Welcome to VeoChat! We take your privacy very seriously and will only process your personal data after obtaining your consent.

This Privacy Policy (hereinafter referred to as "this Policy") explains how we collect, use, and share your personal data when you browse and use the websites/applications (hereinafter referred to as the "Products") operated by TCI ENTERTAINMENT HONGKONG LIMITED (hereinafter referred to as "we") and the services provided by the Products, the rights you have regarding your personal data, and other important information about how we process your personal data.

This Policy applies to VeoChat Products and their related services. We take your privacy very seriously and will, to the extent permitted by applicable law, process your personal data based on consent, performance of a contract, legitimate interests, compliance with legal obligations, or other applicable legal bases. Your access to or use of the Products and services indicates that you have read and understood this Policy; however, for processing scenarios that require separate consent or authorization under applicable law, such as non-essential cookies, targeted advertising, specific device permissions, processing of sensitive personal information, or specific cross-border transfers, we will separately seek your consent or provide you with necessary choices through pop-ups, checkboxes, device permission request pages, separate authorization pages, or other appropriate means.

Please note that you should carefully read this Policy before accessing the Products and/or using the services. Your access and/or use constitutes your agreement to and acceptance of this Policy. If you do not accept this Policy, you may not be able to register, log in, or continue to use all or part of the Products or services. You confirm that (a) you have read and understood this Policy; (b) you accept this Policy and agree to the collection, use, sharing, and other processing of your personal data as described in this Policy; and (c) you agree to receive notifications from us regarding security incidents sent to your email address.

Please note that your use of the Products and services is also subject to the Terms of Service, community rules, recharge rules, Host/streamer rules, activity rules, and other applicable agreements or product page descriptions. We may modify this Policy based on business development, legal changes, or product updates; where such changes require notification or re-obtaining consent under applicable law, we will provide notice through in-app notifications, pop-ups, emails, text messages, push notifications, or other appropriate means.

We have the right to adjust this Policy and may notify you through product notifications (as required by law), but we still recommend that you review this Policy from time to time. If you continue to use the services, you are deemed to agree to and accept the latest version of this Policy.

2.1 Personal Data You Provide

Through using the Products and services, you may provide us with the following personal data:

a. Account Data. This includes your name and email address. If you choose to log in using other platforms (e.g., Google), we will receive the service data used for login, and (depending on your account settings on platforms such as Google) detailed data about you, including your name, email address, or unique user identifier.

b. Messages and Content. This includes content containing personal data that you provide in any free-form or unstructured format while using the Products and services, such as information involving personal data provided in chat sessions with virtual companions or in messages sent to us.

c. Personal Identification Information. This includes your photograph. If you apply to become a Host, you should provide your real photograph for completing facial recognition verification. Please note that this involves your sensitive personal information. Apart from the facial recognition verification information required for Host/streamer onboarding review, we generally do not require ordinary users to provide ID document information, legal real-name information, or biometric information. However, given the nature of voice-chat social products, the chat, voice, images, short videos, or other user content you actively submit may contain sensitive personal information, special category information, or data relating to others. Please exercise caution and avoid uploading, sending, or disclosing any sensitive information that is not necessary for the relevant functions, and do not disclose others' personal data without lawful authorization.

d. Payment and Transaction Data. When you purchase paid services provided by the Products, the third-party payment platforms we cooperate with will provide us with your order number and payment status.

2.2 Personal Data We Automatically Collect

We automatically record the following data:

a. Device and Network Data. This includes the operating system, manufacturer and model, browser, IP address, device and cookie identifiers, language settings, and general location data (such as city, state, or geographic region), microphone permissions, and camera permissions of your computer device.

b. Usage Data. This includes data about how you use the services, such as your interactions with the Products and services, the links and buttons you click, and your page visits.

We and our service providers use cookies, scripts, or similar technologies to manage the services and collect information about you and your use of the services. These technologies help us identify you, customize or personalize your experience, provide you with additional products or services, and analyze the usage of our services to make them more useful to you. Most internet browsers allow you to delete or manage cookie functionality and adjust your privacy and security preferences. However, please note that disabling our cookies may mean that you cannot fully utilize our services.

3.1 General Principles. We will process your personal data within the scope of clear, reasonable, and Product-service-related purposes, and follow the principles of necessity, minimization, transparency, security, and storage period limitations. For users in different jurisdictions, we will select the appropriate legal basis for processing in accordance with applicable legal requirements; for the same processing activity, different legal bases may apply in different regions.

