Privacy Policy

Last Updated: March 7, 2026

This Privacy Policy ("Policy") explains how we collect, use, and process your personal data when you use our mobile, web, and desktop applications (collectively, the "Applications"), which allow you to control your AI Pebble device (the "Device") and use other related services provided by us (collectively, the "Services").

This Service is provided by Shenzhen Duowei Communication Technology Co.,Ltd ("AI Pebble", "we", "our", or "us"). The following is a summary of the information in this Policy. This summary is intended to help you navigate the key points but is not a substitute for reading the full document.

For convenience, this document is available in multiple languages. In case of any inconsistency, the English version shall prevail.

Policy Summary

• Data we collect: Information you actively provide and data automatically generated as necessary for account creation, device control, and service provision. See Section 1 for details.
• How we use data: To provide core features, account management, security protection, and support services. See Section 2 for details.
• Data storage and protection: Stored on secure servers and retained only for as long as necessary. See Section 3 for details.
• To whom we disclose data: Disclosed to affiliates, service providers, or as required by law only when necessary. See Section 4 for details.
• International transfer safeguards: Appropriate safeguards are implemented for cross-border data transfers as required by law. See Section 5 for details.
• Your rights: You may access, correct, and delete your personal data, and manage permission settings. See Section 6 for details.

Special Notice

This Policy is designed to help you understand the features we provide and the personal information necessary for these features to operate. For any non-essential personal information, we will separately obtain your explicit consent when you choose to use the relevant feature.

For special categories of personal data (or sensitive personal information), we will obtain your explicit consent in advance through clear notices (such as pop-up prompts).

Device permissions are disabled by default. When specific features require important or sensitive permissions, we will request your consent via pop-up prompts before activation. You may revoke such permissions at any time in the in-app settings or device system settings. Refusing or disabling a permission will not affect the use of unrelated features.

For example, when you use the camera to take photos or videos, or use the microphone for recording, we will request the corresponding permission before first use.

Scope of This Policy

Please note that this Privacy Policy applies only to services provided by AI Pebble. It does not apply to any third-party websites, services, or applications, even if they are accessed through our platform (for example, via links or third-party SDKs). When you interact with these third parties, they may independently collect your personal information. Their privacy policies and data processing practices will govern their collection and use of your data. We strongly recommend that you review their privacy policies before providing any information to them.

1 What Data Do We Collect?

We are committed to providing you with excellent service while respecting your privacy. To achieve this goal, we strive to collect only personal data necessary to provide and improve our Services.

"Personal data" means any information that can directly or indirectly identify you. We collect this data when you interact with us, such as creating an account, pairing a device, or using the features of the Applications. Details of the data we collect are as follows:

Information You Directly Provide or Create

• Account information: Email address, encrypted password, nickname, avatar, country/region, industry, occupation, role, and account ID.
• Subscription and payment information: Subscription type, order details (such as order number, amount, and payment status), and purchase history. Please note that we do not directly collect or store your sensitive payment information (such as credit card numbers); this is securely processed by our third-party payment partners.
• Contact information: Name, email address, phone number, and mailing address.
• Your content: Content you choose to upload, provide, or create through the Services. This may include audio files, photos, documents, email content or messages you choose to share with the Services, text prompts, and other materials, as well as related metadata (such as file name, timestamp).
• Camera/microphone content: Photos, videos, and recordings (including real-time beauty-processed views) generated when you use the camera and recording features, as well as related metadata. This content is stored locally on your device by default and is transmitted only when you actively save, upload, or share it.
• AI-processed and generated content: Outputs generated at your request when you use AI features, such as transcriptions, summaries, answers, analyses, or other generated content, as well as related metadata.
• Extracted or structured information: Information we may extract from your content to provide the Services (such as key points, meeting-related details, or other structured fields), including text extracted from images or scanned documents where applicable.
• Speaker labeling data: Information generated during recording to distinguish different speakers, speaker labels you assign, and labels related to your own voice.
• Sharing and access data: If you choose to share content with others, we process information necessary to enable sharing and access control, such as sharing settings, links or access identifiers, recipient information (for private sharing), and related metadata (such as creation time, expiration, and revocation status).
• Inference and personalization data: Information we generate or organize based on your interactions or content to personalize the Services, such as saved preferences, memory items you choose to add or created based on your usage, and profile descriptions or summaries where applicable.
• Support and feedback information: Order number, issue details (type, description, device involved), communication records (chat history, emails, call recordings), and any supporting files you provide (images, videos).
• Device settings information: Wi-Fi name and password, Bluetooth name.
• Contract information: Records of your consent to our policies and terms (such as version number, timestamp).

