This Privacy Policy describes how XTEC LABS PTE. LTD. ("we", "us", or "our"), the operator of the xiaoling mobile application and the website xiaoling.io (collectively, the "Service"), collects, uses, discloses, and protects your personal information.

By using xiaoling, you agree to the practices described in this Policy. If you do not agree, please do not use the Service.

1. Who We Are

2. Information We Collect

2.1 Information You Provide

• Account Information: Email address, name (optional), profile preferences when you sign in via Sign in with Apple or email.
• Conversational Content: The messages you send within the AI dialogue feature.
• Reflective Inputs: Birth date, location, time of birth, or any details you voluntarily provide for astrology, I Ching, or related reflective experiences.
• Payment Information: If you subscribe, payment is processed by Apple App Store. We do not receive or store your full payment card details.
• Support Communications: Information you provide when contacting our support team.

2.2 Information Collected Automatically

• Device Information: Device model, operating system version, language, time zone, anonymous device identifiers.
• Usage Information: Features used, session duration, frequency of use, in-app navigation patterns, crash logs.
• Approximate Location: Derived from IP address; we do not collect precise GPS location unless you explicitly grant permission.

3. How We Use Your Information

• To provide and personalize the xiaoling experience, including AI-generated reflections.
• To improve our AI safety guardrails (we may review conversational data in anonymized form to refine content moderation, prevent harmful outputs, and improve quality).
• To process subscriptions and provide customer support.
• To send service-related communications (account verification, security alerts, important policy updates).
• To detect, prevent, and address fraud, abuse, security issues, or violations of our Terms.
• To comply with legal obligations.

4. AI-Generated Content Disclosure

xiaoling uses third-party large language model providers to generate conversational responses. All AI-generated content is for entertainment and self-reflection purposes only. It does not constitute medical, psychological, financial, or legal advice. We have implemented content safety measures to reduce harmful or misleading outputs, but we cannot guarantee that all AI responses will be appropriate or accurate.

5. How We Share Your Information

We do not sell your personal information. We share information only in the following limited circumstances:

• Service Providers: Cloud hosting (e.g., AWS, Cloudflare), AI model providers (e.g., OpenAI, Anthropic, domestic Chinese providers as applicable), payment processors (Apple), analytics providers — strictly to perform services on our behalf under contractual confidentiality obligations.
• Legal Compliance: When required by law, subpoena, court order, or governmental request; or to protect rights, safety, and security.
• Business Transfers: In connection with a merger, acquisition, or transfer of all or part of our business assets, with notice to affected users.
• With Your Consent: Any other sharing with your explicit consent.

6. International Data Transfers

Your information may be processed and stored in Singapore, the United States, the European Union, mainland China, and other regions where our service providers operate. Where required, we use standard contractual clauses or equivalent legal mechanisms to safeguard cross-border data transfers.

7. Data Retention

• Conversation history: retained until you delete it; default automatic deletion after 90 days of inactivity (configurable in app settings).
• Account information: retained while your account is active; deleted within 30 days of account deletion.
• Anonymized analytics: may be retained indefinitely.
• Legal compliance records: retained as required by applicable law.

8. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of your personal information.
• Correction: Update or correct inaccurate information.
• Deletion: Request deletion of your account and associated data.
• Portability: Receive your data in a structured, commonly used format.
• Restriction / Objection: Limit how we process your information.
• Withdraw Consent: Where processing is based on consent.

To exercise these rights, contact us at [email protected]. We will respond within 30 days.

9. Children's Privacy

xiaoling is not intended for users under the age of 17. We do not knowingly collect personal information from individuals under 17. If we become aware that we have collected such information, we will delete it promptly. If you believe a minor has provided us with personal information, please contact [email protected].

10. Crisis & Mental Health Notice

xiaoling is not a substitute for professional mental health support. If you are experiencing a crisis, please contact qualified professionals or local emergency services. We will route certain crisis-related queries to professional resources rather than to AI responses.

11. Security

We employ administrative, technical, and physical safeguards designed to protect your information, including encryption in transit and at rest. However, no system is completely secure, and we cannot guarantee absolute security.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified through in-app notices or email at least 14 days before they take effect. The "Effective Date" at the top of this Policy indicates the most recent revision.

13. Contact

For any questions, requests, or concerns regarding this Privacy Policy, please contact:

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