Privacy Policy

1. Scope of This Privacy Policy

1.1 This Privacy Policy applies to the collection, storage, analysis, transmission, use, processing, transfer, backup, deletion, and protection of user information by NICE TALK and its affiliates in the course of selling products and providing services. Information that cannot identify a user's real identity independently or in combination with other information, or that does not reflect a specific user's activities, is not personal information in the legal sense.

2. Scope and Methods of Collecting User Information

2.1 When you register and use relevant services on the OfoxAI unified API gateway platform, you understand and agree that we may collect, store, and use data related to your user information ("User Information") as set out in Sections 2 and 3 below. If you do not provide or agree to our collection of relevant user information, you may be unable to become a user, unable to order our products, or unable to receive certain services, or the services may not achieve their intended effect:

2.1.1 Personal profile information you fill in and/or provide, including: name/title, phone number, email, address (non-precise address), and questionnaire information related to providing services, that can identify you independently or in combination with other information.

2.1.2 Information obtained across different devices: when you access our website or API endpoints, we will receive and record device or application information (e.g., device name, operating system, browser type and version, device type, unique device identifier, and other hardware/software characteristics), location-related information (e.g., IP address, GPS location, and other sensor information), cross-device information (e.g., OpenID, nickname, avatar), and other technical metadata. We may associate this information to provide consistent service across devices.

2.1.3 Log information: When you use the services, NICE TALK automatically collects information about your use as network logs. Examples include your IP address, browsing information, access records, click information, language, date and time of access, cookies, and web beacons.

2.1.4 Usage data: we automatically collect your API usage information, including request timestamps, token consumption, model selection, response times, and error codes. This data is used for billing, analytics, and service improvement.

2.1.5 User account support information: based on your use of NICE TALK services, user consultation records, fault reports, and related troubleshooting processes (e.g., communication or call records). NICE TALK will record and analyze these to respond to your help requests more promptly and improve services.

2.1.6 Information obtained from third parties: NICE TALK may obtain relevant user information from third parties through proper channels and use such information in compliance with applicable laws.

2.1.7 Transaction and payment information: to help you complete transactions and ensure transaction security, NICE TALK may collect your transaction item/service information, order number, time of order, transaction amount, payment method, and third-party payment account (e.g., Alipay, UnionPay, Stripe).

2.1.8 Information exempt from consent by law: including information directly related to national security, defense security, public safety, public health, or public interest; disclosure or provision required by applicable laws; matters directly related to criminal investigation, prosecution, trial, or enforcement; information necessary to protect the life and property of NICE TALK, other customers, the Company, and its affiliates, or to defend the security of products or services; information that you have voluntarily disclosed to the public or that NICE TALK has lawfully obtained from public disclosures (such as lawful news reports or government disclosures); information necessary to conclude or perform a contract at your request; information used by academic institutions for statistics or research in the public interest, with de-identification applied before external disclosure; and other situations specified by law.

2.2 The scope of user information above is not necessarily what we will collect. We will collect, in a targeted manner, only the necessary information related to providing services to you based on the services you choose.

3. Use of Cookies and Similar Technologies

3.1 You understand and agree that when you register on the OfoxAI website and enjoy our services, we may use related technologies to collect and store user information (including User Information not collected through the cookies below). In this process, one or more cookies or anonymous identifiers may be sent to your computer or mobile device to collect user information from time to time. Cookies or anonymous identifiers typically include identifiers, site names, and some numbers and characters. The cookies we use include those necessary for the normal operation of the website (authentication and security cookies) and analytics cookies that help us understand how visitors interact with the website.

3.2 Many browsers provide a Do Not Track feature, which allows a Do Not Track request to be sent to websites. If your browser has Do Not Track enabled or you choose not to use cookies, we will respect your choice, but you may be unable to log in or use services or features that depend on cookies.

3.3 We will not use cookies or related technologies for any purpose outside this Privacy Policy, nor will we share, transfer, or disclose user information obtained through cookies or related technologies to parties other than those described in this Privacy Policy. You may keep or delete cookies according to your preference, or clear all cookies saved in your browser.

