This Privacy Policy (“Privacy Policy” or “Policy”) outlines the information Haivivi Technology Co., Ltd. and its affiliates (“Haivivi,” “we,” “our,” or “us”) collect and process from and about you.

This Policy applies to all websites, mobile applications, electronic and toy products, and other services offered by Haivivi that link to this Policy, as well as our offline services (collectively referred to as the “Services”).

By using the Services, you consent to the practices described in this Policy. If you do not agree with these practices, please refrain from accessing or using the Services.

Any undefined capitalized terms herein are defined as per the Haivivi Terms of Service.

When you access or use our Services, we collect various types of information based on your usage. It's important to note that certain information is essential for us to provide you with our Services. If you choose not to share this necessary information, or if you request its deletion, you might lose access to some of our services. The information we collect can be categorized into three types: data you directly provide to us, data automatically collected from your interactions with our Services, and data we acquire from other sources.

Information You Provide Directly to Us

We collect information directly from you in various ways. This can happen when you interact with our Services, communicate with us, register for an account, subscribe to our newsletters, or engage in promotions. The information you provide can relate to both yourself and others and may encompass a range of data types, including, but not limited to:

You are not obligated to provide us with this information, but please be aware that without it, certain features of the Services may not be accessible or available to you.

Information We Collect Automatically

Together with our third-party vendors, including ad networks and analytics companies like Google Analytics, we may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services. Below, we detail the types of information we may collect and analyze, which includes, but is not limited to:

We also track when and how frequently you access or use the Services, including your engagement with and navigation of our site or mobile application. This information, including data collected by our third-party vendors, is used for analytics—to identify the most frequently used parts of our Services and understand user preferences—, to evaluate the success of our advertising campaigns, and for other purposes as described in this Policy.

We and our third-party vendors may employ cookies, clear GIFs, pixel tags, and other technologies to gain a better understanding of user behavior, customize preferences, conduct research and analytics, and enhance the Services. These technologies enable us to tailor the Services to your needs, for instance, by saving your password in secure areas, tracking the pages you visit, aiding in content management, and gathering statistics on our Services' usage. Additionally, we or our third-party vendors might utilize some of these technologies in emails to our customers. This helps us monitor email response rates, determine when our emails are viewed, and track whether our emails are forwarded.

Most web browsers are set to accept cookies automatically, but you have the option to change your browser settings to decline cookies if you prefer. Please be aware that disabling cookies might limit your ability to fully utilize the Services, as they may not function as intended without cookies. As we incorporate new technologies, we may also collect additional information through various methods.

When you access the Services, we may gather general location information, which can be inferred from your IP address.

Information Collected from Other Sources

We may also gather information about you from external sources. For instance, if another user refers you to us, or when you interact with our profiles on social media platforms like Facebook or Instagram, we may receive information about you from these third parties.

Information Collected Through Third-Party Accounts

Whenever you use a third-party account, such as a social media account (“Third-Party Account”), to connect to your account with us, we may collect certain information. This collection is based on the permissions you grant and can include data from your Third-Party Accounts. For instance, by connecting to our Services via Third-Party Accounts like Facebook or Google, we receive information that helps us identify your account from those services. We securely collect and store this information to streamline your connection to our Services.

Opting to link your account with a Third-Party Account is entirely your choice. You'll be given the opportunity to provide your consent when you initiate the connection. Should you decide to withdraw this permission, you can easily do so by logging into the Third-Party Account, disconnecting our service from there, or through the native applications on your smartphone. It's important to note that we may keep the information we've previously collected from you.

We may use your information for any of the following purposes:

We may combine information that we collect from you through the Services with information that we obtain from other sources. We may also aggregate and/or de-identify information collected through the Services. We may use and disclose de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes.

We may disclose your information in any of the following circumstances:

Analytics: We utilize third-party web analytics services on our Services, including Google Analytics. These services employ technologies as described in the "Information We Collect Automatically" section to help us understand user interactions with the Services, such as identifying the third-party website you used to connect to our Services. These technologies gather information that is then disclosed to or directly collected by these vendors, who analyze your usage of the Services. Additionally, we may employ Google Analytics for advertising-related purposes as outlined in the subsequent section. If you wish to prevent Google Analytics from utilizing your information for analytics, you can install the Google Analytics Opt-Out Browser Add-on.

