隐私政策

**LOVEAI Privacy Policy**

**1. Introduction**

We, LOVEAI Corporation ("LOVEAI", "we", "us", or "our"), collect information related to individuals ("Personal Data") in the course of providing our LOVEAI communication application ("LOVEAI App") and all related products, applications, services, and websites (collectively, "Services"). We consider the protection of Personal Data to be one of the most important management issues and responsibilities for an internet content service company. We will comply with applicable laws and regulations in the countries and regions where we conduct business (such laws and regulations hereinafter collectively referred to as "Applicable Laws"), and will strive to properly protect Personal Data based on this Privacy Policy (this "Policy").

This "Policy" explains what Personal Data we collect, how we use and share such Personal Data, and how you can manage your Personal Data.

Please read this Privacy Policy carefully before using the Services or submitting any Personal Information to LOVEAI. Use of the Services constitutes your consent to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you may be unable to access any of our applications or otherwise use the Services.

**2. Scope of this Policy**

This Policy applies to all Personal Data collected in the course of using our Services, regardless of the country or region where the Services are used.

**2.1. Target Services and Service Providers**

This Policy applies to all Personal Data collected in the course of using our Services.

We may apply separate privacy policies, terms of use, or supplements to this Policy to specific services (collectively, "Separate Policies"). Separate Policies clarify what Personal Data we will collect for these specific services, how we will use and share such Personal Data, and other policies applicable to these specific services. If the subject matter of any Separate Policy conflicts with this Policy in any way, the Separate Policy shall prevail.

For the purposes of this Policy, LOVEAI is the controller of Personal Data processing.

**2.2. Applicable Countries and Regions**

We will only process Personal Data within the scope described in this Policy and to the extent permitted by Applicable Law.

**3. Personal Data Collected**

We will collect the following Personal Data:

(a) Information you provide to us, such as your email address registered when creating an account, and profile information you set when using our Services.

(b) Information related to your usage status of our Services, such as text, audio, music, images, videos, and other content you post, as well as your access logs.

(c) Information collected from third parties if you create a LOVEAI account using an external social network service account, such as the external social network service account identifier we collect from that third party.

(d) Collected information, such as "Likes."

We will collect the following types of Personal Data in the course of providing our Services. If you do not provide certain types of information (such as an email address required to register for our Services), you may be unable to use all or part of our Services.

**3.1. Personal Data Provided by You**

**3.1.1. Information Required for Account Creation**

Before you start using our Services, we may ask you to provide contact information to create a LOVEAI account ("Account").

For example:

To create an Account, you need to register your email address.

Please note that we assign an internal identifier ("LOVEAI ID") to each account we create for our users.

**3.1.2. Information Necessary for Communication and Transactions**

Depending on the circumstances, we may ask you to provide information necessary to communicate and conduct transactions with you, and collect and store such information.

For example:

(a) To respond to requests or questions you send to customer support, we may ask you for information necessary to identify and investigate incidents or resolve problems, such as your contact information (including email address) and details of the issues you are experiencing.

(b) If you purchase products or services, you must provide information for payment of such products or services. Since credit card settlement is processed by the appropriate third-party payment institution, we will not retain your credit card number or security code.

**3.1.3. Profile and Friend Relationship Information**

When you use our Services, we will collect profile information you set, as well as information related to your friend relationships.

Profile Information

Profile information includes information you set or disclose to connect with other users, such as profile images, display names, and identifiers ("LOVEAI ID"). A LOVEAI ID is an identifier designed to make it easier for your friends to find you in our Services, and your friends can find you through your LOVEAI ID. You may also choose not to allow other users to contact you using your LOVEAI ID.

**3.2. Personal Data Collected in Connection with Your Use of Our Services**

**3.2.1. Service Usage Status**

We automatically collect information related to when and how you use the Services. The collected information includes usage status of various features, such as the date and time you activate features, additional services purchased, and content and advertisements you view or click.

Posts and Reactions to Posts

When distributing your posts to other users, the content you post is sent through our servers.

For example, both standard content you post (such as emojis) and non-standard content (such as text, audio, music, images, and videos) are sent through our servers. Additionally, external information such as content recipients, data format, posting date and time, and other information about how you interact with others is recorded on the servers.

