Privacy Policy

Effective Date: 2025/05/28

This Privacy Policy (the “Policy”) describes how Developer, a company named [Deep X Corporation Limited] and registered at [UNIT 505,5/F KING'S COMM BLDG，2-4 CHATHAM COURT TSIM SHA，TSUI, HONG KONG], referred to as “Developer” or “We”, or “Us”) collects, stores, uses and protects your information when you use the product of [Deepvo.ai] (the “Product”) and use some affiliated sub-domains owned or operated by Developer (collectively, including the Product, the “Services”). This Policy can be modified from time to time; therefore, we encourage users to frequently consult the privacy policy.

By accessing, visiting or using our Services, you warrant and represent that you have read, understood and agreed to this Policy. If you disagree with anything in this Policy, you must not use or access the Services.

Here is a summary of the information contained in this Policy. This summary is to help you navigate the Policy and it is not a substitute for reading everything. You can view the particular sections for more detailed information.

• Personal Information We Collect. If you register an account to use the Services, we will need some personal information from you to set this up. We will also collect and create personal information about you when you use certain functions of the Services. We also use cookies necessary for the provision of our Services, and you may control these cookies in your search engine. For more information, please refer to 1 Personal Information We Collect.
• How We Use the Information We Collect? We process your personal information to manage the contract you have refused/agreed to and to provide functions related to account management, interaction with the Services, etc. We also process your personal information to identify the abnormal status, ensure the stability and security of our Services, and to meet governmental and institutional policy obligations. For more information, please refer to 2 How We Use the Information We Collect.
• How We Disclose Your Information? We may disclose your personal information to affiliates and some third-party service providers (e.g., IT services and business support) who help us deliver the Services. We may also be required to disclose certain personal information about you in response to any legal procedures or requests from regulatory authorities, for audit purposes, in the event of mergers, acquisitions, sale of assets, or transfer of services, and in other circumstances specified under 3 How We Disclose Your Information.
• How Do We Protect Minors? We do not aim to provide Services for minors, and we do not intentionally collect or maintain information from minors. For more information, please refer to 4 How do we protect minors.
• Security. We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. For more information, please refer to 5 Security.
• Retention of Personal Information. We take every reasonable step to ensure that your personal information is only processed for the minimum period necessary for the purposes set out in this Policy. For more details on the duration of the retention of your personal information, please refer to 6 Retention of Personal Information.
• How Will We Transfer Your Information Around the World? Due to the international operation of our business, your personal information may be accessed from and transferred to jurisdictions outside of where you are located. In the event of a cross-border transfer of personal information, we take appropriate measures to provide an adequate level of protection for your personal information. For more information, please refer to 7 How Will We Transfer Your Information Around the World.
• What is Your Data Subject Rights and Choices? Depending on where you are, you may have certain rights with respect to your personal information, such as rights of access and data portability, to correct or delete your personal information, to withdraw your consent, restrict or object to our processing of your personal information, or to lodge complaints with an applicable authority for any breach of data protection laws. For more information, please refer to 8 What is Your Data Subject Rights and Choices. In particular, if you are a United States resident, certain State data privacy legislations may entitle you to additional rights as detailed under 9 Special Information for U.S. State Residents.
• How to Contact Us? If you have any questions or comments regarding this Policy and/or other privacy practices, want to exercise any rights you may have, please contact us by using the information detailed under 10 How to contact us?

1. Personal Information We Collect
2. How We Use the Information We Collect
3. How We Disclose Your Information
4. How Do We Protect Minors
5. Security
6. Retention of Personal Information
7. How Will We Transfer Your Information Around the World
8. What is Your Data Subject Rights and Choices
9. Special Information for U.S. State Residents
10. How to Contact Us

11. Personal Information We Collect

For the purpose of this Policy, the term “personal information” includes any information that identifies or makes an individual identifiable. In certain jurisdictions, this may be referred to as “personal data”. However, for the sake of consistency, this Policy will use the term “personal information” throughout to refer to such data. To the extent that our processing of your personal information is subject to certain data privacy protection laws (including, but not limited to the General Data Protection Regulation (“GDPR”), California Consumer Privacy Act of 2018 (“CCPA”), California Privacy Rights Act of 2020 (“CPRA”), collectively hereafter “appliable laws”), we will also notify you about the legal basis on which we process your personal information and your rights under such laws.

