Privacy Policy

Privacy Policy

 

Last Updated: February 12, 2026

 

Directory

  1. SCOPE AND CONSENT
  2. COLLECTION AND USE OF USER INFORMATION
  3. COOKIES, SDKS, AND SIMILAR TECHNOLOGIES
  4. ADVERTISING
  5. REASONS FOR COLLECTION, PROCESSING, AND USE OF USER INFORMATION
  6. SHARE, TRANSFER, SELLING AND DISCLOSURE OF USER INFORMATION
  7. MANAGEMENT OF USER INFORMATION
  8. RETENTION OF USER INFORMATION
  9. SECURITY OF USER INFORMATION
  10. INTERNATIONAL TRANSFER OF USER INFORMATION
  11. PROTECTION OF CHILD USERS’ PERSONAL INFORMATION
  12. Regional Privacy Disclosures
  13. uSERS’ RIGHT OF REMEDY
  14. CONTACT US

 

This Privacy Policy (“Policy”) applies to to website: PolyBuzz.ai, an online AI chatting web service, and related contents, features and functionality (together, the “Web Services”) provided to users (“you” or “your”) by PolyBuzz.ai, which is operated by Cloud Whale Interactive Technology LLC in the United States and supported by our affiliated companies (if any)(collectively such entities will be referred to as “we”, “our” or “us”).

 

  1. Scope and Consent

     

    This Policy sets out why, how and what personal information we collect, use, store, process, share, transfer and publicly disclose about you, the information security protection measures we take, and the rights we honor for your access, update, deletion and control of your personal information. Please read this Policy in combination with PolyBuzz Terms of Use. If you do not agree to this Policy, you shall stop using PolyBuzz and/or our Services.

     

    We reserve the right to amend this Policy at any time and from time to time, and we encourage you to regularly review this Policy to get the latest revision. If you do not accept the Policy as amended, you shall stop using PolyBuzz.

     

    You must be at least 18-year-old to use PolyBuzz. If you do not meet the minimum age requirement, you are not permitted to access or use PolyBuzz.

     

    When you first use PolyBuzz, whether as a guest or intending to register, you must enter your date of birth. By doing so, you confirm that the information you provide is accurate and truthful. If you enter an incorrect birthdate by mistake, you can correct it later, but only after you become a registered user. Guest users cannot change their birthdate after it is submitted. If we determine that the birthdate you provided is false, we reserve the right to suspend your access to PolyBuzz, either temporarily or permanently, at our sole discretion. Access to content is based on your age: 1) Users above 18 years old can access the full range of AI-generated content (some features may require a subscription); 2) Users under 18 years old will be denied access to our services.

     

    By accessing and/or using our Services, you confirm that you are either an adult at or over the age of majority in your jurisdiction, or a child under your parent or legal guardian’s supervision, and that you have the right, authority, capacity or consent to access and/or use our Services and agree to abide by this Policy.

     

    This Policy is an electronic contract formed under applicable laws, and does not require any physical, electronic or digital signature.

     

    Please read this Policy carefully. By accessing or using PolyBuzz and/or our Services, you agree and acknowledge that you understand, agree and consent to this Policy and to the collection, use, process, share, transfer and disclosure of information about you that you have provided or may in the future provide to us for the purposes set out in this Policy and in accordance with applicable laws.

     

  2. Collection and Use of User Information

 

We will collect personal information (sometimes may include sensitive personal data) from you for the purpose hereof and in line with the principles of legality, legitimacy, necessity, and transparency. If we use personal information about you for any purpose other than those contained herein, or collect personal information from you for any other purposes, we will notify you in a reasonable manner and obtain your prior consent as required under applicable laws. We do not require you to disclose more information than reasonably necessary.

