Privacy Policy

Last Updated: September 1, 2026

Shanghai Whalesbot Robotics Co., Ltd. is a limited‑liability company incorporated under the laws of the People's Republic of China (hereinafter referred to as "Whalesbot" or "we", including its parent companies, subsidiaries, affiliates, etc.). We value and are committed to protecting users' personal information. When you use Whalesbot’s websites, software, applications, products or related services (collectively the "Services"), we may collect and process your personal information. This Privacy Policy explains how we collect, store, use and share your personal information. Please read this Privacy Policy carefully so you can make informed decisions.

By using or continuing to use Whalesbot’s products and services, you agree that we may collect, store, use and share your personal information in accordance with this Privacy Policy.

We solemnly commit to protecting your privacy for information collected intentionally or automatically. Please note that we will never send you spam emails, compromise your confidentiality, or share your personal information with third‑parties without your prior consent. We undertake to keep your personal information strictly confidential during and for five years after the term of any agreement. Upon termination of our business relationship, we will handle the confidential information obtained in accordance with applicable laws, regulations and contractual agreements, including but not limited to returning or destroying such information to ensure data security. However, in the event of a merger, acquisition or other business transaction, customer information may be transferred, and we will ensure your prior consent is obtained in such circumstances. If you suffer economic losses caused by our failure to collect, store, use or share your personal information in compliance with this Privacy Policy, we will provide compensation based on actual damages, not to exceed twice the total fees you have paid to us in the preceding 12‑month period.

I. Types of Information We Collect

We may collect personal information you provide to us, location‑based information and website access data as described below:

(1) Personal Information You Provide to Us

Interaction Growth Report: Data Collection & Usage Statement

The "Interaction Report" is a visual growth report dynamically generated by AI large‑model based on chat interactions with AI robots. For your privacy protection, we state the following:

1. Data Minimization Principle

  • Reports only display topic names and statistical numbers (e.g. "5 chat rounds", "Topic: Animals"). No original dialogue content or raw chat text is shown.
  • Topic names are generated by the AI large‑model (2 Chinese characters or one English word, child‑friendly and concrete). Once generated, topic names are fixed permanently and no synonym substitution is allowed.
  • Sentiment classification outputs only emotion category labels and proportions. Original chat content is never stored or replayed.
  • Reports contain no precise geolocation and no personally identifiable information of any kind.

2. Data Security and Retention

  • Interaction behavioral metrics (topics, rounds, duration, sentiment labels, etc.) are encrypted and stored on servers located within mainland China; data transmission uses SSL encryption.
  • Raw interaction content (original chat text) exists only temporarily in memory for real‑time processing. It is discarded immediately after behavioral features are extracted and will not be persisted to disk for long‑term storage or report generation.
  • Report‑related data is retained for 90 days. Historical data older than 90 days will be anonymized or automatically deleted.
  • Upon account cancellation, all Interaction Report data will be deleted immediately.

3. Scope of Data Usage

  • Interaction behavioral metrics are used solely for generating Interaction Reports and will not be used for ad delivery, commercial recommendations or other unauthorized purposes.
  • Interaction Report data will not be shared with any third‑parties (including advertisers, data analytics firms or other applications), except when required by law or competent regulatory authorities.

(2) Transaction‑Related Information You Provide

To enable you to fully benefit from our Services, you may be asked to provide necessary personal identifiers so we can contact you directly. Personal identifiers include email address, full name, postal address, phone number or persistent identifiers (such as customer numbers stored in Cookies). If you refuse to provide required personal information or decline identity verification, we reserve the right to withhold Services.

To protect your privacy, we implement identity verification steps (e.g. password and username check) before granting access to your data.

(3) Location‑Based Information

We may collect general location information derived from information you voluntarily provide and your device’s IP address. We may also detect when your terminal device is activated. Data may be collected to validate manually‑submitted information and correlate it with location‑based information for internal use and user‑experience improvement.

(4) Access Data

Website access data consists of fully anonymous information regarding platform operation. Data we may collect includes:

Some web browsers feature a "Do Not Track" setting to signal that you do not wish your online activity to be tracked. Our platform currently does not respond to such signals.

(5) Account Cancellation

Pursuant to the Personal Information Protection Law of the People's Republic of China, you have the right to apply for account cancellation (subject to valid account status, no pending transactions and proof of lawful ownership of the account). You may proceed inside APP: go to "My", select "Cancel Account", complete identity verification via verification code sent to your registered mobile phone or verification link sent to your registered email, confirm cancellation consequences and submit your request. Cancellation takes effect immediately and a confirmation notice will be delivered to your original mobile phone / email. Account cancellation is irreversible; you will lose access to this account and associated benefits. The APP will delete all personal information bound to the account immediately (information required by law to be preserved will be anonymized), including all Interaction Report data. Please back‑up important data before cancellation; we are not liable for data loss resulting from account cancellation. Verification materials and cancellation application records will be kept strictly confidential and used solely for cancellation review.

II. How We Use Cookies and Similar Technologies

(1) File Storage

To ensure software operation, we may access and store software‑related information on your computer or mobile device. Such information will not be used for purposes outside this policy.

(2) Web Beacons and Pixel Tags

We also deploy web beacons, pixel tags and other similar technologies on websites and APP. For example, emails we send may contain hyperlinks pointing to content hosted on our website.

(3) Bluetooth

Bluetooth is an open global specification for wireless data and voice communication establishing low‑cost short‑range connections between fixed and mobile devices. When you use Whalesbot products and Services, Bluetooth permission on your device must be enabled to connect to our hardware products.