4. Storage of User Information

4.1 Your data is stored on secure servers provided by reputable cloud infrastructure providers. Unless you request modification or deletion, we will retain user information effectively using security measures that comply with industry standards and are reasonably feasible.

4.2 Retention period: we will retain user information only for the period necessary to achieve the purposes set out in this Policy, unless otherwise required by applicable law. We determine retention mainly based on the following criteria: 4.2.1 Completing transaction purposes with you and maintaining transaction and business records to respond to potential inquiries or complaints; 4.2.2 Ensuring the security and quality of the services we provide; 4.2.3 Whether you have consented to a longer retention period; 4.2.4 Whether there are any other special agreements or legal requirements regarding retention periods.

4.3 After the retention period expires, we will delete or anonymize your personal user information in accordance with applicable law.

5. Use of User Information

5.1 To provide the NICE TALK related services, we will use the collected user information in accordance with this Privacy Policy and authorization agreements. For any other purposes beyond these, we will obtain your prior consent. Specifically, we will use the collected user information for the following purposes:

5.1.1 To provide services to you (including, but not limited to, direct marketing by us or our affiliates to users). NICE TALK and its affiliates will send you information, notices, or conduct business communications, including but not limited to verification codes required to complete services, push notifications necessary for use, and security alerts.

5.1.2 Based on statistical data about user information, we may design, develop, and promote entirely new products and services (including but not limited to ad promotion, user profiling, and statistics).

5.1.3 To enhance the security of services provided by NICE TALK and its affiliates, to ensure a safe operating environment and identify abnormal account states, and to protect the personal and property safety of you and other users or the public from harm; to better prevent phishing sites, fraud, network vulnerabilities, viruses, network attacks, and network intrusions; and to more accurately identify situations in violation of laws or NICE TALK agreements or rules, we may monitor your use patterns, use your user/member information, and combine device information, relevant network logs, and information lawfully shared by our affiliates to assess account and transaction risks, perform identity verification, detect and prevent security incidents, and, as required by law, take necessary recording, auditing, analysis, and handling measures.

5.2 After technical de-identification of user information (we adopt appropriate management measures to reduce the risk of re-identification, and store de-identified data separately from information that could be used to identify you), you agree and understand that we may use such de-identified information and, without disclosing your user information, we may analyze and commercially use such de-identified information.

5.3 You acknowledge and agree that unless you send a request to modify or delete information to NICE TALK and the request has been processed, all user information you provide while using NICE TALK services will continuously authorize us to use all user information within the scope of this Privacy Policy during the period of your use of the services.

5.4 You acknowledge and agree that we may statistically analyze user use of our services and may share such statistics with third parties to showcase the overall trends of our services. Such statistics will not contain any user information.

6. Sharing, Transfer, and Disclosure of User Information

6.1 To achieve the purposes declared in this Privacy Policy, certain of our services will be delegated to third parties to provide to users. To assist third parties located in China, Singapore, or other countries or regions to serve users, we will, on the principles of lawfulness, legitimacy, necessity, specificity, and clear purpose, provide, transfer, or use user information (or part thereof) with/to third parties, who can only access user information necessary to perform their duties.

6.2 We will reasonably investigate third parties' data security capabilities and require them to adopt necessary confidentiality and security measures to store, use, and process the user information we provide or transfer, ensuring that such information is not leaked and is retained no longer than reasonably necessary.

6.3 As our business develops, we may engage in mergers, acquisitions, equity transfers, asset transfers, business transfers, or similar transactions, and changes of control or equity may occur. User information may be transferred to our affiliates located in China, Singapore, or other countries or regions as part of such transactions without further consent or written consent from users. In such changes, we will require the new user information controller to continue protecting user information in accordance with laws and standards no lower than those required by this Privacy Policy.

