Tencent WorkBuddy Privacy Policy

Welcome to Tencent WorkBuddy (“WorkBuddy”)! This Privacy Policy explains the when, how, and why when it comes to the processing of your personal information in connection with the WorkBuddy (the “Service”), and sets out your choices and rights in relation to that information.

There are three platforms through which the Service is available: (1) PC (“Desktop Version”); (2) web (“Web Version”); and (3) mobile (“Mobile Version”). The functionalities of the Service may differ depending on the version you choose to use. This Privacy Policy applies to all three versions; where certain information only applies to a specific version, this will be specified; but in all other cases, the content herein applies to all versions.

For the purposes of data protection laws, the data controller of your personal information in relation to the Service (“we”, “us”, “our”) depends on where you are located:

• Republic of Korea: Tencent Korea Yuhan Hoesa, a Korean registered company located at 152, Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea
• Rest of the world: Tencent Cloud International Pte. Ltd., a Singapore registered company located at 10 Anson Road, #21-07, International Plaza, Singapore 079903

This Privacy Policy does not apply to the enterprise version of WorkBuddy; please see WorkBuddy Enterprise Privacy Policy and Data Processing and Security Agreement for more information.

What is WorkBuddy?

WorkBuddy is an agentic AI software that enables users to issue natural-language instructions to drive AI agents that autonomously plan and execute multi-step complex tasks, delivering ready-to-use work outputs including documents, spreadsheets, presentations, charts, and more. WorkBuddy generates responses and performs automated tasks independently (e.g. browsing the internet, managing files, writing and executing code, creating documents, sending emails and scheduling reminders, etc.). We use various third-party large language models (“LLM”) to support the Service and you may select the specific category of LLM that you would like to use based on their capability, e.g. general purpose, fast thinking, complex tasks etc. The Service allows you to submit text, files, audio, commands, scheduled tasks, and any other documents or instructions (“Inputs”) via the Service or to integrate your chosen instant messaging channel (“Messaging Platforms”). These Inputs are processed by a third party LLM for inference, with the AI-generated responses and actions delivered back to you (“Outputs”).

Depending on the version used, you can also install Skills and various model context protocol (“MCP”) connectors (e.g. GitHub) available through WorkBuddy or from other resources you select to integrate or connect external apps and tools of your choice with the Service.

Please note that this Privacy Policy only applies to the Service. If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service, you are acknowledging how we process your personal information as described in this Privacy Policy and, to the extent performance of a contract or legitimate interest cannot be relied upon in your jurisdiction to process the personal information, you consent to the processing of your personal information as described in this Privacy Policy.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found in Section 7 (Contact) below.

1. Children

Children must not use the Service for any purpose. By children, we mean users under the age of 18 years old or in the case of a region where the minimum age for processing personal information differs, such different age. We do not seek nor knowingly collect personal information from children under 18 for any purpose. If you believe that we have personal information of anyone under the legal minimum age, or if you are the parent or guardian of the user and wish to notify us that a user is under the legal minimum age, please contact us as set out in Section 7 (Contact) below.

2. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

It also identifies the legal basis under which we process your data to the extent required by the data protection laws in your jurisdiction. To the extent the laws in your jurisdiction do not recognize the legal basis of performance of a contract or legitimate interest, you consent to the processing of your personal information for that purpose by consenting to the processing in this Privacy Policy.

Cookies

We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) ("Cookies") to enhance your experience using the Service, including for the Web Version. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all Cookies, or instruct the web browser to provide notice at the time of installation of Cookies, or refuse to accept all Cookies by adjusting the relevant function in the web browser of your computer. However, in the event of your refusal to install Cookies, we may be prevented from providing some features of the Service to you.

For more information about the Cookies we use, please see our Cookies Policy.

3. How We Store and Share Your Personal Information

We have a global platform and may transfer your personal information outside the location in which you are based for the purposes described in the Privacy Policy. Your personal information will be stored in servers in Singapore. We also have global support, engineering, and other teams who support the Service, including from the People’s Republic of China (“PRC”), who may access your personal information for the purposes specified in this Privacy Policy.

To provide the Service, the personal information we collect from you will be transferred to, remotely accessed, locally stored, and/or otherwise processed outside of the jurisdiction in which you are based for the purposes described in this Privacy Policy, including in the aforementioned jurisdictions. When we do so, we will take steps to ensure that your personal information is protected and we implement safeguards where required. Safeguards include standard contractual clauses, adequacy decisions where available, data processing agreements with all third-party data processors, and other contractual safeguards.

