Privacy Policy

Chapter 1 Scope and Operator

1.1This Policy applies to the Uooda mobile application, the website https://uooda.carbosilexnexus.com and the services we provide through those channels (together, the “service”). Our Service Regions are those listed in Section 1.5 of the Terms of Service; use outside the Service Regions is governed by Section 1.6 of that Agreement.

1.2The data controller for the service is Tao Huang (an individual developer, “we”). The postal address is available upon written request. For the purposes of the General Data Protection Regulation (GDPR), if you are located in the European Economic Area we are a data controller; for the purposes of the California Consumer Privacy Act (CCPA/CPRA) we are a “business”; in other jurisdictions our status as controller or processor is determined by local law and is described in Chapter 17.

1.3We are an individual developer and have no branches. We do not currently provide the service in the European Economic Area or the United Kingdom, and we have not appointed a data protection representative in those regions; if you access the service from those regions, Section 1.5 and Section 1.6 of the Terms of Service apply.

1.4This Policy does not apply to products or services operated independently by third parties, including app stores, third-party sign-in services and external websites to which we link.

1.5This Policy forms part of the Terms of Service. Where this Policy and the AI Services and Data Processing Agreement differ in respect of AI Interaction Data, the AI Services and Data Processing Agreement prevails.

1.6The terms “companion”, “custom companion”, “points”, “quota”, “points that never expire”, “Points Pack”, “30-Day Pass”, “Subscription Center” and “voice cloning” used in this Policy have the same meanings as in Section 1.8 of the Terms of Service.

Chapter 2 Personal Information We Collect

We follow the principle of data minimisation and collect only the information necessary for the purposes set out below.

2.1 Information you provide to us

(a)Account information: your registration email address; or, where you sign in with a third-party account such as Apple or Google, the user identifier provided by that service and the email address you authorise to be shared (including Apple's private relay address). This service does not use a mobile phone number for registration, sign-in or account recovery, and we do not collect your telephone number; if such a method is added in future, we will first update this Policy and obtain your separate consent.

(b)Profile information: nickname, gender, date of birth, avatar, and the country or region in which you are located. The country or region is used to determine the applicable price zone, content rating and statutory age of majority; the date of birth is used for age verification. Interest tags are optional.

(c)Custom companion information: the name, persona description, avatar image and companion parameter settings of the companions you create.

(d)Voice cloning information: the voice samples you record, and the voiceprint features and voice models generated from them. This information may constitute biometric information, and its processing is governed by Section 2.5 of this Policy and Chapter 2 of the Companion Creation and Voice Cloning Agreement (UD-VRC-01).

(e)Emergency contact (optional): the email address of a contact that you voluntarily provide. We do not verify the identity of that contact and do not send marketing messages to them.

(f)Content of your communications with us: customer service tickets, reports, appeals, feedback and related attachments.

2.2 Information we collect automatically

(a)Device and technical information: device model, operating system and version, app version, language and region settings, screen size, time zone, network type, and coarse location (derived from the IP address to country or city level; we do not collect precise geolocation).

(b)Identifiers: account ID, device identifiers generated by us, and push tokens. We do not use the advertising identifier (IDFA) on iOS for cross-app tracking; if this is introduced in future, we will obtain your authorisation separately in accordance with Apple's App Tracking Transparency rules.

(c)Usage logs: sign-in times and IP addresses, records of feature use, conversation turns and duration, points consumption records, crash and error logs, and performance data.

(d)Payment and entitlement information: subscription status, purchased items, order identifiers, transaction time, amount and currency, membership tier, points balance and points ledger. We do not collect or store your full payment card number; payments are processed by the app store.

(e)Security and risk-control information: account status, device risk markers, records of content safety hits, and records of suspected abusive behaviour.

2.3 Content generated when you use the features

(a)Interaction content: text messages between you and companions, voice messages, images you upload or send, and replies generated by companions. This content is used to provide the conversation service, to maintain context memory and to display history.

(b)Voice data: audio from live calls and voice input, used for speech recognition and reply generation. Speech synthesis processes only the text to be read aloud and does not involve your voiceprint.

(c)Behaviour and preferences: conversation language settings, system language settings, companion preferences, and duration and frequency of use, used to provide a localised experience and for security and risk control.

(d)Information formed in conversations: so that a companion remains coherent in later conversations and its replies fit your habits of expression and your situation, our system combines the content of your conversations with a companion to form information that the companion may refer to (called “conversation understanding” in Section 7.11 of the Terms of Service), such as personal circumstances, preferences, recent situation and way of interacting that you mention in the conversation. This information is formed automatically by the system during the conversation, may be inaccurate, and is updated or replaced as new conversations take place. It is used only to provide this service to you, does not constitute a determination of your identity, qualifications, abilities or reputation, is not used to evaluate, score, classify or make decisions producing legal effects about you, is not provided to third parties, and is not used for advertising targeting or commercial solicitation.