3.2 Providing and Managing Accounts and Basic Services. We may use your account data, device data, log data, and necessary contact information for registration and login, identity verification, account management, profile display, message notifications, service maintenance, version updates, basic function operation, transaction processing, customer service communication, ticket routing, and necessary notifications related to the services. Such processing is typically based on the performance of our contract with you, compliance with legal obligations, or our legitimate interests.

3.3 Providing Voice-Chat Social, Interactive, and Content Publishing Functions. We may use your profile data, social relationships, chat content, voice, images, short videos, interaction records, permission call information, and device information to enable you to engage in private chats, voice interactions, content publishing, room interactions, following/blocking, reporting, appeals, and other in-product social activities with other users, Hosts, streamers, and content providers. In relevant functions, your profile, nickname, avatar, status, room speech, posts, or other content that you actively set as public or displayed to specific audiences will be visible to the corresponding range of users according to your settings or Product rules.

3.4 Host/Streamer Application Review, Risk Control, and Revenue Settlement. For users applying to become Hosts, streamers, or other users with revenue qualifications, we may use their photographs, display materials, application materials, review records, facial recognition verification information, risk control results, transaction records, settlement information, and necessary dispute handling materials for identity verification, admission review, anti-fraud, risk control, revenue statistics, withdrawal review, revenue share settlement, dispute handling, and lawful compliance archiving. For facial recognition verification information, we will only process it to the extent necessary for review, anti-fraud, and dispute handling, and will not use it for marketing purposes unrelated to the aforementioned purposes.

3.5 Payments, Recharges, Tipping, and Refunds. We may use order information, payment status, device risk information, transaction logs, and customer service records to complete recharges, tipping, order confirmation, reconciliation, refunds, risk control review, exception handling, and compliance archiving. We generally do not directly store complete bank card numbers, payment passwords, or other sensitive payment credentials independently processed by third-party payment service providers, but we may receive transaction confirmation information, partially desensitized account information, or risk control results returned by them.

3.6 Security, Content Review, and Compliance Enforcement. We may review, monitor, analyze, and process user profiles, messages, voice, images, short videos, live/room interactions, report materials, device and log data through a combination of automated tools and manual review to prevent fraud, harassment, hate, exploitation, illegal pornography, minor-related risks, spam, malicious marketing, account theft, payment fraud, technical abuse, and other behaviors that violate laws, platform rules, or Terms of Service. Such processing is typically based on our legitimate interests, performance of contract, and compliance with legal obligations.

3.7 Service Improvement, Statistical Analysis, and Product R&D. We may analyze usage data, device data, crash logs, page visits, function calls, conversion funnels, user feedback, content labels, review results, and de-identified/aggregated data to improve product functions, fix bugs, optimize recommendations, improve matching effectiveness, train review models, conduct internal reports, business assessments, and product R&D. Where feasible, we will prioritize the use of aggregated, de-identified, or minimum-necessary data.

3.8 Personalized Recommendations, Advertising, Attribution, and Retargeting. Where permitted by applicable law and after completing necessary authorizations or providing opt-out options, we may use device identifiers, advertising identifiers, cookies, pixels, visit events, conversion events, in-app interaction events, page view information, marketing preferences, coarse location information, and similar data for advertising delivery, performance measurement, attribution analysis, user profiling, personalized recommendations, ad frequency control, retargeting, and anti-fraud. In regions requiring prior consent, we will obtain your consent before deploying or reading non-essential advertising technologies; in regions allowing you to opt out of targeted advertising or "sharing," we will provide corresponding opt-out mechanisms.

3.9 Communicating with You and Handling Legal Affairs. We may use your contact information, ticket records, report and appeal materials, transaction records, and necessary logs to communicate and handle matters with you or relevant parties regarding terms changes, privacy policy updates, security incidents, product notifications, customer service responses, complaint handling, dispute resolution, rights defense and litigation, regulatory communications, or corporate restructuring, financing, mergers and acquisitions, and asset transactions.

3.10 Other Legally Permitted Uses. We will not use "other unmentioned purposes" as an indefinitely expandable blanket authorization. If we intend to use your personal data for purposes incompatible with those disclosed in this Policy, we will separately inform you in accordance with applicable legal requirements and, where necessary, seek your consent.

4.1 Unless otherwise stated in this Policy, separately authorized by you, or required by applicable law, we only share your personal data to the extent necessary to achieve the relevant purposes.

4.2 When you use social, posting, feed, room, live-streaming, commenting, private chat, gifting, following, profile display, or other interactive functions, your nickname, avatar, bio, status, online presence, room speech, published content, gift interactions, and other visible profile information that you choose to make public, semi-public, or display to specific audiences may be seen, copied, or forwarded by other users, Hosts, streamers, or content recipients.

