ShadowChat Privacy Policy

Last updated: July 12, 2024

Effective date: July 12, 2024

Welcome to ShadowChat, an artificial intelligence software (hereinafter referred to as "software") developed and operated by PolarisXR Co. Ltd. (hereinafter referred to as "ShadowChat" or "we"). We highly value user privacy and personal information protection, and strictly adhere to relevant national laws and regulations regarding privacy and personal information protection. When you use ShadowChat, we will collect and use your relevant information in accordance with this privacy policy. This privacy policy is designed to help you understand the following:

This privacy policy is closely related to the software you use and the various business functions included in the software. We will collect, store, use, and provide your information externally in accordance with this privacy policy. Therefore, please carefully read and fully understand the entire content of this policy, especially parts marked with underlines, bold text, or other methods that have or may have a significant relationship with your rights and interests. This will help you understand how to maintain your privacy and personal information, and make choices you deem appropriate. After you click a button similar to "Agree" or actively check to agree to this privacy policy or perform other operations, it means you agree that ShadowChat will collect, store, use, and provide your personal information externally in accordance with this privacy policy.

I. How we collect and use your information

We will only collect and use your personal information for the following purposes stated in this privacy policy:

(I) We mainly collect your personal information through the following three channels, to which you express understanding and consent:

  1. Information you directly provide: We may collect and store information you fill in and submit on relevant pages during your use of the software, written materials you provide to us (including paper and any form of electronic materials), information you publish in the software during your use of the software (including but not limited to information you send when interacting with the system, information you fill in or select such as preference information, etc.), information you provide when contacting us, and information about your activities and behaviors generated during your use of the software.
  2. Information we actively collect: When you register, log in, and use our services, and when handling customer complaints, inquiries, or disputes, we will collect relevant information sent to us by the computer, mobile phone, and other access devices you use, collect relevant information you authorize us to obtain, and record relevant information about the computer, mobile phone, and other access devices you use.
  3. Information we obtain from other sources: With your consent, we may also obtain your relevant information from ShadowChat's affiliated companies and partners, as well as third-party institutions that are legally established and legally retain your relevant information.

(II) How we use your information

Situations where you authorize us to collect and use your personal information:

ShadowChat, as an artificial intelligence software, provides various functions, and to realize these functions or for you to use these functions, we need to collect or use your personal information accordingly. Since the collected personal information is a necessary prerequisite for realizing these business functions and improving your user experience, if you do not provide the information, we will not be able to provide you with the corresponding functions and/or services. These functions include:

  1. Registration/Login When you register an account, you need to provide your real mobile phone number and the SMS verification code you received, among other information.
  2. Real-name Authentication Our service is intended for adults. To guide users in scientifically and rationally understanding and legally using the generative AI technology related to this software, to fulfill the relevant obligations of service providers in accordance with the "Interim Measures for the Management of Generative Artificial Intelligence Services," and to prevent minors from over-relying on or becoming addicted to generative AI services, when you use the APP and are identified as a suspected minor user by the platform policy, you need to complete real-name authentication. Through the real-name authentication method provided by ShadowChat, you need to provide us with your real name and ID card number. You agree and authorize that we may provide, query, and verify your aforementioned identity information with relevant real-name authentication institutions (relevant national authorities, public security departments, or other institutions they entrust/cooperate with, or third-party institutions with authentication qualifications). Without your express consent or clear provisions in laws and regulations, we will not use your real-name authentication information for other purposes. If you refuse to provide the above information, you will not be able to use the relevant products and/or services.
  3. Connecting with AI Agents After logging into the software, you can enter the assistant guidance interface. The assistant will guide you to connect with your personalized AI agent. During this process, you need to answer preset questions or complete preset tasks in the software, so that we can understand your preferences and connect you with your personalized AI agent. If you refuse to answer or do not complete the tasks and do not allow us to collect and use your above preferences, you will not be able to connect with the AI agent. The above preset questions and tasks will collect and use your name or nickname so that the AI agent you create can address you by your name during interactions.
  4. Dialogue Interaction Once you have connected with your AI agent, you can engage in dialogue interactions with it. We will analyze and calculate based on the text information you input to provide you with appropriate output content in context, and improve our service quality based on your feedback such as likes, reports, re-inputs, and other evaluations. At the same time, when you use the voice call function to interact with us, we need to obtain your microphone and recording permissions to get your voice input information to realize your use of the corresponding functions. If you refuse to provide this, you will not be able to interact through voice and cannot normally use this function, but this function and permission acquisition are not mandatory.
  5. Achievement System During your interaction with the AI agent, you may trigger the "achievement" function. When you complete corresponding operations, you can obtain specific "achievements". We will record and save your achievement history and send this information to our cloud server for processing, so that we can further understand your preferences and behavior patterns.
  6. Customer Service Function When you contact us, we will require you to provide and use your mobile phone number, ShadowChat account information, and usage information. To ensure the security of your account, we will use your mobile phone number and ShadowChat account information to verify your identity when providing customer service. When you need us to provide customer service related to your usage process information, we will query your usage information. If you refuse to provide this, you will not be able to use this function.
  7. High-fidelity Generation Mode When you use our high-fidelity generation mode, we will require you to provide and use your album permissions (only used when uploading information needed for this function), and upload your original portrait. This permission and information are necessary for this function. If you do not wish to provide the relevant information, you can refuse to let us provide this function for you and upload any other picture as a substitute. At the same time, we provide a basic function that only requires uploading 1 portrait and an advanced function that requires uploading multiple portraits. You can use them according to your needs. We will strictly follow legal regulations and adopt detailed encryption measures in the process of collecting, transmitting, and storing your relevant information to do our utmost to protect your information security. Our service is limited to the necessary purposes of this function, and we will not extract or use any identifying information. Once the service is completed, the system will immediately automatically delete all relevant information without any retention. To protect your portrait, we promise that we will not use your portrait outside of your use of this software and function. The authorization stipulated in the "User Agreement" has already clarified that it does not include any of your personal information (including portraits).
  8. Functions necessary to ensure service security To ensure the stability and security of the system when you use our software, to guarantee your service experience and legal rights, to maintain the normal operation of the software and services, to prevent your personal information from being illegally obtained, and to more accurately prevent fraud and protect account security, we need to collect your: (1) To ensure the secure operation of the software and services and the quality and efficiency of operations, we will collect your hardware and device model, operating system version number, device identifiers (for Android: IMEI/MEID, AndroidID, OAID, IMSI, SIM card information (such as ICCID), GAID, hardware serial number (SN); different identifiers may vary in validity period, whether they can be reset by the user, and acquisition method), network device hardware address (device MAC address), login information (mobile phone number, SMS verification code) and other data to judge the risk of your account, and may record some links ("URLs") that we consider risky. (2) To ensure operational quality and efficiency, we will collect software list or information about currently running processes, overall operation, usage and frequency of applications, application crash situations, overall installation and usage situations, performance data, and application sources. (3) We will also collect your device information to analyze our system problems, conduct traffic statistics, and investigate potential risks. This information will be used to troubleshoot when you choose to send us exception information. If you do not provide the above information, we will not be able to protect your services and account security during your use of our services.
  9. Improving Services (1) To improve our services and software, we will collect your usage information, personal device information, page click frequency, and page dwell time. We may combine the aforementioned personal information from various services after de-identification processing to conduct data analysis to count the number of users, analyze the usage status of the software, discover and solve software failures, and at the same time conduct internal audits, data analysis and research, and third-party SDK statistical services to continuously improve our software to provide you with better software function services; (2) For the information we collect from your usage devices, we may associate them so that we can provide you with services across these devices. We may combine information from one service with information from other services to provide you with services.
  10. Establishing an Account System To establish an account system, we need to collect your Android_ID to provide you with the most basic services.
  11. Situations where you authorize us to call device permissions when using ShadowChat software-related functions: During your use of the software, in order to use the avatar you specify when creating an AI agent, we may ask you to authorize access to network information and album permissions to achieve interactive functionality; during your use of the software, in order to encourage social sharing functionality and provide a better user invitation experience, we may ask you to authorize clipboard permissions to achieve interaction and sharing functions; the above situations where we may need you to call device permissions will be prompted separately when first called to ask whether you want to enable them. Please note that by enabling these permissions, you authorize us to collect and use this personal information to implement the above functions. If you close the permissions, it means you have canceled these authorizations, and we will no longer continue to collect your personal information, nor will we be able to provide you with the above functions corresponding to these authorizations. Your decision to close permissions will not affect the processing of personal information based on your previous authorization.
  12. Personalized Recommendations: (1) In order to recommend more relevant input commands, chatbots, memory books, etc., to you and provide services that better meet your requirements, we will provide you with personalized recommendation services. (2) To provide you with the above personalized services, we may collect and use your input information (including dialogue content and search text) and behavioral information (including your clicks, searches, browsing, and sharing operations and related records when accessing/using the product) when you use the product. We will automatically analyze and calculate the above information, predict your preference characteristics, and provide you with personalized recommended content and services based on the calculation results. (3) You can choose to turn off or on the personalized recommendation function in [My-Settings-Personalized Recommendation Service]. When you choose to turn off personalized recommendations, we will no longer show you personalized recommended content, and you will not be able to enjoy personalized recommendation services, but you can still continue to browse non-personalized recommended content.