Furthermore, when distributing reactions or replies to other users' posts, we collect and use information related to how you react to other users' posts. This information includes actions you take on other users' distributions and the date and time of such actions, such as clicking "Like" on a user's post.

With your additional consent, we may use some of this information for providing and maintaining the Services, developing and improving the Services, preventing unauthorized use, and providing optimized content (including advertisements).

**3.2.2. Location Information**

When we provide you with customized content or advertisements, such as weather forecasts and local news near your area, we may separately ask you to provide your approximate location information. In such cases, you may at any time choose not to provide your location information through your LOVEAI App settings.

Even if you do not accept the sending of location information, we may estimate your approximate location based on network information such as your IP address.

**3.2.3. Application, Browser, Device, and Network Information**

We will collect information related to the devices, browsers, and applications you use (advertising identifiers for identifying devices/browsers, Cookie IDs, device types, operating systems, language/time zone settings, browser types, application versions, etc.), as well as network information (telecommunications carrier names, IP addresses, etc.).

We may also associate collected advertising identifiers with internal identifiers.

**3.3. Personal Data Collected from Third Parties**

We may collect Personal Data from third parties, including our group companies.

For example, we will collect Personal Data from third parties in the following cases.

**3.3.1. Personal Data Collected from Group Companies**

We may collect your Personal Data from our group companies in accordance with their terms or policies. Please confirm the privacy policies applicable to individual services provided by our group companies in each individual service.

**3.3.2. Personal Data Collected from Business Partners**

We may collect your Personal Data from our business partners. There are cases where we collect Personal Data from business partners that operate their own services and from business partners that operate services linked to our Services. For example, when you create an Account using an external social network service account, we will collect that external social network service account identifier.

Additionally, to send official account messages and distribute advertisements from business partners, measure advertising effectiveness, create and provide statistical information, and for other purposes, we may obtain from business partners your identifiers (internal identifiers, advertising identifiers, etc.), one-way encrypted (hashed) email addresses and phone numbers, IP addresses, partial device information (operating systems, etc.), your attribute information, and your action history (including purchase and browsing history).

**3.4. Personal Data Uploaded by Other Users**

There may be cases where certain users upload information containing Personal Data (such as photos of third parties other than that user) when using our Services, and we collect such information.

**4. Purposes of Personal Data Use**

We will use Personal Data for the following purposes:

(a) Provision and maintenance of the Services;

(b) Development and improvement of the Services and content;

(d) Provision of optimized content to you.

We use Personal Data to provide our Services to users, for research and development to provide safer and better services, and to provide services (including advertisements) that are closely relevant to users. We will not process Personal Data we obtain beyond the scope of the purposes of use without your consent or unless permitted by Applicable Law. Additionally, we will take appropriate measures to ensure that Personal Data is not used for any other purpose. Specific uses of Personal Data are as follows.

**4.1. Provision and Maintenance of the Services**

We will use information necessary to provide the services you request, respond to your inquiries, and conduct promotional activities.

For example, we will use Personal Data for the provision and maintenance of the Services in the following cases:

(a) When you log in to the LOVEAI App or inherit your account when changing devices, to verify your identity by comparing it with your registered information;

(b) To process invoices when users purchase products or use paid services;

(d) To notify you of important changes to our Services, such as amendments to terms, planned service termination, or feature changes.

**4.2. Development and Improvement of Services and Content**

We will use Personal Data for the development and improvement of our Services to provide better services, products, and content to users in the future.

For example, we will use Personal Data for the development and improvement of services and content in the following cases:

(a) To improve our Services by creating statistics and models related to the use of our Services;

(b) To conduct surveys related to services we currently provide or may provide in the future.

**4.3. Security and Prevention of Unauthorized Use**

We will use Personal Data and promote security measures and measures to prevent unauthorized use to maintain an environment where our Services can be used at any time, allowing users to use our Services with peace of mind in their daily lives.

For example, we will use Personal Data for security and prevention of unauthorized use in the following cases:

(a) To confirm whether there are violations of the terms of use, illegal acts, unauthorized access, or any other unauthorized use;

(b) To monitor and confirm the details of reports and illegal postings, and to develop tools to prevent unauthorized use by analyzing the details of such reports and illegal postings; or

**4.4. Provision of Optimized Content to You**

We will use Personal Data to provide recommended content, including advertisements, to each user.