Information We Automatically Collect

• Device and application information: AI Pebble device serial number, model, and firmware version; your mobile device's brand, operating system, unique device identifier, and version, or your computer's operating system and version.
• Usage and performance data: Operation logs (such as clicks, feature usage, timestamps), diagnostic and performance data (such as system events, crash reports), and paired device status (such as battery level, network connection).
• Cookie information: Data collected through cookies and similar technologies when you use our web services. For more information, please refer to the Cookie Policy.

2 How Do We Use Your Data?

Legal Basis for Processing

We process your personal data only where we have a legal basis. Depending on the specific circumstances, our processing activities are based on one or more of the following legal bases:

• Contractual necessity: Processing is necessary to provide the services you request, including recording, transcription, summarization, account management, and device functionality.
• Your consent: Certain optional features are enabled only with your explicit consent, which you may withdraw at any time through the app settings.
• Legitimate interests: Processing is necessary to improve the quality, security, and functionality of our Services, provided that these interests are not overridden by your rights and interests.
• Legal obligations: Processing is necessary to comply with applicable laws and legitimate requirements of authorities.

Purposes of Processing

• Core Services and AI-Driven Features

We process your personal data to provide and operate the Services and AI features you use, including device recording, content management, AI-based processing, and cross-platform access. This includes all features necessary or incidental to providing the Services you choose to use, whether available now or launched in the future.

Our Services include cloud sync functionality, which allows you to store recordings, transcriptions, summaries, and related content in your private cloud so that you can access and manage them across supported devices and platforms. For the web application and desktop application, cloud sync is necessary to provide the Services, as these platforms rely on cloud storage and processing to operate.

We also process your content to provide AI-driven features that may be used in the Services. These features may include transcription, summarization, reasoning, analysis, and other AI-generated outputs you request as part of the Services.

Certain features operate only based on your choices, settings, or specific requests, such as but not limited to speaker labeling, memory-related features, and personal AI cognitive assistant features.

• Account Management and Communication

We use your account information and contact information to create and manage your account, verify access, process subscriptions, and communicate with you about important service-related matters.

• Security, Stability, and Service Improvement

We process device and application information and usage and performance data to ensure the security, stability, and reliability of the Services, detect abnormal activities, prevent fraud, and improve performance.

We may also offer an optional user experience improvement program, which operates only with your explicit consent. Participation in this program allows us to use anonymized or aggregated data to improve the Services and conduct quality analysis.

• Legal and Regulatory Compliance

We may process personal data as necessary to comply with applicable laws, regulations, or legitimate requirements of public or governmental authorities.

Our Commitment to Your Content and AI

We want to be fully transparent about how we handle your most sensitive data:

We will never use your content (such as your audio files, photos, or text) to train, optimize, or develop our own or any third-party artificial intelligence (AI) or machine learning models without your prior explicit and informed consent.

We only share certain content you submit to AI features with our large language model (LLM) service providers to perform the requested tasks. Our agreements require that such data not be used to train their models and be retained only for the limited period necessary to provide the Services, meet security requirements, and comply with requirements.

3 How Do We Retain and Protect Your Data?

Your personal data will be processed and stored on secure servers located in Singapore. We retain your data only for as long as necessary to fulfill the purposes described in this Policy, primarily to provide our Services to you. Most of your data is associated with your account and will be retained as long as your account remains active. When you deactivate your account, we will take steps to delete or anonymize this data in accordance with applicable laws.

We are committed to protecting your data and have implemented a range of appropriate technical and organizational security measures designed to prevent unauthorized access, use, alteration, or disclosure of data. These measures are regularly reviewed and updated to adapt to new threats and best practices.

Protecting your data is a shared responsibility. Your role is also crucial. We strongly recommend that you use a unique and complex password for your account and keep it confidential. If you suspect your account security is compromised, please contact us immediately. While we take all reasonable measures to protect your information, please be aware that no Internet transmission can be 100% secure. Therefore, any data you send to our Services is at your own risk.