A. Information you provide to us

When you access or use our Services, we may generally collect the personal information, according to the specific Services, of You Directly and Voluntarily Provide to Us, which may include:

• Customer Support Information, if you are a visitor to the Product, we may collect information that you provide to us when you communicate with us.
• Account Information: When you create an account with us, we will collect information associated with your account, such as your phone number, verification code, email address, password, and other information you add to your profile which absolutely depends on your choice.
• User Content: When using some of our Services, you can create, post, upload or share content by providing us with access to your photos, media and files, and your device’s camera and microphone. You voluntarily provide this information to us.
• AI Interaction Information: when you interact with the AI functions within the Services, we will collect your input data (“Inputs”), which will generate responses (“Outputs”) based on your Inputs.

B. Information Automatically Collected Through the Services

We automatically collect information about you when you use the Services, such as:

• Device Information:If you access the Services through a mobile device, we may collect information about the operating system of the device you use to access the Services. The information collected may depend on the type of device you use and its settings.
• Service Usage Information: We collect information about your use of the Services, such as your User ID, service logs, operation logs, browser type.
• Cookies & Similar Tracking Information: We use cookies and similar tracking technologies to collect information about your interactions with our Services. To learn more about our use of cookies, please see our 【Cookie Policy】. We will obtain your consent to our use of cookies where required by law.
• Network Information: When you use our service, we may automatically collect information about your use of the network, such as your IP address, mobile network, Wi-Fi connection.

You may be able to limit the amount of information collected from your device (e.g., computer, phone, or tablet) with us by adjusting your device or browser settings. However, by preventing us from collecting information from you, we may not be able to provide some functions on our Services.

C. Information You Share on Third Party Websites or through Social Media Services

The Services may include links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information. By interacting with these third parties, you are providing information directly to the third party and not us and subject to the third party’s privacy policy. Please read their data usage policies or other documentation. Our linking to another site or service doesn’t mean we endorse that third party.

2. How We Use the Information We Collect

We will only use your personal Information when the applicable laws allow us to. Our legal bases for collecting and using the personal information described in this Policy depends on the personal information we collect and the specific context in which we collect the information:

• We need to perform a contract with you;
• You have given us consent to do so;
• In specific jurisdictions, processing your personal information is in our legitimate interests, including
  • providing, maintaining and marketing our Services;
  • detecting, preventing and enforcing violations of our [Term of Use] including misuse of services, fraud, abuse, and other trust and safety protocols; and
  • protecting our legal rights and the rights of others.

If legitimate interest is not an available legal basis in a particular jurisdiction, we will engage in the processing activities described above on a legal base that is available in that particular jurisdiction;

• We need to comply with our legal obligations under the applicable laws.

The purposes for which we process personal information, subject to applicable laws, and the legal basis on which we perform such processing, are as follows:

Purpose	Type of Personal Information	Legal Basis
To provide you with functions related to user account management, such as account registration, account deletion, account login, and modification of account information	Account Information Services Usage Information	Performance of contract
To provide and facilitate the Services with you, so that you could interact with the Services, and sent feedback to us.	AI Interaction Information User Content Customer Support Information Services Usage Information	Performance of contract
To communicate with you for non-marketing purposes including by sending you Services-related notice, push notifications, and other messages.	Account Information Device Information	Performance of contract
To send you marketing communications, where you have signed up to receive them.	Account Information	Consent
To identify the abnormal status, ensure the stability and security of our Services, and to meet governmental and institutional policy obligations.	Account Information Device Information Network Information Services Usage Information	Legitimate interests & Legal obligations
To investigate and resolve security issues, and to enforce our [Terms of Use].	Account Information AI Interaction Information User Content Services Usage Information	Legal obligation & Performance of contract
To analyze your use of, and any other interaction or interest in our Services, and to develop and improve our Services (not used for AI model training).	Services Usage Information Device Information	Legitimate interests

3. How We Disclose Your Information

We may disclose your personal information to third parties in the following circumstances for the purposes explained in this Policy.