When you use Whalesbot products and Services, Bluetooth permission on your device must be enabled to connect to our hardware products.

(4) Camera

We invoke your device camera for shooting maps within in‑APP challenge scenarios. Captured images are only used for map recording; we strictly protect privacy and data security.

III. How We Share Your Personal Information

We will not share your personal information with any company, organization or individual outside Shanghai Whalesbot Robotics Co., Ltd. and its affiliates, except for cases caused by our intent or gross negligence, or when required by law, regulatory authorities or other legally‑compliant circumstances. Force Majeure herein specifically refers to natural disasters (earthquake, flood, typhoon, etc.), governmental acts (changes of laws and regulations, official bans, etc.), social abnormal events (war, riot, strike, etc.) and other objective circumstances that are unforeseeable, unavoidable and insurmountable. Unless prohibited by applicable law, we may use your information for the purposes detailed below:

Specific statement for Interaction Report data: Interaction behavioral metrics (topics, rounds, duration, sentiment labels, etc.) are used exclusively to generate reports within the scope of your authorization. They will not be shared with third‑parties for ad delivery, commercial recommendations or other unauthorized purposes, except when required by law or regulatory authorities.

In case of merger, acquisition or other business transaction, customer information may be transferred. We will secure your prior consent for such transfers and notify you of any change of ownership or control by email or website announcement.

In the unfortunate event of a personal‑information security incident, we will notify you as required by applicable laws: basic facts and potential impact of the incident, measures taken or to‑be‑taken, self‑protection recommendations for you, and remedies. Notices will be delivered via email, letter, phone or in‑app push; where individual notification is impracticable, we will publish public announcements by reasonable and effective means.

Meanwhile, we will report the handling of personal‑information security incidents to regulatory authorities as required.

IV. Protection of Your Personal Information

We implement security safeguards to protect your submitted personal information against unauthorized access, disclosure, usage, modification, damage or loss. We take all commercially reasonable measures to protect your personal information. For instance, data exchanged between your browser and our Services (e.g. credit‑card data) is protected by SSL encryption; secure browsing modes are available within our APP; encryption technologies preserve data confidentiality; trusted protection mechanisms defend against malicious attacks; access‑control mechanisms ensure personal‑information access is limited to authorized personnel; and internal privacy‑protection training reinforces employee awareness of personal‑information protection obligations.

Specific security notes for Interaction Report data:

We take all reasonable measures to avoid collection of irrelevant personal information. Personal information will only be retained for periods necessary to achieve purposes described in this policy, unless extended retention is permitted or required by law.

The internet is not an absolutely secure environment. Emails, instant‑messaging and user‑to‑user communications inside APP are not encrypted. We strongly advise you not to transmit personal sensitive information via these channels. Please use complex passwords to help safeguard your account security.

V. Your Right to Opt‑Out

From time to time we may add you to mailing lists to share product updates and enable one‑on‑one discussions with our support team.

Nevertheless, you retain full right and freedom to discontinue our communications and stop receiving newsletters. You may use opt‑out or unsubscribe buttons available in any communication channel we use to contact you.

VI. Privacy for Children and Minors

Whalesbot is committed to protecting privacy of children accessing our websites and platforms.

Our products, websites and Services are accessible to minors. Children shall not create user accounts without parental or guardian consent.

Where personal information of minors is collected with parental consent, we will use or disclose such information only when permitted by law, explicitly approved by parent / guardian, or necessary for minor‑protection purposes.

Notwithstanding varying local definitions of childhood, we treat persons under the age of 14 as children.

Minors:

  1. If you are a minor under 18 years old, you shall read and agree to this policy under supervision and with consent of your guardian before using this software and related Services. If you have not obtained guardian consent, your guardian may notify our official customer‑service contact to request account‑related handling. We reserve the right to restrict account functions and usage including but not limited to browsing, publishing content and interactive communication.
  2. We attach great importance to protection of minors’ personal information. Minors shall exercise caution when submitting personal information and do so under guidance and consent of their guardians.
  3. Minors and their guardians understand and acknowledge that you and your guardians shall bear full corresponding legal liabilities for any breach of applicable laws or this agreement caused by your conduct.
  4. Special Reminder for Minor Users
  1. To better protect minors’ privacy, we remind you to be prudent before publishing materials featuring minors. Once published, you are deemed to have obtained relevant rights‑holders’ consent for displaying minors’ portraits, voices and other content within this software and for us to process such content per this agreement.
  2. Reminder for Guardians

VII. Global Transfer of Your Personal Information

Personal information collected and generated within the People's Republic of China will be stored within the territory of the People's Republic of China. Interaction Report data is likewise stored on servers within mainland China and will not be transmitted across borders.

VIII. Updates to this Privacy Policy

This Privacy Policy takes effect on September 1, 2026. We reserve the right to revise this Privacy Policy at any time. Upon revision, we will publish the updated version on our website. Amendments to this Privacy Policy will require your explicit consent and take effect upon publication. Revisions affecting collection scope, usage patterns or authorization mechanisms for Interaction‑Report data will additionally be notified via in‑APP pop‑up or push notifications, requiring you to re‑confirm your consent.

IX. Contact Us

If you have questions, comments or suggestions about this Privacy Policy, or need to exercise your data‑subject rights (including viewing, deleting or disabling authorization for Interaction Report data), please email us at service@whalesbot.com.