User Privacy Policy

Version effective date: August 13, 2026

This User Privacy Policy (hereinafter referred to as "this Privacy Policy") constitutes an integral part of the User Agreement (hereinafter referred to as the "User Agreement") and is entered into by and between the User (hereinafter referred to as "you") and HONGKONG SEASOUL CO., LIMITED (hereinafter referred to as "HONGKONG SEASOUL CO., LIMITED" or "we").

If you are a minor, you must read this Privacy Policy with your guardian. Please ensure both you and your guardian read it carefully. You may only use our products and services after obtaining your guardian's full consent to all terms of this Privacy Policy.

We strictly respect and protect your privacy and information. When using our products and services, we may collect and process your personal information. This Privacy Policy explains how we handle your information to better safeguard your rights. We hereby provide the following explanations:

I. Definition of Terms

Unless otherwise specified, the terms used in this Privacy Policy have the meanings set forth below. Unless otherwise specified in this Privacy Policy, terms used herein shall have the meanings assigned to them in the User Agreement.

1. Personal Information: This refers to any information recorded electronically or otherwise that can identify a specific individual or reflect their activities, either alone or in combination with other data. Examples of personal information include: basic personal details (such as name, date of birth, gender, address, mobile number, email address, etc.), identity information (including ID card numbers), biometric data (such as fingerprints and facial features), online identity identifiers (including system accounts, passwords, IP addresses, digital certificates, etc.), financial information (including bank accounts, passwords, transaction records, virtual currency, digital transactions, redemption codes, and other virtual assets), contact lists, browsing history (including website visits, software usage, and active application lists), device information (including hardware serial numbers, models, MAC addresses, operating systems, software lists, and unique device identifiers), and location data (including precise geolocation and geographic coordinates). The specific types of personal information we collect are detailed in this Privacy Policy.

2. Sensitive Personal Information: This refers to personal information that, if disclosed, unlawfully provided, or misused, may endanger personal or property security, or may seriously damage personal reputation, physical or mental health, or result in discriminatory treatment. Examples include personal financial information, identity information, biometric information, contact list information, friend lists, group lists, precise location information, and children's personal information. The specific categories of sensitive personal information we collect are described in this Privacy Policy.

3. Device: means a device that can be used to access or use this product and services, such as a computer, tablet, or smartphone.

4. Unique Device Identifier: means a string of characters embedded in a device by its manufacturer that can be used to uniquely identify the device, such as an IMEI, Android ID, IDFA, OpenUDID, GUID, SIM card identifier, or IMSI.

5. IP Address: Every device connected to the Internet is assigned a number known as an Internet Protocol (IP) address. These numbers are generally assigned based on geographic regions.

6. Cookies: Cookies are small files containing strings of characters that are sent to and stored on your computer, mobile device, or other device (usually in encrypted form) when you log in to or use a website or other online content. Cookie-like technologies include technologies used for similar purposes, such as web beacons, proxies, and embedded scripts.

7. Account: Also known as "user account", it refers to the account successfully registered by a user in accordance with the user agreement and relevant laws and regulations to use this product and service.

II. How We Collect and Use Personal Information

We collect and use your personal information in accordance with applicable laws and regulations, adhering to the principles of fairness, legality, and necessity. This includes information you voluntarily provide during service use or that arises from product and/or service requirements. Should we need to use your personal information for purposes not specified in this Privacy Policy, or to repurpose collected data for specific objectives, we will promptly notify you through reasonable means and obtain your consent prior to any such use.

We collect and use two categories of your personal information. The first category consists of information necessary for the core business functions of our products and/or services. Such information is essential for the normal operation of our products and/or services, and you must authorize us to collect it. If you refuse to provide it, you may be unable to use our products and/or services normally. The second category consists of information that may be required for supplementary business functions. This information is not necessary for core business functions, and you may choose whether to authorize its collection. If you refuse to provide it, the supplementary business functions may not be available or may not achieve their intended effects, but your normal use of core business functions will not be affected.

