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Privacy Policy

Last Updated: June 20, 2025

Effective Date: June 20, 2025

TourlinkAI Inc. (hereinafter referred to as "we" or "our") has established this Privacy Policy to explain how we collect, use, disclose, and protect your information when you use our AI Tour Guide App ("App" or "Service").

By using our Services, you acknowledge that you have read and agree to all terms of this Privacy Policy. If you do not agree to these terms, please immediately cease using or accessing our App. We strongly recommend that you read this policy in detail before taking any action.

To optimize your user experience, we need to process your personal information. If you do not wish to have your personal information processed as described in this policy, or if you are under 13 years of age, please stop using our Services.

We primarily collect and use your information to:

  • Provide and improve our Services and user experience
  • Ensure the security and integrity of the platform
  • Fulfill our legal obligations

When necessary, we will share your information with trusted third parties and service providers to provide services, meet legal requirements, and achieve other purposes detailed later in this policy.

1. Information We Collect

We collect personal information that you provide to us (including basic information such as name, email address, password), user content (any personal information collected when you use our Services, including information provided in inputs, file uploads, feedback, or outputs), and communication content (any communications we exchange, including chatbot interface communications, survey responses, or feedback).

We also automatically collect information, including application, browser, and device information (such as device type, operating system, browser information, IP address, and other device characteristics), service usage data (including activity information, diagnostic and troubleshooting information), and information from cookies and similar technologies. Personal information does not include de-identified, anonymized, or aggregated information, and when data is de-identified or anonymized, we maintain it in that form and do not attempt to re-identify the information.

2. How We Use Your Information

We primarily use your personal information for the following purposes: delivering services, personalizing experiences, operational management, improving services, creating and developing new features, while ensuring you receive a secure, smooth, efficient, and customized experience. Additionally, we also use your information based on legal compliance needs and loss prevention. Rest assured, your account password is only used to create and maintain your account and to provide you with services.

  • Creating and Maintaining Your Account: We use your basic information to create and maintain your account, which is necessary for fulfilling our contract with you.
  • Providing Services: To provide you with services, we use your basic information, communication content, application information, browser and device information, service usage data, and other information you submit to us, which is also necessary for fulfilling our contract with you.
  • Providing Customer Support: When providing customer support, we use your basic information, communication content, service usage data (including location information), application information, browser and device information. We rely on legitimate interests to process this information, particularly the interest in ensuring you can optimally use the Services.
  • Sending Service-Related Communications: We use your basic information, communication content, application information, browser and device information, service usage data, and other information you submit, which is necessary for fulfilling the contract and also based on the legitimate interest of ensuring you can optimally use the Services.
  • Promoting the Security, Integrity, and Protection of the Services: We process your basic information, communication content, application information, browser and device information, service usage data, and other information you submit, based on the legitimate interest of maintaining effective operation and delivery of the Services.
  • Complying with Legal and Regulatory Obligations: We use your basic information, communication content, application information, browser and device information, service usage data, and other information you submit, based on the legitimate interest of complying with laws in the jurisdictions where we operate, responding to requests, and fulfilling corporate responsibilities.
  • Customizing Your Service Experience and Improving Our Services: We process your basic information, communication content, application information, browser and device information, and service usage data, based on the legitimate interest of understanding how users interact with the Services to customize and improve products, and to ensure reports are accurate and reliable.
  • Promoting the Safety and Integrity of the Services, Network, Users, Employees, and the Public: We use your basic information, communication content, application information, browser and device information, and service usage data, based on the legitimate interest of preventing fraud, unauthorized use, violations, protecting the safety of all parties, resolving disputes, verifying accounts, combating harmful behavior, and preventing harm.
  • Research and Innovation Purposes: We use your basic information, communication content, and service usage data, based on the legitimate interest of improving and iterating the Services through user feedback.

3. How and Why We Share Your Information

We commit not to sell or share your personal information with third parties for targeted advertising purposes. Additionally, we have never sold or shared personal information of individuals under 16 years of age for targeted advertising purposes.

To provide the Services, we may need to share necessary information with the following categories of third parties:

  1. Service Supporters: Disclosure of necessary personal information to third-party service providers who assist in providing the Services. For example, we may use data analytics platforms to understand how users interact with our services, optimize user experience and improve our product features. These platforms typically only store event data and do not store any chat data you provide.
  2. User-Initiated Sharing: When you use active sharing features such as conversation links, the information recipients will depend on whom you choose to share with.
  3. Legal Compliance Scenarios: Sharing information with advisors, regulatory bodies, or government agencies in the following situations:
    • Responding to legal and regulatory requirements, court orders, or government requests.
    • Fulfilling statutory obligations and regulatory requirements.
    • Investigating and preventing fraud and security issues.
    • Protecting the rights and personal safety of all parties.
  4. Corporate Account Association: If you register using a corporate email, we may share account existence and basic information (such as email address) with that organization to allow corporate administrators to manage account permissions.
  5. Group Internal Collaboration: Based on service efficiency requirements, information may be shared among affiliated companies or group members.
  6. Asset Transaction Scenarios: During company mergers, acquisitions, reorganizations, bankruptcy, or other changes in control, your information may be transferred as part of the business assets.

4. Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, unless a longer retention period is required or permitted by law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

5. Data Security

We have implemented appropriate technical and organizational security measures designed to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, the transmission of information over the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the absolute security of your personal information transmitted to our App. Any transmission of personal information is at your own risk.

6. Your Rights

Depending on the laws of your jurisdiction, you may have certain rights regarding your personal information. These rights may include:

  • Right to Access: The right to request access to the personal information we hold about you.
  • Right to Rectification: The right to request correction of inaccurate or incomplete personal information.
  • Right to Erasure: The right to request the deletion of your personal information in certain circumstances ("right to be forgotten").
  • Right to Restriction of Processing: The right to request the restriction of processing of your personal information in certain circumstances.
  • Right to Data Portability: The right to receive the personal information you have provided to us in a structured, commonly used, and machine-readable format, and the right to transmit those data to another controller.
  • Right to Object: The right to object to the processing of your personal information in certain circumstances, particularly when processing is based on legitimate interests.
  • Right to Withdraw Consent: If you have provided your consent for us to process your personal information, you have the right to withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of any processing carried out before you withdraw your consent.

To exercise these rights, please contact us using the contact details provided at the end of this policy. We may ask you to verify your identity before responding to your request.

7. International Data Transfers

We may transfer and store your personal information on servers located outside of your country of residence, including but not limited to Hong Kong Special Administrative Region of the People's Republic of China. The data protection laws in these countries may differ from those in your country of residence. By using our Services, you consent to the transfer of your personal information to these countries. We will take appropriate measures to ensure that your personal information receives an adequate level of protection during transfer, for example, by implementing standard contractual clauses or relying on other legal mechanisms.

8. Children's Privacy

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us using the contact details provided at the end of this policy. If we become aware that we have collected personal information from a child under 13 without verified parental consent, we will take steps to delete that information.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. All changes will take effect from the "Last Updated" date indicated at the top of this page. Your continued use of our Services will be deemed acceptance of the updated terms. We encourage you to review this Privacy Policy periodically for any changes.

10. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at [email protected].