Tailored Advertising: Although we do not currently engage in advertising as of this Policy's latest update, we may, in the future, permit third-party advertising networks to use cookies or other tracking technologies to collect information about your Service usage. This data collection aims to (a) inform, optimize, and serve marketing content based on your previous interactions with our website and other services, and (b) measure the effectiveness of our marketing content and how interactions with these contents relate to visits to our services. We may also enable other unaffiliated entities (e.g., ad networks and servers like Google Analytics) to deliver personalized marketing to you and to use their own cookies or tracking technologies. Those employing these technologies may provide you with an option to opt out of targeted advertising. Tailored advertising may be delivered to your device via a web browser. Cookies may link to de-identified data that originates from data you have voluntarily provided us (e.g., your email address), which we may share with vendors in a hashed, non-human-readable format.

If you're interested in learning more about tailored advertising and controlling the use of cookies for targeted marketing, you can explore the following resources:

To manage how Google personalizes Display Advertising or to adjust settings for Google Display Network ads, visit the Google Ads Settings page.

Please be aware that opting out of tailored advertising does not mean you will no longer see advertising on our Services; it simply means that the ads will not be customized based on your interests. Additionally, we do not have control over the opt-out links provided above and cannot guarantee their effectiveness or the accuracy of these mechanisms.

Note that if your browser rejects cookies, you erase your cookies, switch computers, or change web browsers after opting out, your opt-out preferences may not be effective anymore.

We offer you several options to control the collection, use, and sharing of your information:

You may designate an authorized agent to make requests on your behalf. To do so, you must provide your authorized agent with signed, written permission or a power of attorney. We may also contact you directly to confirm your identity before we process any requests made by your authorized agent, as allowed by law.

Please be aware that some information may be exempt from such requests under applicable law. For instance, we may need to retain certain information for legal reasons or to ensure the security of our services. Additionally, deleting information required to provide our Services might prevent you from using them.

You have the right not to face discrimination for exercising your rights under applicable law.

Furthermore, you may have the right to opt out of the sale of your personal information or its use in targeted advertising. To opt out of targeted advertising in the future, please refer to the instructions provided in the "Tailored Advertising" section above.

If you're seeking information about your rights under applicable law or wish to exercise any of these rights, please contact us at https://haivivi.com. To ensure your privacy and security, we implement reasonable steps to verify your identity and the legitimacy of your requests. Should we be unable to verify your identity, it may prevent us from fulfilling your requests.

Should your request be denied under applicable law, you may have the right to appeal our decision. We will include information on how to pursue an appeal in our response to such denied requests.

Regional Privacy Disclosures and Rights: We provide additional disclosures for residents of the European Economic Area, United Kingdom, California, and Nevada in the Regional Privacy Disclosures section below.

For Residents of the European Economic Area and the United Kingdom:

Haivivi acts as the "data controller" for the "personal data" we process, as defined under the General Data Protection Regulation (GDPR). This means we are responsible for determining how we collect, use, and disclose personal data, in accordance with applicable laws. The GDPR and UK laws mandate that data controllers disclose the legal bases they rely on for processing your personal data. Where applicable, our legal grounds for processing are as follows:

Legal Compliance:

To fulfill our legal obligations, it is necessary for us to use and disclose personal data in specific ways.

Beyond the rights outlined in this document, you also have the right to lodge a complaint with the appropriate supervisory authority. We encourage you, however, to contact us initially with any concerns. We are committed to doing our utmost to address and resolve any issues you may have.

Residents of Nevada:

If you are a Nevada resident, you possess the right to opt out of the sale of certain personal information to third parties not affiliated with us. To exercise this right, please reach out to us using the contact details provided in the “Contact Us” section below. Use the subject line “Nevada Do Not Sell Request” and include your name and email address in your communication. As of now, we do not engage in the sale of personal information as defined under Nevada Revised Statutes Chapter 603A.