You acknowledge and agree that we strive to deliver comprehensive products and services, which requires continuous improvements including technological enhancements. This may involve regular updates to new features, collection of additional personal information, or modifications to data usage purposes and methods. For any features or services requiring personal information collection not explicitly detailed in this Privacy Policy, we will provide additional information through policy updates, page prompts, pop-ups, or website announcements. You may choose whether to consent to such collection, and we will only proceed after obtaining your explicit consent. Should you have any questions regarding these matters, please contact us via the methods specified in this Privacy Policy, and we will respond promptly.

During your use of this product and services, we generally collect and use your personal information in the following scenarios:

1. Account Registration

(1) When registering and logging into your user account or using our products/services, you must complete the registration process as instructed. During this process, you will need to provide the following information: account nickname, profile photo, phone number, and email address. This data is collected to identify and authenticate your identity while storing login credentials. These details are essential for account registration and accessing core services. Failure to provide this information may result in restricted access to our products/services.

(2) Our products and services support login via third-party platform accounts. When you log in with a third-party account, we will collect relevant information (including the account name, username, nickname, profile picture, and other authorized details, as specified on the third-party account authorization page) based on your consent. This information is collected to provide login services, ensure account security, and mitigate risks. If you decline to authorize this information, you will be unable to log in to our platform using the third-party account, but this will not affect the normal use of other products and services we offer.

2. During your use of this product and services:

(1) Reading from/writing to external storage. We require permission to read from and write to your device's external storage (for Android devices, this may include permissions to read external storage, read from/write to SD card content, and modify/delete SD card content; the same applies below). These permissions are used to install and store the product on your device and to read stored files, including necessary processes and caches, as well as to read, write, download, save, or modify images, photo albums, files, and crash logs. This enables you to log in to and use our services normally and helps maintain the normal and stable operation of core product functions. If you refuse to grant these permissions, you may be unable to use the relevant products and services.

(2) Log information, including login logs, item logs, purchase logs, activity logs, upgrade logs, chat logs, in-product social records, and other logs generated during your use of this product and services. We collect this information for operational statistics and analysis, customer service complaint handling, and service experience optimization, and to enable you to view your historical records in the product client. If you refuse to provide this information, you may be unable to use the relevant products and services.

(3) Interactive Information. When you interact with other users in the product through text, images, voice, or other means, we may collect and retain the content you send to filter inappropriate content such as pornography, violence, political content, abusive language, and malicious advertisements, thereby helping maintain a healthy online environment. If you wish to interact with other users by voice, or take, upload, or save images, we will access your microphone, camera, photo album, and device external-storage permissions after obtaining your authorization. If you refuse to grant these permissions, you may be unable to use certain products and services, but your use of other functions of this product and services will not be affected, except as otherwise provided in this Privacy Policy. You may also disable these permissions at any time in your system settings.

(4) Application and device information (unique device identifier, serial number, manufacturer, name, type, version, model, style, and MAC address), network identity information (IP address), operating system and process details, network environment data, and service crash logs. We collect this information to verify account credentials and ensure account security. Your IP address may be used to identify the device's internet connection location for specific activities.

(5) Transaction data, including order details, address information, recharge records, spending history, and other essential transaction-related information. When using the payment function within a product, we collect this information to enable you to review your transaction records, ensure maximum transaction security, and provide customer service with necessary information for dispute resolution. Recharge and spending records are classified as sensitive personal information. Collecting this information is essential for the payment function to operate; otherwise, transactions cannot be completed.

(6) Facial feature information. We provide you with video synthesis features or services, which are one of the functions of Seachat. To enable this feature, we may collect and use the following information or permissions:

①The information you voluntarily provide, including uploaded photos and videos;

②When you import images or videos to create and synthesize a video, we will request your authorization to access and modify content on your SD card. If you refuse, you will be unable to use the video synthesis function or save the final synthesized video to your photo album, but this will not affect your use of other Seachat functions.

