Privacy Policy - Grasfeel

Introduction

All information and data collected or transmitted via the Grasfeel application are owned by SINGAPORE GRASEFEEL TECH PTE. LTD. (hereinafter referred to as "we," "our company," or "us").

Please review our Privacy Policy thoroughly before using the application to ensure you have read and comprehended all provisions. We value your privacy and are dedicated to protecting your personal data.

Should you have any inquiries regarding our privacy practices, our contact information can be found in the "Contact Information" section below.

Scope

This Privacy Policy applies to the data we collect from the following sources:

Email communications exchanged with us;
Interactions with our mobile application;
Non-browser-based engagements with our advertisements;
Your use of our application and interactions with our advertisements on third-party websites and services, provided such ads and applications are associated with our terms.

How We Collect Your Personal Data

A. Data You Provide

"Personal data" refers to any information relating to an identified or identifiable natural person ("data subject").

An "identifiable natural person" means an individual who can be identified, directly or indirectly—particularly by reference to an identifier such as a name, identification number, location data, online identifier, or one or more specific physical, physiological, genetic, mental, economic, cultural, or social identity attributes. When you use our products or features (including Grasefeel and related services), you may voluntarily share the following information:

Account Information: When registering an account or updating account details, we collect information such as your name, email address, phone number, date of birth, gender, and username.
Content Data: When using social posting, chat, or interaction functions, we collect content you actively upload or send, including but not limited to text, image/video posts, comment replies, chat records, and other personal data.
Activity-Related Information: When participating in Grasfeel's promotional campaigns, marketing activities, quizzes, or similar events, we collect information you voluntarily submit, such as activity clicks, participation records, quiz history, and result calculations.
Contact Details: For specific purposes (e.g., contests or surveys), we collect your username, email address, or similar identifiers, along with any other information you choose to provide.
Voluntarily Submitted Personal Information: This includes data you provide for customization or specific purposes, such as date of birth, age, gender, interests, preferences, feedback, survey responses, and marketing preferences regarding us or third parties.
Communication Records: When you contact us for customer support or other communications, we collect details of these interactions, including your email address, the content of your messages,and related information.

We may also collect additional personal data through the application, solely based on your consent. We do not engage in forced collection or require you to submit such data.

B. Automatically Collected Data

When you access or use the Application, we and our service providers may automatically collect certain data about you (referred to as "Usage Data"). Usage Data may include IP addresses, device identifiers, operating systems, and other similar information. If we combine Usage Data with your personal data, the combined information will be treated as personal data in accordance with this Privacy Policy.

Log Data: This refers to data related to your use of the application, such as pages visited, operating system, date/time stamps, etc., which is stored in log files.
Device Information: We may collect details about your mobile device and internet connection, including the device's unique identifier, IP address, operating system, device model, and related specifications.
App Activity Data: We collect information about your connection and usage of devices (e.g., toys), as well as how you interact with our content, advertisements, and events, and your usage patterns of our applications and services. This includes the pages you visit within the application and the paths that lead you to those pages. We also gather information about your time zone settings, operating system, browser, and the device used to access the application.
Usage Data and Preference Inferences: As you use our services, we collect data about your activities—including interactions with the platform and content (e.g., community posts you click on, search terms you use, graphics you create, text added to comments or descriptions), interactions with other users (e.g., follower relationships), information provided during initial registration, and data from partners and advertisers. Based on this, we may infer your preferences. For example, if you create anime-related graphics, we may infer you are an anime enthusiast.
User-Generated Content: This includes comments, photos, videos, text, links, etc., that you choose to create or upload to the platform, along with related metadata (e.g., creation time, location, and creator). If your uploaded content contains others' personal information (e.g., images of individuals in photos/videos), you are deemed to have obtained legal authorization from the relevant parties.
Game Data and User Information: When participating in game events, we collect gameplay-related information (e.g., avatar, nickname, scores) for in-game leaderboards and to enhance user experience.
Points and Coins Service Information: We record details of your participation in platform tasks and activities (e.g., task type, completion time, results), as well as the acquisition, redemption, and usage of your points and coins.
AI Usage Records: We collect information related to your use of our AI services, including generated content, query history, and usage patterns, to ensure service stability, security, and optimize AI functionality.
Location Recognition Technology: This technology may locate you (sometimes precisely) for purposes such as verifying your location and serving or restricting content based on it.
Stored Information and Files: The application may access metadata, tags, and other information related to files stored on your device (e.g., photos, chat records).
Interaction Information: We collect details about your connections and interactions with friends, followers, other users, and communities, including how you engage with them through our products.
User Choices: We record the settings you select (including privacy settings) and whether you have enabled notifications.

Please exercise caution when posting user-generated content. By participating as a user, you are making such data and content accessible to the public. You hereby grant others the right to view, collect, use, and disclose any information you voluntarily upload or submit. We have no control over how other users may utilize your contributions or who may access them.

We may use your data to generate and share aggregated insights that are anonymized, meaning they do not personally identify you. This type of aggregated data is not considered personal information.

Our application is not intended for, nor do we permit use by, individuals under the age of 18 or the applicable age of majority in their jurisdiction ("minors"). We do not knowingly collect personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, please contact us via email at support@grasfeel.com to request the deletion of such information.

