Privacy Policy

I. INTRODUCTION

Hong Kong Endless Flow Technology Limited ("we," "our," or "the Company") values your privacy. This Privacy Policy explains what information we process when you install and use the chatlulu mobile application (the "App"), why we process it, who we share it with, how long we keep it, and the choices you have.

"Personal data" (or "personal information") means any information relating to an identified or identifiable natural person, directly or indirectly.

The App does not require you to create an account. You can use the App without providing your name, email address, or phone number.

Please read this Privacy Policy carefully. By using the App, you acknowledge that you have read and understood it.

California Residents – Special Notice

Under the California Consumer Privacy Act (CCPA), California residents have the right to request:

1. Disclosure of the categories of personal information we process;
2. Disclosure of the categories of sources from which personal information is collected;
3. Disclosure of the purposes for processing personal information;
4. The categories of third parties with whom we share personal information;
5. Access to, correction of, or deletion of the specific personal information we hold about you, subject to verification.

Quick links:

• Information We Process >>
• How We Share Your Information >>
• Opt-Out Options >>

Under the CCPA, "personal information" does not include de-identified or aggregated data. All third parties that process user data on our behalf act as service providers under written agreements and only for the business purposes described in this Policy.

REQUESTS

To submit a request for access, correction, or deletion of personal information, contact us at [email protected] or via the in-app Support Form, and include the phrase "Your California Privacy Rights." Because the App does not use accounts, please include your in-app user ID (shown in Settings) so that we can locate the relevant data. We may ask for additional information to verify the request, and we will use such information only for verification.

We aim to respond to verifiable requests within forty-five (45) days. If more time is needed, we will inform you of the reason and the extension period.

EQUAL RIGHTS

We will not discriminate against you for exercising your privacy rights, including by charging different prices or providing a different quality of service.

DATA SALES

We do not sell your personal information.

II. INFORMATION WE PROCESS

FUNCTIONAL INFORMATION

The following information is processed to provide the App's features. Without it, we cannot provide those features.

• PHOTOS YOU UPLOAD
  • To create an AI photo or use a template, you may upload one photo from your device. Before your first upload, the App shows a consent dialog that explains how the photo will be processed and which providers will process it. If you choose "Cancel," nothing is uploaded.
  • The App only accesses the photo you select. It does not access the rest of your photo library.
  • You must only upload photos of yourself, or photos of other people for which you have their permission.
  • Uploaded photos are used only to generate the output you request and to check the content for safety (see "Content Moderation" below). We do not use uploaded photos to identify you, and we do not create facial recognition templates or other biometric identifiers from them.


• TEXT PROMPTS: The text you enter to describe the image you want to generate.


• GENERATED CONTENT: The images and videos generated by the App from your prompts, photos, and selected templates.


• REPORTS: If you report a generated result, we process the report reason and the reported content to review it.


• PURCHASE INFORMATION: Your purchase status and coin balance, linked to an anonymous user ID generated by the App. Payments are processed by Apple. We do not receive or store your credit or debit card information.


• SUPPORT INFORMATION: If you contact us, we process your email address and the content of your message to respond to you.

CONTENT MODERATION

To prevent the creation of sexual, nude, or otherwise prohibited content:

• Text prompts are checked by OpenAI's moderation service before generation.
• Uploaded photos and generated results are checked by Alibaba Cloud's content moderation service.
• Requests or results that violate our rules are blocked and are not shown to you.

AI-GENERATED CONTENT LABELING

All generated results are labeled "AI Created" in the App, for all users including subscribers. Files you save or export from the App contain metadata indicating that they were generated by AI.

AUTOMATICALLY PROCESSED INFORMATION

With your permission through Apple's App Tracking Transparency prompt, third-party analytics and advertising tools (see Section IV) may process your device's advertising identifier (IDFA). If you do not grant permission, the IDFA is not accessed. Regardless of tracking permission, we may process limited technical data to operate and improve the App, such as:

1. Device information: device model, operating system version, language, and time zone;
2. Network information: IP address and network type, used for security and to deliver the service;
3. App identifiers: an anonymous user ID generated by the App;
4. Usage information: app launches, features used, crashes, and performance data;
5. Purchase events: in-app purchase and subscription events.

