Privacy Policy

Shanghai Whalesbot Technology Co., Ltd. is a limited liability company established in accordance with the laws of the People's Republic of China (hereinafter referred to as "Whalesbot" or "we", including its parent company, subsidiaries, affiliated companies, etc.). We value the maintenance and protection of users' personal information. When you use Whalesbot's websites, software, applications, products, or related services (collectively referred to as the "Services"), we may collect and use your personal information. This Privacy Policy is intended to explain to you how we collect, store, use, or share your personal information. We hope you will carefully read this Privacy Policy so that you can make appropriate choices when necessary.

Your use or continued use of Whalesbot's products or services means that you agree to our collection, storage, use, and sharing of your personal information in accordance with this Privacy Policy.

We solemnly promise to protect your privacy, including information we collect intentionally or automatically. Please note that we will never send you spam, compromise your confidentiality, or share your personal information with third parties without your prior consent. We commit to strictly keeping your personal information confidential for five years during the signing and performance of the agreement and after the agreement is fully executed. Additionally, after the termination of the cooperative relationship, we will properly handle the obtained confidential information in accordance with relevant laws, regulations, and mutual agreements, including but not limited to returning or destroying the relevant information to ensure information security. However, in the case of a merger, acquisition, or other business transaction, customer information may be transferred, and we will ensure that your consent is obtained in advance in such cases. If you suffer economic losses due to our failure to collect, store, use, or share your personal information in accordance with the privacy policy, we will compensate you based on the actual situation, but the compensation amount will not exceed twice the total amount of fees you have paid to us in the past 12 months.