③We will collect your selected uploaded or voluntarily provided profile photos. Upon obtaining your authorization, we will analyze facial feature data, identify the positions and shapes of the five senses in the photo, process the image, and provide you with a visual rendering. This rendering will contain no personal identification information. It is used to offer you technical services for modifying or editing short videos on the platform. If you do not use the aforementioned services, we will not collect your profile photos.

④We will collect your profile photo information to verify that the uploaded photo is your own and protect your portrait rights from misuse. We will not store your personal facial features.

⑤We neither store nor share/process your personal facial information with any third party. The collection of such information is solely for facial recognition in video synthesis features (including but not limited to face blending effects, AI face-swapping, filter effects, and makeup effects). Your personal facial information is stored on the device (e.g., mobile phone or other smart handheld devices) and its system when you upload your profile photo, and we do not retain your personal facial information.

Refusing to provide the above information may prevent you from using certain features, but it does not affect the use of other Seachat features and services.

3. Customer Service

When you file a complaint, appeal, request consultation, or apply for account cancellation, we may require you to provide account information in advance to verify your user identity by matching it with your previously submitted personal details. To facilitate communication, assist with issues, or send gifts, we may also need your name, phone number, email address, and other contact information. Additionally, we collect communication records (including text, images, audio/video, and call logs) and other necessary information related to your needs. The aforementioned information constitutes sensitive personal information. We collect it to investigate facts and assist in resolving your issues. If you refuse to provide this information, we may not be able to provide timely feedback on your complaint, appeal, or consultation.

To better understand customer needs and optimize services, our customer service team may contact you by phone to inquire about product usage, gather feedback, or conduct follow-up activities. If you prefer not to receive such calls, you can contact us through the methods specified in this Privacy Policy, and we will refrain from making phone calls. We may also send you email updates, news, or promotional materials regarding our products or services.

4. Cookies and Similar Technologies

To improve our services, we may use cookies and similar technologies to store and, at certain times, track relevant user information. Such use is limited to commercial, market-analysis, or academic purposes, including estimating traffic volume and analyzing user preferences. Cookies and similar technologies may also be used by third parties. For example, advertising services may require identifiable data as evaluation metrics. Such data is used only for analysis, to assess and improve the effectiveness of advertising and other promotional activities in our products or services.

5. Circumstances in Which We May Collect and Use Your Personal Information Without Obtaining Your Consent

(1) Related to our compliance with legal and regulatory obligations;

(2) directly related to national interests such as national security and defense security;

(3) Directly related to major public interests such as public safety, public health, and public awareness;

(4) directly related to criminal investigation, prosecution, trial, and judgment enforcement;

(5) When it is necessary to protect your or another individual's life, property, reputation, or other significant legitimate rights and interests, but obtaining your consent is difficult;

(6) The personal information collected was voluntarily disclosed to the public by you;

(7) Collecting personal information from legally disclosed sources, such as authorized news reports or government information disclosure channels;

(8) Essential for the execution and performance of the contract as required by you;

(9) Essential for maintaining the safe and stable operation of the provided products or services, such as identifying and resolving product or service failures;

(10) necessary for carrying out lawful news reporting;

(11) When necessary for public interest statistical or academic research, and when providing externally the results of such research or descriptions, the personal information contained in the results is de-identified;

(12) Other circumstances prescribed by laws and regulations.

Please note that the features and services we provide are continuously updated and enhanced. If any feature or service not listed in the above description involves collecting your information, we will inform you of the scope, purpose, and details of the data collection through page prompts, interactive processes, or website announcements to obtain your consent.

