Privacy Policy

Last Updated: December 1, 2024

1. Introduction

HONG KONG HAPPY MOBILE TECHNOLOGY LIMITED ("we," "our," "the company") is committed to protecting your privacy. This Privacy Policy ("Privacy Policy") explains how we collect, use, share, and safeguard your personal information when you use our product ChatQ AI ("the App").

While the App does not require you to create a login account, we may link your subscription and account information with your Apple ID. By using the App, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

2. Information We Collect

Even though the App does not require a login account, we may collect the following types of personal information through Apple's integration and subscription services:

• Apple ID Information: When you use the "Sign in with Apple" feature to subscribe or purchase services, we may collect and use information shared by Apple, including but not limited to your Apple user ID, email address (if you permit), and subscription details.
• Transaction Information: If you subscribe or purchase services via the App, we will collect relevant transaction records, such as the type of subscription, transaction date, order number, and payment method.
• Device Information: This includes device model, operating system, package name, app version, system version, device identifier (such as IDFA or OAID), IP address, and other technical information related to your device.
• Usage Data: Automatically generated data during your use of the App, such as features used, access records, and operation times, which help us improve user experience and product performance.
• User-Generated Content: Content you upload or generate within the App, such as chat logs, files (e.g., PDFs), and other data.

3. How We Use Your Information

We primarily use your personal information for the following purposes:

• To provide and maintain services: To ensure the normal operation of subscription services, such as verifying your subscription using your Apple ID.
• Transaction management: We process your subscription through Apple's payment system and maintain transaction records to ensure the security of your payments.
• User behavior analysis: We analyze your device information, operation records, and usage data to improve our service quality and enhance user experience.
• Personalized service: We will not display personalized ads but will offer personalized services based on your usage patterns, such as content recommendations or optimizing feature displays.
• Security and fraud prevention: We use Apple ID information and device identifiers to monitor unusual activities, prevent unauthorized use, and ensure the safety of your account and payment information.
• Improving our AI model: We may use the user-generated content you provide (e.g., chat logs, uploaded documents) to improve our AI model. You may opt-out of this data processing by contacting us.

4. International Data Transfers

We work in the cross-border area and provide our App to our Users around the world.This means that your personal data may be transferred to, and stored at, a destination outside your country,where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory , or to the international organization.

5. Cookies and Similar Technologies

We use cookies and similar technologies to enhance and personalize your experience, analyze app usage, and deliver ads. You may manage cookies through your device or browser settings. If you disable cookies, some parts of the App may become inaccessible or not function properly.

6. How We Share Your Information

We do not sell your personal information, but we may share it with third parties in the following circumstances:

• Apple: As part of Apple's integration, your Apple ID information and subscription details may be shared with Apple to complete payments and verify subscriptions.
• Service Providers: We may share information with third-party service providers (e.g., cloud storage, payment processing) to ensure the proper functioning of the app. These providers are required to handle your data securely and in accordance with privacy and security guidelines.
• Legal Requirements: We may disclose your information when required by law, such as responding to legal requests from government authorities or enforcing legal obligations.

7. List of Third-Party Service Providers

Provider	Service	Data Shared
Cloud Provider	Cloud Storage	User Data, Transaction Records
Payment Gateway	Payment Processing	Transaction Details

8. Data Security

We implement reasonable technical and organizational measures to protect your personal data, especially when interacting with us via your Apple ID. These measures include:

• Encrypted transmission: We use encryption technologies (e.g., SSL) to protect sensitive information during transmission, ensuring that your payment and Apple ID data is secure from third-party interception.
• Access control: Only authorized personnel have access to your personal data, and all access is strictly monitored.
• Regular audits: We regularly review and test our security systems to prevent data breaches.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security.

9. Data Storage and Retention

We retain your personal data according to the following criteria:

• Apple ID Information and Transaction Records: Retained for 7 years to comply with financial and legal obligations.
• Device and Usage Data: Retained for 2 years for analytics and optimization purposes, or until the user requests deletion.
• User-Generated Content: Retained for 1 year for improving our services and AI model, or deleted upon user request.

10. Your Rights

Depending on your location, you may have certain rights regarding your personal data, including:

• Right to access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object
• Right to withdraw consent

11. Children’s Privacy

Our App is not intended for children. Therefore, we do not knowingly or intentionally collect or solicit any personal information from children. As a general rule, we consider a person under the age of 16 to be regarded as “a child.” Only the people who have parental responsibility are responsible for stopping their children from giving personal information through the App without the right parental consent that can be verified.

If we find out that we have collected a child's personal information without checking with the person who has parental responsibility for the child, we will delete that information as soon as we can. If you think it's likely that we might have any information from or about a child, or a child has directly given us personal information through the App without verifiable parental consent, please get in touch with us.

12. Cookies and Similar Technologies

Although the App does not require a login, we may use cookies and similar technologies to optimize your experience. Cookies help us understand user preferences and provide personalized services. You can manage or disable cookies via your device or browser settings, but doing so may affect certain functionalities.

13. Links To Third-Party Websites/Services

Our App may contain links to third-party websites or services, or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We encourage you to read the privacy policies of these third-party websites or services before providing them with your personal information or using their services.

14. How to Opt-Out

We respect your privacy and provide multiple ways for you to opt-out of the collection or use of your personal data, including opting out of automated processing, personalized services, and cookies. Below is a detailed explanation of the opt-out mechanisms:

14.1. How to Opt-Out on iPhone Devices

• Disable app tracking:
  1. Open the Settings app.
  2. Tap Privacy & Security.
  3. Select Tracking.
  4. Turn off Allow Apps to Request to Track. This will prevent all apps from requesting tracking permission.
• Disable personalized ads:
  1. Go to Settings > Privacy & Security > Apple Advertising.
  2. Turn off Personalized Ads.

14.2. Contact Support for Opt-Out

If you wish to completely opt-out of all automated processing, personalized analysis, and services, you can contact us via the following methods:

• Email: Send an email to [email protected] to submit an opt-out request.

We will process your opt-out request within 45 days and ensure that your personal data will no longer be used for personalized services or automated analysis during this period.

15. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in our business or legal requirements. If we make significant changes to this Privacy Policy, we will notify you via email or through the App.

16. How to Contact Us

If you have any questions or wish to exercise your privacy rights, please contact us:

HONG KONG HAPPY MOBILE TECHNOLOGY LIMITED
Email: [email protected]