We will only disclose your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and we will only share the personal information required to provide the Services. We will require our partners, through agreements, to retain data only for the necessary period and to implement adequate security measures to protect data security.

We will disclose personal information to the following categories of third parties for the purposes explained in this Policy:

• Affiliates and corporate partners. We disclose the categories of personal information described above between and among our affiliates and related entities, for legitimate business purposes and the operation of the Services, in accordance with applicable laws.
• Service providers and business partners. Third-party service providers who provide us with IT services (such as cloud storage service) and business support (such as statistical analysis and/or advertising service provider) may need to process your data. These third parties will process your personal information on our behalf under relevant contracts.
• Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose your personal information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our [Terms of Use] and other terms, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by applicable laws (including exchanging information with other companies and organizations for the purposes of fraud protection).
• Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your personal information as part of that transaction.

4. How Do We Protect Minors

Our Services are not directed towards, and we do not knowingly collect personal information from children under 18 years old, unless permitted to do so by applicable law. If we become aware that we have unknowingly collected personal information from a child, we will make commercially reasonable efforts to delete such information in our database. If you are a parent or guardian of a child, and you believe your child has provided us with their Personal Information on our Services, please contact us immediately at support@deepvo.ai.

5. Security

We are committed to ensuring the security of your personal information. We have physical, technical and administrative safeguards in place to protect the confidentiality of your personal information. In addition, we require that our service providers handling personal information also maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you provide to us.

Although we will implement all reasonable measures to protect your personal Information, we cannot guarantee its absolute security of your personal information or ensure that loss, misuse, unauthorized acquisition, or alteration will not occur. We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections.

Maintaining the security of your personal information is also your responsibility. Where we require you to register an account, you should choose a password of sufficient length and complexity and keep your password confidential. Do not leave your device unlocked so that other individuals may access it. Make sure you trust the wireless connections you are using to access or use our Services.

If you think there has been unauthorized access to or use of your account, please contact us immediately at support@deepvo.ai.

6. Retention of Personal Information

We adhere to retention policies for the personal information we collect to ensure that it is not retained longer than necessary for the intended purpose. Different retention periods are applied to the various types of personal information collected by us in accordance with the service needs and regulatory requirements.

Upon expiration of the retention period, we will either delete or anonymize your personal information. Measures will be taken to render the information irrecoverable or irreproducible.

When assessing how long your personal information is retained, we consider criteria such as: (i) the nature of the personal information and the activities involved; (ii) the time when and for how long you use the Services; and (iii) our legitimate interests and our legal obligations.

7. How Will We Transfer Your Information Around the World

If you use the Services from regions outside mainland China, your personal information will be processed and stored on servers located in the United States. In line with the international nature of our business, your personal information may also be accessed by our affiliates or be transferred to third-party service providers and business partners, in connection with the purposes set out in this Policy. For this reason, we transfer personal information to other jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located.

In the event of an international transfer of personal information, when required by applicable laws, we will provide an adequate level of protection for your personal information using various means, including implementing Standard Contractual Clauses or data transfer agreements that comply with applicable laws between our affiliates and third parties or any other lawful approach that permits the lawful transfer of personal information from those countries.

8. What is Your Data Subject Rights and Choices

Subject to applicable law and depending on where you reside, you may have some rights regarding your personal information, as described further below. If you have any other requests relating to the access of your personal information, please contact us at support@deepvo.ai.

A. Data Access

You may have the right to know what personal information we process about you, including the categories of personal information, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it and other information according to the applicable law. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee.

B. Data Correction

You may have the right to request that we correct inaccurate personal information that we retain about you, subject to certain exceptions.

Please note that we cannot guarantee the factual accuracy of Outputs. If Outputs contain factually inaccurate personal information relating to you, you can submit a correction request and we will make a reasonable effort to correct this information—but due to the technical complexity of the AI models integrated into the product, it may not always be possible for us to do so.

C. Data Portability

You may contact us to request the personal information you have provided to us in a structured, commonly used and machine-readable format and have it transferred to another controller, to the extent applicable.