4 To Whom Do We Disclose Your Data?

We do not sell your personal data. However, in limited circumstances and for specific purposes, we may disclose your data to the following parties:

• Our service providers and affiliates: We cooperate with trusted third-party service providers and company affiliates to help us operate, provide, and improve our Services. For example, we use them to provide services such as cloud hosting, customer support, and information technology assistance. We only share the data necessary for them to perform these services on our behalf. We have established strict contracts requiring them to keep your data confidential and secure and prohibiting them from using your data for any other purpose.
• At your direction: Certain features allow you to share your content with others. When you choose to share, the recipients you authorize (or, if you choose to share publicly, anyone with the link) may access the content you share, subject to the settings you choose and any access controls we provide.
• For legal compliance and security: We may need to disclose your personal data to comply with applicable laws or respond to valid legal processes, such as court orders, subpoenas, or requests from public or governmental authorities. We may also share your information with our legal counsel, auditors, or other professional advisors when necessary, such as for audits or to protect our legitimate rights and interests.
• In connection with business transfers: If AI Pebble is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, your personal data may be shared or transferred as part of that transaction. We will ensure that the new entity complies with privacy commitments at least as protective as those in this Policy.

5 Where Do We Transfer Your Data?

Our primary servers are located in Singapore. Therefore, your personal data will be transferred to and processed in Singapore, which may not be within your country of residence. In addition, due to the global nature of our business, our affiliates and service providers may access your data from other countries for the purposes described in this Policy.

We understand that data protection laws vary from country to country. To ensure adequate protection when internationally transferring your data, we rely on legally recognized safeguards. These measures may include, for example, implementing approved contractual clauses (such as the European Standard Contractual Clauses) or transferring data to countries deemed by relevant authorities to provide adequate protection.

6 What Rights and Choices Do You Have?

We believe you should be in control of your personal data. Depending on your region, you have certain rights regarding the information we hold about you.

We make it easy for you to exercise many of these rights directly within the application. For example, you can access and correct your account information through the profile settings in our application. Through the same menu, you can also delete your entire account and associated data, or unpair and reset a specific device to delete its associated data.

Depending on applicable law, you may also have other rights, such as the right to data portability, the right to withdraw consent, or the right to object to or restrict certain types of data processing. To exercise these rights or for any requests that cannot be completed within the application, please contact us using the contact information in Section 10.

Please note that the specific rights available to you may vary by region. We have provided more detailed information for California residents in Section 8. When you submit a request, we need to verify your identity before proceeding and will respond in accordance with applicable data protection laws. You also have the right to complain to your local data protection authority.

7 How Do We Protect Minors?

Our Services are intended for adults only. If you have not reached the age of majority in your jurisdiction, please do not use our Services. If you are unsure whether you meet the age requirement, please consult your guardian for verification.

If you are a parent or guardian and discover that a minor is using our Services, please contact us using the contact information provided in Section 10 below so that we can stop providing the relevant services.

8 What Rights Do California Residents Have?

If you are a California resident, the California Privacy Rights Act (CPRA) grants you the following rights regarding personal data. For detailed information on the categories of personal data we have collected and disclosed in the past 12 months, please refer to Sections 1 and 4 of this Policy.

Your California Privacy Rights

• Right to know: You have the right to request information about the personal data we collect, use, and disclose about you.
• Right to correct: You have the right to request that we correct inaccurate personal data we hold about you.
• Right to delete: You have the right to request that we delete your personal data, subject to certain legal exceptions.
• Right to opt out of sale/sharing: You have the right to instruct us not to "sell" or "share" your personal data. Because we use certain analytics and performance cookies, this activity may be considered "sharing" under the California Privacy Rights Act (CPRA). You may exercise your right to opt out by enabling the Global Privacy Control (GPC) signal in your browser or by contacting us.
• Right to limit use of sensitive personal data: You have the right to request that we limit the use of your sensitive personal data. However, please note that there are certain exceptions to this right under the law. For example, your account password is considered sensitive data. We use it only for necessary purposes, such as verifying your access, maintaining the security and integrity of your account, and enabling core features of the Services. Because these uses are necessary to provide the services you request, the right to limit use does not apply to this necessary processing. We do not "sell" or "share" your password or other sensitive personal data.
• Right to non-discrimination: We will not discriminate against you for exercising any of your privacy rights.

How to Exercise Your Rights

To submit a request to exercise these rights, please contact us using the contact information in Section 10. We need to verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf.

