Privacy Policy

PalKai Co., Ltd. (hereinafter referred to as "we", "us", "our", or the "Company") respects your privacy and is committed to protecting your personal data. In order to protect your privacy and personal data, we collect, process, and use personal data in accordance with the Personal Data Protection Act of the Republic of China (Taiwan), the Enforcement Rules of the Personal Data Protection Act, and other applicable laws and regulations (hereinafter collectively referred to as the "Applicable Laws").

You may refer to this Privacy Policy (hereinafter referred to as the "Policy") to understand the specific measures we adopt for the protection of your privacy.

1.Scope and Acknowledgement of this Policy

(1)This Policy applies to you as a user of the Eden application developed by the Company (hereinafter referred to as the "App"). By applying for or using the App, you shall be deemed to have read, understood, and agreed to all of the contents of this Policy. If you do not agree to any provision of this Policy, you shall immediately cease using the App.

(2)Any matters not provided for in this Policy shall be supplemented and interpreted in accordance with the Terms of Service of the App and the applicable laws and regulations of the Republic of China (Taiwan).

2.Types and Sources of Personal Data Collection, Processing, and Use

The types and sources of the personal data that we collect, process, and use include the information you provide when applying to register an account for the App, the information generated through your use of the App, and information obtained from other sources, including the following:

2.1.Information You Provide When Applying to Register an Account and Using the App

(1)Account Information (including your name, username, date of birth, gender, Apple account, X account, Google account, Facebook account, other email accounts, telephone number, login password, preferences, and other account-related information).

(2)Payment Information (including your name, credit card number, security code, expiration date, billing address, and other payment-related information, if applicable).

(3)Input and Interaction Content (including any text, voice recordings, images, character settings, preference settings, conversation records, and other content that you input, upload, generate, or create through interactions with AI virtual characters within the App).

(4)Other Information (including the contents of your chats with third parties and other related information).

2.2Information Generated Through Your Use of the App

(1)Device Information (including the IP address of your device, device hardware model, mobile network data, operating system version, user settings, and other information relating to the device used to access the App).

(2)Location Information (including approximate or precise GPS location data, if you have enabled location services).

(3)Usage Record Information (including the dates, times, and other activity records relating to your use of the functions or systems of the App).

(4)Communication Information (including the dates, times, text, voice, images, and locations relating to communications between you and other users through the App).

(5)We collect certain information through Cookies and from other websites or mobile applications operated by authorized third parties. If you do not wish to accept the placement of Cookies, you may modify your browser settings and set your privacy level to High to refuse the storage and reading of Cookies by the App. However, such settings may result in certain functions of the App and its services being unavailable or not functioning properly.

2.3Information Obtained from Other Sources (including information provided by government authorities, business partners, professional service providers, payment service providers, or third parties in connection with complaints, claims, disputes, referrals, or recommendations).

3.Specific Purposes for the Collection, Processing, and Use of Personal Data

We will collect, process, use, and retain your personal data for the following specific purposes:

(1)To verify your identity and establish and maintain your user account for the App.

(2)To provide the AI virtual character interaction services of the App.

(3)To prepare and provide electronic transaction statements and receipts for payments.

(4)To compile statistics and conduct data analysis and research for the purposes of enhancing the Company's and the App's service offerings, improving the quality of the Company's and the App's services, training and improving the App's AI models, strengthening security protection, optimizing system functions, and other related purposes.

(5)To provide personalized marketing messages, advertisements, promotional offers, and marketing effectiveness analysis.

(6)To respond to your inquiries or feedback and to notify you of updates to the scope of services, these Terms, or this Policy.

(7)For the purposes of performing contractual obligations, administrative processing, complying with applicable laws and regulations, or complying with orders issued by competent authorities.

(8)For other activities within the scope of the Company's business operations.

4.Period and Geographic Areas for the Use of Personal Data

Unless otherwise provided by applicable laws and regulations, we will collect, process, use, and retain your personal data during the period in which the specific purposes for the collection, processing, and use of personal data set forth in the preceding Article continue to exist. Such collection, processing, use, and retention may take place within the regions where our business operations and services are available, as well as in any other regions necessary for the purposes of collection, processing, use, and international transfer of personal data, including, without limitation, the Republic of China (Taiwan), the locations of overseas affiliates or institutions, the locations of the Company's outsourced service providers, and the locations of recipients of internationally transferred personal data where such international transfer is not restricted by applicable policies, laws and regulations, or the competent central authorities.

