Privacy Policy

Preamble

I. Definition & Scope of Personal Information

The term "personal information" as used in this Policy refers to information — recorded in electronic or other form — that, alone or in combination with other information, can identify a specific natural person or reflect the activities of a specific natural person.

When you use the Application, information we may collect includes without limitation: device model, operating system version, device identifier, screen resolution, device settings, network connection type, IP address, and application usage data.

II. How We Collect Your Information

(i) Information you voluntarily provide

• Baby information. You may enter your baby's nickname, estimated due date, and similar information within the Application. This information is stored only in your device's local storage and is not uploaded to our servers.
• Feedback and problem reports. When you submit questions, suggestions, or complaints through the in-app feedback channel, our official email, or other designated methods, we collect the information you provide, including problem descriptions, screenshots, and any contact information (such as an email address) you voluntarily provide, solely to process your feedback.

(ii) Information collected automatically

• Device information. Device model, operating system version, device identifier, screen resolution, device settings, network connection type, IP address, and similar data. This information helps us ensure compatibility, optimize the user experience, and conduct analytics.
• Usage data. Application crash data, user interaction events (such as taps and swipes), and application usage paths. This information is collected through third-party analytics services (such as Google Firebase) to monitor stability, analyze usage, and improve features and user experience.

(iii) Information collected for specific features

• Microphone audio. To enable heartbeat listening and recording, the Application requires access to your device's microphone. Audio captured by the microphone is processed in real time on your device. Recordings you save are stored on your device's local storage. With your agreement to our terms, anonymized recordings may be uploaded to our servers to improve heartbeat detection — see below for details. You may revoke microphone permission at any time in your device's system settings, but core features of the Application may no longer function.
• Heartbeat audio recordings (for product improvement). Upon your agreement to our terms, the Application may upload anonymized audio recordings captured during heartbeat listening sessions to our servers. This data is used solely to improve the accuracy of fetal heartbeat detection and the overall listening experience. Recordings are anonymized before upload — no personal information, device identifiers, or location data are attached. Audio data is stored on our own servers and is never shared with any third party. Recordings are retained for up to 12 months, after which they are permanently deleted.
• Images uploaded for AI baby-face generation. When you use the AI baby-face feature, you may choose to upload parent photos or ultrasound images. For details on how such images are handled, please refer to Section V ("Sharing, Transfer & Disclosure") of this Policy.
• Subscription information. When you subscribe to premium features through Apple In-App Purchase, subscription status is provided through Apple's StoreKit service and used to determine your current entitlements. Actual payment information (such as credit card details and Apple ID credentials) is handled by Apple Inc. We do not collect or store this information.

(iv) Circumstances in which consent is not required

Under applicable laws and regulations, the collection of information in the following circumstances does not require your authorized consent:

• Related to national security or national defense;
• Related to public safety, public health, or significant public interests;
• Related to criminal investigation, prosecution, trial, or the enforcement of judgments;
• For the purpose of safeguarding significant lawful rights and interests — such as the life or property — of you or other individuals, where it is difficult to obtain your consent;
• Information you have disclosed to the public on your own;
• Information collected from lawfully publicly disclosed sources, such as legitimate news reports or government disclosures;
• Necessary for entering into or performing a contract at your request;
• Necessary for maintaining the safe and stable operation of the Application, such as detecting and handling product or service malfunctions;
• Necessary for legitimate news reporting;
• Necessary for academic research institutions conducting statistical or academic research in the public interest, provided that any personally identifying information is de-identified when results are published;
• Other circumstances stipulated by laws and regulations.

III. How We Use Your Information

• To provide and maintain the features and services of the Application, ensure compatibility with your device, and optimize the user experience;
• To conduct analytics and statistical analysis, identify performance bottlenecks, optimize feature logic, and develop new features in order to improve stability, compatibility, and overall experience;
• To send you notifications directly related to the Application, based on your usage context and preferences, including version updates, feature guidance, and service status notices;
• To process questions, suggestions, and complaints you submit through feedback channels;
• To enhance security during your use of the Application and protect you, other users, and the public from harm by preventing fraud, network vulnerabilities, viruses, attacks, and intrusions;
• We may use information collected through one of our services in another of our services — for example, information collected in one service may be used to provide specific content or surface relevant information in another;
• You acknowledge and agree that after collecting your information we may de-identify it through technical means. De-identified information cannot be used to identify you, and we may use such information for user profiling analysis and commercial purposes;
• If we use your information for any purpose not set out in this Policy, we will obtain your prior consent;
• To comply with applicable laws, regulations, and the requirements of application distribution platforms.

IV. Cookie-Like Technologies

The Application is a native iOS application and does not use browser cookies. However, the following similar technologies may be used:

• Device identifiers. To provide services, we may use device-generated identifiers (such as iOS IDFV). Such identifiers are reset when you uninstall the Application.
• Local storage. The Application uses on-device storage to save your baby information, recordings, preferences, and other data.
• Third-party analytics SDKs. Services such as Google Firebase may use similar technologies within the Application to collect usage data. For details on their practices, see Section IX ("Third-Party Services").