Residents of California:

This Policy details the specific pieces of personal and sensitive personal information we collect, their sources, and how we disclose them. Under the California Consumer Privacy Act (CCPA), we are required to categorize the personal and sensitive personal information collected and disclosed for business or commercial purposes.

Categories of Personal Information Collected and Disclosed:

In the past twelve months, we have collected and disclosed the following categories of personal information for business or commercial purposes, as outlined in Section 1:

Sensitive Personal Information:

As defined by the CCPA, we collect:

This information is processed for purposes detailed in Section 2.

Sources of Information:

The categories of personal information are collected from:

Disclosure Practices:

Our practices for disclosing information are further described in Section 3.

“Sale” and “Sharing” of Personal Information:

Under the CCPA, “selling” or “sharing” personal information is defined specifically. We engage in third-party analytics and online advertising, which may involve “sharing” online identifiers with advertising partners. California residents or their authorized agents wishing to opt out can use the tools mentioned in the Tailored Advertising section.

We do not “sell” or “share” personal information of children under 18.

Do-Not-Track Disclosure:

We do not engage with browser-initiated Do Not Track signals due to the lack of industry standards.

Retention of Personal Information:

For details on the retention of your personal information, please refer to the Data Retention section below.

CCPA Rights:

California residents can exercise their rights regarding personal information as outlined in the Rights to Information About You section. The CCPA also provides rights to limit the use or disclosure of “sensitive personal information” for certain purposes.

We prioritize the protection of children's privacy. Accordingly, our services are not designed for minors under the age of 13, unless they have the full understanding and consent of their guardians. Our Terms of Use explicitly state that our services are not intended for minors under the age of 13. For residents of the European Economic Area, the minimum age requirement is under 16.

Children Under the Age of 13

In accordance with the Children’s Online Privacy Protection Act of 1998 and its accompanying regulations (“COPPA”), we are committed to informing parents and legal guardians (hereafter referred to as “parents”) about our practices regarding the collection, use, and disclosure of personal information from children under the age of 13 (“children”). COPPA also mandates that we obtain verifiable parental consent for certain activities involving the child’s personal information.

Section 7: Children Under the Age of 13

This section specifically addresses our practices concerning the personal information of children and takes precedence over any conflicting information in other sections of this policy.

In this section, we inform parents about:

This section is applicable solely to children under the age of 13 and is intended to complement, not replace, the other sections of this privacy policy. For teenagers and adults, the rest of this privacy policy applies.

Definitions provided in the general privacy policy retain the same meanings in this Privacy Policy for Children Under the Age of 13.

1. Collection of Information from Children and Parents

Children can interact with the Device and access many of its features without needing to provide personal information, except for the audio recordings of the child speaking to the Device. However, should children input personal details into the device, such as their name, we would then collect this information. Additionally, we may collect personal information about a child from their parents during the purchase or setup of the Device through our App or Website.

We are committed to collecting only as much information from children as is reasonably necessary to engage in an activity, and we do not require the disclosure of more personal information than is reasonably needed for their participation.

(i) Directly Collected Information

To activate the Device using the App or the Website, a parent must provide certain details about their child. This includes a preferred name for the child (first name or nickname), birth date, family members' names, and the parent’s email address. Additionally, the parent is required to create a member name and password.

The Device allows children to control it and interact through voice commands (“Voice Interaction”). This interaction temporarily records voice audio files. These audio files are used solely to create text transcriptions, facilitating the child’s interaction with the device. Once the audio is transcribed to text, the original audio files are promptly deleted. The text transcriptions are kept for up to 90 days, enabling parents to review their children’s interactions with the device. Although these transcriptions are automatically deleted after 90 days, parents have the option to delete them sooner if desired.

(ii) Automated Information Collection

We employ technology to automatically gather information from children during their interactions with the Device. This automated collection process may capture:

Furthermore, we might merge the non-personal information obtained through these technologies with personal information we have collected about you or your child online.