 

  • In USA, “Sensitive Personal Data” is defined to include ten specified categories of data that may be maintained or collected by U.S. businesses.  The categories of data include types of financial, geolocation, and health data, among others.  Moreover, a U.S. business that maintains or collects these categories of data on U.S. citizens will only be considered to have sensitive personal data to the extent it (i) targets or tailors products or services to certain populations, including U.S. military members and employees of federal agencies with national security responsibilities, (ii) collects or maintains such data on at least one million individuals, or (iii) has a demonstrated business objective to maintain or collect such data on greater than one million individuals and such data is an integrated part of the U.S. business’s primary products or services.  Genetic test information is also included in the definition regardless of whether it meets (i), (ii), or (iii)

     

  • In EU, the following personal data is considered ‘sensitive’ and is subject to specific processing conditions: 1) personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs; 2) trade-union membership; 3) genetic data, biometric data processed solely to identify a human being; 4) health-related data; 5) data concerning a person’s sex life or sexual orientation.

     

    We may synchronize user personal information on your different mobile devices to ensure smooth user experience.

     

    1. Personal information you provide during use of PolyBuzz

       

      1. We respect user privacy and are committed to reasonably protect it in all material respects. You agree that we may collect the following personal information about you:
        1. Information necessary to provide, maintain and improve PolyBuzz and/or our Services;
        2. Information knowingly supplied by you; information collected with your consent;
        3. Information collected from other sources in line with this Policy (e.g., third-party service providers or social media platforms).

 

“Personal Information” means any information, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data or other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

 

2.1.2 By registering an account with PolyBuzz, or accessing or using PolyBuzz (with or without a user account), you consent to provide us necessary information including your personal information as described herein.

 

User personal information that we may collect include, but is not limited to:

  • email address;
  • username;
  • uploaded pictures or input text;
  • purchase and payment records;
  • device information;
  • log information;
  • precise geolocation information;
  • your Contacts.

 

The following describes the extent to which your personal information may be required and collected.

 

2.1.2.1 Registration

 

You may log in with your current Google, or Apple account. When you do so, a PolyBuzz account will be automatically created. You may create a new account through your email and follow our registration steps.

 

Please note that as an unregistered user, you may not be able to use certain features of PolyBuzz, but you may browse the contents and use the AI Chatting features with limitations.

 

2.1.2.2 Profile creation

 

To ensure your pleasant experience with PolyBuzz, you can, but are not required to, provide a username to create a profile. If you do not create a personal profile with optional information, you will still enjoy the basic functions.

 

2.1.2.3 AI Chatting

When you use the “AI Chatting” feature, you can choose from the following three (2) ways to initiate a chat:

  1. Create an AI character via our AI algorithm;
  2. Find an existing AI character on our server.

 

Therefore, if you do not allow access to your album, device internal storage, keyboard (for text inputs), or microphone (for voice inputs), we may not be able to offer you this feature.

 

We may also access your precise geolocation information (through your device) to provide a customized AI Chatting experience based on more accurate simulations to your local environment.

 

2.1.2.4 Online Payment

 

We offer value-added premium services, for which you need to pay in the one of the following two (2) ways:

  1. In-app purchase by credit card; or
  2. through a third party (such as Apple Pay, Google Pay, etc.)

 

As a result of your payment, we may collect some financial information (e.g., payment records or other payment-related data).

 

2.1.2.5 Customer Service

 

When you contact our customer service, you may need to provide your account information for identify verification. In addition, you may need to submit relevant evidence (including but not limited to pictures or texts) and contact information. Without such information, we may not be able to respond to you promptly or assist you as desired.

 

2.1.2.6 User Consent

 

You will be asked to consent to the following:

  • photos/storage: to collect the photos that you wish to upload and display to other users, or train our AI algorithm (photos will be uploaded to our back-end server) 
  • Microphone: to input texts via voice input feature
  • Internet access: to view WLAN state and network connections to optimize Internet access by cellular network status camera: to take photos and/or videos for your questions identity: to link to and enable login through a third-party account (e.g., Google or Apple)
  • precise geolocation: to train our AI algorithm
  • Contacts: to provide an easy way for you to screen if any of your contact persons are using PolyBuzz, and establish connections within PolyBuzz

 

PolyBuzz also requests your permission for flashlight and alarm wake lock, which do not collect user personal information.