For example, we will use Personal Data to provide optimized content to users in the following cases:

(a) To measure the effectiveness of distributed advertisements; or

(b) To display advertisements related to business partner websites you visit;

(c) To distribute advertisements to you by associating or combining information we obtain from business partners (such as your identifiers (internal identifiers, advertising identifiers, etc.) and email addresses, partial device information (operating systems, etc.), and IP addresses) with your Personal Data we hold;

(d) To measure the effectiveness of distributed advertisements by using your identifiers (internal identifiers, advertising identifiers, etc.), partial device information (operating systems, etc.), and IP addresses obtained from business partners; or

(e) To provide prepared statistical information to our business partners by associating or combining information we obtain from business partners (such as your identifiers (internal identifiers, advertising identifiers, etc.), hashed phone numbers and email addresses, attribute information, and your action history (including purchase and browsing history)) with your Personal Data we hold (such as your identifiers (internal identifiers, advertising identifiers, etc.) and email addresses, attribute information, and your usage status of our Services (including your history of accessing advertisements)).

In principle, we will obtain your consent when processing your Personal Data. However, if permitted by Applicable Law, we may process your Personal Data based on any of the following legal grounds:

(a) Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract;

(b) Processing is necessary for compliance with a legal obligation to which we are subject (such as when following an information disclosure order issued by a government agency in accordance with laws and regulations);

(d) Processing is necessary for the investigation, prevention, and taking measures against illegal or suspected illegal acts;

(e) Processing is necessary for the pursuit of legitimate interests by us or a third party, unless such interests are overridden by your rights, interests, and freedoms related to privacy (including operations or system improvements we conduct, fraud prevention, security maintenance, marketing, and research); or

(f) Processing is necessary for any purpose related to the public interest or the creation of historical archives, or any purpose related to investigation or statistics supported by appropriate security measures.

For example, when we process your Personal Data for the provision and maintenance of the Services, development and improvement of the Services, and security and prevention of unauthorized use, such processing may be based on the legitimate interests legal ground described in (e) above.

**5. Provision of Personal Data**

We will not provide, disclose, or share Personal Data to third parties without your consent or unless permitted by Applicable Law.

When we obtain your consent or when permitted by Applicable Law for such transfer of Personal Data, we may transfer Personal Data to third countries that do not have any data protection laws equivalent to those of the country or region where you reside.

In principle, we will not provide Personal Data to third parties without your consent or unless permitted by Applicable Law for such provision of Personal Data.

However, we may provide Personal Data to third parties in the following cases.

Recipients of Personal Data we provide include third parties located outside the country or region where you reside, such as our subcontractors, subsidiaries, and affiliates.

When providing Personal Data, we may transfer Personal Data to third countries that do not have any data protection laws equivalent to those of the country or region where you reside. In such cases, we will use standard contractual clauses regarding data protection approved in your country or region or other means, and transfer Personal Data to third countries in accordance with the requirements of Applicable Law.

**5.1. User's Own Public Disclosure**

Your registered profile information will be treated as public information.

Messages you post on public message boards, and actions such as "Likes" on other users' posts will be provided to third parties.

The aforementioned information may be copied, stored, or disseminated by recipients due to the nature of digital data, and may be accessed by unintended third-party recipients.

**5.2. Vendors and Service Providers**

To help us meet business operation needs and perform certain services and functions, we may share Personal Information with vendors and service providers, including hosting services, cloud services, and other IT service providers, email communication software and email communication services, and web analytics service providers. In accordance with our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.

**5.3. Sharing Personal Data Among Group Companies**

We may share the Personal Data shown in "3. Personal Data Collected" among our Group Companies. For example, to reduce the hassle of creating accounts in services provided by our Group Companies, our Group Companies may refer to information registered in the LOVEAI App.

Since the purposes of sharing Personal Data are the same as the purposes of use described in "4. Purposes of Personal Data Use," for the purposes of use by recipients of shared Personal Data, "LOVEAI" shall be replaced with "our Group Companies," and "Services" shall be replaced with "services provided by our Group Companies."

