approve.
• We don't sell your information or your recipients' information, and we don't share it for targeted advertising. We use website analytics (Google Analytics and Vercel) on our public pages to improve our site. They never get your phone number, name, email, or messages, and we don't use ad pixels or advertising cookies.
• We never share your phone number or text-message consent with anyone for their own marketing.
• If you upload a contacts file, we use it only to remember your important people and dates and to send the gifts you approve. We never contact those people, market to them, use their information for ads, or sell it. You can ask us to delete people you've saved; §9A explains what we have to keep for past orders.
• Your agent is an AI. xAI powers its conversations, Anthropic helps write card notes, and OpenAI creates images. We don't train AI models on your data, and those providers' API terms don't permit them to use it to train theirs.
• You can see, correct, or delete your information by emailing support@specialoccasion.ai, and you can close your account any time in Settings.

1. Information we collect

From you, about you

• Signup: your name and mobile number (your mobile number is your account), the name you give your agent, and the choices you make to build their face (avatar), such as the description and style you pick, plus the AI-generated avatar image. We don't ask for or use photos of real people to make avatars. Later, if you give them: your email and billing address.
• Your messages with your agent. We don't currently view or store photos you text us.
• Gifting details: budgets, preferences, approvals, declines, and changes you request.
• Payment details, which are collected and stored by our payment processor, Stripe. We receive only limited details such as card brand, last four digits, expiration date, and billing ZIP.
• Support messages you send us.

From you, about other people ("recipients")

• Names, relationships, important dates (birthdays, anniversaries, new jobs), shipping addresses, phone numbers if needed for flower delivery, and preferences or details you tell us ("she drinks tea on Sundays").
• What we sent them, the card note, and delivery status.
• Gift sets: if you choose the gift set add-on, items for a recipient are shipped first to our packing location (a location we designate). We keep the order and tracking details for those items, inspection notes and photos of items that arrive damaged or wrong, and the recipient's name and shipping address so we can label and ship the finished set.

Automatically

• Message metadata from our messaging provider (delivery status, timestamps, whether a message went as iMessage, RCS, or SMS, and opt-out status).
• When you visit our website: device and browser information, IP address (which can show your approximate location), and pages visited, collected in our server logs. On our public pages, we also use website analytics (Google Analytics 4, Vercel Web Analytics, and Vercel Speed Insights) to see which pages people visit, how far they scroll, which links they click, how fast pages load, which campaign link brought them (UTM tags), and whether they started signup, created an agent, tapped a "text us" link, or tapped "Log in." Analytics never receives your phone number, name, email, agent name, or messages, and doesn't run on our sign-in page or the private pages for your account, your approvals, or your gifts. See §5 and our Cookie Notice.

From others

• Order, shipping, and delivery updates from retailers, florists, card services, and carriers.
• Payment confirmations and fraud signals from our payment processor.

From a contacts file you choose to upload

• If you upload a contacts file (a .vcf or .csv file), we save every contact in it as a person in your account: their name, phone number, email address, any notes in the file, and their birthday (month and day only). We don't keep postal addresses, photos, company names, or extra phone numbers from the file. See §9A.

2. How we use information

• To run the Service: remember your people and dates, choose and price gifts, write card notes, send proposals, place the orders you approve, and track delivery.
• To charge you only for the orders you approve, and to issue refunds.
• To remember the people and birthdays in a contacts file you upload, so your agent can remind you and suggest gifts (§9A). We never use uploaded contacts to contact those people, for marketing, or for advertising.
• To message you about your account, proposals, orders, and support. That includes reminder texts about upcoming dates you've saved. We don't send marketing texts.
• To keep the Service safe: to secure accounts and prevent fraud, abuse, and unapproved purchases.
• To improve the Service: for example, by reviewing conversations where something went wrong, and by using website analytics to see which pages and campaigns work and how fast the site loads. We don't train any AI models on customer data. Our AI providers' API terms don't permit them to use your data to train their models (see §9). We may use de-identified or aggregated information (which can't reasonably be linked back to you) to understand how the Service is used.
• To comply with law and enforce our Terms of Service.

AI and automated decisions. Your agent uses AI to suggest gifts and draft card notes. It never buys anything without your explicit approval of a specific proposal, and we don't use automated decision-making that produces legal or similarly significant effects about you.