 

2.2 User Information Automatically Collected

 

To safeguard the security of your account and better serve you, we will collect and use the following information generated during your use of PolyBuzz, but only to the extent permitted under applicable laws.

 

2.2.1 Device Information

 

When you use PolyBuzz, we will collect certain of your device information, including device ID, IMEI, OAID, MAC, browser type, operator information and usage, information about device location (IP address), device model, operating system version, IDFA (for iOS only), IDFV (for iOS only), Android ID (for Android only). Such information is the unique identification of the device, and we may combine it with other personal information we collect so that we can provide consistent Services.

 

2.2.2 Log Information

 

PolyBuzz will automatically collect and save user network logs, including browser type, browsing records, network diagnosis, so that we can evaluate use of PolyBuzz, optimize it and improve our Services.

 

2.3 User Information Obtained from Third Parties

 

2.3.1 We may collect and use user personal information from a third party upon your consent. We process your personal information in accordance with the contract with the third party and applicable laws, and we ask that you carefully read the service agreement and privacy policy of such third party. Your refusal to a third party’s collection, use or sending of your personal information may result in failure to use PolyBuzz. Please note that we do not condition your use of our Services on the disclosure of more personal information than is reasonably necessary.

 

2.3.2 When You log into PolyBuzz through a social media plug-in, you will be redirected to the third-party platform, where you can register or log into an account thereof. When logging in through the registered account of a permitted third party, your profile of that third-party account will be bound with an automatically created PolyBuzz account. Currently, we offer social media sign-in for Google and Apple users. Through the link between two accounts, we only collect user name and profile picture from the third-party account. Please note that even if the third-party provider may collect your device version, system version, generated ID, phone style, phone name, ICCID (for iOS only), BSSID (for iOS only), MAC (for iOS only), IMSI (for iOS only), IMEI (for iOS only) for their purpose, such information will not be needed by and transferred to us.

 

WE HAVE NO CONTROL OVER AND ASSUME NO RESPONSIBILITY FOR THE CONTENT, PRIVACY POLICIES OR PRACTICES OF ANY THIRD-PARTY WEBSITES AND MOBILE APPLICATIONS OR ANY SERVICES OFFERED BY SUCH THIRD PARTIES. YOU AGREE THAT WE WILL NOT BE LIABLE FOR ANY BREACH OF YOUR ’S PRIVACY OF PERSONAL INFORMATION NOR FOR ANY LOSS INCURRED TO YOU AS A RESULT OF USE OF SUCH THIRD-PARTY PRODUCTS OR SERVICES.

 

2.3.3 When You pay for our premium services through a third party, we will collect your user’s name, profile picture and payment record from the third party.

 

2.3.4 Mandatory Age Verification in United Kingdom (UK)

The lawful basis for processing your data for age verification is compliance with a legal obligation under the UK Online Safety Act, and to protect the safety of children. Age verification data is processed solely for the purpose of confirming compliance with age restrictions required by UK Online Safety Act.

 

For the purpose of verifying age, you may be asked to provide personal information such as your name, date of birth, or government-issued identification. This information is submitted directly to our approved third-party age verification providers. We use UK-compliant third-party verification providers. Those providers may process your information in accordance with its own privacy and security standards, which comply with the UK GDPR and the Data Protection Act 2018. For Ondato service, check: https://ondato.com/privacy-policy/; For Yoti Service, check: https://www.yoti.com/privacy/age-verification/.

 

PolyBuzz does not store your government-issued identification or verification documents. Only the outcome of the verification (e.g., “verified” or “not verified”) may be retained in our records for compliance and audit purposes. The third-party providers apply appropriate technical and organisational measures to safeguard your data during the verification process.