**5.4. Business Succession**

If there is any inter-company transaction involving our business to which this Policy applies, such as an acquisition, merger, or business entity change, Personal Data may also be transferred to the successor of the business to the extent permitted by Applicable Law.

**5.5. Service Provision and Advertising Distribution Through Cooperation with Other Companies**

When you use the services of our business partners, we may provide them with information used to identify you.

The processing of Personal Data by business partners shall be governed by the terms or policies stipulated by each business partner.

**5.6. Compliance with and Cooperation with Public Agencies**

If we receive a request in accordance with legal procedures (such as a warrant), or if there is imminent danger to someone's life or property (such as suicide threats or bomb threats), we may disclose Personal Data to third parties (including law enforcement agencies such as police or courts) in accordance with Applicable Law.

**6. Chat Privacy and Security**

**6.1. AI Messages**

LOVEAI prioritizes your data privacy and security. As a user, you have full ownership of your inputs and outputs in accordance with relevant regulations. Your data is for your use only and will not be shared or used for model training. LOVEAI never stores your conversation logs with AI. Your data is stored locally on your device until you decide to delete it. Furthermore, LOVEAI has robust security measures to protect your data. All data is encrypted using AES-256 both at rest and in transit, with TLS 1.2+ for the transport layer. We adhere to strict access controls to ensure that only authorized parties can access your information.

**6.2. User Messages**

When chatting with another user, we use end-to-end encryption to protect your conversations. This security measure ensures that only you and the intended recipient can access and understand the content, with no access by intermediaries including LOVEAI. Your messages are protected by a digital lock, and only you and the recipient have the unique keys necessary to unlock and read them. The entire process is seamless and requires no manual activation of special settings to enhance the security of your messages.

**7. Security Control of Personal Data**

We will take strict technical and organizational security measures when managing collected Personal Data. To continuously improve our protection of Personal Data, we will review and strengthen our internal rules and regulations in accordance with changes in laws and social norms.

Unless you request account deletion, we will in principle retain most of your information. Once we receive your request to delete your account, we will delete your information after retaining it for a specified period, in accordance with Applicable Law and internal rules.

**7.1. Security Measures**

We take strict technical and organizational security measures when managing collected Personal Data to respect and protect your privacy and the confidentiality of your Personal Data, and to prevent unauthorized access to your Personal Data. These measures include industry-standard-based security controls to prevent unauthorized access to Personal Data, as well as disclosure, unauthorized use, alteration, or destruction of Personal Data.

For example, we are taking the following measures:

(a) Providing message encryption functionality.

(b) Strict access control based on the principle of minimum knowledge.

(d) External certification for objective evaluation of our security measures.

(e) Research and development of new security technologies.

Furthermore, we will never provide any means for fraudulent access to Personal Data to any third party.

However, since no electronic transmission method or data storage method is perfect or invincible, we cannot guarantee that your Personal Data is absolutely secure from intrusion during transmission or while stored in our systems.

To help protect your privacy and the confidentiality of your Personal Data, we also need your help. Please do not share your password with others or use the same password you use for other services.

**7.2. Storage Location of Personal Data**

In providing our Services, we may store your Personal Data outside the country or region where you reside. When this occurs, we will take measures to ensure that your Personal Data is transferred in accordance with Applicable Law.

**7.3. Storage Period of Personal Data**

LOVEAI collects and retains Personal Data at your request to provide our Services, fulfill any applicable purposes described in this Policy, or comply with Applicable Law.

Unless you request account deletion, we will in principle retain most of your Personal Data. Once your account is deleted, we will properly handle your Personal Data in accordance with Applicable Law and our internal rules after retaining such Personal Data for a specified period for the following purposes:

(a) Responding to inquiries;

(b) Resolving disputes or collecting fees;

(d) Complying with Applicable Law.

Otherwise, we stipulate the storage period of Personal Data based on the following criteria.

(a) Unless we obtain your consent or Applicable Law permits such use, we will not use highly private information between users (such as text, audio, music, image, and video data) for any purpose other than message distribution (including retransmission in case of communication failures or multi-device message synchronization) in any way. While we will retain the aforementioned information for a minimum period, such information will subsequently be automatically deleted from our servers.

