Privacy Policy of TanStar

Date: 17/06/2026

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", "TanStar", "we", "us", or "our").

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 features or when specific account safety and abuse-prevention scenarios apply.

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 Application only collects personal data necessary to provide its services and for the purposes described in this Privacy Policy.

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 Privacy 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 Application sends push notifications only with user consent. Furthermore, the Application 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 Application offers paid subscription plans. To use these plans, we process the data required to manage the subscription.

Usage Data
When using the Application, 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, such as login times, chatbot usage, and message submissions.

Real-Person Liveness Check and Face Data
TanStar may use a real-person liveness check in specific account safety and abuse-prevention scenarios, such as suspicious automated behavior, scripted requests, fake account activity, spam, impersonation, misuse of AI interaction resources, or other unsafe behavior. The liveness check is not required for basic AI chat.
When a user completes a liveness check, TanStar may temporarily transmit face-related data to our trusted third-party verification service provider, ZOLOZ, a digital identity verification and liveness detection service provided by Ant Group, solely to determine whether the current action is being performed by a real person.
ZOLOZ only provides liveness detection services for TanStar and does not store users' raw face images, raw face videos, video frames, face templates, faceprints, biometric identifiers, or any face database after the verification session is completed.
TanStar does not use face data to identify who the user is. TanStar does not create or store a face database, face template, faceprint, or biometric identifier. TanStar does not use face data for advertising, marketing, user profiling, personalized recommendations, dating matching, unrelated purposes, or AI model training.
TanStar does not store users' raw face images, raw face videos, video frames, face templates, faceprints, biometric identifiers, or any face database after the liveness verification is completed. TanStar only stores the final verification result, such as passed or failed, together with the verification time and related account safety records for account security, fraud prevention, anti-abuse, and prevention of misuse of AI interaction resources.
The final verification result, verification time, and related account safety records are retained only as long as necessary for account security, fraud prevention, anti-abuse, prevention of misuse of AI interaction resources, legal compliance, dispute resolution, or enforcement of our rights, and in accordance with the "Data Retention Period" section of this Privacy Policy.
Users may request deletion of their account and related verification records through the Application or by contacting us at deepturinghk@gmail.com.

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 Application requires creating a personal account, regardless of your subscription plan. For this purpose, we only need your email address and data from linked accounts, such as Apple. Without this information, we cannot process your registration or allow you to use the Application. The legal basis for this processing is the performance of pre-contractual and contractual measures.
2. App Usage
   We process the personal data you provide during registration or subsequently, such as identification data, in-app messages, and 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 Application, 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 Application. These processing activities are carried out to fulfill our contractual obligations to you.
3. Account Safety, Anti-Abuse, and Real-Person Liveness Check
   We may process certain data for account safety, fraud prevention, anti-abuse, prevention of fake accounts, spam prevention, impersonation prevention, prevention of scripted or automated abuse, and prevention of misuse of AI interaction resources.
   In specific account safety and abuse-prevention scenarios, TanStar may ask users to complete a real-person liveness check. This check is used only to determine whether the current action is being performed by a real person. It is not used to identify who the user is and is not required for basic AI chat.
   The legal basis for this processing is our legitimate interest in protecting the security, integrity, and proper functioning of the Application and preventing misuse of our services.
4. 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 Application'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 Application up-to-date, functional, and competitive in a rapidly evolving market.
   For clarity, TanStar does not use face data, liveness verification data, raw face images, raw face videos, video frames, face templates, faceprints, biometric identifiers, or face databases for AI model training or model improvement.
5. 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 Application through an advertisement, we may also share certain information, such as 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 Application 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 Application, in accordance with TanStar's instructions and security safeguards.

For real-person liveness checks, face-related data may be temporarily transmitted to ZOLOZ, our trusted third-party liveness detection service provider, solely for the purpose of completing the liveness check. ZOLOZ is not permitted to use such data for advertising, marketing, profiling, personalized recommendations, dating matching, unrelated purposes, or AI model training.

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 Application will not exceed the time necessary to achieve the purposes described in this Privacy Policy and, in any case, will not extend beyond the duration of your account plus five (5) years after account deletion, unless a shorter retention period applies or a longer retention period is required by law, legal claims, disputes, litigation, security reasons, fraud prevention, anti-abuse, compliance obligations, or orders from authorities.

TanStar does not store users' raw face images, raw face videos, video frames, face templates, faceprints, biometric identifiers, or any face database after the liveness verification is completed.

TanStar only stores the final liveness verification result, such as passed or failed, together with the verification time and related account safety records. These records are retained only as long as necessary for account security, fraud prevention, anti-abuse, prevention of misuse of AI interaction resources, legal compliance, dispute resolution, or enforcement of our rights.

If a user deletes their account or requests deletion of related verification records, we will delete or anonymize the relevant records unless retention is required by law or for legitimate security, fraud prevention, anti-abuse, dispute resolution, compliance, or enforcement purposes.

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, or "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 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