2.4 Information from third parties

(a)Apple: when you use Sign in with Apple, Apple provides us with a user identifier, a flag indicating whether the email address is hidden, and the private relay address you authorise to be shared.

(b)Google: when you use Sign in with Google, Google provides us with an account identifier and the email address you authorise to be shared.

(c)App stores: when you purchase a subscription or a Points Pack, Apple or Google provides us with the transaction receipt, transaction identifier and subscription status, used to verify entitlements and to prevent fraud.

(d)IP location service: we use a third-party IP database to resolve your IP address to a country or region, for preselecting the default country at registration, determining the price zone and applying compliance tiers. We do not store the full IP geolocation records returned by that service.

2.5 Sensitive information and biometric information

2.5.1We may process the following information, which is treated as “sensitive” in some jurisdictions: account login credentials, account-level identity identifiers, voiceprint features (only where you use voice cloning), and health or other sensitive content that you voluntarily disclose in a conversation.

2.5.2Voiceprint processing: the voice cloning feature requires the processing of your voiceprint. In some jurisdictions (including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI) and RCW 19.375 of Washington), a voiceprint is a biometric identifier. We process it only on the following conditions:

(a)before you use the feature, we inform you in a separate and express written manner (a dedicated consent screen in the app) of the purpose of processing, the retention period and the destruction schedule, and we obtain your written consent;

(b)we process it solely for the purpose of generating your dedicated voice model; it is not used to identify you, not used for advertising, and not sold, leased or traded to any third party;

(c)the original voice sample for voice cloning is deleted within 48 hours (whether or not the voice model is generated successfully) and is not included in data backups; the voice model is deleted when you delete that companion or close your account, and in any event no later than 30 days after the deletion request;

(d)we establish and follow a written retention schedule, and that schedule is not extended once the purpose has been achieved. The schedule is set out in Section 2.5.2(c) and Section 2.3 of UD-VRC-01.

2.5.3We do not use sensitive information to infer characteristics about you for targeted advertising.

2.5.4Health, sexual orientation, religious or other sensitive content that you voluntarily disclose in a conversation is provided by you of your own accord. We process such content in accordance with the features of the service, do not use it for advertising or sale, and do not build health records from it. If you do not wish it to be processed, please do not submit it in a conversation.

2.5.5The voice cloning feature is currently available only on the PRO tier. Where you do not meet that tier requirement or have not completed the separate consent, we do not begin collecting voice samples.

Chapter 3 How We Use Information and Our Legal Bases

3.1We use personal information only for the following purposes:

(a)to create and manage your account and to verify your age and location;

(b)to provide core features: companion conversations, group chat, live calls, speech recognition, speech synthesis, photo scan, translate, custom companions, history and context memory;

(c)to process subscription and Points Pack purchases, verify entitlements, and calculate points consumption and balances;

(d)to ensure security: content safety checks, anti-fraud, anti-abuse, account risk control and identification of minors;

(e)to improve the service: troubleshooting, performance optimisation, feature analysis, and the de-identified use of conversation content to improve reply quality, safety filtering and speech recognition. The specific de-identification methods, data destinations and retention periods are set out in Chapters 4 and 5 of the AI Services and Data Processing Agreement;

(f)to send you service notices: subscription expiry, price changes, amendments to agreements and security alerts. These notices are necessary for the service and are not marketing;

(g)to send you product recommendations or marketing information after obtaining your express consent. You may unsubscribe at any time;

(h)to comply with legal obligations, respond to lawful requests and enforce this Agreement.

3.2For the purposes of the GDPR (where applicable), our legal bases for processing personal data are: (a) performance of our contract with you (Sections 3.1(a) to (d)); (b) our legitimate interests (Section 3.1(h), having balanced your rights); (c) your consent (marketing information under Section 3.1(g) and voiceprint processing under Section 2.5.2); and (d) compliance with legal obligations (Section 3.1(h)). As for the improvement use in Section 3.1(e), we process on the basis of contract performance and legitimate interests: that use is necessary to maintain and improve the service, the three-layer de-identification measures in Section 4.3 of the AI Services and Data Processing Agreement have been applied, and your rights have been taken into account in the balancing exercise. We do not make your acceptance of that use a condition of providing the service; you may at any time require that your Interaction Data no longer be included in future batches, as described in Sections 4.5 and 6.2 of that Agreement.