III. How We Share, Transfer, and Publicly Disclose Your Personal Information

1. Share

We take great care to protect your personal information, which serves as the essential basis and integral component for providing you with our products and/or services. We collect and use your personal information strictly for the purposes and within the scope specified in this Privacy Policy, or as required by applicable laws and regulations, while maintaining strict confidentiality. Under normal circumstances, we do not share your personal information with any company, organization, or individual, except in the following cases:

(1) You have given explicit authorization or consent in advance;

(2) Sharing your personal information is required under applicable laws and regulations, legal procedures, government-mandated orders, or judicial rulings;

(3) When legally required or permitted, we may disclose your personal information to third parties to protect the interests, property, or safety of the data subject, users, or the public from harm.

(4) Your personal information may be shared among our affiliated companies. We will only share necessary personal information, and such sharing is subject to the purposes stated in this Privacy Policy. If an affiliated company wishes to change the purpose of processing your personal information, it will seek your authorization and consent again.

(5) To provide you with more comprehensive and high-quality products and services, certain services will be delivered by authorized partners. We may share some of your personal information with these partners to enhance customer service and user experience. We will only share your personal information for legitimate, necessary, specific, and clearly defined purposes, and only the information required to provide the service. Additionally, we require partners to handle your personal information in accordance with our guidelines, this Privacy Policy, and other relevant confidentiality and security measures. Our partners are not permitted to use the shared information for any other purposes. If you refuse to allow our partners to collect the personal information necessary for service provision, you may be unable to use the third-party service on our platform.

Our partners' collection and processing of information comply with their respective privacy policies or relevant statements, which do not apply to this Privacy Policy. To maximize your information security, we recommend reviewing third-party service privacy policies prior to use. To protect your legal rights, if you identify risks associated with any third-party services, we advise you to immediately terminate related operations and contact us promptly.

2. Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

(1) Transfer with explicit consent: Upon obtaining your explicit consent, we will transfer your personal information to third parties;

(2) Provision shall be made in accordance with applicable laws and regulations, legal procedural requirements, and mandatory administrative or judicial demands.

(3) In cases involving mergers, acquisitions, asset transfers, bankruptcy liquidations, or similar transactions, if personal information is transferred, we will require the new entity holding your personal information to continue being bound by this Privacy Policy. Otherwise, we will require the entity to obtain your authorization again.

3. Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

(1) With your explicit consent;

(2) Disclosure under legal requirements: We may disclose your personal information when required by law, legal procedures, litigation, or mandatory requirements from government authorities.

4. Situations where prior consent is not required

In accordance with applicable laws, regulations, and national standards, we may share, transfer, or publicly disclose personal information without prior consent in the following cases:

(1) Related to our compliance with legal and regulatory obligations;

(2) directly related to national security or defense security;

(3) directly related to public safety, public health, or major public interests;

(4) directly related to criminal investigation, prosecution, trial, and judgment enforcement;

(5) When safeguarding the vital interests of the data subject or other individuals, such as life and property, but obtaining their consent proves difficult;

(6) Personal information voluntarily disclosed by the data subject to the public;

(7) Collection of personal information from legally disclosed public sources, such as legitimate news reports and government information disclosure channels.

Under legal provisions, the sharing, transfer, or public disclosure of de-identified personal information—provided that the recipient cannot reconstruct or re-identify the data subject—is not considered external sharing, transfer, or public disclosure of personal information. No separate notification or consent from you will be required for the storage or processing of such data.

IV. How We Store and Protect Your Personal Information

1. Information storage

(1) Storage Location: In compliance with applicable laws and regulations, we will store your personal information exclusively in the Western United States. Currently, we do not store your personal information across borders or share it with overseas entities. If cross-border data transfer is necessary, we will provide you with a detailed notice specifying the purpose, recipient, usage scope, content, security measures, and associated risks. Your explicit consent will be obtained, and we will ensure the recipient possesses adequate data protection capabilities to safeguard your personal information.

