This Privacy Policy (the “Privacy Policy” or the “Policy”) outlines the information collected and processed by Shenzhen INFUNITY PlayTech Ltd. and its affiliates (hereinafter referred to as “INFUNITY”, “we”, “our”, or “us”) from you.
This Policy applies to all websites, mobile applications, electronic products and toy products, other services linked to this Policy, and our offline services (collectively referred to as the “Services”) provided by INFUNITY.
By using the Services, you agree to the practices described in this Policy. If you do not agree with these practices, please do not access or use the Services.
Any capitalized terms not defined herein shall have the meanings given to them in the INFUNITY Terms of Service.
I. Information We Collect
When you visit or use our Services, we collect various types of information based on your usage. It is important to note that certain information is crucial for us to provide you with the Services. If you choose not to share this necessary information or request its deletion, you may lose access to certain features of our Services. The information we collect can be divided into three categories: data you directly provide to us, data automatically collected during your interaction with our Services, and data we obtain from other sources.
(I) Information You Directly Provide to Us
We collect information from you directly in various ways. This may occur when you interact with our Services, communicate with us, register an account, subscribe to our newsletters, or participate in promotional activities. The information you provide may relate to you and others and may cover a range of data types, including but not limited to:
·Email;
·Username;
·Payment information (e.g., processed through our payment vendors);
·Your user content (as defined in the Terms of Service);
·The content of your communication with us.
You are not obligated to provide this information to us. However, please note that without this information, you may not be able to access or use certain features of the Services.
(II) Information We Automatically Collect
We may cooperate with third - party vendors (including advertising networks and analytics companies such as Google Analytics) to use cookies, web beacons, and other tracking technologies to collect information about the computer or device (including mobile devices) you use to access the Services. The following details the types of information we may collect and analyze, including but not limited to:
·(a) Browser type;
·(b) ISP or operating system;
·(c) Domain name;
·(d) Access time;
·(e) Referring or exit page;
·(f) Page views;
·(g) IP address;
·(h) Unique device identifier (e.g., IDFA or Android ID);
·(i) The version of our Services you are using;
·(j) The type of device you are using.
We also track the times and frequencies of your visits or use of the Services, including your interactions and navigation on our websites or mobile applications. This information (including data collected by our third - party vendors) will be used for analysis (to identify the most frequently used parts of our Services and understand user preferences), to evaluate the effectiveness of our advertising campaigns, and for other purposes described in this Policy.
We and our third - party vendors may use cookies, transparent GIFs, pixel tags, and other technologies to better understand user behavior, customize preference settings, conduct research and analysis, and enhance the Services. These technologies allow us to customize the Services according to your needs. For example, we can save your password in a secure area, track the pages you visit, assist with content management, and collect statistics on the usage of our Services. In addition, we or our third - party vendors may use some of these technologies in emails sent to customers. This helps us monitor email response rates, determine when our emails are viewed, and track whether our emails are forwarded.
Most web browsers are set to accept cookies automatically, but you can change your browser settings as needed to reject cookies. Please note that disabling cookies may limit your full use of the Services, as the Services may not function properly without cookies. As we introduce new technologies, we may also collect other information in various ways.
When you visit the Services, we may collect general location information, which can be inferred from your IP address.
(III) Information We Collect from Other Sources
We may also collect your information from external sources. For example, if other users refer you to us or you interact with our profiles on social media platforms such as Facebook or Instagram, we may obtain your information from these third parties.
(IV) Information Collected Through Third - Party Accounts
Whenever you use a third - party account (e.g., a social media account) (“third - party account”) to connect to your account with us, we may collect certain information. This collection is based on the permissions you grant and may include data from your third - party account. For example, when you connect to our Services through a third - party account such as Facebook or Google, we will receive information that helps us identify your account from these services. We will securely collect and store this information to simplify your connection to our Services.