For details on our practices regarding the automatic collection of information, including instructions on how to opt out of certain types of data collection, please refer to the “How We Use the Information We Collect” section of this policy.

2. How We Use Your Child’s Information

We utilize the information a parent submits about their child through the Website or App during the setup of the Device for the following purposes:

We convert the audio recorded during Voice Interactions into text using a third-party speech-to-text service, after which the audio is promptly deleted. During these interactions, driven by artificial intelligence, the Device may engage in simulated natural conversations that could prompt the child for personal information. However, providing personal information is not a requirement for continuing the conversation. If personal information is voluntarily provided by the child during a Voice Interaction, it may be used to enhance the conversational experience with the Device.

This information is temporarily utilized by a third-party artificial intelligence service to generate responses during the conversation. Importantly, this third party does not retain the information beyond the duration of the conversation, nor is it used for training or any other purposes. The generated responses, influenced by the provided personal information, are converted from text to speech for audio output, ensuring a seamless interaction.

The Device stores a written record of the child's conversations for up to 90 days to enhance the conversational experience and allow parents to review transcripts of these interactions. Parents have the option to delete these transcripts sooner through the App. For the purpose of improving our devices for all users, we may also keep a written record of the Voice Interactions, including any personal information shared during those conversations, for up to 90 days, unless a parent chooses to delete it earlier.

We leverage the information collected automatically via technology, along with other non-personal information, to enhance the functionality of our Website, App, and Device. This enables us to:

Additionally, the App and Device may collect non-specific location information such as zip code, time zone, and similar details to provide localized content and information more effectively.

3. Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children's personal information, except as outlined in this section. We may disclose information in aggregate form that does not personally identify any individual. Additionally, children's personal information may be disclosed under the following circumstances:

In the event of a corporate transaction, such as a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of the Company’s assets, the personal information we hold may be transferred to the buyer or other successor.

4. Accessing and Correcting Your Child’s Personal Information

You have the right at any time to review your child's personal information that we hold, request corrections or deletions, and/or refuse to allow any further collection or use of your child's information.

To review, modify, or delete your child's personal information, please contact us by email at [email protected]. To safeguard your privacy and security, we may ask you to follow specific steps or provide additional details to confirm your identity before we can disclose, amend, or delete any information.

5. Operators That Collect or Maintain Information from Children

The following operators are involved in the collection or maintenance of personal information from children through our App or Device.

Operator Name

ElevenLabs

Google

OpenAI

Microsoft

Amazon Web Services, Inc.

Cloudflare

At Haivivi, we employ a comprehensive approach to security, incorporating technical, administrative, and physical safeguards designed to protect the information we collect against loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, it's important to acknowledge that no internet or email transmission can be guaranteed to be completely secure or error-free. As such, while we strive to protect your information, we cannot assure or warrant the absolute security of any information or communication.

Our services operate on a global scale, which means your information may be stored and processed in the United States as well as in other countries outside of the United States. These countries may have data protection laws that are different from those in your own country. Additionally, under certain conditions, your data may be accessed by law enforcement and national security authorities in these countries.

By using our Services or providing us with any information, you are consenting to the collection, processing, storage, and transfer of your information in and to the United States and other countries where data protection laws might not offer the same level of protection as those in the country where you reside or are a citizen.

Our Services may include links to websites or services operated by third parties. Please be aware that we do not control these external sites or services, nor are we responsible for their content or their privacy practices. The handling of your information by these third-party sites or services will be governed by their own privacy policies, not ours. We strongly encourage you to review the privacy and security policies of any third parties before sharing your information with them.

We reserve the right to update this Policy in response to developments in legal standards, our information handling processes, or the features of our Services. The date of the most recent revision will be clearly marked at the top of this Policy. In the event of a significant change, we will provide you with a conspicuous notice as required by law. Your continued use of our Services after any such updates take effect constitutes your acceptance of the revised Policy and your agreement to be bound by its terms. We encourage you to regularly review this Policy to ensure you are informed of any changes.

If you have any questions about our privacy policy or information practices, please submit a request through our official website https://haivivi.com or contact us directly by sending an email: [email protected]