5.Recipients and Methods of Disclosure of Personal Data

We may disclose your personal data to specific recipients under the following circumstances by reasonable and lawful means, including but not limited to written documents, messages, electronic mail, and digital files:

(1)Within the scope of the types, specific purposes, periods, and geographic areas for the collection, processing, and use of personal data as set forth in the preceding three Articles, we may disclose the necessary personal data to business partners, professional service providers (including, without limitation, providers of cloud services, AI model services, technical services, data storage services, information security services, and data analytics services), payment service providers, or the Company's affiliated companies.

(2)Where the use of personal data for purposes other than the specific purposes is permitted pursuant to the proviso of Article 20 of the Personal Data Protection Act.

(3)Where required by applicable laws and regulations or pursuant to an order issued by a judicial authority, administrative authority, or any other competent authority.

(4)Where necessary, in emergency circumstances, to protect your lawful rights and interests or those of a third party.

(5)Where, during your registration of an account or use of the App, you engage in any conduct that violates applicable laws and regulations, the Company's Terms or policies, or is likely to damage or prejudice the rights or interests of the Company or any third party, and we reasonably determine that the disclosure of your personal data is necessary for the purposes of identification, contacting you, or taking legal action.

(6)Where a third party succeeds to the Company's rights and obligations by reason of a merger, transfer, or any other legal cause.

6.Retention and Management of Personal Data

(1)We may retain the personal data you provide on servers, databases, or systems owned or managed by the Company or by third-party data storage service providers.

(2)We will retain your personal data only within the scope of the types, specific purposes, and reasonable retention periods for the collection, processing, and use of personal data as set forth in Articles 2 through 4 of this Policy.

(3)In accordance with the applicable laws and regulations, we have implemented appropriate security measures for the protection of personal data, including, without limitation, access control mechanisms, encryption of data transmission and storage, firewalls and intrusion detection systems, regular data backups, management of personnel confidentiality obligations, employee education and training, and periodic internal audits, as well as other technical and organizational measures, in order to reasonably prevent personal data from being stolen, altered, damaged, lost, or disclosed.

(4)Where we entrust a third party (including the data storage service providers referred to in the preceding paragraph and other outsourced service providers) with the collection, processing, or use of personal data, we shall, in accordance with the applicable laws and regulations, exercise appropriate supervision over such entrusted party and require it by contract to comply with its obligations to protect personal data and maintain confidentiality.

(5)In the event that your personal data is stolen, altered, damaged, lost, or disclosed, we will, after ascertaining the facts, notify you by appropriate means in accordance with the applicable laws and regulations and, where appropriate, report the incident to the competent authority, while also informing you of the nature of the incident and the remedial measures that have been taken.

7.Exercise of Rights Relating to Personal Data

(1)Pursuant to Article 3 of the Personal Data Protection Act, unless otherwise restricted by applicable laws and regulations, you are entitled to exercise the rights to inquire about or request access to, obtain a copy of, supplement, correct, request the cessation of the collection, processing, or use of, or request the deletion of, the personal data you have provided. However, where you request to inquire about, access, or obtain a copy of such personal data, the Company may charge a processing fee of NT$100 per request.

(2)If you wish to exercise any of the foregoing rights or have any other inquiries, please refer to the contact information set forth in this Policy for assistance. We will respond to you as soon as reasonably practicable and assist you in exercising your relevant rights.

(3)If you no longer wish to receive marketing communications from us, you may, at any time, unsubscribe or disable notification functions through the options provided in such marketing communications, or contact us using the contact information set forth in this Policy to request, free of charge, that we cease using your personal data for marketing purposes. We will comply with such request within a reasonable period of time.

8.Child and Youth Safety Protection

8.1This service explicitly prohibits any person from engaging in child sexual abuse and exploitation (CSAE) within this service, including but not limited to the following:

(1)Creating, uploading, or publishing content that promotes the exploitation or abuse of minors (such as speech, text, voice, images, pictures, actions, or poses, etc.).