6.4 We may provide, share, or transfer user information to our affiliates located in China, Singapore, or other countries or regions in daily operations, but we will not provide, share, or transfer user information to any third party other than NICE TALK's affiliates, except: 6.4.1 With the prior explicit authorization or consent of the user; 6.4.2 Sharing initiated by the user with third parties; 6.4.3 Where directly related to national security, defense security, public safety, public health, or public interest; 6.4.4 Where disclosure or provision is required by applicable laws, or is directly related to criminal investigation, prosecution, trial, or enforcement. In compliance with laws, when we receive requests to disclose information, we require that the requesting party produce corresponding legal documents such as subpoenas or inquiry letters, and we will carefully examine all requests to ensure legality; 6.4.5 Within the scope permitted by applicable laws, to protect the lives and property of NICE TALK's other users, the Company, and its affiliates, or to defend the security of products or services, such as identifying, preventing, and addressing fraud or illegal activities and reducing credit risks; 6.4.6 User information collected from lawfully disclosed sources, such as legitimate news reports or government disclosures; 6.4.7 Necessary to enter into or perform a contract where the user is a party, or to implement human resources management according to labor rules and lawfully signed collective contracts; 6.4.8 Where an academic institution carries out statistical or academic research in the public interest, provided that information contained in results disclosed externally is de-identified; 6.4.9 Other circumstances provided by law.

6.5 You agree that we may use user information for direct marketing by NICE TALK and/or our affiliates. If you do not agree, you may email us at [email protected] and clearly inform us of your decision. We will cancel and record your opt-out choice and will subsequently stop using your user information for such direct marketing.

7. Security Protection of User Information

7.1 We attach great importance to user information security and will endeavor to take industry-standard reasonable security measures (technical and managerial) to protect user information and prevent improper use or unauthorized access, disclosure, use, modification, damage, loss, or leakage.

7.2 We will use reasonably feasible methods such as encryption and anonymization to protect user information, and use trusted protection mechanisms to prevent malicious attacks.

7.3 We will establish a dedicated information security team, security management systems, and data security processes to safeguard user information. We implement strict data use and access controls, ensuring that only authorized personnel can access user information, and we periodically audit data and technology security.

7.4 Despite the reasonable and effective measures we have taken and compliance with relevant legal standards, please understand that due to technical limitations and possible malicious means, in the internet industry, it is not possible to always fully ensure that user information is absolutely secure. We will do our best to ensure the security of the information you provide. You acknowledge and understand that the systems and communication networks used to access our services may experience issues due to factors beyond our control. For such risks outside our control, you agree that we do not provide any compensation for losses or damages resulting from them. We strongly recommend that you take proactive measures to protect your information.

7.5 We will develop an emergency response plan and activate it immediately upon occurrence of a user information security incident to prevent the expansion of impact and consequences. Upon occurrence of such an incident (leakage, loss, etc.), we will, in accordance with legal requirements, promptly notify users about: the basic nature and possible impact of the incident; measures already taken or to be taken; recommendations for self-prevention and risk reduction; and remedies for users. We will inform users via push notifications, emails, letters, SMS, etc. Where individual notification is impractical, we will publish announcements through reasonable and effective means. We will also report the handling of user information security incidents as required by relevant regulators.

7.6 We hereby specifically remind users that the information protection measures provided in this Privacy Policy apply only to products or services provided by NICE TALK and its affiliates. We have no ability or obligation to protect information submitted by users on applications or websites outside the NICE TALK services, regardless of whether access to such software, websites, or platforms is based on links or guidance from NICE TALK. We bear no legal responsibility for this.

8. User Information Management

8.1 We attach great importance to user management of information and do our utmost to protect your right to access, modify (update or correct), supplement, delete, change the scope of authorization, and withdraw authorization of user information.

8.2 If you wish to access, modify (update or correct), supplement, delete, change the scope of authorization, or withdraw authorization of your user information, you may contact us via our service mailbox [email protected] to submit related requests. After verifying your identity, we will provide services for access, modification, deletion, and termination of authorization as you need.

8.3 If you apply to delete information and terminate our authorization to provide you with related services, we will delete the relevant information in our systems and cease providing the services. At the same time, your decision to withdraw authorization does not affect information processing we have previously carried out based on your authorization. After you or we assist with deletion, due to applicable law and security technology limitations, we may not be able to immediately delete the corresponding information from backup systems. We will store your personal information securely and limit any further processing until the backup can be cleared or anonymized.