I. Types of Information We Collect

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

(1) Personal Information You Provide to Us

SN Information
• Purpose of collection: Device Identification and Management: The SN (Serial Number) is a unique identifier for the device. We collect it to identify the device you use, enabling us to quickly locate the specific device and provide you with more efficient technical support and troubleshooting services when you encounter device-related issues (such as software malfunctions, compatibility problems, etc.). Security Assurance: Through the device serial number, we can detect security risks such as abnormal login and malicious attacks on the device, and take timely measures to protect the security of your account and personal information, preventing others from stealing your device for illegal activities. Service Optimization: We analyze the usage of the device and understand the operation status of the APP on different devices to optimize the APP and improve the overall user experience, such as adapting functions and optimizing performance for specific device models. ;
• Method of collection: When you install and launch our APP on your device, the APP will automatically obtain the device's SN through legal system interfaces, on the premise that you authorize the application to access device information permissions. We will not collect this information through illegal means or without your authorization.;
• Scope of collection: We only collect the SN of the device you use, and will not collect serial number information of other devices. Nor will we associate the collected SN with your other sensitive personal information (such as name, ID card number, bank card number, etc.) unless we obtain your explicit authorization.;
Android ID
• SDK Name: Umeng Mobile Analytics SDK;
• Purpose of Use: Conduct APP data statistics and analysis.;
• Operator: Umeng Tongxin (Beijing) Technology Co., Ltd.;
• Type of Personal Information Collected: Device information (Android ID/IDFA/OAID/OpenUDID/GUID;
• Privacy Policy Link: https://www.umeng.com/page/policy;
Jiguang Security Authentication SDK
• SDK Name: Jiguang Security Authentication SDK;
• Purpose of Use: To implement the Jiguang One-Click Login function, provide users with a convenient login experience, and ensure the security and stability of the login process.;
• Operator: Shenzhen Hexun Huagu Information Technology Co., Ltd.;
• Types of Personal Information Collected: Device identifiers (such as IMEI, Android ID, IDFA, etc., subject to different operating systems), device hardware information (device model, device screen resolution, device hardware manufacturer, etc.), operating system information (operating system version, system name, system language), network information (network type, SSID, BSSID, etc.);
• Privacy Policy Link: https://www.jiguang.cn/license/privacy;
User's Country
• Purpose of collection: Integration of Hardware AI Screen;
• Method of collection: Synchronized after you actively fill it in the APP.;
• Scope of collection: Only collects the country you select yourself.;
Username
• Purpose of collection: Used to identify you in the APP and facilitate your display to other users.;
• Method of collection: Synchronized after you actively fill it in the APP.;
• Scope of collection: Only collects the username information you set yourself.;
Avatar
• Purpose of collection: Used to display your personal image in the APP.;
• Method of collection: Synchronized after you actively upload it in the APP.;
• Scope of collection: Only collects the avatar image information you upload yourself.;
Gender
• Purpose of collection: Helps us better understand user group characteristics.;
• Method of collection: Synchronized after you actively select and fill it in the APP.;
• Scope of collection: Only collects the gender information you select yourself (male, female, other).;
Date of Birth
• Purpose of collection: Helps us better understand user group characteristics.;
• Method of collection: Synchronized after you actively select and fill it in the APP.;
• Scope of collection: Only collects the date of birth information you fill in yourself.;
AI Screen Chat Data
• Purpose of collection: To provide you with more accurate and personalized learning support and services, and optimize product user experience, specifically used for generating exclusive learning reports, optimizing AI robot interaction experience, and improving the adaptability of learning-related services; additionally, upon your authorization, behavioral features extracted from chat data (such as interaction rounds, chat topics, and active initiation ratio) will be used to generate the "Interactive Growth Report." The report will only display AI-summarized topic names and interaction counts; no original conversation content will be shown.;
• Method of collection: Automatic collection. During your chat with the physical AI robot, the system will record conversation data in real time (including text and speech-to-text content) without requiring manual submission from you. Collection will only start after you explicitly authorize it; no chat-related data will be obtained without authorization.;
• Scope of collection: Only collects necessary information related to learning, including core conversation content (communication records related to learning knowledge, skill practice, and problem-solving), learning-related feedback (level of understanding of learning content, confusion points, satisfaction, etc.), and basic chat operation data (chat initiation time, interaction duration, etc.); does not include sensitive personal information, irrelevant casual chat content, private life topics, or other unrelated data; when used for the Interactive Growth Report, only behavioral feature data (interaction rounds, topic categories, active initiation ratio) is extracted, and original conversation text is not extracted.;
AI Screen Painting Data
• Purpose of collection: To provide you with painting creation records and personalized creative support, and optimize the AI robot painting interaction experience; upon your authorization, behavioral features extracted from painting data (such as number of creations and painting topics) will be used to generate the "Interactive Growth Report." The report will only display AI-summarized topic names, creation counts, and up to 3 painting thumbnails; no original records of the painting creation process will be displayed.;
• Method of collection: Automatic collection. When you use the physical AI robot's painting function, the system will record painting creation data (including painting images, painting duration, and painting topic categories) without requiring manual submission from you. Collection will only start after you explicitly authorize it; no painting-related data will be obtained without authorization.;
• Scope of collection: Only collects necessary information for painting creation, including painting images (thumbnails only, up to 3 displayed in the report), painting topic categories (fixed topic names generated by AI), number of paintings, and creation duration; does not include drafts, intermediate versions, or other non-final artwork data; when used for the Interactive Growth Report, only behavioral feature data (number of creations, topic categories) is extracted, and complete painting content is not extracted.;
AI Screen Recognition Data
• Purpose of collection: To provide you with object recognition records and exploration learning support, and optimize the AI robot recognition interaction experience; upon your authorization, behavioral features extracted from recognition data (such as number of recognitions and recognition topics) will be used to generate the "Interactive Growth Report." The report will only display AI-summarized topic names and recognition counts; no original images of recognized objects or detailed recognition results will be displayed.;
• Method of collection: Automatic collection. When you use the physical AI robot's recognition function, the system will record recognition behavior data (including recognized object IDs, recognition duration, and recognition topic categories) without requiring manual submission from you. Collection will only start after you explicitly authorize it; no recognition-related data will be obtained without authorization.;
• Scope of collection: Only collects necessary information for recognition behavior, including recognition topic categories (fixed topic names generated by AI), number of recognitions, duration of each recognition, and number of repeated recognitions of the same object; does not include original images of recognized objects, detailed descriptions of recognition results, or other privacy-sensitive content; when used for the Interactive Growth Report, only behavioral feature data (number of recognitions, topic categories, duration) is extracted, and recognition images and detailed results are not extracted.;
Emotion Classification Data
• Purpose of collection: During your chat interactions with the AI robot, the system classifies each interaction content by emotion (positive/negative/neutral), which is used to generate the "Happiness" star rating in the "Interactive Growth Report." Emotion classification only outputs emotion category labels (such as "happy," "excited," "calm," etc.) and does not save or replay any original conversation content.;
• Method of collection: Automatic collection. The AI emotion classification engine processes chat interaction content in real time, instantly outputting emotion category labels. Original content is discarded after processing, and only classification label results are retained; emotion classification statistics are only initiated after you authorize the Interactive Growth Report; no emotion classification summary is performed without authorization.;
• Scope of collection: Only collects emotion classification label results, including emotion categories (9 positive types: happy, excited, satisfied, joyful, delighted, grateful, appreciative, proud, optimistic; 12 negative types: angry, sad, fearful, disgusted, disappointed, depressed, anxious, annoyed, irritable, confused, exhausted, upset; 1 neutral type: calm) and the occurrence count and proportion of each category; absolutely does not collect, save, or replay original conversation text, voice content, or any personally identifiable information.;
Interactive Growth Report Authorization Information
• Purpose of collection: To verify your identity and obtain your explicit authorization for the data collection of the "Interactive Growth Report," ensuring that only parents/guardians can complete the authorization process (preventing children from authorizing on their own); once authorization is completed, both parents and children may view the report.;
• Method of collection: When you tap the "Interactive Report" button on the APP's "Device Management" page, the system automatically carries your logged-in mobile phone number or email address (which cannot be modified), sends a verification code to that phone number/email, and you complete authorization by entering the verification code and checking your agreement to this Privacy Policy and the "Interactive Growth Report Data Collection and Usage Notice.";
• Scope of collection: Only collects your logged-in account (mobile phone number or email address), verification code verification records, authorization time, and authorization status; does not collect your password or other sensitive identity information; authorization status can be turned off at any time in the APP's "Settings."