(2)Encouraging predatory behavior towards minors.

(3)Inappropriate interactions with minors (such as touching or caressing, etc.).

(4)Content related to child sexual enticement, such as engaging in online friendships with minors for the purpose of engaging in sexual contact with them either online or in real life, and/or exchanging pornographic images, etc.

(5)Content that sexualizes minors, such as images depicting, encouraging, or promoting child sexual abuse behaviors, or portraying minors from a perspective that could lead to their sexual exploitation, etc.

(6)Sexual extortion (e.g., obtaining or falsely claiming to have obtained private images of minors, and using these images for threats or extortion, etc.).

(7)Content related to the trafficking of minors, such as promoting or coercing minors into sexual exploitation activities.

(8)Any other actions that may harm the physical and mental development, rights, or welfare of minors.

8.2 This service will comply with the applicable laws of the Republic of China regarding child safety (including but not limited to the Child and Juvenile Sexual Exploitation Prevention Act, etc.). If this company independently or upon third-party notification, discovers suspected CSAE behavior in this service, the company may take appropriate action immediately (including but not limited to collecting evidence, removing, hiding, or taking down related content, suspending or banning accounts, reporting the related content to the relevant authorities or agencies, etc.), and will not be held liable to you, any member, or third parties.

8.3 If you have any questions regarding violations related to child and youth safety protection or the review process, or if you encounter suspected CSAE behavior from a third party within this service, feel free to contact the company using the email address provided at the end of this Privacy Policy with your comments, feedback, concerns, or reports. A dedicated team will take appropriate action when necessary.

9.Rights and Interests Relating to the Accuracy of Personal Data

If you do not agree to this Privacy Policy, or if you do not provide, or fail to provide complete, accurate, and truthful personal data, you may be unable to apply for and register an account for the App, or you may be unable to fully access and use the services provided by us.

10.Special Categories of Personal Data and User-Submitted Content

(1)As a general principle, we do not proactively require you to provide any special categories of personal data as prescribed under Paragraph 1 of Article 6 of the Personal Data Protection Act (including medical records, medical information, genetic information, sexual life, health examination records, and criminal records). Unless otherwise permitted by applicable laws and regulations or with your consent, you are requested to refrain from voluntarily providing the foregoing special categories of personal data or other highly sensitive information when using the App (including when interacting with AI virtual characters or other users).

(2)You acknowledge and agree that, because the App provides AI virtual character interaction features and free-text input features, if you voluntarily provide any special categories of personal data or other highly sensitive information during conversations, character settings, prompts, uploaded content, or any other interactive activities, the Company and its business partners may passively receive, store, process, or use such content.

(3)The content that you input, upload, or generate through interactions with AI virtual characters within the App (including text, voice recordings, images, and other content) may be collected, processed, and used by the Company within the scope of the specific purposes and to the extent necessary as set forth in this Policy. You shall be solely responsible for the legality of the content you provide and shall not provide any content that infringes upon the rights of any third party or violates any applicable laws and regulations or the Terms of Service of the App.

11.Amendments to this Policy

In order to better protect your privacy and personal data and to provide improved services, we may amend this Policy from time to time in response to changes in the social environment, applicable laws and regulations, and technological developments. In the event of any amendment to this Policy, we will notify you of the amended contents of this Policy by electronic mail, network communications, announcements within the App, or any other appropriate means, or otherwise make the amended Policy publicly available, and such amendment shall become effective immediately upon such notification or announcement. If, after any amendment to this Policy becomes effective, you do not cancel your account for the App or continue to use the App, you shall be deemed to have read, understood, and agreed to all of the amended contents of this Policy.

12.Contact Information

If you have any questions regarding this Policy, the protection of personal data, or the exercise of your rights, please contact the Company using the following contact information:

Email: eden@langlive.com

Address: 4F., No. 500, Sec. 5, Zhongshan N. Rd., Shilin Dist., Taipei City 111, Taiwan

Customer Service Hours: Monday through Friday, 10:00 a.m. to 6:00 p.m. (excluding public holidays)