Connecting your account to a third - party account is entirely your decision. When you initiate the connection, you will have the opportunity to give your consent. If you decide to revoke this permission, you can log in to your third - party account and disconnect our Services from there, or easily do so through the native application on your smartphone. Please note that we may retain any information we have previously collected from you.
II. How We Use the Collected Information
We may use your information for any of the following purposes:·To provide and manage the Services;
·To personalize the Services;
1To communicate with you, including informing you of service features or aspects that we think you may be interested in, or communicating with you about changes to our terms, conditions, or policies;
·To have other communications with you, such as responding to your inquiries, comments, feedback, or questions;
·To analyze, maintain, improve, modify, customize, and measure the Services, including training our artificial intelligence/machine learning models;
·To develop new projects and services;
·To detect and prevent fraud, criminal activities, or misuse of our Services, and to ensure the security of our IT systems, architecture, and networks;
·To comply with legal obligations and legal procedures, and to protect our rights, privacy, security, or property, and/or the rights, privacy, security, or property of our affiliates, you, or other parties, including enforcing our Terms of Service and any other agreements;
·For any other purpose for which the information was collected.
We may combine the information we collect from you through the Services with information we obtain from other sources. We may also aggregate and/or de - identify the information collected through the Services. We may use de - identified or aggregated data for any purpose, including but not limited to research and marketing purposes.
III. When We Disclose the Collected Information
We may disclose your information in the following situations:
·Affiliates: We may share information with our affiliates. Affiliates are any entities that control INFUNITY, are controlled by INFUNITY, or are under common control with INFUNITY. Our affiliates may use the information we share in a manner consistent with this Policy.
·Vendors: We may share your information with employees, consultants, and other service providers who need access to such information to perform work or services on our behalf. Such service providers may include data storage, payment processing, technical support and services, customer service, analytics, fraud prevention, legal services, and marketing service providers.
·INFUNITY and the Safety and Protection of Others: If we sincerely believe it is necessary or appropriate, we may disclose certain information:
·(i) To protect or defend the rights or property of INFUNITY, including enforcing this Policy, our Terms of Service, or any other agreement; or
·(ii) To ensure the personal safety of INFUNITY, our agents and affiliates, our employees, users, and the public.
·Advertising and Analytics: As of the date of this Policy, we are not currently engaged in the advertising business. However, in the future, we may share or provide some of your information with advertising and analytics partners so that they can place advertisements on the Internet and provide analytics services on our behalf. These partners may use cookies and tracking technologies to achieve the following functions: tracking and analyzing data, evaluating the popularity of content, delivering targeted advertisements and content based on your interests, and enhancing the understanding of online activities. For detailed information on managing your web - browsing information for advertising purposes, please refer to the “Online Analytics and Customized Advertising” section below.
·Legal Requirements: If we sincerely believe it is necessary to comply with law enforcement, legal, or regulatory procedures, we may disclose certain information. This includes responding to warrants, subpoenas, court orders, or complying with applicable laws and regulations.
·Business Transfers: In the event of a merger, sale of company assets, financing, or acquisition of all or part of our business by another company, we may disclose certain information during the transaction process or negotiations.
·Your User Content: Your actions on our Services may be visible to other users or may result in content being shared with them. For example, creating user content (e.g., sharing a character) will make that content accessible within the Services. Similarly, participating in a group chat means that you are instructing us to share your chat content with other members of the group chat, who may include characters and other users within the Services.
·Other Disclosures with Your Consent or Instruction: With your consent or instruction, we may share your information with non - affiliated third parties. For example, if you choose to recommend our Services to your friends or acquaintances, you can instruct us to share certain information about you with them.
IV. Online Analytics and Customized Advertising
(I) Analytics
We use third - party web analytics services, including Google Analytics, in our Services. These services use the technologies described in the “Information We Automatically Collect” section to help us understand how users interact with the Services, such as identifying the third - party websites you use to connect to our Services. The information collected by these technologies is then disclosed to these vendors or directly collected by them to analyze your use of the Services. In addition, we may use Google Analytics for advertising - related purposes, as described in the next section. If you wish to prevent Google Analytics from using your information for analysis, you can install the Google Analytics Opt - Out browser plugin.