 

2.4 Exceptions to Acquiring User Consent

 

Subject to applicable laws, we may not need to obtain your consent when collecting and using your personal information, but only if:

  1. it is related to performance of the obligations required by applicable laws;
  2. it is directly related to national security, public safety, public health, or significant public interests;
  3. it is directly related to crime investigation, prosecution, trial and execution of judgment, or is required by the competent authorities or other circumstances required by applicable laws including but not limited to in response to court orders and subpoenas;
  4. it is required for safeguarding a user’s life, property and other significant legal interests but it is difficult to obtain your consent, or we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users, or anyone else that could be harmed by such activities;
  5. the information was made available to the general public by yourself;
  6. it is necessary for execution and performance of a contract between you and us per your request;
  7. the information is collected from legally and publicly disclosed channels, such as legal news reports, published government information or other channels;
  8. it is necessary for maintaining the operation of PolyBuzz, such as troubleshooting, discovering and resolving issues in relation with PolyBuzz and/or our Services; or
  9. other circumstances specified or permitted under applicable laws.

 

  1. Cookies, SDKs and Similar Technologies

     

    1. Cookies

       

      A cookie is a data file, often including a unique identifier, that is sent to your browser from a web server and is then stored on the hard drive of your device.

       

      We only use strictly necessary cookies. These cookies are essential in order to enable you to move around in PolyBuzz and use its features, such as remembering your log-in status and accessing secure areas. Without these cookies, certain services you ask for cannot be provided. These cookies do not contain any personal information. We use these cookies to remember the way you log in (by email, Google or Apple account) and provide our Services accordingly.

       

    2. SDKs

 

An SDK (Software Development Kit) is a collection of software tools, libraries, documentation, code samples, and sometimes APIs (Application Programming Interfaces) that developers use to create applications for specific platforms, frameworks, or devices. SDKs make it easier to integrate certain features or functionalities into an app without building them from scratch.

 

Our application integrates third-party Software Development Kits (SDKs) to enhance its functionality and provide certain features. These SDKs may collect information automatically, such as:

 

  • Device identifiers (e.g., IMEI, MAC address, advertising ID)
  • Usage data (e.g., app interactions, session duration)
  • Technical data (e.g., IP address, operating system, device type, mobile network information)
  • Location information, if you grant permission

 

The data collected by these SDKs is used to improve user experience, provide analytics, serve advertisements, or enable features like in-app purchases. We ensure that any third-party SDK we integrate complies with applicable data protection laws and has a robust privacy policy governing the collection and use of data.

 

Please note that the privacy practices of these third parties are not controlled by us, and we encourage you to review their privacy policies for further details.

 

  1. Advertising

     

    We may allow third-party advertising networks to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our website and other online services and (b) report how our marketing content impressions and interactions with these marketing impressions are related to visits to our online services.

     

    Our third-party operators may provide you with an ad based on your data includes GAID (Google Advertising ID on Android devices) or IDFA (Identifier for Advertising on IOS devices), region, location information and IP address. This Policy does not govern Third-party Operators, as they have their own privacy policies (such as TopOn: https://help.toponad.com/docs/Privacy-Policy).

     

    You may receive advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may disclose to a vendor in hashed, non-human-readable form.

     

    You have the right to “opt-out” the customized advertising. By doing so, you will receive standardized advertisement that may not fit in your interest. To opt-out the customized advertising, you need to file a request to us by the ways set forth in the “Contact Us” section below, and specify on the subject line “Opt-out Request”.

     

  2. Reasons for Collection, Processing, and Use of User Information

     

    In general, we collect, process, and use your information for the following purposes and legal bases.

     

    1. We use your information collected by PolyBuzz to:
  • provide our Services;
  • improve PolyBuzz and/or our Services;
  • respond to your questions and requests;
  • provide you with a safe, efficient, and customized experience, and
  • share with third parties (including the Chat-GPT platform) that help us deliver effective functionality.

 

5.2 We use aggregate user information and non-personal information to analyze PolyBuzz and user behavior and prepare aggregated reports.

 

5.3 We use user information to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, establish, exercise, or defend a legal claim, and enforce our Terms of Use or this Policy. We also use information in response to requests by government or law enforcement authorities, or in response to complaints where we are under a legal or regulatory obligation to adhere to a complaint-handling procedure.

