Privacy Policy

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Email addresses
• Contact preferences
• Portraits, voices, text, pictures, audio materials uploaded for intelligent agent creation
• Actively input text, pictures, audio or voice information, and content instructions for interactive services
• Behavioral information when using the model
• Feedback information

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Conversation data
• Voice biometric data (voiceprints used for voice synthesis)

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Google Pay and Apple Pay. You may find their privacy notice link(s) here: Google Payments Privacy Notice and Apple Pay Privacy Policy.

Social Media Login Data. We may provide you with the option to register with us using your existing Google or Apple account details. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's microphone, photo album, camera, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, for the provision of AI interactive services and generative AI model development, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate — including personal information of a deceased individual provided by their next of kin, who warrants that they are authorized to submit such data and that the data is accurate. You must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your device characteristics, crash logs, and performance metrics — is collected automatically when you use our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics, diagnostics, and reporting purposes.

The information we collect includes:

• Device Information. We collect device model, manufacturer, operating system version, app version and build number, language and locale settings, and device identifiers such as Android ID or iOS identifier for vendor where applicable.
• Crash and Diagnostic Data. Through Firebase Crashlytics (provided by Google), we collect crash logs, stack traces, and related technical diagnostics to identify and fix app stability issues.
• Performance and Monitoring Data. Through Alibaba Cloud Real User Monitoring (RUM), we collect app performance metrics, error events, custom logs, and service quality data, including technical metrics, exception diagnostics, and limited device or runtime environment information needed for monitoring and fault analysis.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To provide AI interactive services and generate intelligent agents. Process uploaded portraits, voices, text, pictures, audio and actively input information to realize dialogue and other interactive functions. AI-generated text and voice responses are produced by our overseas AI service providers on our behalf.
• To provide personalized voice synthesis services. Process voice samples you provide to create personalized voice models through our third-party voice technology provider deployed overseas, and generate synthesized voice responses in AI chat conversations.
• To optimize generative AI models. Analyze user interaction data (with separate consent) and behavior information to adjust and improve model performance; no model training with your interaction data without your explicit consent.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To create and generate virtual character profiles. We may process uploaded conversation, audio materials to generate virtual character profiles. During the development and testing stage, we may temporarily retain original source materials for model iteration. Once the service reaches stable production status, original source files will no longer be retained.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

We process your personal information only to the extent permitted by and in compliance with applicable privacy laws, which impose limits on the collection, use, sharing and cross-border transfer of personal information — especially voice biometric data. The specific legal bases we rely on are set forth below, and all processing activities are subject to the requirements of the applicable laws.

3.1 Express Written Consent (Primary Basis for Sensitive Data)

Our primary legal basis for collecting, using, sharing and transferring voice biometric data, portrait information, audio recordings, and other sensitive personal information is your unambiguous, express written consent — including valid electronic consent as required by the applicable laws. For deceased individuals, this consent must be provided by their authorized next of kin, who must also provide proof of their relationship to the deceased and proof of the deceased's identity (double verification); user interaction data for model training requires an additional separate pop-up consent, which you may withdraw via "Me → Security & Login" in the App.

Your consent is voluntary, revocable at any time, and cannot be tied to the provision of basic Services (we will not deny you access to our core Services if you decline to provide consent for non-essential processing).

Consent is obtained only after full, clear disclosure of the purpose of processing, data retention periods, cross-border transfer details, and third-party sharing with our overseas voice model provider — no hidden or blanket consent is used.

Revocation of your consent will result in the immediate suspension of processing of your sensitive data and permanent deletion of all voice biometric data, with no discrimination against you for exercising this right.

3.2 Performance of a Contract

We process non-sensitive personal information (e.g., your name, email address, account details) to fulfill our contractual obligations to you in providing the Echo Elephant Services — including account creation, service delivery, troubleshooting, and responding to your service requests. This processing is limited to the information necessary to perform the contract.

3.3 Compliance with Legal Obligations

We process your personal information when we are required to do so under applicable law — including:

• Responding to valid requests from law enforcement or regulatory bodies;
• Complying with record-keeping and data retention requirements under applicable privacy and consumer protection laws;
• Fulfilling data breach notification obligations;
• Complying with children's online privacy protection requirements (excluding all users who are under the age of 18, or the legal age of majority in their jurisdiction of residence, from our Services).