3. How we share information

We don't sell personal information, and we don't share it for cross-context behavioral (targeted) advertising. We share it only as follows:

• Messaging provider: Sendblue (Round One, Inc.). Sendblue sends and receives our text messages, as iMessage where available and otherwise RCS or SMS, and so processes your phone number, message content, and delivery data on our behalf. Sendblue's own privacy policy is at https://www.sendblue.com/privacy-policy. Mobile carriers and Apple also handle messages in transit.
• Fulfillment partners. To complete an order you approved, we share what's needed to fulfill it (the recipient's name and shipping address, the card note, and the items) with:

- A retail purchasing partner, which buys retail items from online retailers on our behalf. The retailer that sells and ships the item (for example, Amazon or Target) also receives the order and shipping details. - A handwritten card service, which writes and mails cards. It receives the recipient's name and address and the card note. - A floral delivery network, which sends flower orders to an independent local florist for delivery. The network and the local florist receive the recipient's name, delivery address, and phone number, the card message, and the order details, and use them only to fulfill and deliver the order. - Gift-card issuers, when you send a gift card. Each partner's handling of that data is governed by its own privacy policy.

• Shipping carriers, through the retailer or directly, to deliver and track packages. For gift sets, we give the carrier the recipient's name and address to ship the set from our packing location.
• Payment processor: Stripe, to charge your card, issue refunds, and prevent fraud (privacy policy). It receives the details needed to process your payment, including a description of the gift, which may include the recipient's name and the occasion.
• Email delivery provider: Resend, which sends our emails, such as receipts, from hello@specialoccasion.ai. It processes your email address and the content of those emails on our behalf.
• AI model providers: xAI, Anthropic, and OpenAI. Each one acts on our behalf, and their API terms don't permit them to use your data to train their models (see §9).

- xAI (xAI's API is now offered by SpaceX Super Intelligence LLC) powers your agent's conversations. It receives your recent messages with your agent and a summary of the people you've saved (including people from a contacts file you upload). The summary includes each person's name, relationship, interests, notes, street address if you've added one, and birthday (month and day). It doesn't include your people's phone numbers or email addresses. - Anthropic (Anthropic, PBC) writes card notes and the short explanation of why a gift fits. For that it receives your name, the recipient's name, your relationship, the occasion, the recipient's interests, and the gift's items, stores, and prices. It doesn't receive phone numbers, email addresses, notes, or dates. - OpenAI creates images: your agent's avatar from the description you give at signup, a picture of each gift from the recipient's first name, the occasion, and the gift's items, and product artwork from product information only. It doesn't handle your conversations. - How they handle business and API data: xAI, https://x.ai/legal/faq-enterprise · Anthropic, https://www.anthropic.com/legal/commercial-terms · OpenAI, https://openai.com/enterprise-privacy/

• Hosting and database: Vercel (hosts our website and app) and PlanetScale (our database), to store and run the Service.
• Contacts you upload are treated like any other person you save. They're stored by our hosting and database providers. xAI receives each person's name, relationship, notes, street address if you've added one, and birthday as part of your agent's conversations, and Anthropic receives the names and details listed above when it writes a card note. Neither receives your contacts' phone numbers or email addresses. Fulfillment partners receive a person's details only for a gift you approve. We never sell them, share them for advertising, or give them to data brokers (§9A).
• Website analytics and performance providers, acting as our service providers: Google (Google Analytics 4, for website analytics; privacy policy) and Vercel (Web Analytics and Speed Insights, for website analytics and page-speed measurement). They receive website usage data from our public pages as described in §5, and only to provide analytics to us. We've turned off Google signals and ads personalization in Google Analytics, so our analytics data isn't used for Google's advertising.
• Professional advisers such as accountants and auditors, under confidentiality duties.
• Legal and safety: when required by law or legal process, or to protect the rights, property, or safety of you, recipients, us, or others.
• Business transfers: as part of a merger, acquisition, financing, or sale of assets, with notice to you.
• With your consent or at your direction.

Our service providers may use the information only to provide services to us, under contracts that restrict other uses.

Text-message opt-in data

We will not share your mobile number, text-message opt-in, or consent with any third party or affiliate for their marketing or promotional purposes. We share your text-message opt-in and consent only with vendors who help deliver messages (such as Sendblue and mobile carriers), and only for that purpose. Your mobile number also goes to the service providers that run the Service for us (such as our hosting and database providers), only to provide the Service. The categories of sharing above exclude text-messaging originator opt-in data and consent.

