Privacy Policy
Effective Date：【2026.5.11】
Last Updated：【2026.5.11】
This Privacy Policy (this “Policy”) sets out how SyncTide Network Technology Limited (the “Company”, “we”, “us”, “our”) collects, uses, discloses, transfers and safeguards the personal information you provide when using our AI companion chat application “Amouree” (the “Application” or “Service”).
This Policy applies to:
• all users of the Application, including minor users who have reached the age of 13 (calculated according to the age threshold under applicable law) and adult users;
• all personal information collected, held, processed or used through the Application; and
• the services provided in Canada (excluding the Province of Quebec), Australia, Hong Kong, Taiwan, New Zealand and Singapore.
The Company commits to:
• comply with all applicable laws and regulations;
• collect and process personal information in a fair and lawful manner;
• ensure that all our employees and agents comply with the strictest security and confidentiality standards;
• take all reasonably practicable steps to protect the privacy of personal information; and
• respect and protect your rights in relation to personal information.
The types of personal information we obtain about you depends on how you interact with us and our products and services. When we use the term “personal information,” we are referring to information that identifies, relates to, describes, or can be associated with you. The following are the categories and specific types of personal information that we collect:
• Login information: Google account, Apple ID or email account, password, and UID
• Profile Information: avatar, nickname, age, gender, profession, data of birth, self-introduction, linguistic style
• Text content of conversations with the AI.
• Images proactively uploaded by users.
• Descriptions of AI characters created by users.
Please note that the conversations in the “Private Room” feature are not retained after the user exits the feature.
• Usage record, including login time, frequency of use, feature usage records, clicks, browsing records and dwell time.
• Engagement Information, including Users’ likes and follow records.
• Order information (transaction number, merchant order number, payment time, payment method, payment amount, transaction status);
• Virtual asset balance and consumption details (e.g., per-round chat consumption records);
Please note that we do not directly store complete payment or bank-card or other actual financial information; all transactions are processed by payment platforms.
• Device identifiers: Android ID, OAID, IDFV, IDFA, Serial Number, user-agent, mobile device identifiers;
• Basic device specification: device manufacturer, brand, model, software/system version, screen width, screen height, CPU architecture, CPU count, available memory, CPU frequency;
• Network information: network type, IP address, time zone, network operator;
• Application version;
The Application uses tracking technologies such as mobile device identifiers to identify and track user sessions, maintain users’ login status, and provide a personalised service experience.
We collect personal information directly from you in the following circumstances:
• when a user registers/logs in an account of the Application;
• when a user proactively inputs or uploads content during use;
• when a user proactively edits the profile information;
• when a user makes in-app purchases or transactions.
The Application allows you to log in using your Google or Apple account. When you choose to log in via a third-party account, we will obtain your email address from that third party.
In addition, when you complete a transaction through a third-party payment platform, we receive confirmation information regarding the transaction outcome (e.g., payment status) from that platform, for the purposes of order reconciliation and the issuance of virtual assets.
We may automatically collect your personal information through mobile device identifiers and application analytics tools, including information used to identify and track user sessions, maintain login status, and provide personalised experiences.
We process personal information for the following purposes:
If we intend to use your personal information for a new purpose beyond those stated at the time of collection, we will:
• expressly notify you of the new purpose in advance;
• obtain your express and voluntary consent; and
• provide a free-of-charge communication channel for you to indicate objection.
Unless we have your consent or are required by law, the Company will not sell, lease, trade or otherwise disclose your personal information to any third party (including all AI service providers).
We may transfer personal information to the following categories of third-party service providers (including all AI service providers), but only to the extent necessary to perform the Service:
|
Service Provider |
Purpose |
Types of Information Collected |
|
Google Inc. |
User registration and login |
Email address, IP address |
|
User-behaviour analytics |
Device model, OS version, Application version, approximate geolocation (city/country estimated from IP), device language, Firebase Installation ID, Crashlytics Install UUID, Firebase Installation ID, crash traces, Breakpad mini-dump-format data |
|
|
Verifying user-side payment receipts |
Payment receipts |
|
|
Apple Inc. |
Verifying user-side payment receipts |
Payment receipts |
|
Cloud Storage Service Provider |
Storing data related to the Service |
Account Information, User-Generated Content, Usage Data, Transaction and Payment Information, Device and Technical Information, Information Collected via Tracking Technologies |
|
AI large-language-model and content-safety review providers |
Real-time generation of AI responses and dialogue content; content-safety review and filtering; service-quality monitoring and technical optimisation; fault diagnosis and technical support. |
Dialogue content proactively input by users |
|
Third-party advertising and marketing platforms and data-analytics service providers |
Analysis of users’ behaviour and consumption data |
Approximate location (received IP address is associated with a region/city); other app-performance and diagnostic data (e.g., app start-up time or battery-level data used for anti-cheat detection); device IDs or other IDs (e.g., Serial Number, IMEI identifiers, MAC addresses, and advertising identifiers IDFA, IDFV, GAID) |
We enter into data-processing agreements with third-party data processors (including all AI service providers) which expressly stipulate that:
• the third party may only process personal information within the scope of the Company’s instructions;
• personal information shall not be used for the third party’s own purposes;
• technical and organisational security measures of no less than industry standards must be adopted;
• upon termination of the service or end of cooperation, the relevant personal information must be deleted or returned; and
• in the event of an information security incident, the Company must be notified promptly.