(2) Storage Period: We retain your personal information for the shortest necessary duration required to fulfill product and service purposes. For instance, when you use our registration and membership features, we collect your phone number. After collection and during feature usage, we continue to store this information to ensure seamless functionality and safeguard your account and system security. Additionally, we may retain your data for the legally mandated period as stipulated by applicable regulations.

(3) After the aforementioned storage period expires, we will delete or anonymize (de-identify) your personal information.

2. Information Protection

(1) The security of your personal information is of paramount importance to us. We will strictly comply with relevant laws and regulations and implement industry-recognized reasonable and feasible measures to protect your personal information. We will prevent unauthorized access, disclosure, use, or modification of the information, and avoid damage or loss of the data.

(2) When requesting users to provide personal identity-related information, we will disclose our Privacy Policy in a clear and visible manner in advance, and take necessary measures to protect user information.

(3) Unless expressly stipulated in this Privacy Policy, user registration data including name, valid personal identification number, contact information, and residential address shall not be provided, disclosed, or shared with any third party without user consent, except under the following circumstances: disclosure authorized by the user or their legal guardian; disclosure required by applicable laws or mandatory regulations; provision mandated by judicial or administrative authorities through statutory procedures; litigation or arbitration proceedings initiated by the user to protect legitimate rights; or disclosure of personal identity information upon lawful request from the user's guardian.

3. User Account Usage and Management

To ensure account security, we reserve the right to verify the authenticity and validity of user-provided identity information during registration, and shall implement appropriate technical and managerial measures to safeguard account integrity. Users are obligated to properly safeguard their accounts and passwords, and to use them correctly and securely. Any party failing to fulfill these obligations, resulting in account password loss or theft that causes civil rights infringement to users or third parties, shall be held legally liable.

V. Your Rights to Manage Your Personal Information

We understand your concern regarding personal information and make every effort to ensure your rights to inquire about, correct, delete, and withdraw consent for your personal information, so that you have sufficient capacity to protect your privacy and security. Your rights include:

1. You have the right to access your personal information

You can check the personal information you provided to us according to the instructions (or settings) for the products and services we offer. This includes:

(1) Account Information: You can log in to your profile page at any time through the relevant page to access your personal information in the product, including: profile picture, nickname, etc.;

(2) Additional Information: If you encounter operational issues during your visit and require access to other personal information not covered above, please contact us through the methods specified in this Privacy Policy.

2. You have the right to correct your personal information

If you find any errors, incomplete information, or outdated details in the personal information you provided, you may contact us through the methods specified in this Privacy Policy and submit a correction request.

(1) For some of your personal information, such as your profile picture and nickname, we provide settings on the relevant product pages where you can directly make corrections or modifications.

(2) If you encounter difficulties in exercising the aforementioned rights, or if we are currently unable to provide you with online self-correction/modification services, you may contact us through the methods specified in this Privacy Policy to request corrections or modifications to your data. Upon identity verification and provided that such corrections or modifications do not compromise the objectivity and accuracy of the information, we may make the necessary adjustments to any erroneous or incomplete data, unless otherwise required by applicable laws and regulations.

3. You have the right to delete your personal information

(1) For certain personal information, you may submit a deletion request to us through the methods specified in this Privacy Policy. Upon approval of your request, we will delete or anonymize such information unless otherwise required by applicable laws and regulations.

(2) You may request us to delete your personal information directly under the following circumstances, unless the information has been anonymized or otherwise required by law:

① When our handling of personal information violates laws and regulations;

② When we collect or use your personal information without obtaining your consent;

③ When our processing of personal information violates the agreement with you;

④ When you log out of your user account;

⑤ When we terminate services and operations.

4. You have the right to withdraw your authorization for personal information

As previously stated, certain features of our products and services require access to your device permissions (including: photo album, camera, microphone, etc., subject to actual functionality). You may revoke (or terminate) these permissions at any time after authorization. For example, you can disable access to your phone's photo album through "Settings-Privacy-Photos" on iOS devices. You may also withdraw consent to this privacy policy via the product's dedicated settings page, or permanently revoke all authorization for continued collection of your personal information by logging out of your account. Please note that after revoking permissions, we will no longer provide the specific features and/or services associated with those permissions. However, your decision to revoke permissions will not affect any prior personal information processing conducted based on your previously granted authorization.

