Privacy Policy

1. Introduction

OceanPath Tech ("we", "us", or "our") operates the AI Girlfriend mobile application (the "App"). This Privacy Policy explains what data the App collects, how it is collected, every purpose for which it is used, which third parties receive it, how long it is kept, and how you can control it. Please read this Privacy Policy carefully. Where your consent is required, the App asks for it explicitly before the relevant feature is used (see Section 11).

The App does not require an account. We do not collect your name, email address, phone number, or any other identifier that could link the data described below to you.

2. AI Data Sharing at a Glance

The App relies on third-party AI providers to generate replies, voice, and character images. The table below summarizes exactly what is sent, to whom, where it is processed, and why. Full details for each provider are in Section 5.

None of this data is accompanied by your name, email address, phone number, device identifier, or account information, because the App does not collect them.

3. Information We Collect

3.1 Information You Provide Directly

• Chat Messages: The text messages you type during conversations with AI characters. To generate each reply, your new message is sent, together with your recent conversation history and the selected character's profile, to the AI conversation providers listed in Section 5. Your full chat history is stored only on your device.
• Voice Data: When you use voice chat, your recording is transcribed using Apple's Speech Recognition framework (on your device, or by Apple under Apple's privacy policy). Only the resulting text is sent to the AI conversation providers. The audio itself is stored only on your device and is never sent to any third-party AI provider.
• Custom Character Information: If you create a custom AI girlfriend, the name, city, and personality traits you enter are stored on your device and included in the prompt sent to the AI conversation providers so that replies match the character.
• Character Appearance Description: If you generate a custom avatar, the appearance options you choose (style, body type, ethnicity, age range, profession) are sent to the image generation providers listed in Section 5. No photos of you are requested or sent.
• Feedback Data: If you choose to submit feedback through our survey forms, the information you provide is collected via Google Forms.

3.2 Information Collected Automatically

• Usage Analytics: We use Firebase Analytics to collect anonymized usage data, including:
  • App launch events
  • Character selection events
  • Chat activity (message count, not message content)
  • Subscription purchase events and sources
  • Custom character creation events
• Subscription Information: Your subscription status and expiration dates are managed through Apple's StoreKit framework and stored locally on your device.
• Device Information: Firebase Analytics may collect standard device information such as device model, operating system version, and app version.

3.3 Information NOT Collected

4. How We Use Your Information

The table below lists every type of data the App handles, how it is collected, what it is used for, and whether it leaves your device.

We use your data for no purpose other than those listed above. We do not use it for advertising, marketing, profiling, or sale to any party.

5. Third-Party AI Services: Who Receives Your Data

The App sends the data described in Sections 2 and 3 to the providers below. We do not operate our own AI servers; each provider receives only the data needed for the specific request and returns the result to your device.

5.1 Alibaba Cloud Model Studio (Bailian, International Edition)

• Legal entity: Alibaba Cloud (Singapore) Private Limited, operator of the Alibaba Cloud international service.
• Location of processing: Singapore.
• Data received: Your chat messages, recent conversation history, and the selected character's profile (for AI replies); the AI reply text and your voice preference settings (for text-to-speech).
• Purpose: Primary provider for generating AI character replies and converting them to speech.
• Retention: Request logs are retained by Alibaba Cloud in accordance with its service agreement and are not linked to your identity. We will submit a deletion request on your behalf if you ask us to (see Section 10).
• Model training: Alibaba Cloud states that it never uses customer data submitted through Model Studio to train its models. Model Studio is SOC 2 certified and encrypts data with AES-256.
• Privacy documentation: Model Studio Security & Privacy Notice · Alibaba Cloud International Privacy Policy