If you wish to appeal a decision we make regarding your request, you may do so by contacting us. If your appeal is denied, you have the right to contact the California Attorney General.

Other California Disclosures

Shine the Light: We do not disclose personal data to third parties for their direct marketing purposes.

Minors: We do not knowingly "sell" or "share" the personal information of users under 16 years of age.

9 Additional Disclosures for EEA, UK, and Swiss Users

This section provides additional information for individuals located in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland.

International Transfers

As described in Section 5, depending on your location and how you use the Services, we may store and process your personal data in jurisdictions outside your country of residence and access it from such jurisdictions. Where required by applicable law, we implement appropriate safeguards for such international data transfers, which may include:

• For transfers subject to EU GDPR: EU Commission Standard Contractual Clauses (SCCs);
• For transfers subject to UK GDPR: UK International Data Transfer Agreement (IDTA) and/or UK Addendum to the EU SCCs;
• For transfers involving Switzerland: EU Standard Contractual Clauses with Swiss-specific modifications where applicable.

You may contact us using the contact information in Section 10 to request information about relevant transfer safeguards (and, where feasible, how to obtain copies).

Supervisory Authorities

If you believe that our processing of your personal data violates applicable law, you have the right to complain to the competent data protection supervisory authority. Specifically:

• UK: Information Commissioner's Office (ICO);
• Switzerland: Federal Data Protection and Information Commissioner (FDPIC);
• EEA: Your local supervisory authority (e.g., in your habitual residence, place of work, or place of the alleged infringement).

We encourage you to first contact us using the contact information in Section 10 so that we can promptly resolve your issue.

Automated Processing and Personalization

Certain features of the Services use automated processing to generate outputs you request and personalize your experience (for example, by using recent interactions or content you choose to provide to improve the relevance of summaries, recommendations, or responses). Where necessary, we provide additional feature-specific transparency information and control options so that you understand how the feature works and manage your choices.

This automated processing does not produce legal effects concerning you or similarly significantly affect you. We do not use automated decision-making that produces such effects solely. You may manage applicable settings and options as described in Section 6.

Requirement to Provide Personal Data

Certain personal data is required to provide the Services. If you choose not to provide such data, we may not be able to provide some or all of the Services. Where processing is optional and based on your consent, you may refuse or withdraw consent as described in this Policy.

10 How to Contact Us?

If you have any questions about this Privacy Policy, wish to exercise your rights, or have any concerns about your data, please feel free to contact us.

To ensure your request is handled efficiently, please use the following email address: support@sz-duowei.com

11 How Will This Policy Be Updated?

We will update this Policy in a timely manner and recommend that you regularly check the latest version of this Policy via the App's "Me > About AI Pebble > Privacy Policy". If there are any material changes to this Policy, we will notify you in advance through appropriate means such as pop-ups, push notifications, or emails, depending on the nature of the change.

12 Background Service Description

This application uses background services only for the operation of core features and will not auto-start or associate-start other applications without user consent. All background services will stop after exiting the application.

13 Camera and Microphone Usage

AI Pebble provides beauty camera, image editing, meeting recording, AI translation, and Bluetooth device management features. To provide these features, we may use your device's camera and microphone. The following is a transparent explanation of how these permissions are used:

Camera

• Photo capture and beauty: When you use the camera to take photos or record videos, the camera is used for real-time beauty preview (skin smoothing, whitening, face slimming, filters, stickers, etc.). Image processing is primarily performed locally on your device; processed photos or videos leave your device only when you actively save, export, or share them.
• Screen casting: When you cast the camera view to a paired AI Pebble Bluetooth device (such as a smart watch), the real-time view is transmitted to that device over a Bluetooth connection. This transmission occurs only when you actively enable screen casting and is used solely for display on that device.
• We do not use the camera in the background and do not use camera images for facial recognition, identity verification, or any purpose without your consent.

Microphone

• Meeting recording: When you use the meeting recording feature, the microphone records audio. The recording is used to generate AI content such as meeting minutes, to-do items, and mind maps, and is uploaded to your cloud account for cross-device access.
• AI translation: When you use the conversation translation feature, the microphone captures speech for recognition and translation.
• We do not listen to or record your conversations without your explicit authorization.

All sensitive permissions (camera, microphone, etc.) are disabled by default and are requested only when you actively use the corresponding feature. You may revoke these permissions at any time in system settings or in-app settings; doing so only affects the related feature and does not affect the use of other features.