Privacy Policy

Latest version release date: March 11, 2025

Latest version effective date: March 11, 2025​

The operator of the "ViiTor AI" app is VIITOR AI PTE. LTD. (Registered address is 346C King George's Avenue, King George's Building, Singapore 208577, hereinafter referred to as "we") . We are well aware of the importance of personal information to you, and will do our best to protect your personal information safely and reliably. We are committed to maintaining your trust in us and abiding by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimum necessity, the principle of ensuring security, the principle of subject participation, and the principle of openness and transparency. At the same time, we promise that we will take corresponding security protection measures to protect your personal information according to the common security solutions in the industry. In view of this, we have formulated this "Privacy Policy" (hereinafter referred to as "this Policy/this Privacy Policy") and remind you: This policy applies to the ViiTor AI application (including our website) and related services.

Before using the "ViiTor AI" app and related services, please be sure to read and understand this policy carefully, and use related products or services after confirming that you fully understand and agree to this policy. Once you use the "ViiTor AI" app and related services, it means that you have fully understood and agreed to this policy. If you have any questions, opinions or suggestions about the content of this policy, you can contact us through the contact information provided by "ViiTor AI".

This Privacy Policy does not apply to the collection and processing of information by third parties in products or services (including any third-party websites) provided in our products and services. Such third-party products and services may include other products or services linked to our products and services. If you use such third-party products and services (including any personal information you provide to such third parties), you will be subject to the terms of service and privacy policy of such third parties (not this Privacy Policy). Please read the relevant terms of the third party carefully for specific provisions.

This Privacy Policy will help you understand the following:

I. Personal information we collect from you

II. How we use your personal information

III. How do we share and disclose your personal information

IV. How do we protect your personal information

V. How do you manage your personal information

VI. How do we handle personal information of minors

VII. Where and how we store your personal information

VIII. How to update this privacy policy

IX. How to contact us

1. Personal information we collect from you

We will collect your personal information from you to provide you with our products and services and to improve the quality of our products and services. The personal information we collect from you includes two categories: personal information you provide to us and personal information collected automatically.

•             Personal information you provide to us

The personal information you provide to us includes all your personal information that you actively provide to us when using our products and services, as well as any content that you provide to us that contains your personal information, including:

1. Personal information: including name, gender, age, address, communication contact information, email address, etc.
2. Content containing personal information: including text, images, photos, sounds, videos, communication records, service records, service feedback, etc.

In addition, third parties that provide products or services in our products and services may also collect your personal information. Please read the third party’s terms of service and privacy policy and their updated versions carefully for specific provisions.

•             Personal Information Collected Automatically

Automatically collected personal information includes your personal information that is automatically transmitted and sent to us through your device when you use our products and services, including:

1. Device information: including hardware model, operating system version, operating system API version, International Mobile Equipment Identity (IMEI), unique device identifier, CPU architecture type, memory usage, network access method, and the currently running application's process name and process ID (PID).
2. Business data: including audio collected by microphone, etc.
3. Movement trajectory data: including positioning, etc.
4. Network log data: including the network address and network port you use, etc.

In addition, third parties that provide products and services in our products and services may also automatically collect your personal information through SDK. Such personal information may include the following information. Please read the third party's terms of service and privacy policy and their updated versions carefully for specific provisions:

1.          SDK name: U-Share SDK

Purpose: To support users to share APP content on mainstream applications

Operator: Umeng Tongxin (Beijing) Technology Co., Ltd.

