Privacy Policy

Effective Date: May 11, 2026 · Last Updated: July 16, 2026 · NEXBASE TECH PTE. LTD.

1. About This Policy

This Policy describes the way NEXBASE TECH PTE. LTD. (referred to below as “NEXBASE,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards information in connection with Whispy.AI. In this Policy, “Whispy” or the “App” includes both the device-based application and the web service.

We respect the privacy of everyone who uses Whispy and process information only as permitted by applicable law. The practices explained here support account security, reliable service delivery, and improvements to the user experience.

Adults Only

Whispy is available only to people who are at least 18 years old. We do not intend to offer the App to anyone under 18 and do not knowingly do so.

Every new user must complete the initial intake process, whether the App is accessed through a registered account or as a guest. Information supplied during that process must be truthful, accurate, complete, and kept current. You are responsible for the information you provide and for its accuracy. False, misleading, or incomplete submissions may lead us to suspend or end your access and may also expose you to legal liability.

2. Information Handled Through Whispy

The information we collect and process falls into the categories below.

Information Connected With Your Account

This category includes your email address, information associated with a Google or Apple account, age, and gender.

Device, Browser, and Technical Information

We may receive a device ID; IDFA or IDFV on iOS; device type and model; operating-system version; browser type; and other unique device identifiers.

Technical and activity information may also include network logs, browsing history, chat records, use of particular features, and network-diagnostic information.

Content You Provide

We process the text, images, and other files you submit to Whispy. Examples include materials used to create AI characters or enrich a chat. This category also covers what you say in conversations with AI characters.

Information Associated With Third-Party SDKs

Third-party software development kits used to operate the App may collect device IDs, usage patterns, and interaction information. These SDKs may support functions such as analytics, crash reporting, authentication, AI inference, and push notifications.

Purchases

Whispy offers paid features through individual in-app purchases. Purchases are processed using Apple In-App Purchase on iOS or Google Play Billing on Android.

We neither process nor retain payment-card details ourselves. Purchase providers may instead make transaction information and related metadata available to us. This can include a transaction identifier, purchase amount, product identifier, and, when the provider supplies them, the name and profile image linked to your account with that provider.

3. Microsoft Clarity

Microsoft Clarity is used to help us understand interaction with Whispy and to improve the App’s usability, features, performance, stability, design, and overall experience.

Clarity may automatically receive limited technical and usage information, including:

  • device and operating-system details;
  • the App version;
  • screen and interface information;
  • an approximate location inferred from an IP address;
  • taps, touches, gestures, navigation paths, and similar interactions; and
  • certain performance information.

Microsoft uses this information to produce behavioral analytics, heatmaps, usage measurements, and reconstructed session replays. A reconstructed replay is created from interface-rendering and interaction data; it is not a conventional screenshot or video recording of your device.

Where the relevant functionality is supported, sensitive material, personally identifiable information, and content typed into input fields are masked, sanitized, or excluded before transmission to Microsoft. We do not deliberately configure Clarity to capture account credentials, payment information, or text entered into private-chat input fields.

Information handled through Clarity may be sent to and processed by Microsoft under the Microsoft Privacy Statement and the Microsoft Clarity Terms of Use.

4. What We Do With Information

Information described in this Policy may be used for the following purposes:

  • Operating Whispy. We use information to create accounts and provide chat, AI-character, and space-personalization functionality.
  • Personalizing the experience. Information helps us tailor the user experience and suggested content.
  • Understanding and improving the App. We review feature use, interactions, navigation behavior, App performance, heatmaps, and reconstructed session replays. This helps us understand how Whispy is used, find technical and usability problems, and improve functionality, stability, design, and the overall experience.
  • Improving AI. Data generated when a user interacts with AI may be used to train and improve our AI algorithms. You can turn off the use of your conversations for AI training in the App settings. Doing so does not limit your ability to use the Services.
  • Protecting the App and meeting our obligations. We use information to maintain security and integrity, prevent fraud and abuse, and comply with legal requirements.

