VibeMe Privacy Policy
Issue Date: August 1, 2024 ｜ Effective Date: August 1, 2024
This Privacy Policy of VibeMe App (the “Policy”) explains how we collect, use, store, disclose and share (collectively, “process”) your personal information when you [browse our website and] use our VibeMe mobile application (the “App”) to create your profile and find compatible matches with the help of the copilot powered by artificial intelligence (collectively, the “Services”). We respect your privacy and will take security protection measures to protect your personal information. Please note, our Services may involve integrations with websites, applications, and services managed by third parties. By interacting with these third parties, you are providing information directly to the third party and not us and subject to the third party’s privacy policy. Please read their data usage policies or other documentation. Our linking to another site or service doesn’t mean we endorse that third party.
In this Policy, “VibeMe App”, “we”, “us” or “our” refers to TETRAS.AI SINGAPORE PTE. LTD, a company registered in Singapore with its registered address located at [ 5/F,manulife place 348 kwun, tong road kowloon, Hong Kong, China ].
This Policy may be updated from time to time and therefore please check back periodically for the latest version of the Policy, as indicated below. If there will be any significant changes made to the use of your personal information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our App or by other means.
If you have any questions regarding this Policy, please contact us according to the information listed below under the Section “Contact Us”.
1. PERSONAL INFORMATION WE COLLECT
For the purpose of this Policy, “personal information” means any information relating to an identified or identifiable individual. In certain jurisdictions, this may be referred to as “personal data”. However, for the sake of consistency, this Policy will use the term “personal information” throughout to refer to such data. To the extent that our processing of your personal information is subject to certain data privacy protection laws (including, but not limited to the California Consumer Privacy Act (“CCPA”) as amended by California Privacy Rights Act of 2020 (“CPRA”), Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”), Federal Law on Protection of Personal Data Held by Private Parties of Mexico (“FLPPDPP”), collectively hereafter “appliable laws”).
1.1. Information you provide
Through your use of the Services, you may provide us with the following information:
a. Account Information. This includes your phone number, verification code and password. When you use our Service, you may create an account with your phone number to complete the registration and become our user. We may verify your identity by sending a verification code. If you refuse to provide Account Information for registration and login, we may be unable to offer you our Services.
b. Profile Information.
i) Essential Profile Information. To help you find compatible matches, we may request essential profile information during onboarding, including your location, school, name, gender, birthday, purpose for socializing, sexual orientation, gender preference and photos. To add photos, you may allow us to access your camera or photo album.
ii) Optional Profile Information. Additionally, you have the option to provide details including your zodiac sign, hometown, language, religion, major, interests, MBTI (Myers-Briggs Type Indicator), pets, drinking habits, and smoking habits. After completing onboarding process, you can further enrich your profile in the “ Me ” by adding information about yourself, height, ethnicity, job title, workplace, weed usage, drug usage, and your personal story.
If you do not provide the Essential Profile Information, you may not be able to proceed to the next step and continue to use our services. If you choose not to provide Optional Profile Information, it will not affect your ability to use our services. However, providing more details can help increase the likelihood of being matched with compatible conversation partners.
c. Messages and Contents.
We will also collect the messages and contents between you and your AI Copilot (Interactions with your AI Copilot), as well as the messages and contents between you and other users and their AI Copilots (Interactions with other users and their AI Copilot), including text messages and voice messages. When you wish to send a voice message, you may allow us to access the microphone on your device.
1.2. Information we collect automatically
We automatically log the following information about you, your computer or mobile device, your network, and your interactions over time with our Services:
a. Device and Network Data. This includes the device ID, device manufacturer, device model, device platform, device brand, device identification code (IMEI, IDFA, Android ID, MAC, OAID, Advertising ID, Serial Number, IMSI, UAID, ICCID, IDFV, BSSID, SSID), installed app list, operating system name, operating system version, device size, IP address, Wi-Fi information, base station information and operator information.
b. Usage Data. This includes your behavior information while using the Services, including but not limited to:
· Click activity records (such as button clicks, feature selections)
· Browsing activity records (such as page views, navigation patterns, time spent on different sections)
· Editing activity records (such as profile updates, settings changes)
· Interaction with our AI assistant (queries, responses, feedback)
· Chat behavior and patterns
· Connection initiation and response activities
· Feature usage frequency and duration
· App performance metrics
This data helps us understand how you use our Services, improve your experience, enhance our AI capabilities, and provide better features and functionality.
c. Other Information with your consent. If you give us your consent, we can collect your geolocation (Geolocation Data) from your device to find chat partners close to you. If you decline permission for us to collect your precise geolocation, we will not collect it, and our services that rely on precise geolocation may not be available to you.
d. We may also use the following technologies to collect the above data when you access our Services via website:
Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate online advertising.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Most browsers accept cookies automatically but allow you to disable them through setting your browser or indicate when a cookie is being sent. However, disabling cookies entirely may limit your access to certain features of the Services.
1.3. Personal data collected From Third Parties
When you use a third-party account to register or log in to our Services (e.g., AppleID), we collect certain information related to your third-party account (“Third Parties Information”), including your User ID, name, profile picture, username, and email address under such third-party account.
1.4. Sensitive Personal Information
Sensitive personal information generally refers to information concerning an individual’s privacy rights that, when breached, directly impacts the individual’s legitimate rights and interests. The scope of sensitive personal information may vary in different jurisdictions, and in compliance with legal requirements in each jurisdiction, we have identified the sensitive personal information that may be collected by us:
We collect your sensitive personal information to build your profile and match you with compatible and nearby conversation partners. We also process your chat content to provide our services but do not actively collect sensitive personal information during conversations. If you prefer not to provide such information, you can avoid discussing topics related to your health, political views, etc., which may involve sensitive personal information. Additionally, we will implement security measures to protect any sensitive personal information you provide in accordance with applicable laws.
2. HOW WE USE YOUR INFORMATION
We will only use your personal information when the applicable laws allow us to. The purposes for which we process personal information are as follows:
To help generate your chat content and update your profile and preferences based on AI copilot, we may analyze you by using the Messages and Contents collected during your use of our Services. This analysis aims to provide personalized recommendations to enhance your social interactions. We will obtain your consent before using your chat log for this purpose.
Please note, when we use the information you provide us to improve our Services, for example to train the models that power VIBEME APP, we will de-identify the information so that it may no longer be used to identify you. If you would like to opt out of such training, please contact us via contact details’ information. After it is disabled, new conversations will not be used to train our models.
3. HOW WE SHARE YOUR PERSONAL INFORMATION
In order to provide you with more comprehensive and high-quality Services, we will authorize our commercial partners to provide certain services to you. In such cases, we may share some of your personal information with our partners.
We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and we will only share the personal information required to provide the Services. We will require our partners, through agreements, to retain data only for the necessary period and to implement adequate security measures to protect data security. According to the applicable laws, we will request your express consent if we share your personal information with business partners for their marketing or other commercial purposes.
We will disclose personal information to the following third parties for the purposes explained in this Policy:
· Affiliates and corporate partners. We disclose the categories of personal data described above between and among our affiliates and related entities, for legitimate business purposes and the operation of the Services, in accordance with applicable laws.
· Service providers and business partners. Third-party service providers who provide us with IT services and business support may need to process your data. These third parties will process your personal data on our behalf under relevant contracts.
· Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our [Terms of Use] and other terms, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by applicable laws (including exchanging information with other companies and organizations for the purposes of fraud protection).
· Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.
4. HOW WILL WE TRANSFER YOUR DATA AROUND THE WORLD
Our servers are located in California and Virginia, United States. If you are located outside the United States, please be aware that the information you provide to us may be transferred to, stored, and processed in the United States. Meanwhile, due to the international nature of our business, your personal information may also be accessed by our affiliates or be transferred to third-party service providers and business partners, in connection with the purposes set out in this Policy. For this reason, we transfer personal information to other jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located. Additionally, in accordance with applicable laws and regulations, your personal information may be accessed by law enforcement authorities in the recipient country.
In the event of an international transfer of personal information, when required by applicable laws, we will provide an adequate level of protection for your personal information using various means, including implementing data transfer agreement that comply with applicable laws between our affiliates and third parties or any other lawful approach that permits the lawful transfer of personal information from those countries.
If you have any questions regarding the cross-border transfer of your data or wish to obtain further information, please contact us using the details provided in the “Contact Us” section of this policy.
5. HOW WE SECURE YOUR INFORMATION
We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable laws.
Your account is protected by a password or verification codes for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately, using verification codes and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If you have any concerns that your account or personal information has been put at risk, for example if someone could have found out your password, please contact us by using the contact details provided in the Section “Contact Us”.
While we use reasonable commercial efforts to protect the data, no technology, data transmission, or system can be guaranteed to be 100% secure. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your data, we will notify you according to the applicable laws.
6. HOW DO WE RETAIN YOUR PERSONAL INFORMATION
We adhere to retention policies for the personal information we collect to ensure that it is not retained longer than necessary for the intended purpose. Different retention periods are applied to the various types of personal information collected by us in accordance with the service needs and regulatory requirements.
Upon expiration of the retention period, we will either delete or anonymize your Personal Data. Measures will be taken to render the information irrecoverable or irreproducible.
When assessing how long your personal information is retained, we consider criteria such as: (i) the nature of the personal information and the activities involved; (ii) when and for how long you use the Services; and (iii) our legitimate interests and our legal obligations.
7. YOUR RIGHTS AND CHOICES
Subject to applicable law and depending on where you reside, you may have some rights regarding your personal information, as described further below. You may exercise some of your right in the App or Website via “Me”. If you have any other requests relating to the access of your personal information, please contact us using the contact details listed in the Section “Contact Us” or contact us through “Contact Support” in our APP.
7.1 Data Access
You may have the right to know what personal data we process about you, including the categories of personal data, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it. You can access your Profile Information via “Me”.
7.2 Data Correction
You may have the right to request that we correct inaccurate personal information that we retain about you, subject to certain exceptions. You can correct your Profile Information via “Me”.
7.3 Data Deletion
You have the right to delete your account and erase your personal information through “Me - Settings - Delete Account”. Upon deleting your account, all your personal information will be deleted. Additionally, you may also request deletion of the personal information you provide by contacting us. If some of your personal information cannot be deleted, we will inform you of the reasons for not taking action.
Please note that we reserve the right to retain some of your personal information where there are valid grounds for us to do so under applicable laws.
7.4 Withdrawal of Consent
Where we process your personal information on the basis of your consent, you may withdraw your consent by contacting us using the contact details listed in the Section “Contact Us”. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
7.5 Objection to the Processing
Subject to applicable laws, you may object to the processing of your personal information based on our legitimate interests where there are grounds relating to your particular situation by contacting us using the contact details listed in the Section “Contact Us”. Please note that we may have an overriding legitimate interest to keep processing your personal information, but we will let you know where this is the case.
7.6 Restriction to the Processing
If you would like to restrict our processing of your personal information, you may contact us using the contact details listed in the Section “Contact Us”. In specific jurisdictions, you may only have the right to request the restriction of processing your personal information under certain circumstances.
7.7 Lodge a complaint with your local data protection authority
Subject to applicable data protection laws, you may have the right to submit your complaint to the local data protection authority where you reside if you consider that the processing of your personal information infringes any applicable data protection laws.
8. ADDITIONAL U.S. STATE DISCLOSURES
We collect personal information from and about you in the preceding 12 months as described in Section 1. PERSONAL INFORMATION WE COLLECT above.We disclose personal information with third parties for business purposes in the preceding 12 months as below:
SUPPLEMENTAL TERMS
Apple Requirements
1. Acknowledgment: These Terms between VibeMe and you; Apple is not a party to these Terms.
2. Scope of License: The license granted to you for the App is limited to a non-transferable license to use the App on any Apple-branded products that you own or control and as permitted by the Usage Rules set forth in the App Store Terms of Use, except that the App may be accessed, acquired, and used by other accounts associated with you via Family Sharing or volume purchasing.