Interactive Growth Report Data Collection and Usage Notice

The "Interactive Growth Report" is a visual growth report dynamically generated by AI large language models based on your child's three types of interaction data with the AI robot: chat, painting, and recognition. To ensure your privacy rights, we specially declare the following:

(2) Transaction Information You Provide to Us

To fully benefit from our services, you may be required to provide necessary personal identification information that enables us to contact you directly. Personal identification information includes an email address, name, postal address, telephone number, or persistent identifier (such as a customer number held in a cookie) associated with personal identity information. If you refuse to provide necessary personal identification information or cooperate with identity verification, we reserve the right to refuse service.

To protect your privacy, we will implement steps to verify your identity before granting access to your data, such as requiring a password and username.

(3) Location-Based Information

We may collect information about your general location based on information you are willing to provide to us and the IP address of your computer. We can also detect when your terminal device is activated. We may collect data to verify information you manually provide and correlate it with location-based information for our internal use and to improve the user experience.

(4) Access Data

Website access data is completely anonymous information about how our website operates. Information we may collect includes:

• The date and time you access our platform;
• Your Internet service provider, mobile carrier, or data service provider;
• Your Internet Protocol (IP) address;
• The web pages you visit;
• The links you click;
• How and when you interact with the Services;
• The content, images, and advertisements you select.

Some web browsers have a "Do Not Track" feature that allows you to tell websites that you do not want your online activities tracked. Our website is not currently configured to respond to these signals.

(5) Account Cancellation

In accordance with the provisions of the Personal Information Protection Law of the People's Republic of China, you have the right to apply for the cancellation of your account in this APP (you must ensure that the account is in normal status, has no pending business, and that you are the legitimate user of the account). You can follow these steps to proceed: Open the APP, go to "Me - Settings" and select "Cancel Account". Complete identity verification by receiving a verification code via your registered mobile phone number or a verification link via your registered email. After confirming the consequences of cancellation and submitting the application, the system will complete the cancellation immediately and send a success notification to your original mobile phone number/email. Account cancellation is irreversible. After cancellation, you will no longer be able to use the account or its associated rights and interests. This APP will immediately delete all personal information associated with the account (information required to be retained by laws and regulations will be anonymized), including all data from the Interactive Growth Report; please back up important data yourself before cancellation. This APP shall not be liable for any data loss caused by cancellation; your verification information and application records during the cancellation process will be strictly kept confidential and used only for cancellation review.

II. How We Use Cookies and Similar Technologies

(1) File Storage

To ensure the operation of our software, we may access and store software information on your computer or mobile device. We will not use this information for any purpose other than those described in this policy.

(2) Web Beacons and Pixel Tags

We also use other similar technologies such as web beacons and pixel tags on our websites and apps. For example, emails we send you may contain URLs linked to content on our website.

(3) Bluetooth

Bluetooth technology is an open global specification for wireless data and voice communication. It is based on low-cost, short-range wireless connections and is a special short-range wireless technology connection that establishes a communication environment for fixed and mobile devices. When you use Whalesbot's products or services, you need to turn on the device's Bluetooth permission to connect to the product.

When you use Whalesbot's products or services, you need to turn on the device's Bluetooth permission to connect to the product.

(4) Camera

We may use the camera to capture images for the adventure maps in our app. The image information is only used for map recording, and we strictly protect the security of privacy data.

III. How We Share Your Personal Information

We will not share your personal information with any company, organization, or individual outside of Shanghai Whalesbot Technology Co., Ltd. and its affiliated parties, except in cases where our intentional or gross negligence causes your property damage, or when required by law, regulatory authorities, or other legal and compliant circumstances. Additionally, for the definition of force majeure, we specifically refer to the following situations: natural disasters (such as earthquakes, floods, typhoons, etc.), government actions (such as changes in laws and regulations, government bans, etc.), social abnormal events (such as wars, riots, strikes, etc.), and other objective situations that cannot be foreseen, avoided, or overcome. Unless prohibited by applicable law, we will detail how we use your information below:

• To provide you with the products and services you request.
• To communicate with you regarding your account or transactions with us and to send you information about the features of our website and applications or changes to our policies.
• To detect, investigate, and prevent possible violations of our policies or illegal activities.

Regarding Interactive Growth Report data, we specifically declare: Interaction behavioral feature data (topics, rounds, duration, emotion labels, etc.) is only used to generate growth reports within the scope of your authorization and will not be shared with any third party for advertising, commercial recommendations, or other unauthorized purposes. Data will only be provided as required by law or regulatory authorities.

In the event of a merger, acquisition, or any other business transaction, customer information may be transferred. We will ensure that your consent is obtained in advance in such cases and will notify you of any changes in ownership or control via email or on our website.

In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take to address it, suggestions you can take to protect yourself and reduce risks, and remedies available to you. We will promptly notify you of relevant incident information via email, letter, telephone, push notification, or other means. When it is difficult to notify each individual information subject, we will publish an announcement in a reasonable and effective manner.

At the same time, we will also actively report the handling of the personal information security incident to regulatory authorities as required.

IV. Protecting Your Personal Information

We have implemented security measures to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, data exchanged between your browser and the "Services" (such as credit card information) is protected by SSL encryption; we also provide a secure browsing mode for our software app; we use encryption technology to ensure data confidentiality; we use trusted protection mechanisms to prevent malicious attacks on data; we deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we conduct security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.

Regarding the security protection of Interactive Growth Report data, we specifically note:

• Interaction behavioral feature data (topics, rounds, duration, emotion labels, etc.) is encrypted and stored on servers within China, with SSL encryption protection during transmission;
• Original interaction content (chat transcripts, original recognition images, original paintings) only exists briefly in memory during real-time processing, is immediately discarded after behavioral features are extracted, and is not written to disk or stored long-term;
• The emotion classification engine processes content and outputs labels instantly; original conversation text is not stored, replayed, or transmitted to any third party;
• The authorization process for the Interactive Growth Report is restricted to parents/guardians only; children cannot authorize on their own; once authorization is completed, both parents and children may view the report, and the report content is desensitized and child-safe;
• The authorization verification code is sent to the parent's logged-in account; the account cannot be modified; the verification code is valid for 5 minutes, with a maximum of 5 sending attempts per person per day.

We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for the period necessary to achieve the purposes described in this policy, unless a longer retention period is required or permitted by law.

The Internet is not an absolutely secure environment, and communication methods such as email, instant messaging, and interactions with other app users are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use a complex password to help us ensure the security of your account.

V. Right to Opt-Out

When you decide to contact us, we may occasionally choose to include you in our email list to provide information about our products, updates, and one-on-one discussions with our support team.

However, you still have full rights and freedom to stop interacting with us and stop receiving our news. To do so, please select the "Opt-Out" option or "Unsubscribe" button on any communication channel we use to contact you.

Interactive Growth Report Authorization Management

Regarding the "Interactive Growth Report," you have the following rights:

• Enable Authorization: Tap the "Interactive Report" button in the APP's "Device Management," complete identity verification via verification code, and check your agreement to the relevant policies to complete authorization; data collection begins the day after authorization;
• Disable Authorization: You may turn off the Interactive Growth Report authorization at any time in the APP's "Settings"; once turned off, data collection stops immediately; a second confirmation is required when turning off to prevent accidental operation;
• Re-enable: Within 7 days of turning off authorization, you can re-enable it directly (without re-verification); after 7 days, the authorization verification process must be repeated;
• Data Deletion: You may request deletion of generated Interactive Growth Report data by contacting customer service (service@whalesbot.com); we will complete the deletion within 15 business days and notify you;
• Account Cancellation: Upon account cancellation, all Interactive Growth Report data is immediately deleted and cannot be recovered.

VI. Privacy Policy for Children and Minors

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

Our products, websites, and services are designed for both adults and minors. Minors may not create their own user accounts without the consent of a parent or guardian.

In cases where personal information of minors is collected with parental consent, we will only use or publicly disclose such information when permitted by law, explicitly consented to by the parent or guardian, or necessary to protect the minor.

Although the definition of a child varies according to local laws and customs, we consider anyone under the age of 14 to be a child.

If we discover that we have collected personal information from a child without prior verifiable parental consent, we will immediately stop processing the information and take the following measures: 1) Contact the parent or guardian as soon as possible to obtain their explicit consent; 2) If consent cannot be obtained, we will delete the relevant information and notify the parent or guardian within a reasonable time; 3) Record the incident and conduct an internal review to prevent similar incidents from occurring again. At the same time, we are not responsible for the leakage or improper use of minors' information caused by third-party actions or other force majeure factors. Additionally, when processing minors' information, we will adopt a dual verification or manual review mechanism to ensure the authenticity and validity of the consent.;

Interactive Growth Report Children's Protection Special Notice:

• The authorization process for the Interactive Growth Report is restricted to parents/guardians only; children cannot complete authorization on their own (the verification code is sent to the parent's account and the account cannot be modified); once authorization is completed, both parents and children may view the report; the "For Your Little One" section in the report is specifically designed for children, using fun and encouraging language without exposing any privacy;
• The authorization verification code is sent to the parent's logged-in mobile phone number or email; the account cannot be modified, preventing children from completing the authorization process on their own;
• The report does not contain any original conversation content, original recognition images, or personally identifiable information about the child, ensuring that even when children view the report directly, they will not encounter sensitive content;
• Emotion classification data is not used to assess children's mental health or emotional status; it is solely for counting positive signals of the interaction experience;
• Ability scores (Curiosity, Creativity, Expressiveness, Observation) are purely encouraging, with a minimum of 60 points, and are not compared with any other children; no rankings are generated, ensuring children will not feel anxious even when viewing the report themselves.

Minors:

1. If you are a minor under the age of 18, you should carefully read and agree to this agreement under the supervision and guidance of your guardian and with the guardian's consent before using this software and related services. If your guardian does not give consent, the guardian can contact our company's official customer service contact information to notify us to handle the relevant account. Our company has the right to restrict the functions and use of the relevant account, including but not limited to browsing, posting information, and interactive communication functions.
2. Our company attaches great importance to the protection of minors' personal information. When filling in personal information, minor users should strengthen their personal protection awareness and be cautious, and should use this software and related services correctly under the guardian's consent and guidance.
3. Minor users and their guardians understand and confirm that if you violate laws, regulations, or the content of this agreement, you and your guardian shall bear all legal responsibilities that may arise therefrom in accordance with the law.
4. Special Reminder for Minor Users

• Minors should use this software and related services under the supervision and guidance of their guardians, learn to use the Internet correctly within a reasonable range, and develop good Internet habits;
• Teenage users must abide by the "National Youth Network Civilization Convention";
• Be good at online learning and do not browse bad information;
• Communicate honestly and friendly, and do not insult or defraud others;
• Strengthen self-protection awareness and do not casually meet netizens;
• Maintain network security and do not disrupt network order;
• Maintain physical and mental health and do not indulge in virtual reality.

6. To better protect the privacy rights and interests of minors, our company specifically reminds you to carefully post content containing minors' materials. Once posted, it is deemed that you have obtained the consent of the rights holder to display the minors' portraits, voices, and other information in this software and related services, and allow our company to use and process such content related to minors in accordance with this agreement.
7. Special Reminder for Guardians

• If your ward uses this software and related services, as the guardian, you should guide and supervise the ward's registration and use behavior. If your ward applies to register for this software account, our company will have the right to assume that they have obtained your consent;

VII. How Your Personal Information Is Transferred Globally

Personal information collected and generated by us within the People's Republic of China will be stored within the People's Republic of China. Interactive Growth Report data is likewise stored on servers within the People's Republic of China and is not subject to cross-border transfer.

VIII. How This Privacy Policy Is Updated

This Privacy Policy is effective as of June 17, 2026. We reserve the right to modify this Privacy Policy at any time. If changes are made, we will post the latest Privacy Policy on our website. Any changes to this Privacy Policy will require your explicit authorization and consent and will take effect from the date of publication. For changes involving the scope of Interactive Growth Report data collection, usage methods, or authorization mechanisms, we will notify you separately via APP push notifications or pop-up prompts and require you to re-confirm your authorization.

IX. Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, or need to exercise your data rights (including viewing, deleting, or disabling authorization for Interactive Growth Report data), please contact us via email: service@whalesbot.com