8.4 In the following situations, we may not respond to your request as required by applicable laws: 8.4.1 Related to national security or defense; 8.4.2 Related to public safety, public health, or major public interest; 8.4.3 Related to criminal investigation, prosecution, trial, or enforcement; 8.4.4 Where there is sufficient evidence that the user has subjective malice or is abusing rights; 8.4.5 Where responding would seriously harm the lawful rights of the user or others or organizations; 8.4.6 Involving trade secrets; 8.4.7 Other situations specified by law.

9. API Content Processing

9.1 When you send API requests through our services, your input content (prompts) will be transmitted to the third-party AI model provider you select for processing. As a routing intermediary, we will not use your input content for any purpose other than fulfilling the API request.

9.2 Your API request content is processed in real time and we do not persistently store it beyond short-term operational logs. However, third-party AI model providers may have their own data retention policies, governed by their respective terms of service or privacy policies. We recommend that you review the underlying AI model providers' terms of service or privacy policies and avoid including unnecessary sensitive personal information in API requests.

10. Cross-Border Data Transfers

10.1 Our services are operated by NICE TALK PTE. LTD., a company incorporated in Singapore. Depending on the AI model you choose, your API request data may be processed in different jurisdictions:

10.1.1 Mainland China models: When you access AI models provided by Mainland China cloud vendors (such as DeepSeek, Qwen, Kimi, etc.), your API requests are processed directly by the corresponding Mainland China vendor's API service and data remains within the Mainland;

10.1.2 Overseas models: When you access international AI models (such as GPT, Claude, Gemini, etc.), your API requests are routed via our Hong Kong servers and processed by infrastructure operated by a Singapore service provider before being forwarded to the respective model provider.

10.2 We take reasonable measures in each jurisdiction to ensure that your information is adequately protected in accordance with the data protection laws applicable there. By using our services you consent to the data-routing arrangements above and to the jurisdiction of the corresponding regions.

11. Minors

11.1 If you are a minor under 18, you should read this Privacy Policy together with your legal guardian under their supervision and guidance before using NICE TALK products or services, and use them only with the guardian's consent. We protect minors' personal information in accordance with applicable laws and will collect, use, store, share, transfer, or disclose minors' personal information only where permitted by law, with the explicit consent of a parent or other guardian, or where necessary to protect the child.

11.2 You and your guardian are responsible for the authenticity of the information you provide. If we are unable to determine from the information you provide that you are a minor, we do not bear responsibility for protecting minors' privacy.

12. Effectiveness and Changes to This Privacy Policy

12.1 To provide users with better service, NICE TALK services will be updated and changed from time to time. We may revise this Privacy Policy as appropriate; such revisions form part of this Privacy Policy and have the same legal effect. In principle, we will not diminish the rights you are entitled to under the currently effective version of this Privacy Policy.

12.2 After updates, we will inform you of the specific changes through website announcements, email, or other appropriate means so that you can keep up with the latest version. You acknowledge and agree that we need not notify you individually. Updates to the Privacy Policy may take effect immediately without requiring your further written consent. If you disagree with the modifications, please contact us immediately and stop using the Services. If you continue to use the Services, you are deemed to have agreed to and accepted the modifications.

13. Dispute Resolution

13.1 In performing this Agreement, any disputes between the parties should first be resolved through consultation, including by filing complaints with data-protection authorities. If consultation fails, either party may apply to the Singapore International Arbitration Centre ("SIAC") for arbitration under the SIAC Rules then in force. The seat of arbitration shall be Shanghai, China; the language shall be Chinese. The arbitral award is final and binding on both parties.

14. Miscellaneous

14.1 The headings in this Privacy Policy are for convenience of reading only and do not affect the meaning or interpretation of any provision.

14.2 If you have opinions or suggestions regarding this Privacy Policy or the collection, storage, use, sharing, disclosure, or protection of user information, you may provide feedback or complaints through NICE TALK feedback channels. We will respond as quickly as possible after receiving your feedback.

14.3 We have set up a dedicated feedback channel for information protection. You may contact us via our service mailbox: [email protected].

14.4 The copyright of this Privacy Policy belongs to NICE TALK. Within the scope permitted by law, the Company reserves the right of final interpretation and modification.