 

5.4 We use user information to contact you to maintain PolyBuzz or to comply with your stated communication preferences, to provide other services as described at the time when we collect the information from you, or to contact you for other purposes authorized by law.

 

  1. Share, Transfer, Selling and Disclosure of User Information

 

6.1 Share of user information

 

You have the right to the knowledge that whether your information has been shared. Except as otherwise expressly described herein or otherwise permitted by applicable laws, we will not share user personal information with any third party, unless:

  1. you propose the request for doing so, or we have obtained your prior express consent for doing so;
  2. it is related to performance of our obligations required by applicable laws;
  3. it is directly related to national security, public safety, public health, and/or significant public interests;
  4. it is directly related to crime investigation, prosecution, trial and execution of judgment, or is required by the competent or law enforcement authorities or other circumstances required by applicable laws including but not limited to in response to court orders and subpoenas;
  5. it is required for safeguarding your life, property and other significant legal interests, but it is difficult to obtain your consent, or we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users, or anyone else that could be harmed by such activities;
  6. the information was made available to the general public by yourself;
  7. the information is collected from legally and publicly disclosed channels, such as legal news reports, published government information or other channels;
  8. it is shared with our business partners, subsidiaries, affiliates, contractors, service providers, and
  9. other third parties we collaborate with to support our Services in compliance with this Policy, as may be needed.

 

To provide users with integrated services of high quality, some features may be supported by our technical service contractors, and we may therefore subcontract the processing of personal information to them. We will enter into a strict confidentiality agreement and data processing agreement with each service contractor regarding user personal information. Such agreements will specify the responsibilities of the parties, the information to be processed, and the period, nature and purpose of processing. We will require the contactors to process user personal information only as per our request, this Policy and any other relevant confidentiality and security measures.

 

Any such contractor is deemed an independent data processor who has been asked to obtain your consent in its own name. Each contractor may have its independent service agreement and privacy policy, and we suggest that you read them carefully and decide on your own as to whether to grant consent. But please be reminded that your refusal may result in failure to use certain functions contained in PolyBuzz that are provided by such contractor.

 

To obtain accurate information regarding whether your information has been shared, you may contact us by the ways set forth in the “Contact Us” section below.

 

If you wish to “opt-out” of information sharing, you may file a request to us by the ways set forth in the “Contact Us” section below, and specify on the subject line “Opt-out Request”. But please be reminded that your opt-out may result in failure to use certain functions contained in PolyBuzz as explained above.

 

6.2 Transfer of Control of User Information

 

In principle, we will not transfer the right to control user personal information to any other individual, company, or organization, unless we are subject to merger, acquisition, bankruptcy, or liquidation. On that occasion, we will notify you of the purpose of transfer, the type of information to be transferred and the recipient of that information.

 

6.3 Selling of User Information

 

We DO NOT sell User Information to any other individual, company, or organization. If you suspect that your personal data has been sold or commodified, you should contact our Data Protection Officer (DPO) immediately. You may find our DPO contact information in the “Contact Us” section below.

 

6.4 Disclosure of User Information 

 

Generally, we will not disclose any user personal information, unless:

  1. it is necessary for us to perform our obligations stipulated in our Terms of Use, this Policy, or applicable laws;
  2. we have obtained your consent;
  3. we are legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders and subpoenas, or other legal requirements; or
  4. we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, potential threats to the safety of any person, violations of our Terms and Condition or this Policy, or as evidence in litigation in which we are involved.

 

6.5 Transfer of Selected User Information Upon Subscription Cancellation Request

 

You have the right and may cancel your paid subscription at any time. But you must be aware and consent that some of your personal information will be transferred to the third-party payment vender (such as Apple Pay, Google Pay, Stripe, etc.) you used to make the payment. The transferred information is for the purpose of ensuring an accurate cancellation. The personal information to be collected and transferred will include, but not limited to, days of your account registration, active hours of your account, the in-app virtual merchandise you have purchased, usage of your purchased in-app virtual merchandise, value of your purchased in-app virtual merchandise, etc.