(II) Customized Advertising
Although as of the latest update of this Policy, we are not currently engaged in the advertising business, in the future, we may allow third - party advertising networks to use cookies or other tracking technologies to collect information about your use of the Services. The data collection is intended to: (a) provide marketing content based on your previous interactions with our website and other Services, and to update, optimize, and deliver the content; (b) measure the effectiveness of our marketing content and the relationship between your interaction with the content and your access to our Services. We may also allow other non - affiliated entities (e.g., advertising networks and servers such as Google Analytics) to provide you with personalized marketing information and use their own cookies or tracking technologies. Entities using these technologies may provide you with an option to opt out of targeted advertising. Customized advertising may be delivered to your device through a web browser. Cookies may be linked to de - identified data derived from the data you voluntarily provide to us (e.g., your email address), and we may share this data with vendors in a hashed, non - human - readable format.
If you are interested in learning more about customized advertising and controlling cookie use for targeted marketing, you can explore the following resources:
·Network Advertising Initiative (NAI): Visit the NAI’s consumer opt - out page to block cookies that send personalized ads from member companies.
·Digital Advertising Alliance (DAA): Use the DAA’s consumer opt - out link to choose not to receive customized ads from participating companies.
·European Interactive Digital Advertising Alliance: For European users, this alliance provides a similar opt - out mechanism.
To manage how Google personalizes display ads or adjust the settings of Google Display Network ads, please visit the Google Ads Settings page.
Please note that opting out of customized advertising does not mean you will no longer see ads on our Services; it only means that the ads will no longer be customized based on your interests. In addition, we cannot control the above opt - out links, nor can we guarantee their effectiveness or the accuracy of these mechanisms.
Please note that if your browser rejects cookies, you delete cookies after opting out, switch computers, or change web browsers, your opt - out preferences may no longer be valid.
V. Your Choices
We offer you multiple options to control the collection, use, and sharing of your information:
·Profile Information: You can deactivate your account through your account profile page. In addition, you can verify, correct, update, or delete some of your information through the same page.
·Marketing Communications: To unsubscribe from our marketing emails, please follow the instructions in the emails. Please note that unsubscribing from marketing communications does not mean you will not receive administrative information related to our Services, such as updates to our Terms of Service or Privacy Policy.
·Cookies and Analytics: You can opt out of certain cookie - related analytics activities in accordance with the instructions outlined in this Policy.
·Your Rights Regarding Information: Depending on your place of residence, local laws may grant you certain rights regarding your personal information, including:
(i) Requesting detailed information about the categories of personal information we collect and disclose and the purposes of collection, as described in this Policy.
(ii) Accessing and/or obtaining a copy of the specific information we hold about you.
(iii) Objecting to our processing of your information for direct marketing purposes.
(iv) Correcting outdated or incorrect information we hold about you.
(v) Requesting the deletion of some of the information we hold about you.
(vi) Restricting the ways we process and share your specific information.
(vii) Transferring your information to third - party service providers.
(viii) Opting out of analytics used for decisions with legal or similar significant impact, where applicable.
(ix) Revoking your consent to the processing of your information, where permitted by law.
You can designate an authorized agent to make requests on your behalf. To do so, you must provide the authorized agent with a signed written permission or power of attorney. Where permitted by law, we may also contact you directly before processing any request from your authorized agent to confirm your identity.
Please note that, depending on applicable laws, some information may not be subject to such requests. For example, for legal reasons or to ensure the security of our Services, we may need to retain certain information. In addition, deleting information required to provide the Services may result in your inability to use our Services.
You have the right not to be discriminated against for exercising your rights under applicable laws.
In addition, you have the right to choose not to sell your personal information or use it for targeted advertising. To choose not to receive targeted advertising in the future, please refer to the instructions provided in the “Customized Advertising” section above.
If you want to know about your rights under applicable laws or want to exercise any of these rights, please contact us via https://infunityai.com. To ensure your privacy and security, we will take reasonable measures to verify your identity and the legitimacy of your request. If we are unable to verify your identity, we may not be able to fulfill your request.
If your request is denied in accordance with applicable laws, you have the right to appeal our decision. We will provide information on how to appeal in our response to such a denied request.
Regional Privacy Disclosures and Rights
We provide additional disclosures for residents of the European Economic Area, the United Kingdom, California, and Nevada in the Regional Privacy Disclosures section below.
VI. Regional Privacy Disclosures
(I) Residents of the European Economic Area and the United Kingdom
According to the definition in the General Data Protection Regulation (GDPR), INFUNITY is the “data controller” of the “personal data” we process. This means that we are responsible for determining how to collect, use, and disclose personal data in accordance with applicable laws. The GDPR and UK laws require data controllers to disclose the legal basis for processing your personal data. Where applicable, the legal bases for our processing of personal data are as follows:
·Contractual Obligation: We process personal data to fulfill our contractual obligations to you. This includes complying with our agreements and fulfilling our contractual commitments.
·Your Consent: Where required by law and in other cases, we process personal data based on your explicit consent.
·Legitimate Interests: We generally process personal data based on its serving our legitimate business interests, and such interests do not outweigh your interests or fundamental rights and freedoms. This covers activities such as customer support, certain marketing activities, business analysis and improvement, service assurance, fraud prevention, and legal affairs management.
·Legal Compliance: To fulfill our legal obligations, it is necessary for us to use and disclose personal data in specific ways.
In addition to the rights outlined in this document, you also have the right to file a complaint with the relevant regulatory authority. However, we encourage you to contact us first if you have any questions. We will do our best to handle and resolve any issues you may encounter.
(II) Residents of Nevada
If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information to third parties not affiliated with us. To exercise this right, please contact us using the contact information provided in the “Contact Us” section below. Use the subject line “Nevada Do Not Sell Request” and include your name and email address in the email. As of now, we do not engage in the sale of personal information as defined in Chapter 603A of the Nevada Revised Statutes.
(III) Residents of California
This Policy details the specific content of the personal and sensitive personal information we collect, its sources, and how we disclose this information. According to the California Consumer Privacy Act (CCPA), we need to classify the personal and sensitive personal information collected and disclosed for commercial purposes.
1. Categories of Collected and Disclosed Personal Information
In the past twelve months, we have collected and disclosed the following categories of personal information for business or commercial purposes, as described in Section 1:
·Identifiers
·Financial information, including payment details
·Business or transaction information
·Internet or electronic network activity information
·General location data
·Audio or video information, such as submitted pictures and videos
·Voluntarily provided information, including through user content
·Other identifying information and inferences drawn from the collected data
2. Sensitive Personal Information
According to the definition of the CCPA, we collect:
·Account login names, passwords, or other credentials
·Sensitive personal information voluntarily provided by users through user content (e.g., race, religion, sexual orientation)
The processing purposes of this information are detailed in Section 2.
3. Information Sources
The categories of personal information are collected from:
1.Your direct interaction with us
2.Your use of the Services
3.Other users and non - affiliated parties
4. Disclosure Practices
Our disclosure practices are further described in Section 3.
5. “Sale” and “Sharing” of Personal Information
According to the CCPA, the “sale” or “sharing” of personal information has clear definitions. We are engaged in third - party analytics and online advertising activities, which may involve “sharing” online identifiers with advertising partners. California residents or their authorized agents can opt out using the tools mentioned in the “Customized Advertising” section.
We will not “sell” or “share” the personal information of children under the age of 18.
6. Do - Not - Track Disclosure
Due to the lack of industry standards, we do not accept browser - initiated “do not track” signals.
7. Retention of Personal Information
For detailed information on the retention of your personal information, please refer to the Data Retention section below.
8. CCPA Rights
California residents can exercise the personal information - related rights outlined in the “Your Information Rights” section. The CCPA also gives them the right to restrict the use or disclosure of “sensitive personal information” for specific purposes.