5.2 SiliconFlow (International)

• Legal entity: SiliconFlow Technology Pte. Ltd.
• Location of processing: Singapore.
• Data received: The same data as in 5.1 when SiliconFlow is used as a fallback for AI replies or text-to-speech; the character appearance description when used as a fallback for avatar generation.
• Purpose: Fallback provider, used only when the primary provider is unavailable.
• Retention: Retained only as long as necessary to provide the service, in accordance with SiliconFlow's privacy policy and the Singapore Personal Data Protection Act.
• Model training: SiliconFlow acts as our data processor and processes interaction data strictly under our instructions. We do not permit any use of your data other than generating the requested response; this excludes model training.
• Privacy policy: SiliconFlow Privacy Policy

5.3 Evolink

• Legal entity: EVO Global Technologies Limited.
• Location of processing: Hong Kong.
• Data received: Only the character appearance description you choose (style, body type, ethnicity, age range, profession). No chat messages, voice data, photos, or personal data are sent.
• Purpose: Primary provider for generating custom character avatars.
• Retention: Retained only as long as necessary to provide the service, in accordance with Evolink's privacy policy.
• Model training: Evolink receives no personal data from the App; appearance descriptions are used only to generate the requested image.
• Privacy policy: Evolink Privacy Policy

These providers host open-source and proprietary language models (including Qwen and DeepSeek models) on their own infrastructure in the locations listed above. Your data is sent only to the providers listed above; it is not sent to the developers of those models.

5.4 Other Third-Party Services

• Firebase Analytics (Google LLC, United States): Receives anonymized usage statistics only (see Section 3.2). It never receives chat content, voice data, or character information. Google Privacy Policy
• Apple StoreKit (Apple Inc.): Manages subscriptions and purchases. Apple Privacy Policy
• Google Forms (Google LLC): Collects feedback only if you choose to submit a survey. Google Privacy Policy

5.5 Equal Protection of Your Data

Before using any third-party AI provider, we review its terms and privacy commitments. We only use AI providers that (a) process your data solely to deliver the requested service to us, (b) do not use your data to train or improve their models, (c) protect your data with encryption in transit and at rest and appropriate organizational measures, and (d) retain it no longer than necessary. These providers provide the same or equal protection of your data as described in this Privacy Policy and as required by the App Store Review Guidelines. We do not sell your data to any third party, and no third party may use it for advertising or profiling. Google processes analytics data under the Google Analytics for Firebase terms and never receives chat content.

6. Tracking and User Profiling

• No Tracking: We do not track you across apps or websites owned by other companies. We do not use the Apple Advertising Identifier (IDFA) or any other identifier for cross-app tracking purposes.
• No User Profiling: We do not build user profiles based on collected data. We do not attempt to identify anonymous users or reconstruct user profiles from aggregated or anonymized data.
• No Data Selling: We do not sell, rent, or trade your personal data to any third party.
• Data Linkage: The analytics data collected by Firebase is not linked to your identity. We do not associate analytics events with any personal identifiers.

7. AI-Generated Content and Third-Party AI Services

• All data is sent over encrypted HTTPS connections.
• No name, email address, phone number, device identifier, or account information is attached to any request, because the App does not collect them.
• Replies are generated by AI and may be inaccurate or fictional. They are not advice of any kind.
• We recommend not sharing sensitive personal information (such as financial details, passwords, identification numbers, or health information) in chat conversations.

8. Data Storage and Security

• Local Storage: Chat history, voice recordings, generated images, and user preferences are stored locally on your device in the app's sandboxed storage.
• No Cloud Sync: We do not sync your chat data to any cloud server of our own. Your conversations remain on your device.
• Encryption in Transit: All data transmitted to third-party services uses HTTPS encryption.
• Provider-Side Security: Alibaba Cloud Model Studio encrypts data with AES-256 and is SOC 2 certified. SiliconFlow and Evolink apply industry-standard technical and organizational security measures under their privacy policies.
• Data Minimization: We only send the minimum data necessary to provide the service (e.g., chat messages for AI responses, text for text-to-speech, appearance descriptions for avatars).