3.3We do not use your personal information for automated decision-making that produces legal or similarly significant effects on you. Content safety mechanisms may automatically restrict features, and you may request human review under Section 9.6.

3.4We do not sell or rent your personal information, or use it for cross-context behavioural advertising.

Chapter 4 Cookies and Similar Technologies

4.1Our website uses essential cookies and local storage to maintain your signed-in state, remember language and interface preferences, and keep the service secure. The mobile app uses local storage to save session settings and caches.

4.2We do not currently use third-party advertising cookies or carry out cross-site tracking. If analytics or advertising SDKs are introduced in future, we will update this Policy and provide a consent management interface where the law requires one.

4.3Global Privacy Control (GPC): our website recognises the GPC signal sent by browsers and treats it as a valid request to opt out of sale or sharing. Because we do not sell or share personal information, a GPC signal does not change the service you receive.

4.4You may clear local storage or refuse cookies through your device or browser settings, although this may require you to sign in again or may cause some preferences to be lost.

Chapter 5 How We Share Information

5.1We do not sell your personal information. We share only the information necessary in the following circumstances:

(a)with the service providers (sub-processors) listed below, where necessary to provide the service;

(b)with your express consent;

(c)to comply with laws, regulations, court orders, subpoenas or lawful requests from competent authorities;

(d)to investigate, prevent or address fraud, security incidents or unlawful conduct;

(e)in a merger, acquisition, reorganisation or transfer of assets, where personal information is transferred we will require the transferee to remain bound by this Policy, failing which we will obtain your consent separately;

(f)to protect the vital interests of you or others, for example contacting your emergency contact under Section 2.1(e) in an emergency.

5.2The main service providers as at the effective date of this Policy:

5.3We enter into data processing agreements with the service providers above (or rely on their published data processing terms) requiring them to process information only on our instructions and to apply protection measures no less protective than the standards in this Policy.

5.4Model service providers: to generate replies and to run content safety checks, your conversation text and voice are transmitted to model service providers. Content safety checks and reply generation are carried out by the same provider in the same region, and do not further expand the categories of data or the geographic scope of transmission. Before transmission we remove account identifiers and transmit only the content and context necessary to generate the reply and to run the checks. Model service providers process that data under their terms for business customers and, under their commercial terms, do not use request data to train their general models. See Chapters 2 and 4.3 of the AI Services and Data Processing Agreement.

5.5Changes of providers: we may add, replace or reduce providers. Where such a change occurs, we will update Section 5.2 of this Policy and Chapter 2 of the AI Services and Data Processing Agreement at least 30 days before it takes effect, and notify you through in-app messages. Where a change involves a new purpose of processing or expands the scope of processing, we will obtain your consent separately.

5.6Public disclosure: we do not publicly disclose your personal information except where required by law or with your consent.

5.7Government and law enforcement requests: we provide information only where a request has a lawful basis, a defined scope and complies with due process. We review the lawfulness of requests to the extent permitted by law and notify you where permitted.

Chapter 6 International Transfers of Data

6.1Processing locations: our servers, object storage and all model endpoints are located in the Singapore region (Alibaba Cloud Singapore region, ap-southeast-1); speech synthesis for some voice profiles is processed in the Azure Southeast Asia region; text translation uses Azure global-region resources. All of these are outside mainland China. Other than audited remote administrative access from mainland China, we do not store your personal information in, or bring it into, information systems within mainland China, nor engage service providers located in mainland China to process it. Your information will therefore be transmitted to and processed in regions outside your country (mainly Singapore). If a processor located in mainland China is genuinely required in future, we will give notice in advance under Section 5.5 and obtain your separate consent for it.

6.2We apply the following mechanisms to ensure the lawfulness of international transfers:

(a)if we provide the service in the European Economic Area in future, we will adopt the Standard Contractual Clauses approved by the European Commission (SCC, 2021 version) and will first complete a transfer impact assessment; at present we do not provide the service in that region and do not carry out transfers originating there;

(b)if we provide the service in the United Kingdom in future, we will adopt the UK International Data Transfer Addendum (IDTA) or the UK Addendum; at present we do not provide the service in that region;

(c)for Canada, we ensure that recipients are subject to substantially similar obligations to protect personal information;

(d)for Japan, we inform you under the Act on the Protection of Personal Information of the recipient's country, that country's personal information protection system and the measures taken by the recipient, and obtain consent where required;

(e)for Korea, we inform you under the Personal Information Protection Act of the recipient of the overseas transfer, the items transferred, the purpose, the retention period and the means of refusal, and obtain consent;

(f)for other jurisdictions that require an assessment or filing for cross-border transfers, we comply with local law, as described in Chapter 17.