VII. Children's Privacy
We prioritize the protection of children's privacy. Therefore, our Services are not intended for minors under the age of 13, unless they have the full understanding and consent of their guardians. Our Terms of Service clearly state that our Services are not suitable for minors under the age of 13. For residents of the European Economic Area, the minimum age requirement is under 16.
Minors Under the Age of 13
In accordance with the Children's Online Privacy Protection Act of 1998 (“COPPA”) and its accompanying regulations, we promise to inform parents and legal guardians (hereinafter referred to as “parents”) of our practices regarding the collection, use, and disclosure of personal information of minors under the age of 13 (hereinafter referred to as “children”). COPPA also stipulates that for certain activities involving the personal information of children, we must obtain verifiable parental consent.
This section specifically addresses our practices regarding the personal information of children and takes precedence over any conflicting information in other parts of this Privacy Policy.
In this section, we inform parents:
·The categories of information we may collect from children.
·How we use the collected information.
·Our practices for disclosing the information.
·How we notify parents and obtain their consent to collect the personal information of children, including the process for parents to revoke their consent.
·The identification of all operators who collect or maintain the information of children through our website, application, or any device.
This clause only applies to children under the age of 13 and is intended to supplement rather than replace other clauses of this Privacy Policy. For teenagers and adults, the remaining clauses of this Privacy Policy apply.
The definitions provided in the general Privacy Policy retain the same meanings for children under the age of 13 in this Privacy Policy.
1. Collection of Information from Children and Parents
Children can interact with the device and use many of its functions without providing personal information, except for the recording of children's speech on the device. However, if a child enters personal information (e.g., name) on the device, we will collect this information. In addition, we may collect the personal information of children from their parents when they purchase or set up the device through our application or website.
We are committed to only collecting information that is reasonably necessary for a child to participate in an activity and will not require the disclosure of personal information beyond what is reasonably necessary for their participation.
·(i) Directly Collected Information
To activate the device through the application or website, parents must provide certain details about their child. This information includes the child's common name (first name or nickname), date of birth, family member names, and the parent's email address. In addition, parents need to create a membership name and password.
The device allows children to control and interact through voice commands (“voice interaction”). This interaction temporarily records voice audio files. These audio files are only used to create text transcripts to facilitate the child's interaction with the device. After the audio transcript is completed, the original audio files will be immediately deleted. The text transcript can be saved for up to 90 days to facilitate parents to view the child's interaction with the device. Although these transcripts will be automatically deleted after 90 days, parents can choose to delete them in advance if needed.
·(ii) Automatically Collected Information
We use technical means to automatically collect information during the child's interaction with the device. This automatic collection process may capture:
oPersistent identifiers that can identify the device across various websites and online services over time.
In addition, we may merge non - personal information obtained through these technologies with the personal information about you or your child that we collect online.
For detailed information about our automatic collection practices, including instructions on how to opt out of certain types of data collection, please refer to the “How We Use the Information We Collect” section of this Policy.
2. How We Use Your Child's Information
We will use the information about your child submitted by you through the website or application during the device setup to achieve the following purposes:
·To confirm, for compliance purposes, that the person submitting the information is indeed the child's parent, through verification by a third - party provider.
·To enable parents to enter their child's information into the device, thereby enhancing the interaction between the device and the child.
We use a third - party voice - to - text service to convert the audio recorded during the voice interaction into text, and then the audio will be immediately deleted. Driven by artificial intelligence, the device may conduct simulated natural conversations and prompt the child to provide personal information. However, providing personal information is not a necessary condition for continuing the conversation. If the child voluntarily provides personal information during the voice interaction, this information may be used to enhance the dialogue experience with the device.
This information will be temporarily used by third - party artificial intelligence services to generate responses during the conversation. Importantly, the third party will not retain this information after the conversation ends, nor will it use it for training or any other purpose. The generated responses will be processed according to the provided personal information and converted from text to speech for audio output, ensuring seamless interaction.