Types of personal information collected: device information (IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM card IMSI/ICCID), location information, network information

Privacy Policy Link: https://www.umeng.com/page/policy

2. How we use your personal information

•             We will use your personal information to implement the business functions of our products and services and to enable you to access and use our products and services, including:

1. To provide you with our products and services, including:

1.         Apply for your Bluetooth permissions: If you use a Bluetooth device, we need to obtain authorization to access your Bluetooth device and use your personal information;
2.         Apply for your location permission: If you use a Bluetooth device, we need to obtain authorization to access your location and use your personal information simultaneously;
3.         Apply for your network-related permissions: If you use our products and services, we need to obtain your authorization for network access, network connection viewing permissions, WLAN connection viewing permissions, and use your personal information;
4.         Apply for your recording permission: If you use our products and services, we need to obtain your authorization for recording permission and use your personal information.
5.         Apply for your storage permission: If you use functions related to uploading or downloading, we need to access your local files, or save files such as audio, video, and subtitles.

2. Used to train models related to our products and services.
3. Other situations where it is necessary to use your personal information to achieve the various business functions of products and services and to enable you to access and use our products and services.

If you refuse to grant us the authorization necessary to provide our products and services or refuse our collection and use of your personal information, you may not be able to use all or part of our products and services.

•             We may combine the personal information you provide with personal information collected automatically and general information we receive from other trusted sources to provide you with a better experience of our products and services.
•             We will use your personal information for the purpose of improving our products and services, including:

1. For analysis, market research, technology evaluation and business development, including to operate and improve our products and services;

•             We will use your personal information when contacting you or helping you solve problems, or recording the solutions and results of your related issues.
•             Exceptions to obtaining authorization

In accordance with relevant laws and regulations, we will use your personal information without your authorization in the following circumstances:

1. Related to national security and national defense security;
2. Related to public safety, public health, and major public interests;
3. Related to criminal investigation, prosecution, trial and execution of judgment;
4. For the purpose of protecting your or other individuals’ important legal rights such as life and property, but it is difficult to obtain your consent;
5. personal information collected is disclosed to the public by you yourself;
6. your personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;
7. Necessary for entering into a contract at your request;
8. Other circumstances prescribed by laws and regulations.

If we cease operating the "ViiTor AI" APP and related services, we will immediately stop collecting your personal information, notify you of the cessation of operations by individual delivery or announcement, and delete or anonymize your personal information in accordance with relevant laws and regulations.

III. How do we share and disclose your personal information

•             Sharing

We will not share your personal information.

•             Disclosure

We do not disclose your personal information to any third party, except in the following circumstances:

1. You voluntarily choose to disclose or authorize us to disclose to a third party, we will disclose the personal information you agree or choose to disclose to the third party you designate.
2. We disclose your personal information in accordance with relevant laws and regulations based on the following circumstances:

1.         Related to national security and national defense security;
2.         Related to public safety, public health, and major public interests;
3.          Related to criminal investigation, prosecution, trial and execution of judgment;
4.         For the purpose of protecting your or other individuals’ important legal rights such as life and property, but it is difficult to obtain your consent;
5.         Other circumstances stipulated by laws and regulations or required by judicial authorities.

According to the provisions of the "Cybersecurity Law of the People's Republic of China" and other relevant laws and regulations, sharing and disclosing de-identified personal information, and ensuring that the data recipient cannot restore and re-identify the subject of the personal information, does not constitute external sharing and disclosure of personal information, and the storage and processing of such data will no longer be notified to you separately and your consent will be obtained.

IV. How do we protect your personal information

•             We strive to provide security for your personal information to prevent illegal use, unauthorized access and disclosure, leakage, damage and loss of your personal information. We will use various security protection measures within a reasonable security level to ensure the security of information. Such security protection measures include but are not limited to encryption technology (for example, SSL), anonymization, information authorization management, etc.
•             Although we will do our best to protect the security of the personal information you provide to us, we also remind you that no security measures are 100% secure, and no security measures can guarantee the absolute security of personal information. You are responsible for choosing any passwords and their overall security strength to ensure the security of your information within the scope of our products and services. For example, ensure that any passwords related to accessing your personal information and accounts are secure and confidential.