6.3If you require a copy of the relevant transfer mechanisms, you may contact us under Section 16.

Chapter 7 Retention Periods

7.1We retain personal information for the following periods, after which it is deleted or irreversibly de-identified:

(a)Account information: retained while the account exists; deleted from the production environment within 30 days after closure, except for the signature records, minimal trace and backup copies described in Sections 7.1(j), (k) and (l);

(b)Conversation records and interaction content: retained while the account exists; after you delete a single conversation or record, deleted from the production environment within 30 days; this content is not included in backups, so no backup copies arise; conversations with a custom companion are deleted together with that companion when it is cleaned up under Section 7.3;

(c)Voice samples: deleted within 48 hours (whether or not the voice model is generated successfully) and not included in data backups;

(d)Voice models and custom companion data: retained while the companion exists; deleted within 30 days after you delete the companion, close your account, or the companion is reclaimed for inactivity under Section 7.3, with the voice profile deleted immediately in the case of reclamation for inactivity;

(e)Payment and transaction records, points ledgers, orders and entitlement ledgers: retained in accordance with tax and accounting law for 7 years from the year in which the transaction occurred; where the law requires a shorter or longer period, that period applies;

(f)Server and security logs: 12 months;

(g)Customer service tickets, reports and appeal records: 3 years after the matter is closed;

(h)De-identified aggregate statistics: 24 months from the date the batch or version was generated, after which they are deleted; aggregate reports that contain no personal information and cannot be linked to any specific individual in any way may be retained for longer without identifying individuals. Such aggregation uses only the profile information you voluntarily provide and de-identified conversation corpora, and does not use the conversation understanding formed in your conversations with companions;

(i)De-identified data sets used for service improvement: 24 months from the date the batch was generated, after which they are deleted;

(j)Records of agreement signatures (evidence of consent): containing the signing time, account identifier, contact details, a snapshot of the text of the agreement as shown to you at the time and a tamper-evident checksum, retained until 7 years after account closure;

(k)Minimal trace after account closure: containing the closure reference, an irreversible checksum, the masked contact details, the closure time and the closure method, without conversation content; retained for 12 months after closure, or 3 years where a risk-control matter is involved;

(l)Daily backup copies: the backup scope covers only accounts, binding relationships, orders, points and entitlement ledgers, subscriptions, coupons and operational configuration, and does not include the body of conversations or memory; backups rotate in three tiers: one copy per day for the last 30 days, one copy per month for the following 12 months, and one copy per year for the following 7 years, with anything beyond that erased automatically.

7.2Where the law requires a longer retention period, or where necessary to establish, exercise or defend legal claims, we may extend retention to the extent necessary.

7.3Reclamation of custom companions for inactivity: a custom companion is a vehicle through which a feature of this service is provided, not your digital asset (see Section 7.7 of the Terms of Service). If you have made no operation on a custom companion for 30 consecutive days (text or voice chat with that companion and editing its character settings both count as operations), we may reclaim that companion instance and delete its voice model and voice profile, avatar, character card, and the conversation records, memory and conversation understanding between you and that companion (without archiving). The scope of reclamation does not include the account itself, nor your order and points records. Any operation restarts the 30-day period. We may give notice before reclamation through in-app messages or other means, but we do not guarantee delivery; failure to receive notice does not affect the validity of the reclamation.

7.4Storage cost and risk control: to control storage costs and reduce the risk of holding data for long periods, we may, where an account has been inactive for a long time, delete the conversation records, companion personas and memory data under your account, and delete the associated voice profiles. The account, companion instances not reclaimed under Section 7.3, orders and points records are retained. Cleaning up conversations and memory does not affect the validity period of any paid benefit. This Section is an operational measure on our part and does not constitute a commitment that cleanup will necessarily occur within a particular period.

7.5The cleanup described above is a measure we take to control storage costs and reduce the risk of holding data, and does not constitute a commitment that data will necessarily be deleted within a particular period. If you wish data to be deleted immediately, please exercise your right to erasure under Chapter 9.

Chapter 8 Security

8.1We take the following measures to protect personal information:

(a)transport encryption (TLS) and encryption of data at rest;

(b)access control based on the principle of least privilege, and internal auditing;

(c)isolated management of keys and credentials, which are not written into code repositories;

(d)regular dependency updates and security self-assessments;

(e)an emergency plan for security incidents.