4. Recipients' information

People you send gifts to haven't signed up with us, so we hold their information carefully:

• We use it only to send the gifts you approve and to remember the dates and details you shared, including people and birthdays found in a contacts file you upload.
• We never text, email, or call anyone in a contacts file you upload.
• We never market to recipients, and we never contact them except through the gift itself (and any delivery notices a retailer, florist, or carrier sends).
• We share a recipient's information only with the service providers in §3 that run the Service for us (hosting, database, our AI providers as described there, and Stripe, which receives a description of each gift that may include the recipient's name and the occasion), and with the fulfillment partners (our retail purchasing partner, handwritten card service, and floral delivery network), retailers, florists, and carriers needed to deliver an approved gift.
• A recipient can ask us to delete their information by emailing support@specialoccasion.ai. If no gift has been ordered for them through us, we'll delete their details. If one has, we keep only what we need for order and financial records, including their name, for as long as we need them for financial, tax, and legal reasons (§7), and we stop using them for reminders and suggestions. Messages the customer has already exchanged with their agent may still mention them. Either way, we'll keep a minimal record of the request so we don't add them back by accident, and we'll let the customer know that we can no longer send gifts to that person.
• Recipients have the same state-law privacy rights described in §6, where those laws apply to them.
• You confirm you have a legitimate reason to share a recipient's information for gifting (see our Terms).

5. Cookies, analytics, Do Not Track, and Global Privacy Control

What we use. Our website uses:

• Essential cookies and browser storage that keep the site and signup form working and secure, and keep you signed in: a sign-in cookie that keeps you signed in on the web (it lasts 400 days), a security cookie that protects against forged requests, and a cookie that returns you to the right page after you sign in (those two last until you close your browser). Our mobile app keeps you signed in with a sign-in token stored in the app, not a cookie, which lasts 30 days. Tap-to-approve links carry a signed token in the link itself, which expires after 21 days. Our payment processor, Stripe, may set its own cookies on payment pages to prevent fraud.
• Google Analytics 4 (Google LLC), on our public pages only. It sets two first-party cookies, `_ga` and `_ga_<ID>`, to tell visits apart. By Google's default they last up to 2 years, unless you or your browser delete them sooner. It counts page views, how far people scroll, outbound link clicks, video engagement, and four steps: starting signup, creating your agent, tapping a "text us" link, and tapping "Log in." We keep Google Analytics data for 14 months, and the 14 months start over each time you visit again.
• Vercel Web Analytics and Vercel Speed Insights (Vercel Inc.), on our public pages only. They count visits and measure how fast pages load, without cookies. Before a page address is sent, we remove everything after the "?" except campaign (UTM) tags.
• Session storage that remembers which campaign link (UTM tags) brought you, for your visit only. It's cleared when you close the tab.
• Local storage that remembers you closed our cookie bar, so it doesn't keep popping up.

The full list, with what each one does and how long it lasts, is in our Cookie Notice.

Where analytics never go. Our analytics tools don't run on our sign-in page or the private pages for your account, your approvals, or your gifts. They never receive your phone number, name, email, agent name, or anything you text your agent.

No ads. We don't use advertising cookies, ad pixels, retargeting or remarketing, or session recording. We've turned off Google signals and ads personalization, and Google Analytics is set not to store advertising data. Google and Vercel process analytics data as our service providers, only to give us analytics. So we don't sell your information or share it for cross-context behavioral advertising.

Turning analytics off.

• Install Google's Google Analytics Opt-out Browser Add-on. It stops Google Analytics on every site you visit.
• Block or delete cookies in your browser settings. If you block all cookies, signing in may stop working.
• Turn on Global Privacy Control in your browser (see below). Google Analytics won't load.
• Vercel's tools don't use cookies, so there's nothing to clear for them.

Global Privacy Control (GPC). If your browser sends a GPC signal, we treat it as a request to opt out of the sale and sharing of your personal information for that browser, and for your account if we can tell it's you. We don't sell or share personal information, and we also don't load Google Analytics in a browser that sends GPC, so no Google Analytics cookies are set and no visit data goes to Google. Vercel's cookieless analytics still count the visit. If we ever add advertising technology, GPC will switch it off for you. Learn more at globalprivacycontrol.org. Do Not Track: there's no common standard for Do Not Track signals, so we respond to GPC instead.