(III) You fully understand that in the following situations, we collect and use personal information without your authorization and consent:

  1. Directly related to national security and national defense security;
  2. Directly related to public safety, public health, and major public interests;
  3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
  4. For the purpose of protecting the life, property, and other significant legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the consent of the person;
  5. The personal information collected is information that the personal information subject has voluntarily disclosed to the public;
  6. Collecting your personal information from legally disclosed information;
  7. Necessary for signing and performing contracts as requested by you;
  8. Necessary for maintaining the safe and stable operation of the software provided, such as discovering and handling faults in the service;
  9. Necessary for legitimate news reporting;
  10. When it is necessary for academic research institutions to carry out statistical or academic research based on public interests, and the results of academic research or description are provided externally, the personal information contained in the results is de-identified;
  11. Other situations stipulated by laws and regulations.

(IV) Situations where we obtain your personal information from third parties

We may obtain account information you have authorized to share from third parties, and directly log in and use our software through third-party accounts after you agree to this privacy policy. We will use your personal information in compliance with relevant laws and regulations, based on agreements with third parties and confirmation of the legitimacy of the personal information source.

(V) Other uses of your personal information

  1. After we de-identify personal information through technical means, the de-identified information will not be able to identify the subject. Please understand and agree that in this case, we have the right to use de-identified information; we have the right to analyze and commercially utilize the user database without disclosing your personal information.
  2. We will conduct statistics on the usage of our software and may share these statistical information with the public or third parties to show the overall usage trends of our software. However, these statistical information do not contain any of your identifying information.
  3. When we display your personal information, we will use methods including content replacement and anonymization to de-identify your information to protect your information security.
  4. When we want to use your personal information for purposes not stated in this policy, or when information collected for a specific purpose is to be used for other purposes, we will seek your consent in advance. Please understand that the software we provide to you will be constantly updated and changed. If you choose to use other functions not yet listed in this privacy policy, before we collect your personal information, we will explain in detail the purpose, method, and scope of information collection through business agreements, page prompts, etc., and seek your explicit consent. If you do not agree to provide the aforementioned information, you may not be able to use that service, but it will not affect your use of other services.

II. How we share, transfer, and publicly disclose your personal information

(I) Sharing

  1. We will not share your personal information with any company, organization, or individual outside of ShadowChat, except in the following situations: (1) With your explicit consent or authorization; (2) Sharing is necessary in accordance with applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements; (3) To the extent permitted by laws and regulations, it is necessary to provide information to protect ShadowChat, ShadowChat's affiliated companies or partners, you or other users of ShadowChat software, or the public interest, property or safety from damage; (4) Only by sharing your information can we achieve the core functions of our software or provide the services you need, such as transmitting your information to our cloud server for processing by our cloud service provider to realize various interaction functions between you and the AI agent you create; (5) Handling disputes or conflicts between you and others at your request; (6) Provided in accordance with relevant agreements (including online electronic agreements and corresponding software rules) or other legal documents signed with you; (7) Used based on public interest that complies with laws and regulations.
  2. We may share your personal information with our affiliated companies. However, we will only share necessary personal information, and it will be bound by the purposes stated in this privacy policy. If our affiliated companies want to change the purpose of processing personal information, they will seek your authorization and consent again.
  3. We may share your personal information with partners and other third parties to ensure the realization of software functions, which may include specific functions such as registration and login, dialogue interaction, AI agent WeChat binding, sharing photos, etc. You hereby confirm that these services are what you want to obtain (including but not limited to transmitting your dialogue content to our cloud server for processing by our cloud service provider). However, we will only share your personal information for legitimate, proper, necessary, specific, and clear purposes, and will only share personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purposes.
  4. For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our agreements, this privacy policy, and relevant confidentiality and security measures.

(II) Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following situations:

  1. With your explicit consent or authorization;
  2. In accordance with applicable laws and regulations, legal procedures, mandatory administrative or industry association requirements, or as required by relevant regulatory authorities;
  3. In accordance with relevant agreements (including online electronic agreements and corresponding software rules) or other legal documents signed with you;
  4. In the event of mergers, acquisitions, asset transfers, or similar transactions, if personal information transfer is involved, we will require the new company and organization holding your personal information to continue to be bound by this privacy policy, otherwise, we will require that company and organization to seek authorization and consent from you again.

(III) Public Disclosure

We will only publicly disclose your personal information under the following circumstances and on the premise of taking industry-standard security protection measures:

  1. Based on your needs, disclose your designated personal information in a disclosure method that you explicitly agree to;
  2. In cases where it is necessary to provide your personal information in accordance with laws, regulations, mandatory administrative enforcement, or requirements of relevant regulatory authorities, industry associations, administrative agencies, judicial authorities, or other authorized agencies, we may publicly disclose your personal information based on the type of personal information and disclosure method required;
  3. Other circumstances stipulated by laws and regulations.

III. How we protect and store your personal information

(I) Our technical measures and technologies for protecting your personal information

We attach great importance to personal information security and take all reasonable and feasible measures to protect your personal information:

  1. Data security technical measures We will adopt security protection measures that meet industry standards and common security technologies in the industry to prevent your personal information from unauthorized access, modification, and to avoid your personal information from being leaked, damaged, or lost: (1) We use encryption technology to encrypt and store your personal information, and set strict data access permissions to ensure your personal information security. (2) We occasionally hire security experts to provide corresponding training for technical personnel and set up corresponding security experts within the technical department to check the security of the system.
  2. Security incident handling (1) In the event of a personal information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, remedial measures for you, etc., in accordance with the requirements of laws and regulations. We will timely inform you of the relevant situation of the incident by email, letter, telephone, push notification, and other means. When it is difficult to inform the personal information subjects one by one, we will take reasonable and effective ways to publish announcements. At the same time, we will also actively report the handling of personal information security incidents as required by regulatory authorities. (2) Although we have taken the above technical security measures, please understand that due to technical limitations and rapid development in the Internet industry, as well as possible malicious attack means, even if we do our best to strengthen security measures, it is impossible to always guarantee 100% security of information. Please understand that the systems and communication networks you use when using our software may have security problems due to factors beyond our control. If you find that your personal information has been leaked, especially if your account or password has been leaked, you should immediately contact us through the contact methods stipulated in Article X below so that we can take corresponding measures.