8.2Security incident notification: if a security incident occurs that results in unauthorised access to, disclosure of, alteration of or loss of your personal information, we will notify you and the competent authorities within the periods required by applicable law (including the state data breach notification laws of the United States, PIPEDA of Canada, PIPA of Korea, UU PDP of Indonesia, PDPA of Thailand, the Data Privacy Act of the Philippines, POPIA of South Africa, the Act on the Protection of Personal Information of Japan and the Personal Data Protection Act of Singapore), explaining the nature of the incident, the categories of information involved, the measures we have taken and the protective steps you may take.

8.3No system can guarantee absolute security. Please keep your account credentials safe, and do not disclose passwords, payment card numbers, social security numbers or other highly sensitive information in conversations.

Chapter 9 Your Rights

9.1To the extent provided by applicable law, you have the following rights:

(a)right to be informed: to know the categories of information we collect, their sources, the purposes of use and the recipients;

(b)right of access and to obtain a copy: to obtain a copy of your personal information;

(c)right to rectification: to correct inaccurate personal information;

(d)right to erasure: to delete your personal information, except where retention is required by law;

(e)right to portability: to obtain the information you provided in a structured, commonly used and machine-readable format, and to require it to be transmitted to another provider where technically feasible;

(f)right to restrict or object to processing: to object to processing based on legitimate interests, or to request restriction of processing;

(g)right to withdraw consent and to stop inclusion: to withdraw consent previously given (including the separate consent for voice cloning and consent to marketing information), without affecting the lawfulness of processing before withdrawal; as for the use under service improvement, because it is not based on consent, you may at any time require that your data no longer be included in future batches, as described in Sections 4.5 and 6.2 of the AI Services and Data Processing Agreement;

(h)right not to be discriminated against: exercising your rights will not result in a downgrade of service or price discrimination;

(i)right to complain: to lodge a complaint with the data protection authority in your location;

(j)right to object to automated decision-making: to request human review of decisions such as restricting features or refusing service made by us on the basis of automated processing.

9.2How to exercise your rights: you may access, correct or delete most information directly in “Settings” in the app; other requests may be submitted through the email address in Section 16. We will act after verifying your identity and reply within 30 days; where an extension is needed because a request is complex, we will explain the reasons and the expected period (not exceeding an additional 45 days).

9.3We do not charge a fee for exercising your rights, except where a request is manifestly unfounded or excessively repetitive.

9.4Authorised agents: you may authorise an agent to make a request on your behalf. We may require a signed authorisation and may verify your identity directly with you.

9.5Limits of deletion: after deletion the relevant data is removed from production systems, and copies in backups are erased within the backup rotation cycle. Data already included in de-identified data sets is not removed on a deletion request, because that data is no longer linked to your account and we cannot locate your portion; the reasons and scope are set out in Section 4.6 of the AI Services and Data Processing Agreement. The minimum copies that must be retained to comply with legal obligations, resolve disputes or prevent fraud may be retained for longer (see Section 7.1(k)).

9.6Review of automated decisions: if you consider that a content safety mechanism or account risk control has treated you incorrectly, you may request human review, and we will explain the basis of the decision.

9.7Cross-platform entry point for account deletion: this app provides account deletion in “Settings” in the app. If you downloaded the app through Google Play, we also provide a deletion request entry point at the web address specified by the app store, in accordance with Google Play's account deletion policy; if you downloaded through the Apple App Store, the in-app entry point is the equivalent entry point. The scope and time limits for deletion are the same on both routes (see Section 9.5).

9.8If you are not satisfied with the outcome of a request, you may complain to the relevant supervisory authority under Section 16.2; in some jurisdictions you also have further administrative or judicial remedies, as described in Chapter 17.

Chapter 10 United States Residents (California and Other States)

10.1 California residents (CCPA/CPRA)

10.1.1The categories of personal information we have collected in the past 12 months, corresponding to the definitions in the CCPA, are as follows:

(a)identifiers: account ID, email address, IP address, device identifiers and push tokens;

(b)customer records: nickname, gender, date of birth, country or region and membership tier;

(c)commercial information: purchase records, subscription tier, points consumption and balance;

(d)internet or other network activity: records of feature use and interaction logs;

(e)geolocation data: coarse location derived from the IP address (country or city level);

(f)audio, electronic and visual information: voice messages, voice samples, uploaded images and custom companion avatars;

(g)inferences: inferences about preferences and usage habits drawn from usage behaviour;

(h)sensitive personal information: account login credentials and voiceprint (only where you use voice cloning).

10.1.2The sources, purposes and recipients of the information listed above are set out in Chapters 2, 3 and 5 of this Policy.

10.1.3We do not sell your personal information, and we do not share your personal information for cross-context behavioural advertising. We do not knowingly sell or share the personal information of consumers under 16 years of age.