The device will save the written records of the child's conversations for up to 90 days to enhance the conversation experience and allow parents to view the records of these interactions. Parents can choose to delete these records in advance through the application. To improve our device for the use of all users, we may also save the written records of the voice interaction (including any personal information shared during the conversation) for up to 90 days, unless the parent chooses to delete them in advance.
We use the information automatically collected through technology and other non - personal information to enhance the functions of our website, application, and device. This enables us to:
·Measure our audience size and understand usage patterns.
·Monitor progress through the onboarding process.
·Detect and resolve any errors in the website, application, or device.
In addition, the application and device may collect non - specific location information, such as zip codes, time zones, and similar details, to more effectively provide localized content and information.
3. How We Disclose Your Child's Information
Except as described in this section, we will not share, sell, rent, or transfer the personal information of children. We may disclose non - identifiable information in an aggregated form. In addition, the personal information of children may be disclosed in the following situations:
·To third - party service providers that support the internal operations of our website, device, and application.
·When required by law or legal proceedings, such as complying with court orders, subpoenas, or responding to requests from government or regulatory agencies.
·When we believe it is necessary to protect the rights, property, or safety of the company, customers, or others. This includes:
(i) Ensuring the safety of children.
(ii) Ensuring the safety of the website, application, or device.
(iii) Taking preventive measures to avoid liability.
·To law enforcement agencies or for public - safety - related investigations.
·If a corporate transaction occurs, such as a merger, divestiture, reorganization, restructuring, dissolution, or sale or transfer of all or part of the company's assets, the personal information we hold may be transferred to the buyer or other successor.
4. Accessing and Correcting Your Child's Personal Information
You have the right to view the personal information of your child that we hold at any time, request correction or deletion, and/or refuse to allow further collection or use of your child's information.
To view, modify, or delete your child's personal information, please contact us by sending an email to info@infunityai.com. To protect your privacy and security, we may ask you to follow specific steps or provide other detailed information to confirm your identity before we can disclose, modify, or delete any information.
5. Operators Who Collect or Maintain Information of Children
The following operators are involved in collecting or maintaining the personal information of children through our application or device.
Operator Name
ElevenLabs
OpenAI
Microsoft
Amazon Web Services Inc.
Cloudflare
VIII. Security
At INFUNITY, we implement comprehensive security measures, including technical, managerial, and physical safeguards, to protect the information we collect from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, it must be acknowledged that no internet or email transmission can be guaranteed to be completely secure or error - free. Therefore, while we strive to protect your information, we cannot guarantee the absolute security of any information or communication.
IX. Consent to Transfer
Our services operate globally, which means your information may be stored and processed in the United States and other countries outside of your own. The data protection laws in these countries may differ from those in your country of residence. Additionally, in some cases, law enforcement and national security agencies in these countries may access your data.
By using our services or providing us with any information, you consent to the collection, processing, storage, and transfer of your information in the United States and other countries, where the data protection laws may not provide the same level of protection as those in your country of residence or citizenship.
X. Links to Third-Party Websites
Our services may contain links to websites or services operated by third parties. Please note that we do not control these external websites or services, nor are we responsible for their content or privacy practices. The processing of your information by these third-party websites or services will be governed by their own privacy policies (not our Privacy Policy). We strongly recommend that you review the privacy and security policies of any third party before sharing your information with them.
XI. Changes to This Policy
We reserve the right to update this policy in accordance with changes in legal standards, information processing procedures, or service features. The date of the latest revision will be clearly indicated at the top of this policy. In the event of any significant changes, we will provide you with prominent notice in accordance with the law. By continuing to use our services after any such updates take effect, you are deemed to have accepted the revised policy and agreed to be bound by its terms. We recommend that you regularly review this policy to stay informed of any changes.
XII. Contact Us
If you have any questions about our Privacy Policy or information practices, please contact us via our official website https://infunityai.com or directly send an email to us: info@infunity.com