(II) Storage of your personal information

  1. We will store personal information collected within the People's Republic of China within the territory of the People's Republic of China.
  2. We promise that in order to protect your rights and interests, we will generally retain your personal information for the shortest time necessary to achieve the purpose, unless required by laws and regulations. In the following situations, we will have the right to change the storage period of your personal information: · To comply with applicable laws and regulations and other relevant provisions; · To comply with court judgments, rulings, or other legal proceedings; · To comply with the requirements of relevant government agencies or legally authorized organizations; · We have reason to believe that we need to comply with laws and regulations and other relevant provisions; · To execute relevant service agreements or this policy, maintain social public interests, protect our customers, us or our affiliated companies, other users or employees' personal and property safety or other legitimate rights and interests, as reasonably necessary. After your personal information exceeds the retention period we keep, we will delete or anonymize your personal information.
  3. If we terminate our service or operation, we will notify you at least 30 days in advance and delete or anonymize your personal information after the termination of service or operation.
  4. Your personal information that has been anonymized can be used and circulated after anonymization treatment. We do not need to separately notify you and obtain your consent for the retention and use of such anonymized information.

IV. How you manage your personal information

We attach great importance to your concern about personal information and do our utmost to protect your rights to access, correct, delete, and withdraw consent to your personal information, so that you have full ability to protect your privacy and security. You can manage your personal information in the following ways:

  1. Accessing and correcting your personal information Except as required by laws and regulations, for personal information generated during your use of our software that needs to be accessed or corrected, please contact us at any time. We will respond to your request according to the methods and time limits specified in this privacy policy. However, you understand and agree that for some of your personal information, we cannot provide you with access and/or correction services. This information is collected to ensure service security and meet relevant mandatory legal and regulatory requirements, such as your device information and personal information generated when you use our software. We will use this information within the scope of your authorization in accordance with relevant laws and regulations, and you cannot change or delete it independently.
  2. Deleting your personal information In the following situations, you can request us to delete personal information: (1) If our handling of personal information violates laws and regulations; (2) If we collect and use your personal information without obtaining your consent; (3) If our handling of personal information violates our agreement with you; (4) If you no longer use our products or services, or you have cancelled your ShadowChat account; (5) If we terminate our services and operations. After receiving your deletion request, we will process the subsequent deletion according to your requirements and relevant laws and regulations, and feed back the results to you. We will also notify entities that have obtained your personal information from us, requiring them to delete it promptly, unless otherwise stipulated by laws and regulations, or these entities have obtained your independent authorization. When you delete information from our services, we may not immediately delete the corresponding information from our backup system, but we will delete this information when the backup is updated.
  3. Changing the scope of your consent or withdrawing your authorization You can change part of the scope of your authorization for us to continue collecting personal information or withdraw your authorization by turning off device functions, contacting us through the methods stipulated in Article X below, etc. You can also contact us through the methods stipulated in Article X below to withdraw all authorization for us to continue collecting your personal information. Please understand that each business function requires some basic personal information to be completed. When you withdraw consent or authorization, we will not be able to continue to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect the processing of personal information based on your authorization prior to the withdrawal.
  4. Cancellation You can contact us through the contact methods listed in Article X below to apply for account cancellation or cancellation of specific ShadowChat service functions. After verifying your cancellation information, the performance of the software you use, and other specific details, we will process your account cancellation application.
  5. Responding to your requests To ensure security, we may need you to provide written materials or other means to prove your identity. We will respond to your request within fifteen working days after receiving your feedback and verifying your identity. In principle, we do not charge for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost fee as appropriate. We may refuse those requests that are groundless, require excessive technical means, bring risks to the legitimate rights and interests of others, or are very impractical. However, you understand and agree that in accordance with legal requirements, we will be unable to respond to your request in the following situations: (1) Related to national security and national defense security; (2) Related to public safety, public health, and major public interests; (3) Related to criminal investigation, prosecution, and trial; (4) There is sufficient evidence to show that you have subjective malice or abuse of rights; (5) Responding to your request will cause serious harm to the legitimate rights and interests of you or other individuals and organizations.