9. International Data Transfers

Your chat data is processed in Singapore (Alibaba Cloud Model Studio, SiliconFlow) and, for avatar generation, in Hong Kong (Evolink). Analytics data is processed by Google in the United States. When your data is transferred outside the country you live in, we rely on the providers' contractual data-protection commitments and, for users in the European Economic Area and the United Kingdom, on standard contractual clauses or equivalent safeguards under the GDPR and UK GDPR.

10. Data Retention and Deletion

• Chat History: Stored locally on your device. You can delete individual conversations or all chat data through the app's settings.
• Voice Recordings: Stored locally. Automatically cleaned up when associated messages are deleted.
• Generated Images: Stored locally. Deleted when you delete the character or uninstall the App.
• Data Sent to AI Providers: Retained by the provider only as long as needed to generate the reply and for operational logging under its policy, and never linked to your identity. To request deletion of data held by a provider, email us at the address in Section 18 and we will submit the request to the provider on your behalf.
• Analytics Data: Retained by Firebase according to Google's data retention policies (typically 14 months for event data).
• Complete Data Deletion: Uninstalling the App will permanently delete all locally stored data, including chat history, voice recordings, and generated images.

11. Consent and Withdrawal

Consent

The first time you open the App, before any message can be sent, the App shows a "Protecting Your Privacy" screen stating that your conversations are processed by third-party AI services to generate replies and that your chat history stays on your phone, with a link to this Privacy Policy. AI chat, voice, and avatar features are not available until you tap Agree & Continue. If you do not agree, you can close the App; these features cannot be used without this permission. Microphone, speech recognition, and notification access are requested separately through iOS system prompts before those capabilities are used.

Withdrawal of Consent

You may withdraw your consent at any time by:

• Stopping use of specific features (e.g., voice chat)
• Revoking microphone, speech recognition, or notification permissions through iOS Settings › AI Girlfriend
• Deleting your chat data within the App
• Uninstalling the App
• Contacting us at the address in Section 18 to object to further processing

Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

12. Your Rights and Choices

You have the following rights regarding your data:

• Delete Chat Data: Delete individual or all chat conversations within the App.
• Disable Voice Features: You can choose not to use voice chat features, preventing any voice data collection.
• Analytics: The usage analytics we collect are anonymous and not linked to you. If you object to analytics collection, contact us at the address in Section 18.
• Manage Notifications: You can enable or disable push notifications through iOS Settings.
• Manage Subscriptions: You can manage or cancel subscriptions through iOS Settings › Apple ID › Subscriptions.
• Data Deletion: We do not store your data on servers of our own; everything the App keeps is on your device and can be deleted by deleting conversations within the App or by uninstalling the App. For data held by the AI providers, see Section 10.

13. Children's Privacy

This App is not intended for children under the age of 17. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to delete such information.

14. Your Rights Under GDPR / CCPA

If you reside in the European Union, the United Kingdom, or California, you have the right to:

• Access the personal data we hold about you
• Request correction or deletion of your information
• Restrict or object to data processing
• Withdraw consent at any time
• File a complaint with a data protection authority

Since we do not store personal data on servers of our own, most of your data can be managed directly on your device. To exercise any of these rights regarding data processed by third-party services (such as the AI providers listed in Section 5 or Firebase Analytics), please contact us via the email address provided below.

15. Automated Decision-Making

This App uses AI models to generate conversational responses. These AI-generated responses are based solely on the text you provide in the chat and the character profile you selected. No automated decisions are made that produce legal effects or similarly significant effects concerning you.

16. Governing Law

This Privacy Policy shall be governed by and construed in accordance with applicable laws. If any provision of this Privacy Policy is found to be unenforceable, the remaining provisions shall remain in full force and effect.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by updating the "Last Updated" date at the top of this Privacy Policy. If we add a new third-party AI provider or change what data is shared, we will update this Privacy Policy and the in-app notice before the change takes effect. You are advised to review this Privacy Policy periodically for any changes.

18. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact us at: