Privacy Policy

NEXBASE TECH PTE. LTD. ("Company," "we," or "us") respects your privacy. This Privacy Policy explains how we collect, use, and protect your information when you use Whispy.AI ("App", both on-device and web-based service).

1. Age Restriction

You must be at least eighteen (18) years of age to access or use the App. The App is not intended for, and we do not knowingly provide any services to, individuals under the age of eighteen. All new users, whether creating a registered account or accessing the App as a guest, are required to complete our initial intake process. You agree to fully and truthfully cooperate with this process and to provide accurate, complete, and current information at all times. You are solely responsible for all information you submit to us and for ensuring its accuracy. Providing false, misleading, or incomplete information may result in suspension or termination of your access to the App and may subject you to legal liability.

2. Information We Collect

To ensure the security of your account, provide consistent services, and optimize the user experience, we will collect and process the following information when you use our services, only to the extent permitted by applicable laws.

2.1 Account and Personal Information

Collected Data: Email address, Google/Apple account information, age, gender.

2.2 Device and Permission Data

Collected Data: Device ID, IDFA/IDFV (iOS only), device model, operating system version, browser type.

2.3 Automatically Collected Information

Device Information: Device type, unique device identifiers.

Usage Data: Network logs, browsing history, chat records, feature usage, network diagnostics.

2.4 User-Generated Content

Collected Data: Text, images, or other files you upload (e.g., for creating AI characters or enhancing chats), and the content of your conversations with AI characters.

2.5 Third-Party SDK Information

Collected Data: Device ID, usage patterns, and interaction data that may be collected by third-party SDKs (e.g., analytics, crash reporting, authentication, AI inference, and push notification services).

2.6 Payment-Related Data

We offer value-added Services through single in-app purchases, processed by:

• Apple In-App Purchase (iOS)
• Google Play Billing (Android)

We do not directly process or store your payment card details. As a result of your payment, we may collect transaction records and related metadata from these payment providers (including transaction identifier, purchase amount, product identifier, and, where provided, your account name and profile picture associated with the payment provider).

3. How We Use Your Information

• a. To Provide the App: Facilitate account creation, chat functionality, and AI character/space personalization.
• b. Personalization: Customize user experience and suggested content.
• c. Improvement and Analytics: Analyze usage patterns to improve the App.
• d. AI Training: Data of user interacting with AI may be used to train and improve our AI algorithms. You may opt out of having your conversations used for AI training through in-app settings; opting out does not affect your ability to use the Services.
• e. Safety and Compliance: Ensure the security and integrity of the App, prevent fraud and abuse, and comply with legal obligations.

4. Information Sharing

We do not sell your personal information. We share information only as follows:

• a. With Service Providers: For app functionality and support (e.g., AI engines, analytics providers, SDK providers, cloud hosting).
• b. For Legal Compliance: To comply with legal obligations or respond to lawful requests.
• c. In Business Transactions: In case of mergers, acquisitions, or asset sales.

5. Data Security

We implement robust measures to protect your data from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach affecting your personal data, we will notify you and the relevant supervisory authorities as required by applicable law.

6. Your Rights

Depending on your location, you may have the following rights:

• Access and Correction: Request access to or correction of your personal data.
• Data Deletion: Request deletion of your personal data.
• Objection to Processing: Opt-out of certain data uses, including AI training and personalized suggestions.
• Withdrawal of Consent: Withdraw consent where processing is based on consent.

California residents additionally have the right to know what personal information we collect, the right to non-discrimination for exercising privacy rights, and the right to opt out of sale or sharing of personal information (we do not sell or share personal information as defined under the CCPA).

Taiwan users may exercise the rights provided under the Taiwan Personal Data Protection Act (個人資料保護法), including inquiry, review, copy, supplementation/correction, cessation of processing, and deletion.

Hong Kong users may submit Data Access Requests and Data Correction Requests under the Personal Data (Privacy) Ordinance (Cap. 486).

Singapore users may exercise the rights provided under the Singapore Personal Data Protection Act 2012, and may lodge complaints with the Personal Data Protection Commission (PDPC).

7. Data Retention

We retain your data only as long as necessary to provide the services you have requested and for legitimate business purposes. You can request deletion of your data at any time, by sending a formal request to our support team or by using in-app account deletion. (See Contact Information section)

8. International Users

Your data may be transferred and processed in Singapore, the United States, or other countries where our service providers operate. By using the App, you consent to such transfers. Where required by applicable law, we implement appropriate safeguards for international transfers, including Standard Contractual Clauses for transfers from the EEA/UK.

9. Regional Privacy Disclosures (EU & UK)

Whispy.AI (operated by NEXBASE TECH PTE. LTD.) is considered the "data controller" of the "personal data" (as defined under the General Data Protection Regulation, GDPR) we handle under this Policy. In other words, we are responsible for deciding how to collect, use, and disclose personal data, subject to applicable law. The laws of the European Economic Area and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing your personal data. To the extent those laws apply, our legal grounds are as follows:

• Contractual Commitments: We may use, share, or disclose personal data to honor our contractual commitments to you. For example, we will process your personal data to comply with our agreements with you, and to honor our commitments in any contracts that we have with you.
• With Your Consent: Where required by law, and in some other cases, we use, share, or disclose personal data on the basis of your consent.
• Legitimate Interests: In many cases, we use, share, or disclose personal data on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for the Services, preventing fraud, and managing legal issues.
• Legal Compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

In addition to those rights described herein, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

10. Changes to Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last Updated" date above and, where appropriate, through in-app notification or email. Continued use of the App after updates constitutes acceptance of the revised policy.

11. Contact Information

If you have questions or concerns, contact us at:

• General Support: contact@whispy.ai
• Company: NEXBASE TECH PTE. LTD., Singapore