Legal Grounds for Users in the EEA and United Kingdom

For purposes of the General Data Protection Regulation, Whispy.AI, operated by NEXBASE TECH PTE. LTD., is the data controller for the personal data covered by this Policy. This means that we determine how that personal data is collected, used, and disclosed, subject to applicable law.

Where EEA or UK law applies, our processing rests on one or more of these grounds:

  • Performance of contractual commitments. Personal data may be used, shared, or disclosed when needed to perform our agreements with you and meet commitments under a contract.
  • Consent. When the law requires consent, and in certain other circumstances, consent provides the basis for our use, sharing, or disclosure of personal data.
  • Legitimate interests. We may process personal data to advance legitimate business interests that are not outweighed by the affected person’s interests or fundamental rights and freedoms. These interests include customer service, certain promotional activities, business analysis and improvement, security for the Services, fraud prevention, and management of legal matters.
  • Compliance with law. Some uses and disclosures are necessary for us to satisfy legal obligations.

In addition to the rights set out elsewhere in this Policy, you may complain to the relevant supervisory authority. We encourage you to contact us first so that we have an opportunity to address your concern.

5. When Information May Be Disclosed

We do not sell your personal information. Disclosure is limited to the circumstances described below:

  • Companies that support the App. Information may be shared with, or otherwise made available to, providers that help us run, analyze, protect, and improve Whispy. These can include providers of AI services, cloud hosting, authentication, analytics and behavioral analytics (including Microsoft Clarity), crash reporting, SDKs, and push notifications.
  • Legal requirements. Information may be disclosed to meet a legal obligation or respond to a lawful request.
  • Corporate transactions. Information may be disclosed in connection with a merger, acquisition, or sale of assets.

6. Security and Retention

We use robust safeguards designed to prevent unauthorized access to, alteration of, disclosure of, or destruction of your information. Absolute security cannot be guaranteed, however, because internet transmission and electronic storage methods are never completely secure. If a data breach affects your personal data, we will notify you and the appropriate supervisory authorities when applicable law requires us to do so.

Information is kept only for the period needed to deliver the Services you requested and to serve legitimate business purposes. You may request deletion at any time through the in-app account-deletion function or by submitting a formal request to our support team using the details at the end of this Policy.

7. Processing Across Borders

Information may be transferred to and processed in Singapore, the United States, or another country in which one of our service providers operates. Your use of Whispy constitutes consent to these transfers. When applicable law requires additional protection for an international transfer, we apply appropriate safeguards. These include Standard Contractual Clauses for transfers from the EEA or United Kingdom.

8. Your Privacy Rights and Choices

The rights available to you depend on where you live. Subject to applicable requirements and exceptions, they may include the ability to:

  • ask for access to your personal data or correction of inaccurate personal data;
  • ask us to delete your personal data;
  • object to particular processing or opt out of specified uses, including AI training and personalized suggestions; and
  • withdraw consent when consent is the basis for processing.

Additional Regional Disclosures

  • California. California residents may request information about the personal information we collect, exercise their privacy rights without discrimination, and opt out of the sale or sharing of personal information. We do not sell or share personal information as those terms are defined by the California Consumer Privacy Act.
  • Taiwan. Users in Taiwan may exercise rights granted by the Taiwan Personal Data Protection Act, including inquiry, review, copying, supplementation or correction, cessation of processing, and deletion.
  • Hong Kong. Users in Hong Kong may make Data Access Requests and Data Correction Requests under the Personal Data (Privacy) Ordinance (Cap. 486).
  • Singapore. Users in Singapore may exercise rights available under the Personal Data Protection Act 2012 and may submit complaints to the Personal Data Protection Commission.

9. Revisions to This Policy

We may revise this Policy periodically. Material revisions will be communicated by changing the revision date shown above and, when appropriate, through an in-app notice or email. If you continue using Whispy after a revision takes effect, that continued use signifies acceptance of the revised Policy.

10. Contact Us

Questions or concerns about this Policy may be sent to:

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