4.3 We may share necessary personal data with third parties acting on our behalf to provide services, such as cloud service providers, hosting providers, content delivery networks, database and security service providers, customer service system providers, email or SMS service providers, content review and risk control service providers or data labeling service providers, payment and settlement service providers, order processing service providers, analytics and statistics service providers, advertising attribution and marketing partners, app stores, anti-fraud service providers, identity verification service providers, and other partners necessary for Product operations. Such third parties may only process relevant data in accordance with our instructions, subject to contractual, confidentiality, and applicable legal constraints.

4.4 Based on unified operations, customer support, technical maintenance, settlement management, product R&D, internal auditing, risk control, compliance management, or other legitimate purposes directly related to the Products and services, we may share personal data with affiliated companies to the necessary extent.

4.5 For payment and settlement scenarios, we may share order and transaction-related data with payment platforms, app stores, and settlement service providers. For advertising, attribution, statistics, or retargeting scenarios, where permitted by applicable law and after completing necessary authorizations or providing opt-out mechanisms, we may share device identifiers, cookies, pixel events, conversion events, technical logs, and necessary data related to marketing effectiveness measurement with advertising platforms, attribution platforms, and analytics partners. Unless otherwise stated, we will not provide advertisers with the complete content of your private chats, voice, images, short videos, etc. for ad targeting.

4.6 We may share personal data with lawyers, auditors, accountants, insurance companies, banks, investors, counterparties, and their advisors to the extent reasonably necessary to support corporate governance, financing, mergers and acquisitions, restructuring, asset transactions, claims and litigation, compliance audits, or risk control. We may also disclose personal data to relevant authorities or authorized third parties in accordance with laws and regulations, court orders, arbitration proceedings, regulatory requirements, law enforcement investigations, or to protect the rights, property, and safety of us, users, or third parties.

4.7 In the event of a merger, division, asset sale, restructuring, change of control, bankruptcy, or similar transaction, your personal data may be transferred as part of the transaction; we will require the successor to continue to be bound by this Policy or arrangements no less protective than this Policy.

4.8 We will not directly sell your personal data for valuable consideration; however, in certain jurisdictions, disclosing certain identifiers, event data, or network activity information to advertising, attribution, analytics, or retargeting partners may be classified as "selling," "sharing," or "targeted advertising," and you may exercise relevant opt-out rights in accordance with applicable law.

Technologies such as cookies and device information identifiers are widely used on the internet. When you access the Products and use the services, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device to collect and identify information about your access to and use of the Products. We promise not to use cookies for any purpose other than those described in this Policy. We use cookies and similar technologies primarily for the following functions or services:

5.1 Ensuring the Secure and Efficient Operation of Products and Services

We may set cookies or anonymous identifiers for authentication and security purposes, enabling us to confirm whether you have securely logged into the services or have encountered account theft, fraud, or other unlawful activities. These technologies also help us improve service efficiency and enhance login and response speeds.

5.2 Helping You Access Easier

Using such technologies can help you skip the steps and processes of repeatedly filling in personal data and entering search content (e.g., recording searches and form entries).

5.3 Clearing Cookies

Most browsers provide users with the ability to clear browser cache data, and you can perform corresponding data clearing operations in browser settings. If you clear cookies, you may not be able to use services or corresponding functions provided by us that rely on cookies.

Given that we and our affiliated companies, service providers, and partners may provide technical, operational, review, support, settlement, advertising, analytics, or security services in different jurisdictions, your personal data may be transferred to, accessed from, stored in, or processed in jurisdictions other than your country or region of residence. We will, to the extent required by applicable law, take appropriate safeguards for such cross-border transfers, such as signing standard contractual clauses, adopting recognized transfer mechanisms, conducting necessary assessments, obtaining separate consent, or fulfilling other statutory obligations.

We will retain your personal data for the shortest reasonable period necessary to achieve the purposes described in this Policy, and will determine specific retention periods based on data categories, processing purposes, business needs, dispute resolution, account status, security requirements, backup and recovery needs, and retention obligations under applicable law. Under normal circumstances, basic account data will be retained during the existence of your account; transaction, payment, settlement, tax, audit, and dispute resolution-related data may continue to be retained for the period required by applicable law or risk control needs; report, appeal, review, security, anti-fraud, and log data may be retained for the period necessary to achieve investigation, disposition, and archiving purposes. When the retention period expires or the processing purpose has been achieved, we will delete, anonymize, or take other appropriate measures in accordance with the law; however, where otherwise required by law, where ongoing disputes exist, where fraud prevention is needed, where system security maintenance is needed, or where other legitimate obligations must be fulfilled, we may extend retention within the necessary scope.