V. Sharing, Transfer & Disclosure

(i) Sharing

Except in the circumstances below, we will not share your information with any third party outside of us without your consent:

1. With your express consent or where you actively choose to share.
2. As required by law. We may share information as required by laws or regulations, for dispute resolution, or at the request of administrative or judicial authorities.
3. With affiliates. In such cases, we will share only the information necessary and subject to the commitments in this Policy. If an affiliate wishes to change the purpose of processing, they will seek your authorization again.
4. With authorized partners:
   • Third-party AI service providers (for AI baby-face generation). When you use the AI baby-face feature, any parent photo or ultrasound image you upload will be transmitted to a third-party AI service provider for processing in order to generate the imaginative baby portrait. We do not retain the original images you upload. The third-party AI provider may process the images according to its own data-handling rules during its provision of services; please refer to the relevant provider's privacy policy for details. Generated results are saved to your device's local storage only when you choose to "save to timeline." We recommend that you carefully consider what you upload and avoid uploading any image you do not wish to be processed by a third party.
   • Google Firebase (application analytics). For performance monitoring and usage analysis, we share device information and application usage data (excluding directly identifying sensitive information) with Google Firebase. Google Firebase will process this information in accordance with its own privacy policy.
   • Apple Inc. (subscription and payment). Subscription purchases and renewals are handled by Apple Inc. Related payment information and subscription status are managed by Apple Inc. under its own privacy policy.
   We will enter into strict data-protection agreements with those with whom we share information, requiring them to process personal information strictly in accordance with our instructions, this Policy, and other relevant confidentiality and security measures.

(ii) Transfer

1. As our business continues to evolve, we may undergo mergers, acquisitions, asset transfers, or similar transactions, and your information may be transferred as part of such transactions. We will require the new holder of your information to continue to be bound by this Policy; otherwise, we will require that entity to seek your authorization again.
2. After obtaining your express consent, we may transfer your information to other parties.

(iii) Disclosure

We will disclose your information only in the following circumstances and only after adopting industry-standard security measures:

1. To disclose information you specify, in the manner of disclosure to which you have expressly consented;
2. When required to provide your information by laws, regulations, or by administrative or judicial authorities, we may disclose it in accordance with the type of information and manner of disclosure required. Where permitted by law, upon receiving such a request we will require the requesting party to produce appropriate legal documents.

(iv) Exceptions to prior consent

In the following cases, prior consent is not required for sharing, transfer, or disclosure:

• Related to national security or national defense;
• Related to public safety, public health, or significant public interests;
• Related to judicial or administrative law enforcement, such as criminal investigation, prosecution, trial, or enforcement of judgments;
• For the purpose of safeguarding significant lawful rights and interests — such as the life or property — of you or other individuals, where it is difficult to obtain your consent;
• Information you have disclosed to the public on your own;
• Information collected from lawfully publicly disclosed sources, such as legitimate news reports or government disclosures.

Under applicable laws, the sharing or transfer of information that has been de-identified such that the recipient cannot re-identify the data subject is not considered external sharing, transfer, or disclosure of information, and does not require separate notification to or consent from you for storage and processing.

VI. How We Store and Protect Information

(i) Storage location

Our service infrastructure is hosted by cloud service providers and may be located in multiple countries or regions. Where you use the Application in a particular region, processing and temporary storage of related data may involve servers in that region.

We reiterate:

• Your heartbeat recordings are stored only on your device and are not uploaded to our servers;
• Your baby information, saved AI images, and timeline content are stored only on your device;
• Original photos uploaded for AI generation are accessed by third-party AI service providers during processing; we do not retain them ourselves.

(ii) Retention period

We store your information only for as long as necessary to provide the Services. When you uninstall the Application, information stored on your device is deleted; you may also actively delete your local content within the Application at any time. De-identified usage data received from Google Firebase and similar analytics services may be retained according to the retention rules of those services.

(iii) Protection of information

1. We adopt security measures in line with industry standards, including reasonable institutional norms and security technologies, to prevent unauthorized access, use, or modification of your information and to avoid data corruption or loss.
2. We manage the storage and use of information through data classification and grading systems, data security management standards, and data security development standards.
3. We allow access to your information only by employees and partners who need to know it, and have established strict access controls and monitoring mechanisms. We require all persons with access to fulfill corresponding confidentiality obligations; failure to do so may result in legal liability or termination of the relationship.
4. The internet is not an absolutely secure environment. We recommend that you take necessary protective measures when using the Application — for example, avoid uploading images containing sensitive information (such as identification documents) through the AI baby-face feature.
5. In the unlikely event of an information security incident, we will inform you in accordance with applicable laws and regulations of: the basic nature and potential impact of the incident, the measures we have taken or will take, suggestions for reducing your own risk, and any remedial steps for you. We will notify you by email, letter, phone, or push notification; where individual notification is not feasible, we will make a public announcement in a reasonable and effective manner.
6. Please understand that, given technical and risk-prevention limitations, even with our best efforts we cannot always guarantee 100% security of information. Circumstances beyond our control may cause issues during your use of the Application.