How We Use Your Personal Data and the Purposes

Provision of Services: We utilize identifiers, app activity data, and (for registered users only) contact information, payment and commercial details, and user contributions to present our application and its content to you—including interactive features.
Customer Management: Identifiers, contact information, and payment/business details are used to manage your account, provide customer support, and notify you of updates to our application or details about products and services offered through it.
Content and Marketing Customization: We tailor content and advertisements to your interests based on your app usage and engagement with in-app products, services, and content.
Analytics: Using identifiers and app activity data, we track aggregate metrics such as total visitors, pages visited, and demographic trends.
Bluetooth Connection: When you use Bluetooth to connect to toys, we collect and use your precise location data, product information, device details, and other relevant data.
Game Rankings and User Display: Your gameplay data—including participation records, avatar, nickname, and scores—is used to populate leaderboards visible to other users.
Points and Coins Service: Collected personal information is used to provide and optimize the points and coins service on the Grasfeel platform.
AI Function Optimization: We may use de-identified or anonymized data to improve and maintain our artificial intelligence (AI) functionalities.
Functionality and Security: We may use any collected information to verify payment details, detect and address actual or suspected fraud, illegal activities, or intellectual property infringement, and identify and resolve technical issues.
Compliance: We may use any collected data to fulfill legal obligations and enforce our terms and conditions.
Communication: With your consent, we may use your personal information to communicate with you via email, phone, or mail.

Contact information and personally identifiable information submitted by users will be used for any additional purposes specified at the time of submission (e.g., contests) or for other purposes if you provide separate consent outside of this privacy policy.

The Legal Basis for Our Use of Your Personal Data

We process personal data based on the following lawful grounds, as defined under applicable data protection regulations:

Contractual Necessity: Processing is required to fulfill obligations under our Terms of Service and any supplementary agreements with you.
Legal Obligations: Processing is necessary to comply with statutory requirements, such as identity verification procedures mandated by anti-money laundering laws, tax regulations, and other legal directives applicable to the relevant jurisdiction.
Legitimate Interests: Processing is conducted for purposes including, but not limited to:
- Optimizing services through aggregated analytics (with personal identifiers excluded).
- Conducting targeted marketing activities, with due consideration for the rights of data subjects.
- Implementing operational security measures to prevent fraudulent acts.
Consent: Processing takes place in specific scenarios where we have obtained your explicit prior authorization.

How We Share Your Personal Data

With the Public: When using our application and services, you may choose to voluntarily publish user-generated content, such as audio or video files, which will be accessible to the public.
Within Our Corporate Group: We may share any category of personal information with affiliates and affiliated entities within our corporate group, but only to the extent necessary to achieve the objectives outlined in the preceding sections.
With Service Providers: We share the necessary categories of collected personal data with approved service providers that perform specific functions on our behalf.
With Legal Successors: In the event of a merger, acquisition, sale, or transfer of some or all of our assets, we may disclose all categories of collected personal information to the buyer or other successor.
To Comply with Legal Obligations: We may share your information to meet legal obligations, including responding to court orders, laws, or legal processes.

Protection of Personal Data

We implement measures to safeguard your information against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. For instance, we adopt technical and administrative access controls to restrict employee access to non-public personal information. However, you should be aware that no data storage system or transmission over the Internet or any public network can be guaranteed to be entirely secure.

We retain your personal data only for as long as necessary to fulfill the purposes for which it was initially collected—this may include meeting reporting, accounting, or legal obligations—or for the duration your account remains active.

Your Rights Concerning Your Personal Data

You hold various rights regarding the personal information we collect, use, or disclose about you. These rights include the following:

Right to withdraw consent: You may inform us at any time that you no longer wish for us to process or use your personal data.
Right to correct data: You have the right to notify us at any time to correct inaccurate personal data.
Right to deletion (right to be forgotten): You may request the deletion or destruction of your personal data at any time.
Right to object: You may restrict our use of your personal data when such use is solely to further our legitimate interests or the public interest.
Right to restrict processing: In certain circumstances, you have the right to limit our processing of your personal data.
Right of access: You have the right to access your personal data stored and processed by us.
Right to data portability: You may obtain a copy of your personal data stored and processed by us, or instruct us to transfer this data to another data controller.

To exercise any of these rights, you may email us at support@grasfeel.com to exercise these rights, subject to applicable legal limitations and requirements.

Transfers of Your Personal Data to Foreign Countries

By using the application, you consent to the transfer of any personal information we collect from you to other countries where we, our service providers, affiliates, and other corporate group entities are located, to the extent permitted by applicable law.

When we transfer personal data to countries outside the European Economic Area ("EEA") or other regions with strict data protection regulations, we ensure such transfers comply with relevant legal requirements.

Third-Party Websites

If you click on a link to a website operated by a third party, you will be directed to platforms not under our control. This Privacy Policy does not govern the privacy practices of these third-party websites—we strongly advise you to review their privacy policies carefully. We assume no responsibility for the actions of these third parties.

California Rights and Choices

Under the California Consumer Privacy Act (CCPA), you are granted the following rights concerning your personal data:

Right to Know / Access: The right to request information about the categories of personal information we collect.
Right to Delete: The right to request the deletion of personal information we collected from you.
Right to Correct: The right to request correction of inaccurate personal information we maintain about you.
Right to Opt Out of Sale / Share: To the extent we "sell" or "share" your personal information as defined under California privacy laws, you have the right to opt out of such sales or sharing.
Right to Limit Use and Disclosure of Sensitive Personal Information: California residents may request limits on our use or sharing of sensitive personal information under the CCPA.

To exercise the above rights, please email us at support@grasfeel.com with the subject line "CCPA Request."

Notice to Nevada Residents/Your Nevada Privacy Rights

We do not provide personal information of Nevada residents to third parties for the purpose of selling or licensing such information to others in exchange for payment.

Modifications to Our Privacy Policy

We reserve the right to revise or update this Privacy Policy from time to time. Any changes to the Privacy Policy will be marked with a "last modified date." Where required by law, we may seek to notify you of material revisions. We encourage you to regularly review the most current version of this Privacy Policy, which will be posted here, to stay informed of any updates.