We take the security of your personal data very seriously and will endeavor to take reasonable security measures (both technical and administrative) to protect your personal data, preventing the personal data you provide from being improperly used or accessed, publicly disclosed, used, modified, damaged, lost, or leaked without authorization. For example, we use static encryption to protect all user data (including database files and backups) and use secure keys for data management. We use transport encryption to protect data flows from user devices to servers and from server to server in public network environments. We also ensure the effective implementation of these technical measures through code review mechanisms. In addition, we regularly test applications and systems for vulnerabilities and security issues, and adopt access control measures (such as access tokens and two-factor authentication) to ensure data security.

Please note and understand that we cannot guarantee a completely secure internet environment. If you discover that your personal data has been leaked, please contact us immediately so that we can take corresponding measures.

If any incident, force majeure event, or other situation causing a leak of your personal data occurs, we will make every effort to minimize losses and promptly inform you of the situation, the security measures we have taken and that you can take, and other relevant personal data. If a security incident related to personal data occurs, we will report such incident to the competent authorities in accordance with applicable laws and regulations, promptly investigate the issue, and take emergency measures.

9.1 You have the right to access a copy of the personal data we collect about you. Where appropriate, we will provide personal data in a portable, machine-readable, and easy-to-use format.

9.2 You have the right to request that we correct your personal data, i.e., you may request that we correct inaccurate personal data. If needed, you may also supplement your personal data.

9.3 You have the right to request that we delete your personal data, including your VeoChat account and related personal data. If you wish to delete your account, you can contact us via email at contact@veo-chat.com. Please note that after you submit an account deletion request, you will no longer be able to use VeoChat, so please consider carefully. In addition, when the purposes of use described in this Policy no longer exist or the personal data retention period has expired, we will also proactively delete your personal data.

9.4 Withdrawal of Consent. You may withdraw your consent to our processing of your personal data at any time by sending an email to contact@veo-chat.com, and the withdrawal of consent does not affect the lawfulness of our processing of your personal data before the withdrawal. Upon receiving your withdrawal request, we will process it promptly, and unless otherwise provided by law, we will no longer process your personal data.

9.5 Other rights, such as the right to object to and request that we restrict the use of your personal data.

If you wish to make any of the above requests, please contact us using the methods provided in Section 14 "Contact Us" below. To protect the security of your personal data, before responding to your rights request, we may need to verify your identity, for example, by requiring you to provide certain identity-related supporting information. We will respond to your rights request in a timely manner in accordance with the requirements of applicable laws and regulations.

Our Products and services are only available to users aged 18 and above, and we do not provide registration, login, or usage eligibility to minors under 18 years of age. We will not knowingly collect personal data of minors under 18 years of age. If we have reasonable grounds to believe that an account is held by, used by, or associated with a minor, we may take measures such as restricting functions, suspending services, requesting supplementary explanations, deleting relevant content, terminating the account, or deleting relevant personal data.

The Products and services may contain links to other third-party products or applications, or may direct users to other third-party products or applications not operated by us. This Policy does not apply to these products or applications. The inclusion of third-party links in the Services does not imply that we endorse or have reviewed these products or applications. We cannot control or ensure that the personal data processing practices of these products or applications comply with legal requirements. We recommend that you promptly review the privacy policies of these products or applications directly.

Our products and services may change from time to time. Accordingly, we need to adjust this Policy. We reserve the right to update or modify this Policy at any time and may notify you through product notifications (as required by law), but we still recommend that you review this Policy from time to time. If you continue to use the services, you are deemed to agree to and accept the latest version of this Policy.

If you are located in one of the following U.S. states: California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, or Virginia, in addition to the rights described above, you have the right to request from us:

The prohibition of the sale of your personal data. Please note that we do not sell your personal data;

If our Products involve user profiling and targeted advertising, you may object to user profiling and targeted advertising. You must submit a verifiable request to opt out of each of the above activities. Please note that these measures may have a negative impact on your customer experience when using our products and third-party services.

You may exercise the above rights through the methods described in Section 14 "Contact Us" of this Policy. Please note that data privacy laws vary by state. If you are located in the United States, please consult a certified local legal advisor for more detailed regulatory information.

If you have any questions, concerns, or complaints regarding this Policy or the processing of your personal data, you can contact us by sending an email to contact@veo-chat.com. Where applicable law requires us to designate a specific regional representative, designated contact person, privacy officer, data protection officer, or local agent, we will disclose the relevant information through this Policy, product pages, or separate notices.