V. How do you manage your personal information

You can access and manage your personal information in the following ways:

•             Change the scope of your authorization

Each business function requires basic personal information to be completed. In addition, for the collection and use of additional personal information, you can set to give or withdraw your personal information use authorization consent or contact us by email to give or withdraw your personal information use authorization consent. After you withdraw your authorization consent, we will no longer collect your personal information. However, your decision to withdraw authorization consent will not affect the collection, use and processing of personal information previously carried out based on your authorization.

•             Respond to your requests

When you make a request to us, you may need to provide a written request and prove your identity for security reasons. We may ask you to verify your identity before processing your request.

We will make a first-round reply within 15 days. If you are not satisfied, you can file a complaint via email.

In principle, we do not charge any fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the circumstances. We may reject requests that are unreasonably repeated, require too many technical means (for example, require the development of new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are impractical.

In the following circumstances, we will not be able to agree to your request in accordance with laws and regulations:

1. Related to national security and national defense security;
2. Related to public safety, public health, and major public interests;
3. Related to criminal investigation, prosecution, trial and execution of judgment;
4. There is sufficient evidence to show that the subject of personal information has subjective malice or abuses his rights;
5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
6. Involving trade secrets;
7. Other situations where we are unable to respond to your request in accordance with laws and regulations.

VI. How do we handle personal information of minors

If you are a minor under the age of 14, you should read and agree to this Privacy Policy under the supervision and guidance of your guardian before using our products and services .

We will not actively collect personal information from minors.

If we discover that we have collected personal information of minors without prior consent in accordance with the law, we will try to delete the relevant information as soon as possible. If you are the guardian of a minor, if you have questions about the personal information of the minor you are protecting, or if you request to correct or delete the personal information of the minor, please contact us through the contact information provided in this Privacy Policy.

If you are the guardian of a minor, upon your submission of a guardianship application to us, we will collect personal information of both you and the minor under your guardianship (including name, ID number, address, proof of guardianship, etc.) to verify the guardianship relationship between you and the minor, as well as the minor's usage behavior. If a third party objects to your application, you agree and authorize us to provide your and the minor's personal information to the third party or the authority.

VII. Where and how we store your personal information

Your personal information collected by us in accordance with this policy is stored in China.

Your personal information collected by us in accordance with this policy is stored in an encrypted manner.

Your personal information collected by us in accordance with this policy will be kept for no less than 1 month after you first provide it to us or your personal information is first automatically collected, and no longer than 12 months. You have the right to delete your personal information. Your personal information stored by us will be deleted immediately after you delete it or anonymized in accordance with the relevant laws and regulations, except where the retention period needs to be extended in accordance with the requirements of relevant laws and regulations or judicial authorities. During the extended retention period, we will securely store your personal information in an encrypted form and isolate it until it can be deleted or anonymized in accordance with the requirements of relevant laws and regulations or judicial authorities.

VIII. How this Privacy Policy is updated

Our Privacy Policy may be updated.

Without your explicit consent, we will not restrict your rights under this Privacy Policy. For significant changes, we will provide prominent notice (including notifications through the ViiTor AI platform and pop-up alerts to you).

Significant changes referred to in this policy include but are not limited to:

1. Our service model has undergone significant changes, such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;
2. We have major changes in control, etc., such as changes in ownership caused by mergers and acquisitions, reorganizations, etc.;
3. The primary recipients of personal information sharing, transfer, or public disclosure have changed;
4. There are significant changes in your rights to participate in the processing of personal information and how you exercise them;
5. There are changes to our responsible department for handling personal information security, contact information, and complaint channels;
6. The personal information security impact assessment report indicates a high risk.

IX. How to contact us

We have set up a dedicated department for personal information protection, which will protect your and end users' personal information in accordance with this policy. If you and end users have complaints or reports regarding information security, or have any questions, comments or suggestions regarding this policy, privacy measures, or the collection, use, storage, sharing, transfer, disclosure and processing of your personal information, please contact our personal information protection staff by sending an email to [email protected].

Generally, we will respond within fifteen working days after receiving relevant questions, comments or suggestions and verifying your identity.

If you continue to use our products and services , please read and agree to the Privacy Policy.

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