 

  1. Management of User Information

     

    7.1 Access, Correction and Portability

     

    You are advised to ensure that your user information is accurate and complete. You have the right to log into and access your account at any time to view your user information, including your profile and account information. If you discover that your user information is incorrect or no longer up to date, or any other circumstance arises provided by applicable laws, you may contact us for assistance to correct or update you user information.

     

    If you need a copy of your user information retained by PolyBuzz, you may contact us for assistance. Where it is technically feasible and reasonably requested by you, we may supply your user information to a third party.

     

    7.2 Consent Withdrawal and Modification

     

    To fully enjoy PolyBuzz, you may need to provide some basic personal information. If you want to withdraw certain consent, you may do so in the “Settings” menu. Alternatively, you may contact us for assistance.

     

    Please note that after you withdraw or modify the scope of consent, we will no longer collect and use the pertinent personal information about you, and we may not be able to continue our Services to you. However, withdrawal or change to the scope of your consent will not affect our collection, processing and storage of your user information obtained on your prior consent unless such information is deleted from PolyBuzz.

     

    7.3 Account Deletion

     

    7.3.1 To delete your PolyBuzz account, you may go to the “Setting” page, and then click “Account” – “Delete”.

     

    7.3.2 Unless otherwise required by applicable laws, we may not delete certain user information from the backup system immediately but will do so when the backup system is updated or upgraded.

     

    7.3.3 Deletion of your account is irreversible, and upon deletion you may no longer enjoy all contents or functions of PolyBuzz. Please be cautious when choosing to delete your account.

     

    7.4 Respond to User Requests

     

    7.4.1 When you contact us to exercise the user rights set out in Sections 7.1 through 7.3 above, we will need to verify your identity before processing your request. During the identification process, it is vital that you provide and keep a valid email, ideally the same email that you registered your account. We will respond as soon as possible and generally no more than 30 days from receipt of your request and verification of your identity.

     

    7.4.2 We do not ordinarily charge any fee for dealing with user inquiries and/or requests to the extent commercially reasonable. We reserve the right to refuse any request that:

    1. is not directly associated with you;
    2. is repetitive without good cause;
    3. needs excessive technical investment (for example, to develop new systems or fundamentally change existing business practices);
    4. threatens the legal rights and/or interests of others;
    5. is impossible, impractical, or unreasonable to implement;
    6. or is in violation of ourTerms of Use, this Policy and applicable laws.

     

  2. Retention of User Information

     

    8.1 All user personal information will be retained for no longer than is necessary for the purposes that are stated herein or that you have authorized, unless otherwise set forth in these Terms and/or required or permitted by applicable laws.

     

    8.2 We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of PolyBuzz, or when we are legally obligated to retain this data for longer time periods.

     

    8.3 We reserve the right to retain the aggregated and anonymized data derived from user personal information for any purpose (commercial and non-commercial) as we deem fit and proper.

     

    Please note that such anonymous data may be derived from your or your child’s personal information, but will not be considered personal information at law if it will not be linked to you or your child personally and cannot be used to identify you or your child.

     

  3. Security of User Information

     

    9.1 We use appropriate organizational, technical, and physical safeguards to protect user information. We have adopted protective measures at multiple levels (e.g., industry-standard technical security measures, supporting organizational structures and management systems) to prevent, to the maximum extent technically practical, user information from leakage, destruction, misuse, unauthorized access, unauthorized disclosure or modification.

     

    9.2 THE SECURITY OF USER INFORMATION IS VERY IMPORTANT TO US, BUT PLEASE BE REMINDED THAT NO METHOD OF TRANSMISSION OVER THE INTERNET OR METHOD OF ELECTRONIC STORAGE IS 100% SECURE. WHILE WE STRIVE TO USE COMMERCIALLY VIABLE MEANS TO PROTECT USER PERSONAL INFORMATION, WE CANNOT GUARANTEE ITS ABSOLUTE SECURITY.