3. MAINTENANCE AND SUPPORT: Apple is not responsible for the VibeMe Platform or its content and has no obligation to provide any maintenance or support services for VibeMe.
4. WARRANTIES: If the VibeMe Platform fails to conform to any applicable warranty, you may notify Apple, and Apple will refund your purchase price (if any) for the VibeMe Platform. To the maximum extent permitted by applicable law, Apple will not be liable for any other warranties with respect to the VibeMe Platform.
5. Product Claims: Apple is not responsible for addressing any claims made by you or third parties with respect to the VibeMe Platform or your ownership or use of the VibeMe Platform, including, but not limited to, (a) product liability claims; (b) any claim that the Platform fails to comply with any applicable legal or regulatory requirement; and (c) claims arising under consumer protection or similar laws.
6. Intellectual Property Rights: If any third party claims that the VibeMe Platform or your ownership and use of the VibeMe Platform infringes that third party’s intellectual property rights, Apple is not responsible for investigating, defending, resolving, or discharging claims of such intellectual property infringement.
7. You represent and warrant that: (i) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a “terrorist supporting” country; and (ii) you are not listed on any U.S. Government list of prohibited or restricted parties.
8. Developer’s Name and Address: For any questions, complaints or claims related to the Application, VibeMe can be contacted as follows: contact@thevibeme.com.
9. Third Party Agreement Terms: You must comply with the terms of third party agreements when using the Application.
10. Third Party Beneficiaries: VibeMe and you acknowledge and agree that Apple and Apple’s subsidiaries are third party beneficiaries of the Terms and that, upon your acceptance of the Terms, Apple will have the right (and will be deemed to have accepted that right) to enforce the Terms against you as a third party beneficiary.
To the extent provided for by local law and subject to applicable exceptions, you may have the following rights:
Opt-out of marketing communications. At present, we do not use your personal information for marketing purposes. In the event that we use your personal information for marketing in compliance with legal requirements, you will have the right to opt out of marketing-related emails and other communications by contacting us as provided in the Section “Contact us” below. You may continue to receive Services-related and other non-marketing emails from us.
Limit the Use of Sensitive Personal Information. You also have the right to request limitation of use and disclosure of your sensitive personal information, subject to certain exceptions. If you would like to limit the use of your sensitive personal information, please contact us by using the contact details provided in the Section “Contact Us” below.
The verification codes, password, precise geolocation, religion, ethnicity, text messages, sex orientation, sex preference are sensitive personal information under certain State data protection laws. Currently, we may use and disclose the sensitive information to our affiliates and third-party service providers for the purpose necessary to providing or maintaining our Service. We do not “sell” or “share” (as defined under applicable State data protection laws) your sensitive personal information.
Do Not Sell or Share My Personal Information. Based on the definition of “sell” and “share” under applicable State data protection laws, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.
Appeal. You may appeal our refusal to take action on a request by contacting us using the contact details provided in Section 12 below.
Direct Marketing. We do not disclose personal information to third parties for their direct marketing purposes.
If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in the Section “Contact Us” below. According to applicable laws, we may request you to provide documents such as application form and proof of identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under the applicable laws.
10. USE BY MINORS
Our Services are not directed towards, and we do not knowingly collect, sell, or share any information about individuals that are minors under applicable laws (under the age of 18 or 21 depending on the jurisdiction). If you become aware that a child has provided any personal information to us while using our Services, please email us at the contact details provided in the Section “Contact Us” below, and we will investigate the matter and, if appropriate, delete the personal information.
11. CHANGES TO THIS PRIVACY POLICY
The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Policy. we recommend that you regularly check the latest version of this Policy in the APP and Website. If there are any substantial changes to this Policy, depending on the nature of such changes, we will notify you in advance through pop-ups, push notifications, emails, and other appropriate means.
12. CONTACT US
For more information about your data subject rights, or how we process your personal information, please contact us by using the information below.
Controller: SenseCore Technology Limited
Contactor: [Andy Zhao]
Address: [5/F,manulife place 348 kwun, tong road kowloon, Hong Kong, China]
Contact Details: [contact@thevibeme.com]