6. Your privacy rights

Everyone can use these rights, wherever you live:

• Stop texts: reply STOP at any time. For help, email support@specialoccasion.ai.
• See, correct, or delete your data: email support@specialoccasion.ai with "Privacy Request" in the subject. You can also ask your agent to forget a person or a date at any time; that stops reminders about them but doesn't delete them. To remove a person you've saved, ask your agent or email us. When you remove someone, we delete their details, or, if you've bought them a gift through us, keep only what we need for order and financial records (§7), and stop using them for reminders and suggestions. Messages you've already exchanged with your agent that mention them stay in your message history.
• Close your account: use Settings on our website or in our app. Closing your account signs you out right away, and you can't sign in to it again. We remove or de-identify your name, email, password, address, and recovery details, and we delete your message history with your agent, your agent's memory and settings, and gift suggestions you never ordered. People you've saved who've never had a gift ordered through us are deleted, along with their dates. For people you have sent gifts to, we clear their email, phone number, notes, street address, and interests, turn off their dates, and keep their name, city, state, and ZIP with your order records. We keep financial records, such as purchases, orders, refunds, fulfillment, return claims, and payment events, and suggestions tied to an order (without the card message). If a gift is still on its way, the rest of this cleanup finishes once that order is complete, and we keep the recipient's street address until then so it can be delivered. If you sign up again later with the same number, you start a brand-new account. To ask us to delete other information, email support@specialoccasion.ai with "Privacy Request" in the subject (see "How to make a request" below).

State privacy rights. Depending on where you live, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other states with consumer privacy laws, you may have the right to:

• know what personal information we've collected about you, where it came from, why we use it, and who we've disclosed it to;
• get a copy of it in a portable format;
• correct inaccurate information;
• delete it;
• opt out of sale, sharing for targeted advertising, and profiling that produces significant effects (we don't do any of these today; see §5 and Your Privacy Choices); and
• limit the use of sensitive personal information (we use it only as §8 describes).

How to make a request. Email support@specialoccasion.ai with "Privacy Request" in the subject, or write to the address in §15. To close your account, use Settings on our website or in our app. We'll confirm we received your request within 10 business days and respond within 45 days. If we need more time (up to another 45 days), we'll tell you why. To protect you, we verify requests by confirming control of the mobile number on the account (for example, with a code we text to it). We may ask for more information if a request involves sensitive data. You can use an authorized agent. We'll ask for proof that the agent has your signed permission, and we may ask you to verify your identity directly.

Appeals. If we deny your request, you can appeal by replying to our decision or emailing support@specialoccasion.ai with "Privacy Appeal" in the subject. We'll respond within 45 days (60 days in Colorado). If you're not satisfied, you can contact your state attorney general.

No discrimination. We won't deny you service, charge a different price, or provide a different quality of service because you used these rights. We don't offer financial incentives for personal information.

California "Shine the Light." We don't disclose personal information to third parties for their own direct marketing. Nevada: we don't sell covered information as Nevada law defines it.

7. How long we keep information

We keep information only as long as we need it for the purposes in this policy:

Deleted information may remain in encrypted backups for up to 90 more days before it's overwritten. We may keep information longer if the law requires it or to resolve a dispute.

8. Categories of personal information (California and other state notices)

This table is our notice at collection, and our disclosure of what we collected in the last 12 months. For every category: we have not sold it or shared it for targeted advertising, and we disclose it for business purposes only to the recipients listed. We keep each category for the periods in §7.

We use sensitive personal information only for purposes the law permits without a right to limit, such as providing the Service you requested, security, and fraud prevention. It never goes to analytics or advertising tools.

9. AI and your avatar

• Your agent is an AI. Messages from your agent are written by AI software, not a person. It will say so if you ask. A person from our team may read a conversation to give support, investigate a problem, or keep the Service safe.
• We don't train AI models on your data. Your conversations are used only to run your agent and give you support.
• AI providers. xAI powers your agent's conversations. Anthropic writes card notes and gift explanations. OpenAI creates images (your avatar, gift pictures, and product artwork) and doesn't handle your conversations. §3 lists what each one receives. They process your information only to provide those services to us. Our AI providers' API terms don't permit them to use your data to train their models, and we haven't opted in to any program that would allow it. Under those terms, each provider may keep API requests and responses for up to 30 days, and then deletes them, unless it needs to keep them longer to comply with the law or to investigate misuse of its service.
• Avatar. Your agent's face is AI-generated by OpenAI from the choices you make at signup. It isn't made from photos of real people, we don't ask you to upload one, and it isn't meant to look like any real person. We don't collect face scans or any other biometric information.