     

    9.3 In the event of a data breach, we will carry out an assessment expeditiously. If the breach results in, or is likely to result in, significant harm to affected individuals, or is, or is likely to be, of a significant scale, we will notify the relevant authorities and our users as soon as it is practicable to do so, and in any event, no later than the mandatory time limit under applicable laws.

     

  4. International Transfer of User Information

     

    Subject to applicable laws, user personal information may be transferred and processed outside of your local jurisdiction. We will endeavor to ensure appropriate safeguards so that user information will remain protected in accordance with this Policy and applicable laws.

     

    We will take reasonably necessary steps to ensure that your personal information is treated securely and in accordance with this Policy and applicable laws, and no transfer of your personal information will be made to an organization or a country unless there is adequate security control in place.

     

  5. Protection of Child Users’ Personal Information

     

    The Services are not designed for minors under 14, and our Terms of Service prohibit use by anyone under 14 or under 16 if you are a resident of the European Economic Area. If we discover that an individual under 14 has provided us with “personal information,” as defined in the Children's Online Privacy Protection Act (“COPPA”), we will close the account and delete the personal information to the extent required by COPPA. We may, where permitted by law, retain certain information internally for purposes described in this Policy.

     

    You confirm that you are the parent of the child who uses PolyBuzz or an adult user at or above the minimum age permitted to use services like ours in your jurisdiction. If you do not acknowledge and agree to this Policy, please do not use PolyBuzz and/or our Services and we will not collect personal information from you or your child.

     

  6. Regional Privacy Disclosures

     

    1. Residents of the European Economic Area and United Kingdom

       

      PolyBuzz is considered the “data controller” of the “personal data” (as defined under the General Data Protection Regulation, GDPR) we handle under this Policy. In other words, PolyBuzz is responsible for deciding how to collect, use, and disclose personal data, subject to applicable law. The laws of the European Economic Area and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing your personal data. To the extent those laws apply, our legal grounds are as follows:

       

      Contractual Commitments: We may use, share, or disclose personal data to honor our contractual commitments to you. For example, we will process your personal data to comply with our agreements with you, and to honor our commitments in any contracts that we have with you.

       

      With Your Consent: Where required by law, and in some other cases, we use, share, or disclose personal data on the basis of your consent.

       

      Legitimate Interests: In many cases, we use, share, or disclose personal data on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for the Services, preventing fraud, and managing legal issues.

       

      Legal Compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

       

      In addition to those rights described herein, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

       

    2. Residents of California

       

      Starting on January 1, 2020, the California Consumer Privacy Act (“CCPA”) governs how businesses handle the personal information of California residents. CCPA was amended by the adoption of the Consumer Privacy Rights Act (“CPRA”) effective March 29, 2023. At PolyBuzz, we are committed to our subscribers’ success, including their compliance efforts with respect to the CCPA. We’re here to assist our subscribers with their efforts to comply with the CCPA.

       

      For PolyBuzz’s subscribers, PolyBuzz is a “service provider” under the CCPA. We process personal information only on behalf of our subscribers, pursuant to written contracts. Those contracts, which are already in place, permit PolyBuzz to process our subscribers’ data (including personal information) only for the purpose of providing our services. While we necessarily have to process personal information transmitted through our network, we do not sell that information to third parties.

       

      The CCPA sets forth certain obligations for businesses that “sell” or “share” personal information. Where we refer to “sell” or “share” (or their variants) in quotes, we are referring to those terms as uniquely defined in the CCPA.

       

      We may use third-party analytics services and online advertising services that may result in the “sharing” of online identifiers (e.g., cookie data, IP addresses, device identifiers, general location information, and usage information) with advertising partners to advertise the Services on other websites. If you or your authorized agent would like to opt out of our “sharing” of your information for such purposes, you may do so by go to “settings” on our website or in-app and disable the data sharing. We do not knowingly “sell” or “share” the personal information of children under 17.

       

      If you are an individual seeking to exercise your rights under the CCPA (as amended by the CRPA) please see our Privacy Policy for more information. We updated our Privacy Policy periodically to align with the requirements of the CPRA to better provide you with information about how PolyBuzz collects your personal information and how to exercise your rights with respect to that information.