We do not transfer personal information to other independent corporate entities within the Company’s group.
The Application may contain links to third-party websites or services. The Company is not responsible for the privacy practices or content of such third-party websites or services.
When you click on a third-party link or use a third-party service, you will be subject to that third party’s privacy policy. We recommend that you review the privacy policies of such third parties.
We may be required to disclose your personal information in the following circumstances:
• to comply with applicable laws, regulations, legal process or mandatory governmental requests;
• to enforce applicable terms of service, including investigating potential violations;
• to detect, prevent or otherwise address fraud, security or technical issues; and
• to protect, to the extent required or permitted by law, the rights, property or safety of the Company, our users or the public from harm.
This Application is an AI companion product and not a social media platform. The minimum age of use for the Application is 13 years. We will not knowingly collect or process the personal information of children under 13.
For minor users aged 13 to under 18:
• we provide only basic chat-service functions, and do not display, recommend or allow access to adult-oriented character content;
• through content rating and recommendation restrictions, we ensure exposure only to age-appropriate content;
• the system restricts the generation of inappropriate content.
• we apply more stringent personal information protection measures for minor users.
Where we aware that a user is under the age of 13 (including but not limited to where the user has provided false information for registration in breach of rules or has accessed without authorization), we will immediately cease providing the Service, and block the user’s account and delete all historical interaction data and personal information.
Your personal data is stored on servers located in Singapore. By using our services, you acknowledge that your personal data will be transferred to and stored in Singapore.
We may also transfer your personal data to third-party service providers located in other countries or regions (for example, providers of cloud computing, analytics, or customer support services).
In respect of the cross-border transfers of personal information described above, we will take such compliance measures as may be required by law to ensure that your personal information is adequately protected, including but not limited to: adopting security technical measures such as encryption and de-identification, and binding overseas recipients’ processing of personal information by means including by entering into Standard Contractual Clauses (SCCs) or equivalent data transfer agreements with overseas recipients, or by other means that comply with applicable law.
We will retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected. The specific retention periods are as follows:
|
Category of Personal Information |
Retention Period |
Retention Consideration |
|
Account information |
Duration of the account |
To provide the Service |
|
Conversation content |
Duration of the account |
To provide the Service |
|
Usage records |
Duration of the account |
Service improvement |
|
Transaction records |
35 days after account deletion |
Billing purposes |
|
User identification information |
Duration of the account |
To prevent re-registration and fraudulent use |
|
Users’ message (complaint handling) |
Duration of the account |
Handling complaints |
We have systematic deletion processes in place, supported by access controls and logging, to ensure timely deletion of personal information.
In certain circumstances, even after the purposes of collection have been fulfilled, we may need to retain personal information in order to:
• comply with legal, accounting or reporting requirements;
• resolve disputes;
• enforce our agreements; and
• protect our legitimate interests.
The Company implements strict system access controls to prevent unauthorised access and uses a secure server environment to store personal information. The Company also deploys firewalls and intrusion-detection systems and conducts periodic security assessments and vulnerability scans to ensure that system security is continuously monitored and maintained.
As regards organizational measures, the Company adopts a tiered access-rights system whereby employees may access personal information only on a “need-to-know” basis. All employees who handle personal information must undergo regular training and sign confidentiality agreements. The Company also formulates and enforces a comprehensive information-security policy, and has established an information-security incident response mechanism to deal with potential security events.
The Company imposes strict access restrictions on facilities housing personal information and operates visitor-registration and surveillance systems to ensure that the physical security of the relevant premises is properly safeguarded.
In the event of a personal information breach which may pose risks to your rights and freedoms, we will assess the nature and impact of the incident as soon as practicable and will notify affected users and/or report to the relevant regulator(s) in accordance with applicable law.
Notwithstanding the reasonable and effective measures described above, and notwithstanding our compliance with the standards required by applicable law, we cannot guarantee the security of your personal information when communicated through insecure channels. You should take active measures to safeguard the security of your personal information, including setting complex passwords, changing account passwords regularly, and not disclosing your account or password information to others, in order to assist us in safeguarding the security of your account and your personal information.
In addition, you understand and agree that: when using this App, any content (including name, telephone number, identity-card number, address, bank account, biometric data and other sensitive information) that you proactively input, transmit, share or disclose constitutes your own autonomous act. Any acquisition, forwarding or misuse by third parties resulting from your proactive disclosure, and all losses, damages and legal liabilities arising therefrom, shall be borne by you alone, and the Company shall not be liable for any compensation or any joint or several liability.
If the Company intends in the future to use your personal data for direct marketing, we will expressly notify you in writing in advance of:
• the Company’s intention to use your personal data for direct marketing;
• the categories of personal data intended to be used in such marketing;
• the types of products or services to be marketed; and
• where personal data is intended to be provided to third parties for direct marketing, the classes of such third parties.
We have always been mindful of engaging our customers in a more targeted and relevant way. We will only send marketing messages to you if:
• you have given us consent;
• you have not registered with the national DNC Registry; and
• the sending of such messages is permissible under applicable laws and regulations.
We respect your right to control your personal information. This Part sets out the rights you may exercise in respect of personal data held by the Company about you. Save where it is indicated that a right may be exercised by self-service, you may contact us in the manner set out in Section “How to Exercise Your Rights”.
You have the right to request access to personal information held by the Company about you, including:
• confirmation as to whether the Company holds personal information about you;
• a copy of your personal information; and
• information about the purposes for which the personal information is used and the classes of persons to whom it may be disclosed/ transferred.
You may self-access via the “Settings” function within the Application. For information not available through that function, please submit a written request to us.
You have the right to request the correction of any inaccurate personal information held by the Company about you.
You may directly modify or update your personal information in the “Profile” settings within the Application. For information not available through that function, please submit a written request to us.
Upon receipt of a correction request:
• if we are of the view that the information is inaccurate, we will make the correction as soon as practicable;
• during the period for determining whether the information is inaccurate, we will not use such information; and
• where such information has been disclosed to a third party, we will notify that third party of the correction.
Where any of the following circumstances applies, you have the right to request that we delete your personal information:
In the following circumstances, we may be unable to delete your personal information immediately:
• where law requires us to retain the information;
• where the information is needed to complete a transaction or provide a service you have requested;
• where the information is needed to detect or address security or technical issues; and
• to protect the legitimate rights and interests of the Company or others.
You may at any time cease using the Service and delete your account to stop our collection and use of your personal information. You may take such action yourself via “Settings” > “Account Management” > “Delete Account” within the Application. For further assistance, please submit a written request to us.
You may save certain records of conversations between yourself and the AI by way of screenshots. We do not currently provide a full personal-information export function; if you need to export other data, please submit a written request to us.
Where our processing of your personal information is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal. To withdraw consent, please submit a written request to us.
To enable you to make an informed decision, we will, so far as reasonably practicable, inform you of the consequences that withdrawal may have on your use of the Application or the products or services we provide to you (for example, withdrawal of consent in respect of particular processing may result in certain functions no longer being available to you).
Save where it is indicated that a right may be exercised by self-service, you may submit a request by email to [amouree.services@gmail.com].
We will respond within 20 working days or 30 calendar days from receipt of the request (whichever is shorter, save where extension is permitted by law).
In order to protect the security of your information, we will verify your identity (or, where applicable, the authority of an authorised representative) before handling a request, and may require you to provide identity-verification documents.
In principle, we will not charge a fee for a reasonable rights request. We may refuse a request that is manifestly unfounded or repetitive, technically impracticable (e.g., requiring the development of new systems or fundamental changes to existing practices), poses a risk to the legitimate rights and interests of others, or is otherwise unreasonable.
In the following circumstances, we may be unable to respond to your request:
• where it relates to our performance of obligations imposed by laws and regulations;
• where it is directly related to national security or national defence;
• where it is directly related to public safety, public health or significant public interest;
• where it is directly related to criminal investigation, prosecution, adjudication or enforcement of judgments;
• where there is sufficient evidence that you are acting in bad faith or abusing your rights;
• where it is for the purpose of safeguarding the life, property or other significant legitimate rights and interests of you or others, but it is difficult to obtain the consent of the person concerned;
• where responding to the request would seriously prejudice the legitimate rights and interests of you, others or any organisation; or
• where the request involves trade secrets.
If you believe that the way we process your personal information violates the rights granted to you under applicable laws, you have the right to file a complaint with the relevant regulatory authorities.
You may contact us in the following ways:
• the “Feedback” or “Customer Service” function within the Application;
• by email to the DPO, Luo Ming, at [amouree.services@gmail.com];
• by written letter to [Registered address: Suite 1802, Tower One, Lippo Centre, 89 Queensway, Hong Kong].
We will acknowledge receipt within [14] working days of receiving a complaint, carry out investigation and verification, and respond and make adjustments (where applicable) within a reasonable time.
The Company reserves the right to amend this Privacy Policy Policy at any time to reflect changes in the law or in the Service.
When we amend this Policy, we will publish the revised version within the Application. For material changes (such as changes to items of personal information collected, or to purposes of use, that affect user rights), we will notify you at least 30 days before the change takes effect, through in-app notification or other appropriate means.
After the amended Privacy Policy Policy takes effect, your continued use of the Service will be deemed to constitute your acceptance of the amended terms.