9A. Contacts you upload

You can choose to upload a contacts file (a .vcf or .csv file, such as one exported from your phone or email) on our website, so your agent knows the people and birthdays that matter to you. It's optional, and the Service works without it. Uploading is on the website only.

• Every contact in the file is saved. We import every contact in the file as a person in your account; you don't pick which ones. If you only want some people saved, upload a file with just those contacts. A contact with the same name as someone already saved is skipped, not merged. One upload can add up to 500 people.
• What we save for each contact: their name; their relationship to you (set to "Friend" until you change it); their phone number and email address; any notes in the file (up to 2,000 characters); and their birthday as a yearly date (month and day only; we discard the birth year).
• What we don't save: postal addresses, photos, company or organization names, and any extra phone numbers in the file. We don't keep the file itself.
• What we use it for: only to remember your important people and dates, so your agent can remind you and suggest gifts, and, if you approve a gift, to send it. We never use uploaded contacts to text, email, call, or market to the people in them, we never use them for advertising, and we never sell them.
• Who sees it: uploaded people are stored by our hosting and database providers. Like every person you save, they're part of the summary your agent's conversation provider (xAI) receives: name, relationship, interests, notes, street address if you've added one later, and birthday (month and day). When we write a card note for one of them, Anthropic receives their name, relationship, interests, and the occasion. Their phone numbers and email addresses are never sent to any AI provider. All of these providers work under the no-training terms in §9. Our team doesn't look at your uploaded contacts unless you ask us to (for example, for support), or it's needed for security or to comply with the law.
• No AI training. We don't use uploaded contacts to train, create, or improve AI or machine learning models.
• Removing uploaded people. Ask your agent or email support@specialoccasion.ai. When you remove someone, we delete their details, or, if you've bought them a gift through us, keep only what we need for order and financial records (§7), and stop using them for reminders and suggestions. Asking your agent to "forget" someone stops their reminders but doesn't delete them.
• Your responsibility. By uploading a file, you confirm that you have the right to share it with us for this purpose (see our Terms).

10. Security and breach notice

We use reasonable administrative, technical, and physical safeguards, including encryption in transit, access controls, and limiting access to staff and vendors who need it. No system is perfectly secure. Text messages, especially SMS, can be read by your carrier and anyone with access to your phone, so don't text us full card numbers or passwords. We'll never ask for them by text. If a security breach affects your personal information, we'll notify you and the appropriate regulators as the law requires, by text or email, without unreasonable delay.

11. Children

The Service is for adults 18 and over. We don't knowingly collect personal information from children under 13, or from anyone under 18, as users. If you believe someone under 18 has signed up, email support@specialoccasion.ai with "Privacy Request" in the subject, and we'll handle it as a deletion request (§6). The account holder can also close the account at any time in Settings on our website or in our app. You may tell us about a child as a gift recipient (for example, a niece's birthday). We use that information only to send gifts you approve, never to contact the child, and a parent or guardian can ask us to delete it at support@specialoccasion.ai.

12. United States only

The Service is offered only in the United States. We're a US company, and our main service providers (including Vercel, PlanetScale, Stripe, Resend, Google, xAI, Anthropic, and OpenAI) are US companies. Some of them may process or store information in other countries where they or their providers operate (for example, a content delivery network serves our website from locations near each visitor). If you visit our website from outside the US, your information will be processed in the US and possibly elsewhere, where privacy laws may differ from those where you live.

13. Accessibility

If you need this policy in another format, or have trouble using our website or texts with assistive technology, email support@specialoccasion.ai.

14. Changes

We'll post changes here and update the "last updated" date. If a change is material, we'll text or email you before it takes effect. We won't use information we already collected in a materially different way without your consent.

15. Contact

Special Occasion, Inc. 169 Madison Ave STE 69154, New York, NY 10016 support@specialoccasion.ai (privacy requests, appeals, and questions)

Your privacy choices: Your Privacy Choices