       

      If you or anyone in your organization has questions about how PolyBuzz helps your organization comply with the CCPA, contact: legal@mail.polybuzz.ai

       

    3. Residents of Nevada

       

      If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to unaffiliated parties. You can exercise this right by contacting us as described in the “Contact Us” section below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address. We do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

       

    4. Residents of Brazilian

       

      We are committed to complying with the Brazilian General Data Protection Law (LGPD) regarding the collection, use, and protection of personal data for users located in Brazil. Other than the detailed explanations of how we handle your personal data in this Privacy Policy, as a Brazilian user, you have the following rights regarding your personal data under the LGPD: 1) Right to Confirmation: You have the right to know whether we process any of your personal data. 2) Right to Access: You may request access to your personal data and receive a copy of the data we hold about you. 3) Right to Rectification: You can request correction of inaccurate, incomplete, or outdated data. 4) Right to Anonymization, Blocking, or Deletion: You may request the anonymization, blocking, or deletion of unnecessary or excessive data. 5) Right to Data Portability: You have the right to request the transfer of your data to another service provider. 6) Right to Information: You can request information about the entities with whom we have shared your data. 7) Right to Withdraw Consent: You have the right to withdraw your consent at any time when data processing is based on consent. 8) Right to Object to Processing: You can object to certain types of data processing, such as direct marketing or profiling. 9) Right to Review Automated Decisions: You may request a review of decisions made solely on automated processing, which affect your interests.

       

    5. Residents of Virginia

     

    This section explains the rights of Virginia residents under the Virginia Consumer Data Protection Act (VCDPA). As a Virginia resident, you have the following rights regarding your personal data: 1) Right to Access: You have the right to confirm whether we process your personal data and to access such data. 2) Right to Correct: You may request that we correct inaccuracies in the personal data we hold about you. 3) Right to Delete: You can request the deletion of personal data that we have collected from you, subject to certain exceptions. 4) Right to Data Portability: You have the right to obtain a copy of your personal data in a portable and readily usable format. 5) Right to Opt Out of Targeted Advertising, Sale of Personal Data, and Profiling: You may opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

     

    To exercise your rights under the VCDPA, you may submit a request by contacting us at: legal@mail.polybuzz.ai We will respond to your request within 45 days, as required by the VCDPA. If necessary, we may extend this period by an additional 45 days and will inform you of the extension. If we decline to take action on your request, you may appeal our decision by submitting a written request within a reasonable period. We will review your appeal and provide you with a response within 60 days of receipt.

     

  7. User’s Right of Remedy

     

    You have the right to seek an effective remedy if your privacy is violated. You may file a complaint with the relevant authorities or pursue legal action to protect your rights. However, if you believe your privacy has been compromised while using PolyBuzz, we encourage you to contact us immediately. We take privacy concerns very seriously and are committed to addressing them promptly. Please refer to the "Contact Us" section below for our contact information.

     

  8. Contact Us

     

    We have established a department dedicated to user information protection and specially appointed a person responsible for child users’ personal information protection.

     

    1. Contact Our Data Controller

       

      We have a data management team working and monitoring data 24/7. If you want to contact our Data Controller, you may send an email to: legal@mail.polybuzz.ai and specify on the subjection line “Attn: Data Controller”.

       

    2. Contact Our Data Protection Officer (DPO)

       

      Our project manager also serves as our Data Protection Officer. If you want to contact our DPO, you may send an email to: legal@mail.polybuzz.ai and specify on the subject line “Attn: DPO”.

       

    3. Contact Us in General

 

If you have any question concerning user privacy or this Policy, please contact us through the following means:

  1. going to PolyBuzz Feedback for assistance;
  2. sending an email to support@mail.polybuzz.ai; or
  3. sending a mail to:

 

Cloud Whale Interactive Technology LLC

300 Delaware Avenue, Suite 210-2207

Wilmington, DE 19801