All legal processing is conducted in accordance with applicable law, including limiting data disclosure to the minimum necessary for the legal request.

3.4 Protection of the Security of Our Services and Users

We process personal information to protect the security of our Services, prevent fraud, and safeguard our users — a permissible basis under applicable law. This processing is limited to fraud monitoring, security testing, and responding to unauthorized access attempts, and does not include the processing of biometric data for this purpose without your explicit consent.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We do not sell your personal information to third parties for commercial or marketing purposes.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• AI Chat Service Providers. We share your chat messages, prompts, and conversation context with our designated overseas AI service providers for the sole purpose of generating AI-powered text responses within the Services.
• Voice Synthesis Service Providers. We share your uploaded voice materials and interaction data (with your explicit consent) with our designated overseas voice model service provider for the sole purpose of voice synthesis, and AI model inference. For deceased individuals' data, such sharing requires the next of kin's express written consent. All cross-border sharing is protected by encryption and governed by a written Data Processing Agreement (DPA).
• Crash Reporting (Firebase Crashlytics). We share crash logs, stack traces, and diagnostic data with Google's Firebase Crashlytics service for the sole purpose of identifying and resolving app stability issues.
• Performance Monitoring (Alibaba Cloud RUM). We share performance metrics, error events, and limited device information with Alibaba Cloud Real User Monitoring for the sole purpose of monitoring service quality and diagnosing errors.
• Payment Processors. Payments are processed through Apple App Store and Google Play. We do not directly store your full payment card details.

Cross-Border Data Transfer

Our servers and services — including AI chat services and voice synthesis services — are deployed overseas. We may transfer your personal information, including voice biometric data, to our overseas service providers for the purpose of AI model inference, voice synthesis, and service delivery.

Transfer of a deceased individual's voice biometric data is permitted only with the express written consent of the authorized next of kin, who is fully informed of the cross-border transfer destination and purpose.

We have entered into Data Processing Agreements (DPAs) with our service providers that comply with applicable laws. All cross-border data transfers are conducted with encryption, and we obtain your express consent prior to any such cross-border data processing where required by law.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party account details (Google Sign-In or Sign in with Apple). Where you choose to do this, we will receive certain profile information about you from the provider. The profile information we receive may vary depending on the provider concerned, but will often include your name, email address, and profile picture, as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

Voice samples and voice models used for voice synthesis are retained for as long as you maintain the related feature or account. You may request deletion of your voice samples and voice models at any time by contacting us or through the app settings where available.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

In the event of a personal data breach involving your sensitive information, we will notify the applicable regulatory authorities and affected users within 72 hours of discovery, in compliance with applicable laws.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Depending on where you are located, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) to withdraw your express consent at any time; and (v) for California residents, to opt out of the sharing of your personal information. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Review/correct your account information (name, email, contact preferences) by clicking the avatar/account section in the Echo Elephant App.
• Delete your account by navigating to Me → Security & Login → Delete Account in the Echo Elephant App, and following the on-screen instructions. For full details, see our Account Deletion page.
• Request deletion of your voice samples, voice models, or chat history by contacting us.
• Contact us using the contact information provided.

Upon your request to delete your account, we will delete your account profile information, account identifiers, and other personal data associated with your account from our active databases. However, we may retain limited information where required or permitted by law, including for security and fraud prevention, subscription/payment/tax/accounting records, dispute resolution and legal compliance, and enforcement of our terms. Any retained information will be kept only as long as reasonably necessary for such purposes.

If you have questions or comments about your privacy rights, you may email us at echoelephant@huishengyunxiang.com.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

1. every individual who is in the State of California for other than a temporary or transitory purpose and
2. every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation of the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.

Echo Elephant has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Echo Elephant will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• Whether we collect and use your personal information;
• The categories of personal information that we collect;
• The purposes for which the collected personal information is used;
• Whether we sell your personal information to third parties;
• The categories of personal information that we sold or disclosed for a business purpose;
• The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification Process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other Privacy Rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at echoelephant@huishengyunxiang.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at:

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us by email at echoelephant@huishengyunxiang.com.