We do not use your location to change the App's features, content, or availability.

III. PURPOSES OF PROCESSING

• Providing the service: generating images and videos you request and delivering them to you;
• Safety: moderating prompts, uploads, and results, and reviewing user reports;
• Purchases: processing coin purchases and subscriptions and restoring purchases;
• Improving the App: analyzing usage and performance to fix problems;
• Advertising measurement: only if you permit tracking;
• Support: responding to your requests;
• Legal compliance and fraud prevention.

We do not use your photos, prompts, or generated content to train AI models, and our agreements with our AI providers do not permit them to use this content to train their models.

IV. INFORMATION SHARING

We share information only with the service providers listed below, only as needed to provide the App, and under agreements that require them to protect it. We do not sell or rent your personal information.

We may also disclose information: (a) to comply with legal obligations; (b) to protect the rights, property, or safety of us, our users, or others; or (c) in connection with a merger, acquisition, or sale of assets, in which case we will notify you in the App.

V. INTERNATIONAL DATA TRANSFERS

All of our servers are located in the United States. Your photos, prompts, generated content, and other personal information are processed and stored only in the United States. We do not transfer, store, or process your personal information in mainland China.

Our service providers listed in Section IV process this information in the United States. If you are located outside the United States, including in the European Economic Area or the United Kingdom, your information is transferred to the United States. Where required, we rely on appropriate safeguards for these transfers, such as the European Commission's standard contractual clauses.

All data is encrypted in transit.

VI. DATA RETENTION

• Uploaded photos, prompts, and generated results on our servers: automatically deleted within 24 hours after generation.
• Google (Gemini API): Google may retain inputs and outputs for a limited period of up to 50 days solely for abuse monitoring, as described in Google's terms, and does not use them to train its models under our agreement.
• Generation history in the App: stored on your device for 30 days so you can view your recent results. You can remove any item at any time by tapping the "×" button on it. Deleting the App also deletes this history.
• Reports: kept for as long as needed to review the report and prevent abuse, and no longer than 12 months.
• Purchase records: kept as long as required for accounting and legal obligations.
• Support messages: kept for as long as needed to resolve your request.

VII. YOUR RIGHTS

Depending on where you live, you may have the right to:

• Access or receive a copy of your personal information;
• Correct inaccurate personal information;
• Request deletion of personal information we hold;
• Restrict or object to certain processing;
• Withdraw consent at any time, without affecting processing before withdrawal.

To exercise these rights, contact us at [email protected] or via the in-app Support Form. You may also file a complaint with your local data protection authority.

VIII. OPT-OUT OPTIONS

Tracking

You can allow or deny tracking when the App asks. You can change this at any time in Settings > Privacy & Security > Tracking. For more information, visit https://support.apple.com/en-us/HT212025.

Photo Access

You can change the App's photo access at any time in Settings > chatlulu > Photos.

IX. SECURITY

We use reasonable technical and organizational measures, including encryption in transit, access controls, and automatic deletion, to protect personal information. No method of transmission or storage is completely secure. If a security incident affects your personal information, we will notify you as required by law.

X. AGE REQUIREMENT AND CHILDREN'S PRIVACY

The App is intended only for users aged 16 and older. We do not knowingly collect personal information from anyone under 16. If we learn that we have collected such information, we will delete it promptly. If you believe a child under 16 has provided us with information, please contact us.

Uploading photos of minors to create content of a sexual or suggestive nature is strictly prohibited and is blocked by our moderation systems.

XI. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will post the updated version on this page, update the "Last Updated" date, and notify you in the App of material changes.

XII. CONTACT US

Hong Kong Endless Flow Technology Limited
Email: [email protected]
In-app: Support Form