10.1.4Your California rights include: the right to know (including what was collected and shared in the past 12 months), the right to delete, the right to correct, the right to opt out of sale or sharing, the right to limit the use of sensitive personal information, and the right not to be discriminated against. We provide the means of exercise in Chapter 9.

10.1.5Sensitive personal information: we use sensitive personal information only for the purpose of providing the service and do not use it to infer characteristics about consumers. You may request limitation of use under Section 1798.121 of the CPRA, although our current use is already limited to what is necessary for the service.

10.1.6Shine the Light (California Civil Code §1798.83): we do not disclose your personal information to third parties for their direct marketing purposes. To confirm this, you may make a written request under Section 16.

10.1.7Nevada residents: we do not sell “covered information”, and we do not authorise others to sell it. You may submit a request not to sell under Nevada SB 220.

10.2 Other state privacy laws

10.2.1If you live in a state that has a comprehensive privacy law in force, such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky or Rhode Island, you have the rights conferred by that state's law to access, correct, delete and port your data, to opt out of targeted advertising and profiling (that is, automated analysis or prediction of personal characteristics), and to appeal. This service does not provide targeted advertising and does not make decisions producing legal effects about you on the basis of such analysis; if you wish us to stop our conversation understanding, you may delete conversation records and AI memory under Chapter 9 of this Policy. We provide a unified means of exercise in Chapters 9 and 16 of this Policy.

10.2.2Appeals: if we refuse a request, you may appeal within 60 days of receiving notice. We will reply within 45 days; if you remain dissatisfied, you may complain to the attorney general of your state.

10.3 Washington My Health My Data Act

10.3.1We are not a “regulated entity” under the Washington My Health My Data Act, and we do not provide medical services. If you voluntarily mention your health in a conversation, that content is used only to generate a reply; we do not build consumer health data profiles from it, do not use it for advertising and do not sell it.

Chapter 11 Canadian Residents

11.1We process the personal information of Canadian residents in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial privacy laws, including by collecting for reasonable purposes, obtaining informed consent, limiting collection, limiting use and disclosure, ensuring accuracy, applying security safeguards, being transparent, providing access, allowing correction and responding to complaints.

11.2Access requests: you may request access to the personal information we hold about you and information about its use and disclosure. We will reply within 30 days, subject to any extension permitted by law.

11.3Quebec (Law 25): you have the rights to be informed, to access, to correct, to delete, to portability, to withdraw consent and to learn about automated decision-making. We have designated a privacy officer, whose contact details are in Section 16. If you object to our processing, you may complain to the Commission d'accès à l'information du Québec (CAI). If you ask to receive this Policy or to exercise your rights in French, we can provide a French version; where the Charter of the French Language requires a contract to be entered into in French, the French version prevails.

11.4Commercial electronic messages (CASL): we send commercial electronic messages only with your express or implied consent. Every commercial email includes the sender's identity, a mailing address and a one-click unsubscribe mechanism. Unsubscribe requests take effect within 10 business days. Service notices (such as subscription expiry, amendments to agreements and security alerts) are not commercial electronic messages.

11.5If you have questions or complaints about privacy, you may contact our privacy officer first; if you are not satisfied with the response, you may complain to the Office of the Privacy Commissioner of Canada (OPC) or to the privacy commissioner of your province.

Chapter 12 Children's Privacy

12.1The service is not directed to users below the age of majority prescribed in their country or region (which is not lower than 18). We do not knowingly collect personal information from anyone below that age; because that threshold is higher than the age of 13 set by any children's online privacy legislation, this Policy contains no separate provisions for children's information.

12.2If we learn that an account has been registered by a user below the age of majority, we will terminate that account immediately and delete the relevant information. If you believe we hold information about a child, please notify us under Section 16.

12.3Users below the age of majority prescribed in their country or region may not use this service, even with the consent of a parent or other guardian. If such an account is discovered, we will restrict or terminate the service and handle the data in accordance with Chapter 7.

12.4We do not use age inference technology for any purpose other than inferring whether a user is an adult, and we do not serve advertising on the basis of children's data.

Chapter 13 Artificial Intelligence and Automated Processing

13.1Service improvement and model training: we de-identify conversation content and use it to improve this service, namely reply quality and context understanding, the accuracy of safety filtering, speech recognition and synthesis, and translation quality. The specific measures are set out in Section 4.3 of the AI Services and Data Processing Agreement (three layers: structural, content and quasi-identifier). That use forms part of the service; its basis is processing necessary to provide and improve the service, and it is not a condition of providing the service. If you do not wish your Interaction Data to be included in future batches, you may ask us to stop in the manner described in Section 16, and we will give effect to it in the next batch without affecting your continued use of the service. The part already included in de-identified data sets cannot be deleted separately (see Section 4.6 of that Agreement). We do not currently train foundation models ourselves; if we do so in future, we will obtain your consent separately.