(b) If you explicitly state your intention to store Personal Data, we may respect your intention and store your Personal Data for a long period.

After the storage period stipulated by Applicable Law and our internal rules expires, we may continue to retain Personal Data in a form that does not allow identification of individuals.

**8. Choices Regarding Personal Data**

You have rights regarding your Personal Data that we process, such as the right to access your Personal Data and the right to correct your Personal Data, to the extent permitted by Applicable Law.

We are endeavoring to provide features in our Services that allow you to edit your profile yourself and set and manage the collection, use, and sharing of your Personal Data.

To the extent permitted by Applicable Law, you have the right to access, rectify, delete, restrict processing, withdraw consent, data portability, confirm whether we process any of your Personal Data, and request review of any automated decisions that may be made as a result of processing.

Furthermore, to the extent permitted by Applicable Law, you also have the right to object to the processing of your Personal Data in certain cases where we process it.

We are endeavoring to provide features in our Services that allow you to manage your Personal Data yourself on the LOVEAI App, edit your profile, set the collection, use, and sharing of Personal Data, and set and manage your Personal Data, including post visibility, advertising opt-out, and account deletion. Please periodically confirm that no old or inaccurate information remains and properly update your Personal Data.

Specifically, we provide the following functions:

(a) Confirming and changing public profile information.

(b) Setting and changing email addresses, deleting email addresses.

(d) Whether to allow third parties to view your Personal Data retained by your friends.

If you no longer wish to use our Services, or if you withdraw your consent for LOVEAI to process your Personal Data (which is necessary for us to provide the Services), you may choose to delete your entire account. However, withdrawing your consent will in no way affect the lawfulness of our processing of your Personal Data based on your consent before you withdraw it.

**9. Use of Third-Party Modules and Cookies**

We may use tags and modules, including Cookies and third-party SDKs, for the purposes described in this Policy.

**9.1. Third-Party Modules**

We may install modules of third-party software development kits in our Services for the following purposes:

(a) Analyzing the usage status of our Services; and

(b) Distributing advertisements on our behalf and measuring their effectiveness.

The third party's privacy policy applies to your Personal Data processed by that third party through modules provided by that third party.

**9.2. Cookies and Other Analytics Tools**

Cookies are small text files stored on your computer when you visit a website. This text file stores information that can later be read by the website operator when you visit the website again.

We may use Cookies and similar web tracking technologies (web beacons, pixels, etc.) for the following purposes:

(a) Storing your login status, verifying visitors, maintaining sessions, and taking security measures;

(b) Storing language settings and recently visited date and time, and improving user-friendliness;

(d) Distributing advertisements that are of greater interest to you; and

(e) Measuring advertising effectiveness.

You can control whether to accept Cookies through your browser settings or by using other tools. However, if you disable Cookies or restrict the ability to set Cookies, you may not be able to take full advantage of the website or access all its functions, which may limit your overall user experience.

**9.3. Information About Use of Google Analytics**

To improve our Services, we use Google Analytics to measure our Services, such as our website. At that time, Google may set Cookies or read existing Cookies to collect data. Information such as the URL of the pages you visit and your IP address will be automatically sent to Google at that time. We may use such information to understand the usage status of our Services or use such information in our Services. Please read the Google Analytics Terms of Service and Google's Privacy Policy regarding how Google processes data in Google Analytics.

**9.4. Information About Use of Apple True Depth API**

LOVEAI may use Apple's TrueDepth camera to collect additional information from your device's camera to improve the camera and video call quality we provide, or to improve features such as special effects. However, this information is only processed in real time for the delivery and improvement of these features. This information is not saved on our servers or shared with any third party.

**10. Other Important Information**

We may amend this Policy. The latest version of the Policy will always be posted on this website, and we encourage you to carefully read the contents of the latest version of the Policy.

When we make any material changes to this Policy, we will notify you by reasonable means.

Except as mentioned herein, we will be the data controller for Personal Data collected through our Services to which this Policy applies.

If you do not agree to any changes and no longer wish to use our Services, you may choose to close your account. Continued use of our Services after the change notification has been communicated to you or posted on our Services constitutes your acceptance of the change and agreement to the modified version of this Policy. We will seek your consent when required by Applicable Law.