5. You have the right to cancel your account

You may contact us through the methods specified in this Privacy Policy to request account cancellation. Upon cancellation, you will no longer be able to log in or use the product or services with this account. All benefits accrued during the account's active period (including unused entitlements and future overdue benefits) will be fully cleared. Content, information, data, and records associated with this account will be deleted or anonymized (unless otherwise required by laws or regulatory authorities). Once the account is canceled, it cannot be restored.

VI. Protection of Minors

1. We attach great importance to the information security and protection of minors. We encourage parents or other guardians (hereinafter referred to as "guardians") to guide minors in using our services. If you are a minor, please notify your guardian to jointly review the content and obtain their consent and guidance before using this product and service or submitting personal information.

2. For personal information of minors collected with the guardian's consent, we will only use or disclose such information when permitted by law, with explicit consent from the guardian, or when necessary to protect the minor.

3. If you are the legal guardian of a minor, please ensure that the minor under your guardianship has obtained your authorization before using this product or service. If the guardian explicitly refuses our services to the minor through the aforementioned methods, we will promptly delete the collected, stored, or used personal information of the minor in accordance with legal requirements and cease providing services to the minor.

VII. Suspension and Termination of Services

1. If a user posts illegal content, seriously violates social ethics, or commits other acts prohibited by law, we reserve the right to immediately terminate services for that user.

2. If a user engages in improper conduct during service use, the provider reserves the right to terminate service provision.

VIII. Updates to and Accessing This Privacy Policy

1. To provide you with enhanced services, we will update this Privacy Policy in accordance with product updates and relevant legal requirements. Such updates shall form an integral part of this Privacy Policy. Without your explicit consent, we will not reduce your rights under this Privacy Policy. If such updates result in material reduction or significant changes to your rights under this Privacy Policy, we will notify you through prominent displays, push notifications, or other means. By continuing to use our services, you acknowledge that you have read, understood, and agreed to be bound by the revised Privacy Policy.

2. Major changes include but are not limited to:

(1) Our service model has undergone significant changes, including the purposes for processing personal information, the types of personal information processed, and the methods of personal information utilization.

(2) Significant changes occur in ownership structure and organizational framework, such as business adjustments, bankruptcy, mergers and acquisitions, etc.

(3) The primary recipients of personal information sharing, transfer, or public disclosure have changed;

(4) Significant changes occur in your rights to personal information processing and how you exercise them;

(5) We are responsible for handling changes in contact information and complaint channels for personnel involved in personal information security;

(6) When the personal information security impact assessment report indicates a high risk.

3. You can access this Privacy Policy through the product's relevant feature pages or the official website. If you have any questions about these access options, please contact us using the methods specified in this Privacy Policy.

IX. Contact Us

1. If you have any questions, inquiries, or complaints regarding the content of this User Privacy Policy or personal information protection issues encountered while using our services, you may contact us through any of the following methods:

(1) You can contact customer service or submit feedback online through the product's relevant feature page.

(2) You can contact us by emailing customer@seachat.ai.

2. We will respond to your feedback within 15 business days after receiving your comments and verifying your user identity. In exceptional circumstances, the response time may be extended. Please note that we may not be able to process your request under the following personal information-related conditions:

(1) Those related to national security and defense security;

(2) Related to public safety, public health, or major public interests;

(3) those related to criminal investigation, prosecution, and adjudication;

(4) There is conclusive evidence of your subjective malice or abuse of power;

(5) Responding to your request would cause serious harm to the lawful rights and interests of you or other individuals or organizations;

(6) Involving trade secrets;

(7) Other circumstances stipulated by laws and regulations.