13.2Disclosure of training data: our foundation model capabilities come from third-party model service providers, and we do not train foundation models ourselves. We may use de-identified Interaction Data to optimise prompting strategy, reply quality and safety filtering. As to what California AB 2013 and similar legislation require to be disclosed: the models underlying our generative features are developed by third parties, and the composition of their training data sets is disclosed by each model service provider; we have not used any specific copyrighted work as training material.

13.3Labelling of AI output: we label AI-generated content, including in-app statements (such as an “AI” label on companion cards and notices on the conversation screen) and machine-readable metadata where available, so that it can be distinguished from the work of a real person. In accordance with applicable law, app store rules and our platform rules, we do not present AI-generated content as the work of a real person; if you export or screenshot content and share it, please retain the labels.

13.4Deepfakes and likeness: we prohibit the use of the service to create another person's likeness, voice or intimate imagery without consent. The relevant rules are set out in Section 9.1 of the Terms of Service and Chapter 5 of the Companion Creation and Voice Cloning Agreement.

13.5We do not use AI output as a basis for determining your legal, medical, financial or psychological condition, and we do not make decisions producing legal effects about you on that basis.

13.6Model output may contain inaccurate or fabricated content. Your use of AI output does not create any obligation on us beyond this Policy and the Terms of Service.

Chapter 14 Third-Party Links and Services

14.1The service may contain links to third-party websites or services. Those third parties operate independently and their privacy practices are not governed by this Policy. We recommend that you read their privacy policies before use.

14.2For purchases made through an app store, payment information is processed by the app store, and we receive only the transaction result and subscription status.

Chapter 15 Changes to this Policy

15.1We may amend this Policy. For material changes (including new categories of information, expanded purposes of use, new recipients and changes to retention periods), we will notify you at least 30 days before they take effect through a prominent in-app notice and by email to your registered address, and will obtain your consent again in regions where the law requires it.

15.2If you continue to use the service after a change takes effect, you are deemed to accept the amended Policy; if you do not accept it, you may stop using the service and close your account.

15.3Previous versions of this Policy are available from us on request.

Chapter 16 Contacting Us and Complaints

16.1If you have any question, request or complaint about this Policy, the processing of personal information or your rights, please contact:

•Privacy email: hallo.uooda@gmail.com

•General enquiries: hallo.uooda@gmail.com

•Privacy Officer (for Canada and Quebec): Tao Huang (the operator)

•Data protection contact (for jurisdictions such as Korea, Indonesia, Thailand and the Philippines that require a designated contact): hallo.uooda@gmail.com

•Postal address: available upon written request (this Policy does not publish a personal residential address)

16.2We will reply within 30 days after receiving a request and completing identity verification. If you are not satisfied with the response, you may complain to the following bodies (the full list is in Chapter 17):

•California, United States: the California Privacy Protection Agency (CPPA) or the Attorney General of California

•Other states of the United States: the attorney general of your state

•Canada: the Office of the Privacy Commissioner of Canada (OPC) or the privacy commissioner of your province

Chapter 17 Jurisdiction-Specific Provisions

This Chapter sets out the key points of data protection law applicable by jurisdiction. Where this Chapter conflicts with the preceding Chapters, this Chapter prevails in respect of residents of the relevant jurisdiction. This Chapter does not constitute a commitment by us to provide the service in regions not covered, or a compliance commitment.

17.1 Japan

Under the Act on the Protection of Personal Information (個人情報の保護に関する法律), we act as a personal information handling business operator and inform you of the purpose of use, the record-keeping obligation when providing data to third parties, and the matters required when providing data to third parties overseas (the recipient's name, its country, that country's system and the recipient's measures). You may request disclosure, correction, suspension of use and deletion. The supervisory authority is the Personal Information Protection Commission (PPC).

17.2 Korea

Under the Personal Information Protection Act (개인정보 보호법), we inform you of the items collected, the purpose, the retention period and your right to refuse, and we give separate notice of and obtain consent to overseas transfers. You may request access, correction, deletion and suspension of processing. Where the statutory threshold is met, we will designate a domestic agent (국내대리인). The supervisory authority is the Personal Information Protection Commission (PIPC).

17.3 Singapore

Under the Personal Data Protection Act 2012 (PDPA), we obtain consent, inform you of the purposes, provide channels for access and correction, and comply with the Do Not Call (DNC) Registry requirements. Data breaches are notified to the Personal Data Protection Commission (PDPC) and to affected individuals after assessment, in accordance with that Act.