D. Data Deletion

You have the right to delete your account and erase your personal information. Upon deleting your account, all your personal information will be deleted. Additionally, you may also request deletion of the personal information you provide by contacting us. If some of your personal information cannot be deleted, we will inform you of the reasons for not taking action.

Please note that we reserve the right to retain some of your personal information where there are valid grounds for us to do so under applicable laws.

E. Withdrawal of Consent

Where we process your personal information on the basis of your consent, you may withdraw your consent by contacting us. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

You may withdraw your consent to receiving direct marketing messages and/or emails by using the unsubscribe mechanism at the bottom of such communications, or by contacting us at support@deepvo.ai.

F. Objection to the Processing

Subject to applicable laws, you may object to the processing of your personal information based on our legitimate interests where there are grounds relating to your particular situation by contacting us. Please note that we may have an overriding legitimate interest to keep processing your personal information, but we will let you know where this is the case.

G.Restriction to the Processing

If you would like to restrict our processing of your personal information, you may contact us. You have the right to restrict the processing of your data where one of the following applies:

• the processing is unlawful and you oppose the erasure of relevant personal information;
• for the purpose of establishment, exercise or defense of legal claims, you request us to retain your personal information that we were supposed to delete;
• your objection regarding the accuracy of your personal information is pending our verification;
• your request to object to the processing of your personal information is pending our verification.

H. Other Rights

Depending on your jurisdiction, you may be entitled to additional rights in relation to your personal information. For example, you may also have the right to lodge complaints with an applicable data protection authority if you consider that the processing of your personal information infringes any applicable data protection laws (for example, the EU GDPR). For United States residents, please find more details of your rights in Section 9 below.

If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may contact us at support@deepvo.ai. When submitting a right request, please specify the scope and basis of your request and provide us with the necessary information to verify your identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under applicable data protection laws.

9. Special Information for U.S. State Residents

As a new service launched on [2025/05/28], we have collected personal information since our product launch as described in Section 1 above. We will update this disclosure annually in accordance with CCPA requirements.

As a new service launched on [2025/05/28], we disclose personal information with third parties since our product launch as below. We will update this disclosure annually in accordance with CCPA requirements. You also have the right to request for a list of third parties to which we have disclosed your personal information under certain State data protection laws.

Categories of personal information	Disclosed to which categories of third parties
All categories detailed in Section 1 above	Cloud storage services provider and our affiliates
AI Interaction Information	AI service provider
Services Usage Information	Advertising service provider
Device Information and Network Information	Statistical analysis provider (if any)
Account Information Customer Support Information	Customer service vendors (if any)
Services Usage Information, such as your error logs	Error detection and analysis service provider

To the extent provided for by local law and subject to applicable exceptions, you may have the following rights:

• Limit the Use of Sensitive Personal Information. “Sensitive personal information” may have different definitions and scopes according to applicable State data protection laws, but generally include personal race or ethnicity, religious beliefs, sexual orientation, personal health data, biometric data, financial data, credit data, online data of children under 13, and precise location data.

You have the right to request limitation of use and disclosure of your sensitive personal information, subject to certain exceptions. If you would like to limit the use of your sensitive personal information, please contact us by using the contact details provided in the Section 10 below.

• Do Not Sell or Share My Personal Information. Based on the definition of “sell” and “share” under applicable State data protection laws, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.
• Appeal. You may appeal our refusal to take action on a request by contacting us using the contact details provided in Section 10 below.
• The Right to Non-discrimination. You have a right to not be discriminated against for exercising any of your rights.
• The Right to an Authorized Agent. You may have the right to designate another person to make a request on your behalf under certain State data protection laws. We verify all requests through email before taking any action and reserve the right to deny a request where we are unable to verify your identity satisfactorily. This also applies to requests submitted on your behalf by someone else.

If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in the Section 10 below. According to applicable laws, we may request you to provide documents such as application form and proof of identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under the applicable laws.

10. How to Contact Us

For more information about your data subject rights, or how we process your personal information, please contact us by using the information below.

Controller: [Deep X Corporation Limited]

Address: [UNIT 505,5/F KING'S COMM BLDG，2-4 CHATHAM COURT TSIM SHA，TSUI, HONG KONG]

Contact Details: support@deepvo.ai