We will share your personal information with third parties in the following situations:

• Third parties that provide services in support of the Service, including providers of services that process personal information identified in this policy in our legitimate interests of efficiently providing the Service. For example, we will transfer your personal information to:
  • third-party AI LLM providers that support the Service by processing your Inputs and providing you with Outputs;
  • Messaging Platforms that relay messages between you and the Service, if you choose to interact with the Service through a Messaging Platform;
  • third-party payment processors that process payment instruction data for payment of the Service; and
  • third-party service providers for Skills and MCP Connectors that process personal information in order to provide Skills and MCP Connectors that you have installed or configured on the Service (where such feature is available in the version you use). Please find the Third-Party MCP Connector List here.

Google Workspace API user data: WorkBuddy does not use data obtained through Google Workspace APIs (including Gmail) to develop, improve, or train generalized AI and/or ML models, and does not transfer such data to any third party for those purposes. This applies regardless of whether you have enabled the AI model training setting. WorkBuddy's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

• Third party websites and services: You may choose to integrate the Service with various third-party websites, apps and services (e.g. through API keys, Messaging Platforms or MCP Connectors). If you choose to do so, we will share your personal information with these third-party websites, apps and services in accordance with your instruction. Processing once transferred to such third-party websites and services shall be subject to the third party’s privacy policy.
• Companies within our corporate group who process your personal information in our legitimate interests to efficiently provide the Service. All such group companies may only use your personal information in accordance with this Privacy Policy.
• Regulators, judicial authorities, and law enforcement agencies. There are circumstances in which we may be legally required to disclose personal information about you, such as to comply with legal obligations or processes.
• Third parties to ensure safety, security, or compliance with laws. We may disclose your personal information to: (a) enforce our terms and conditions; (b) detect, prevent, or otherwise address security, fraud, or technical issues; or (c) protect the rights, property, or safety of us, our users, a third party, or the public as required or permitted by law.
• Professional advisors. We may disclose your personal information to auditors, law firms, or accounting firms.
• A third party that acquires all or substantially all of us or our business. We may also disclose your personal information to third parties if we either sell, transfer, merge, consolidate, or reorganize any part(s) of our business.

4. The Security of Your Personal Information

We have information security and access policies regarding access to our systems and technology, and we protect personal information using appropriate technological protection measures such as encryption, hashing, role-based access controls, and audit logs of data access.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted via the internet; any transmission is at your own risk.

5. Data Retention

Please note that we do not keep your data for longer than is necessary to fulfill the relevant purpose described above unless we are required or permitted to do so under law.

6. Your Rights

We offer our users the following rights in respect of your personal information (which you may have a legal right to exercise depending on where you are). Some of these only apply in certain circumstances. You can exercise some of these rights directly by accessing and updating the personal information in your account. Otherwise, you can exercise those rights (including data erasure and relevant opt-outs) by contacting us using the details in Section 7 (Contact) below.

• Access. You may have the right to access personal information we hold about you, how we use it, and who we share it with.
• Portability. You may have the right to receive a copy of certain personal information we process about you.
• Correction. You may have the right to correct personal information we hold that is inaccurate.
• Erasure. You may be able to delete your account, or remove certain personal information, by logging into your Service account or requesting erasure from us.
• Restriction of Processing to Storage Only. You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances).
• Objection. You may have the right to object to our processing of your personal information in certain situations.
• Consent Withdrawal. To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

You also have the right to lodge a complaint directly with us, as well as with the relevant data protection authority in the country you live or work.

7. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: workbuddy_ai@tencent.com

If you wish to opt out of having your Inputs and Outputs used for AI model training and are unable to do so via the toggle button in your settings, you may submit an opt-out request by emailing us at workbuddy_ai@tencent.com.

We will endeavor to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the jurisdiction in which you live or work where you think we have infringed data protection laws.

8. Third-Party Websites and Links

We may provide links or access to third-party websites, services and features as part of the Service. If you follow links to sites or platforms or enable features (such as Skills or MCP Connectors) that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Our inclusion of such links or access to such features does not, by itself, imply any endorsement of the content on such platforms, the operation of such features, or of their owners or operators.

9. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

10. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

Our Representatives in Certain Jurisdictions

11. Jurisdictional Addendum

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Algeria

By using the Service, you give your consent to the collection, storage, treatment and use of your personal information, and transfer of your personal information to third parties or our affiliates to help us deliver the Service, in each case location in the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

Argentina

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the Service, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients. You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.

If you are under the age of 18, you must not use the Service.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and in-Service purchases.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Bangladesh

By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in Section 7 (Contact). This may affect our provision of the Service to you.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 7 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Colombia

Your authorization to process personal information for the Service may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information. You can contact us to exercise any of these rights, using the information specified in Section 7 (Contact).

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

You may also consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

France

Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, the heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us as set out in Section 7 (Contact).

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Where we permit any third parties to collect and use sensitive personal information, we shall use reasonable measures to ensure that the third parties do not further disclose such information to the extent required by applicable laws.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us as set out in Section 7 (Contact). Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service. Where the processing of your personal data is not based on consent, our processing is based on certain legitimate uses as permitted under law and in compliance with applicable law.

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

If you are under the age of 18, you must not use the Service.

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

If you are under the age of 18, you must not use the Service.

By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

The categories of personal information specified in to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 7 (Contact).

Kazakhstan

If you are under the age of 18, you must not use the Service.

By clicking “accept”, you consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information as described in this Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore and the PRC.

In the event of any discrepancy or inconsistency between the English version and the Kazakh version of this Privacy Policy, the Kazakh version shall prevail.

Your Rights

• Right of access: You have the right to request access to and obtain a copy of the personal information we have process about you or that is being processed on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

• Right to correction: You may request for the correction of your personal information or delete such personal information if it is impossible to correct it. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.
• Right to blocking / de-blocking: You have the right to request the blocking of personal information related you, if you become aware of a violation regarding the collection and processing your data. If the violation has not been proved, you may request to de-block your data.
• Right to deletion: You have the right to request deletion of your personal data if the collection and processing of your data has been conducted in violation of Kazakh laws.
• Processing of your personal information in public sources of personal data: You may request to limit or provide your consent on the processing of your personal information in public sources of personal data.

Kingdom of Saudi Arabia

How We Store and Share Your Personal Information

Your personal data may be transferred abroad and to third parties as follows:

Transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

Your Rights

You have the right to be informed about our processing of your personal information, which we satisfy by providing this Privacy Policy to you. You also have the following rights as further described in Section 6 (Your Rights): the right to access, correction, erasure, restriction and to withdraw consent. Unless otherwise stipulated by law in Saudi Arabia, you will not be required to pay any fees in return for exercising these rights. We will respond to your request within 30 days of receiving it. Where you wish to make such requests, please contact us as set out in Section 7 (Contact).

You also have a right to lodge a complaint with the Saudi Data and Artificial Intelligence Authority by contacting them directly. Their website is accessible at: www.sdaia.gov.sa

Data Destruction

Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

Kuwait

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information:

• Telephone: +603-22872388
• Other Contact: see Section 7 (Contact).

Mexico

Some of the purposes of processing specified in Section 3 (How We Store and Share Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising.

In general, we do not require your consent to carry out the transfers detailed in Section 3 (How We Store and Share Your Personal Information). In any case, by using the Service and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us as specified in Section 7 (Contact).

Morocco

We collect information for purposes strictly necessary for the proper use of the Service. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Service.

Kindly note:

• the identity of the Data Controller is set out at the beginning of this Privacy Policy
• the purposes of processing personal data are set out in Section 2 (How We Process Your Personal Information)
• recipients or categories of recipients are set out in Section 3 (How We Store and Share Your Personal Information)
• whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 2 (How We Process Your Personal Information) and Section 6 (Your Rights)

New Zealand

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to request the correction of any of your personal information we hold that is inaccurate.

If you are under the age of 16, you must not use the Service.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, pursuant to the Personal Data Protection Law (the “Law”). You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

• Data Protection Team, responsible for the management and safety of your personal information
• Contact: as set out in Section 7 (Contact)

Philippines

You are entitled to the following rights:

• Right to be informed. You may in certain circumstances have the right to be informed whether personal information pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
• Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
• Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
• Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
• Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy, you consent to us:

• collecting and processing your personal information as described in Section 2 (How We Process Your Personal Information);
• sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
• transferring or storing your personal information in destinations outside the Philippines when the processing shall need to occur outside the Philippines, as described in Section 3 (How We Store and Share Your Personal Information).

Republic of Korea

Collection and Use of Personal Information

We collect your personal information for the purposes described in this Privacy Policy. Personal information that we collect from Republic of Korea is stored in and processed on our server located in Singapore.

With regards to the legal basis of processing personal information included in Section 3 “How We Process Your Personal Information,” the following legal provisions under the PIPA applies:

• (for consent): we use this information pursuant with your consent, pursuant to Article 15(1)(1) of the PIPA.
• (for complying with legal obligations): we use this information where necessary to comply with a legal obligation pursuant to Article 15(1)(2) of the PIPA.
• (for contractual necessity): we use this information where necessary to perform our contract with you to provide our Services, pursuant to Article 15(1)(4) of PIPA.

Delegation of Personal Information

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information detailed in section “Data Retention” are required to be retained pursuant to the following laws:

Your Rights

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, or objecting to or requesting an explanation on an automated decision concerning your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act (“PIPA”). You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Measures to Ensure Safety of Personal Information

We implement the following measures to ensure safety of your personal information:

• Managerial measures: establishment and implementation of internal management plan, operation of dedicated organization, regular employee training
• Technical measures: management of access rights to the personal information processing system, installation of an access control system, encryption of personal information, and installation and renewal of security programs
• Physical measures: access control of computer rooms, data storage rooms, etc.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

• Data Protection Department, responsible for the management and safety of your personal information
• Telephone: +82-2-2185-0926
• Email: specified in Section 7 (Contact)

Remedies for Infringement of Rights and Interests

In order to seek remedies for personal information infringement, you may file an application for dispute resolution or consultation with the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency's Personal Information Infringement Reporting Center, etc. In addition, you may contact the following institutions for other reports and consultations on personal information infringement:

• Personal Information Dispute Mediation Committee: (no area code required) 1833-6972 (www.kopico.go.kr)
• Personal Information Infringement Report Center: (no area code required) 118 (privacy.kisa.or.kr)
• Supreme Prosecutors’ Office: (no area code required) 1301 (www.spo.go.kr)
• National Police Agency: (no area code required) 182 (ecrm.cyber.go.kr)

Qatar

If you are using the Service in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 3 (How We Store and Share Your Personal Information).

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 7 (Contact).

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Sri Lanka

By clicking “accept”, you consent to the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you must not use the Service.

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on the Service platform. If you are under 7 years of age, please do not attempt to use or register for our Service or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Service. In the case of users located in Taiwan, persons under the age of 20 shall not use the Service.

Thailand

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as follows and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

• Name: Tencent (Thailand) Company Limited
• Address: 8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand

If you are under the age of 20, you must not use the Service.

Türkiye

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

• learn whether or not your personal data has been processed;
• request information about processing if your personal data has been processed;
• learn the purpose of processing of your personal data and whether they have been used accordingly;
• know the third parties in the country or abroad to whom personal data has been transferred;
• request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
• request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
• object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
• demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries or regions other than Ukraine, to the extent and for the purposes provided in this Privacy Policy.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

United States

Residents of certain US states, such as California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, and other states to the extent they enact similar privacy laws, may have additional rights under their corresponding state laws.

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”) and other similar laws (collectively, “US State Laws”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:

• Identifiers, such as your username, third-party login identifiers, IP address, device ID, avatar, email address, and username/nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
• Internet or other electronic network activity information, such as your information regarding your use of the Service, date and time stamps, log data, and application and performance metrics. This information is collected directly from you and your device.
• Commercial information about any transactions within the Service such as purchased token information and billing information. This information is collected directly from you and your device.
• Geolocation information such as approximate location derived from your IP address. This information is collected directly from your device.
• Audio and visual information such as photos shared in the Service, and voice or audio Input you provide to the Service. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
• Account access credentials* such as account log-in information used to access your Service account, including credentials associated with third-party login providers you use to sign in.
• Contents of your Inputs sent on the Service*such as text prompts, voice/audio input, files and content you upload, instructions you submit during chat, coding, and agentic sessions, conversation records, generated responses and actions, information returned through MCP Connectors from third-party applications you authorize, and any personal information you choose to embed in those Inputs. If your Inputs include personal information categories listed in the California Customer Records statute (such as your address and phone number), characteristics of protected classifications under California or federal law (such as national origin, gender, or age), or professional or employment-related information such as your profession, we will also process this information, and this will be collected directly from you in the context of being our consumer.

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

• to provide you with the Service, maintain your account, provide customer service, and process payments;
• to improve our services, including the functionality of the Service;
• to provide you with marketing communications and personalized recommendations if you choose to receive marketing information;
• for security and verification purposes, including to prevent and detect fraudulent activity;
• to address and remediate technical issues and bugs; and
• to fulfill our legal obligations.

For additional information about what each type of personal information is used for, see Section 2 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect as described in Section 3 (How We Store and Share Your Personal Information).

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see Section 5 (Data Retention).

Rights under the U.S. State Laws

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format. If you are a California resident, you may request:
  • the categories of personal information about you that we collected;
  • the categories of sources from which the personal information was collected;
  • the business or commercial purposes for collecting personal information about you;
  • the categories of third parties to whom we disclosed your personal information and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing; and
  • the specific pieces of personal information we collected about you;
• Request to Delete. Request we delete personal information we collected about you;
• Request to Correct. Request we correct inaccurate personal information that we maintain about you; and
• Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights by contacting us as specified in Section 7 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, if we deny your rights request, you may have the right to appeal our decision by contacting us through the methods described above. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 7 (Contact).

Vietnam

By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.