17.4 Indonesia

Under Law No. 27 of 2022 on Personal Data Protection (UU PDP), we process personal data on the basis of explicit consent or another lawful basis, provide channels for access, correction, deletion, withdrawal of consent and objection to automated decision-making, and notify data subjects and the competent authority within the statutory period if a breach occurs. The privacy notice is provided in Indonesian or available on request. The supervisory authority is the data protection agency (Lembaga PDP).

17.5 Thailand

Under the Personal Data Protection Act 2019 (PDPA), we process personal data on the basis of consent or another lawful basis, provide channels for access, correction, deletion, restriction of processing, portability and objection, and notify the Personal Data Protection Committee (PDPC) of a breach within 72 hours. Where the statutory conditions are met, we will appoint a Data Protection Officer (DPO).

17.6 Malaysia

Under the Personal Data Protection Act 2010 and its 2024 amendments, we inform you of the purpose and obtain consent before processing, provide channels for access and correction, notify the Personal Data Protection Commissioner and affected individuals of a data breach in accordance with that Act, and appoint a Data Protection Officer (DPO) where the statutory conditions are met.

17.7 Philippines

Under the Data Privacy Act of 2012 (RA 10173) and its implementing rules, we process personal data in accordance with lawful criteria and provide channels for information, objection, access, correction, deletion, portability and complaint; where a breach is notifiable by law, we notify the National Privacy Commission (NPC) and affected data subjects within 72 hours.

17.8 Taiwan region

Under the Personal Data Protection Act (個人資料保護法), at the time of collection we inform you of the purpose and categories of collection, the period and manner of use, and how you may exercise your rights to inquire, review, obtain copies, supplement or correct, stop collection, processing or use, and delete. You may request the exercise of those rights under that Act, and we will act within the statutory period.

17.9 Hong Kong, China

Under the Personal Data (Privacy) Ordinance (Cap. 486), we comply with the six data protection principles, including those on collection limitation, accuracy, retention, use limitation, security and openness. You may make data access and correction requests under that Ordinance (we may charge a fee within the statutory cap for access requests). The supervisory body is the Office of the Privacy Commissioner for Personal Data (PCPD).

17.10 Mexico

Under the Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP) and its Regulations, we provide a privacy notice (aviso de privacidad) in Spanish stating the purposes of processing, the retention period, how to exercise the ARCO rights (access, rectification, cancellation and objection) and the transfers of data. We do not process sensitive personal data without consent. The supervisory authority is the National Institute for Transparency, Access to Information and Protection of Personal Data (INAI).

17.11 Colombia

Under Law 1581 of 2012 and Decree 1377 of 2013, we obtain authorisation before processing, publish our processing policy, and register with the National Database Registry (RNBD) of the Superintendence of Industry and Commerce (SIC) the databases that are required by law to be registered. You may exercise your rights of access, update, correction and deletion.

17.12 Argentina

Under Personal Data Protection Law No. 25.326, we process personal data for lawful purposes and provide the rights of access, correction, deletion and confidentiality, and we complete registration where required by law. The supervisory authority is the National Directorate for Personal Data Protection (AAIP).

17.13 Chile

We process personal data under Law No. 19.628, and will process it in accordance with Law No. 21.719 once that law takes effect on 1 December 2026, including the full implementation of data subject rights, a data protection officer (where the statutory conditions are met) and the rules on cross-border transfers. Until then we protect your rights in accordance with the law currently in force.

17.14 Peru

Under Personal Data Protection Law No. 29733 and its Regulations, we obtain consent before processing, inform you of the purposes and retention periods, and have registered with the National Authority for Personal Data Protection (ANPD) the databases that are required by law to be registered. You may exercise your rights of access, correction, deletion and objection.

17.15 South Africa

Under the Protection of Personal Information Act 2013 (POPIA), we process personal information in accordance with the conditions for lawful processing, provide channels for access, correction and deletion, and notify the Information Regulator and affected data subjects where a data breach occurs that creates a risk.

17.16 Australia and New Zealand

Australia: we process personal information in accordance with the Privacy Act 1988 and the Australian Privacy Principles (APPs) and provide channels for access and correction; where a breach is notifiable by law, we assess it and notify the Office of the Australian Information Commissioner (OAIC) and affected individuals under the Notifiable Data Breaches (NDB) scheme. New Zealand: we process personal information in accordance with the Privacy Act 2020 and the information privacy principles and provide channels for access and correction; where a breach is notifiable by law, we notify the Office of the Privacy Commissioner (OPC).

Chapter 18 Effective Date and Versions

This Policy takes effect on 15 November 2026 and supersedes the version published on 30 October 2026.