VII. Your Rights

(i) Access, correction, and deletion

• You can directly view, modify, or delete baby information, heartbeat recordings, saved AI photos, timeline notes, and other local content within the Application.
• Uninstalling the Application will permanently delete all data stored on your device, and such data cannot be recovered. Please back up any content you wish to keep before uninstalling.

(ii) Sharing and disclosure

Certain features of the Application (such as weekly card sharing) allow you to share content to other platforms. Content shared through such channels may be further disseminated by the recipients or third parties and may remain publicly available for an extended period. Even after you delete shared content, it may be independently cached, copied, or stored by recipients or third parties not under our control. We are not liable for any disclosure of your information through such channels. We therefore remind you to carefully consider whether to share or publicly disclose information.

(iii) Permission management

• You may revoke the Application's access to microphone, photo library, and other permissions at any time in your device's system settings. Revoking permissions may affect some or all features of the Application.
• You have the right to withdraw your prior consent to our collection and use of information at any time, but doing so may affect your use of certain Services.
• If you believe our handling of information violates your lawful rights and interests, you have the right to file a complaint or report.

(iv) Subscription management

You can view, manage, or disable auto-renewal of your subscription at any time in your device's Apple ID account settings. Please refer to Apple's full Terms of Use for details.

VIII. Do-Not-Track Signals

The Application does not operate in a web-browser environment, and Do-Not-Track (DNT) signals are generally not applicable to it. We do not use cross-site tracking technology to deliver targeted advertising to you.

IX. Third-Party Services

(i) Google Firebase

The Application uses Google Firebase for application analytics. Google Firebase collects data related to the use of the Application. For specific rules on information collection and use, please refer to Google Firebase's privacy policy. We are not responsible for Google Firebase's information-processing practices.

(ii) Third-party AI service providers (image generation)

The Application uses image-generation capabilities provided by third-party AI service providers to power the AI baby-face feature. Images you upload when using this feature will be transmitted to the third-party AI service provider for processing. The third-party AI service provider processes such information in accordance with its own data-handling rules, and we are not responsible for its information-processing practices. If you have concerns about specific data-handling practices, please consider this carefully before using the feature.

(iii) Apple Inc.

Distribution of the Application, subscription payment, and related services are provided by Apple Inc. Apple Inc. handles the related information in accordance with its own privacy policy.

X. Protection of Minors

1. The Application is designed for adult expectant parents and does not target users under the age of 18. We do not actively provide the Application's services to minors.
2. If you are a minor under the age of 18 (a "Minor"), you should read and agree to this Policy under the supervision and guidance of a parent or other guardian and may use the Application only after obtaining their consent.
3. We protect the personal information of minors in accordance with applicable laws and regulations, and collect, use, store, share, transfer, or disclose the personal information of minors only where permitted by law, where a parent or guardian has given express consent, or where necessary to protect the minor's lawful rights and interests.
4. If we discover that we have collected a minor's personal information without verifiable parental consent, we will delete such information as soon as possible.
5. If you are the guardian of a minor and have questions about the personal information of the minor under your guardianship, please contact us through the details provided in this Policy.

XI. Payment Processing

Payments within the Application are completed through official channels provided by Apple Inc. You provide payment information directly to Apple, which operates secure servers to process payment details, encrypt your payment information, and authorize the transaction. The information you provide is not controlled by us and is subject to Apple's own privacy policy and terms and conditions.

XII. Notices & Revisions

1. We may revise this Policy from time to time in response to updates in laws, regulations, or business developments. The revised Privacy Policy will be published within the Application or on the Company's official website. If you continue to use the Application, you are deemed to agree to the revised Policy.
2. We may issue service-related announcements when necessary (for example, when services are suspended for system maintenance). You may not be able to opt out of such non-promotional service-related announcements.

XIII. Governing Law & Dispute Resolution

1. This Policy shall be interpreted and applied in accordance with the laws of the Hong Kong Special Administrative Region of the People's Republic of China.
2. Any dispute arising from this Policy shall first be resolved through friendly consultation between the parties. If consultation fails, the parties agree to submit the dispute to the Hong Kong International Arbitration Centre (HKIAC) for arbitration in Hong Kong in accordance with the arbitration rules in force at the time. The arbitral award shall be final and binding on both parties.

XIV. Contact Us

If you have any questions or suggestions regarding this Policy, please contact us at:

Email: support@picksai.vip