Privacy Policy of Tanstar

Date:23/05/2025

This Privacy Policy applies to the Tanstar app (hereinafter referred to as the "Application") for mobile devices, created by Deep Turing Test Technology Limited (hereinafter referred to as the "Service Provider").

Data to Be Processed

The use of our application and services involves the collection and processing of personal data. Below is an overview of the categories of personal data collected. Some data is necessary for creating an account and accessing the application (such as your email and information from linked accounts like Apple), while other data is only requested if you choose to enable certain premium features. As for the sources of your personal data, some information is provided directly by you, while other personal data is automatically collected when you interact with the application.

The app only collects personal data necessary to provide its services and for the purposes described in this policy. Specifically:

Account Data:
To access this application, you need to create a personal account through Apple's authentication service. We only process the email address and basic information associated with the selected account, which are necessary for creating your profile. In any case, you can update your account-related information at any time in the "Profile" section of the application.

App Usage:
While using the application, you may interact with existing chatbots (created by us). During conversations, you may voluntarily share personal data, including sensitive information. We advise against providing unnecessary information, especially details related to third parties. Conversation data will be stored in our system as outlined in this policy. Additionally, your messages and other data may be used to optimize your chatbot interaction experience and improve the chatbot for all users.

Notifications:
This app sends push notifications only with user consent. Furthermore, the app may send in-app messages, including service updates, system announcements, or changes to the End User License Agreement (EULA) and this Privacy Policy.

Support and Assistance:
Users can contact us via email at deepturinghk@gmail.com. We only process data voluntarily provided by users to respond to support requests and encourage users to limit the information shared to what is absolutely necessary.

Subscription Plans:
The app offers paid subscription plans. To use these plans, we process the data required to manage the subscription.

Usage Data:
When using the app, we automatically collect technical information related to your device and connection, such as IP address, access time, browser type, operating system, internet service provider, and other technical parameters. We also use necessary cookies and similar technologies to enable login and ensure the proper functioning of the service. Additionally, to troubleshoot technical issues, we log activities associated with your user ID (e.g., login times, chatbot usage, message submissions).

Purposes and Legal Basis for Processing

The aforementioned data processing activities are conducted solely for the following purposes:

1. Registration, Creation, and Management of Your Personal Account:
   Accessing the app requires creating a personal account, regardless of your subscription plan. For this purpose, we only need your email address and data from linked accounts (e.g., Apple). Without this information, we cannot process your registration or allow you to use the app. The legal basis for this processing is the performance of (pre-)contractual measures.
2. App Usage:
   We process the personal data you provide during registration or subsequently (e.g., identification data, in-app messages, logs) to enable you to interact with chatbots by sending and receiving messages, create new chatbots, manage in-app purchases, and ensure the proper functioning of the app, including all technical and organizational activities required for service delivery. Additionally, we use your data to address support requests related to issues you encounter while accessing or using the app. These processing activities are carried out to fulfill our contractual obligations to you.
3. Model Improvement:
   We use personal data obtained from your in-app conversations with chatbots to enhance and fine-tune the AI models these chatbots rely on. Before using any conversation data for this purpose, we remove personally identifiable information. This means only the information you provide during chatbot interactions is used. This processing aims to optimize the app's functionality, ensuring more accurate, personalized, and consistent performance in line with your expectations. By processing your data, we can deliver more engaging conversations, improve interaction quality, and better tailor chatbot responses to your needs. This processing is based on our legitimate interest in keeping the app up-to-date, functional, and competitive in a rapidly evolving market.
4. Marketing and Advertising:
   If you have a free subscription, we may use your personal data to send you advertisements based on your consent. If you downloaded the app through an advertisement, we may also share certain information (e.g., usage patterns) with our advertising partners to evaluate the effectiveness of their campaigns and ensure accurate attribution. This processing is based on our legitimate interest in ensuring business effectiveness and competitiveness.

Additionally, where necessary, we may process your data collected through the app for other legally compliant purposes.

Who Can Access Your Data

Only specifically authorized personnel acting under the data controller's instructions can access your personal data, adhering to strict guidelines that prioritize your rights and our security standards.

Your data may also be shared with vendor companies (acting as data processors) involved in the provision and operation of the app, in accordance with Tanstar's instructions and security safeguards.

Finally, your data may be disclosed to third parties to comply with legal obligations and/or requests from authorities.

Data Retention Period

The processing of data collected through your use of the app will not exceed the time necessary to achieve the aforementioned purposes and, in any case, will not extend beyond the duration of your account plus five (5) years after account deletion.

In certain circumstances, a longer retention period may be necessary to enable Tanstar to defend and enforce its rights in legal claims, disputes, or litigation, or to comply with applicable laws or orders from authorities.

Rights of Data Subjects

Under relevant applicable privacy laws, you may have the following rights:

• Access: You have the right to know whether your data is being processed and, if so, to receive a copy of that personal data, along with information about the processing purposes, data categories involved, recipients of the data, applicable retention periods, and the existence of any automated decision-making processes.
• Rectification: You have the right to request the immediate correction or updating of any inaccurate personal data concerning you.
• Erasure ("Right to Be Forgotten"): You may request the deletion of your data, subject to specific exceptions, such as when:
  1. The data is no longer necessary for the purposes for which it was collected or processed;
  2. You have withdrawn consent for specific processing activities, and no other legal basis exists;
  3. You object to a specific processing activity (see "Objection" below) for reasons related to your particular situation, and there are no overriding legitimate grounds for continued processing;
  4. The data has been unlawfully processed; or
  5. The data must be erased to comply with a legal obligation we are subject to.
• Restriction of Processing: You have the right to request a temporary halt to data processing when:
  1. You contest the accuracy of your data, and we need time to verify it;
  2. The processing is unlawful, but you oppose erasure and request restricted use instead;
  3. The data is no longer needed for the original purposes, but you require it to establish, exercise, or defend legal claims; or
  4. You have objected to one or more processing activities, and we are verifying whether legitimate grounds for continued processing exist.
• Data Portability: You may request to receive your personal data in a structured, commonly used, and machine-readable format and/or have it transmitted directly to another controller.
• Objection: You may object to our processing of your data based on legitimate interests, citing reasons related to your particular situation. Processing will cease unless:
  1. There are compelling legitimate grounds overriding your interests, rights, and freedoms; or
  2. The data is necessary for the establishment, exercise, or defense of legal claims.
• Withdrawal of Consent: You may withdraw previously given consent at any time, without affecting the lawfulness of processing before the withdrawal.
• Complaint: If you believe we have not complied with applicable privacy laws, you have the right to lodge a complaint with your local data protection authority. This does not prejudice your right to seek administrative or judicial remedies.

To exercise your rights and/or request information or clarifications regarding Tanstar's processing of your data, you may contact the data controller at any time using the following details:

• Email: deepturinghk@gmail.com