V. Protection of minors' information

  1. We attach great importance to the protection of personal information of minors. Our software is mainly aimed at adults and is not open to minors in principle. If you are a minor, you should obtain the special consent of your legal guardian before using our software and send a notice to our email. We will protect the personal information of minors in accordance with relevant national laws and regulations.
  2. For situations where we collect personal information of minors with the consent of legal guardians, we will only use or publicly disclose this information when permitted by law, explicitly agreed by the guardian, or when necessary to protect the minor.
  3. If your legal guardian does not agree for you to provide us with your personal information in accordance with this privacy policy, please notify us immediately so that we can process your information.

VI. Notification and revision

  1. To provide you with better services and as our business develops, this privacy policy will also be updated accordingly. But without your explicit consent, we will not reduce your rights under this privacy policy. We will release updated versions on our official website and mobile software and remind you of the relevant content updates through website announcements or other appropriate methods before they take effect. Please also visit our software to stay informed of the latest privacy policy.
  2. For significant changes, we will also provide more prominent notice (we will explain the specific changes to the privacy policy through methods including but not limited to email, SMS, or special prompts on browsing pages). This policy defines significant changes as including but not limited to: (1) Significant changes in our business model and service model. Such as the purpose of processing personal information, the type of personal information processed, the way personal information is used, business functions, etc.; (2) Significant changes in our ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.; (3) Changes in the main objects of personal information sharing, transfer, or public disclosure; (4) Significant changes in your rights to participate in personal information processing and how to exercise them; (5) Changes in our responsible department, contact information, and complaint channels for handling personal information security; (6) When the personal information security impact assessment report indicates high risks.

VII. Third-party service statement

Our software may include third-party SDKs or other similar applications. If you use such services provided by third parties on our software, you agree that they will directly collect and process your information (such as in the form of embedded code, plugins, etc.). The device information usually collected by third-party SDKs includes: SDK or API version, platform, timestamp, application identifier, application version, application distribution channel, iOS vendor identifier (IDFV), iOS advertising identifier (IDFA), Android advertising master identifier, network card (MAC) address, International Mobile Equipment Identity (IMEI), device model, terminal manufacturer, terminal device operating system version, session start/stop time, language location, time zone and network status (WiFi, etc.), hard disk, CPU and battery usage, etc. We do not collect or store any personal information you fill in and submit on other third-party service pages.

Please be sure to note that these third-party entities have different privacy policies from ours. We will make commercially reasonable efforts to require such third parties to take protective measures for your personal information, but we cannot guarantee that such third parties will definitely take protective measures according to our requirements, nor will we be responsible for any actions and consequences of such third parties. Therefore, to maximize the security of your information, we recommend that you review their privacy terms before using any third-party SDK-type services. To protect your legal rights, if you find that these SDKs or other similar applications pose risks, it is recommended that you immediately terminate the relevant operations and contact us promptly.

The SDKs we involve and their corresponding information, privacy policies, etc. are as follows:

VIII. Our basic information

Developer: PolarisXR Co. Ltd.

Address: 3rd and 4th floors, Building 2, 598 Guanghua Road, Minhang District, Shanghai

IX. How to contact us

If you have any questions, comments, or suggestions regarding this privacy policy or your personal information-related matters, you can contact us through the following methods:

  1. Send an email to support@polarisxr.cn

After verifying the relevant situation, we will generally reply within 15 working days.

We remind you that in some cases, to ensure the security of your personal information, we may need you to provide a written request or prove your identity in other ways.

X. Definitions

"Personal Information": Refers to various information recorded electronically or in other ways that can identify a specific natural person's identity or reflect the activities of a specific natural person alone or in combination with other information.

Examples of personal information:

"Personal Sensitive Information": Refers to personal information that, once leaked, illegally provided, or abused, may endanger personal and property safety, easily lead to personal reputation, physical and mental health damage, or discriminatory treatment, etc.

Examples of personal sensitive information: