Privacy Policy

§A.1 Definitions

Personal Data means any information relating to an identified or identifiable natural person. Examples: name, email, IP address, device identifier, advertising identifier (IDFA or GAID).

Processing means any operation performed on Personal Data — collection, storage, use, disclosure, deletion.

Controller means the entity that determines the purposes and means of Processing. For this policy, the Controller is JOICE.AI CO., LIMITED.

Processor means an entity that processes Personal Data on behalf of the Controller — for example, an analytics vendor.

User means any natural person who visits joicettech.com or installs a JOICE.AI mobile application.

Device Identifier means a value used to identify a device — for example, an IDFA (iOS) or GAID (Android), an Android ID, an iOS Identifier for Vendors (IDFV), or a hardware fingerprint.

Ad Identifier means a Device Identifier specifically used for advertising purposes, subject to platform-level controls (e.g., iOS App Tracking Transparency, Android Advertising ID).

SDK means a software development kit integrated into our mobile applications for a specific purpose — analytics, advertising, crash reporting, and so on.

Service means joicettech.com and all JOICE.AI mobile applications collectively.

App means each individual JOICE.AI mobile application published on Google Play or the Apple App Store.

§A.2 Who we are (controller)

Legal name: JOICE.AI CO., LIMITED

Registered office: Rm 701(108B) 7/F NEW MANDARIN PLZ TWR B, 14 SCIENCE MUSEUM RD, Tsim Sha Tsui East, Hong Kong

Website: https://joicettech.com

General support: support@joicettech.com

Key accounts: shaoyixin@joicettech.com

Privacy / DPO contact: dpo@joicettech.com (operational alias routing to support@joicettech.com)

EU representative: To be appointed and listed here before any EU-targeted app release — placeholder slot reserved per Article 27 GDPR.

UK representative: To be appointed and listed here before any UK-targeted app release — placeholder slot reserved per Article 27 UK GDPR.

If you are in the EU/UK and we have not yet listed a local representative, please contact dpo@joicettech.com and we will respond directly from our Hong Kong office or appoint a representative without undue delay.

§A.3 Scope of this policy

This policy applies to:

• The website — joicettech.com, including all subpages (the homepage, business services, corporate culture, company news, contact, this privacy policy, and the terms of service).
• The mobile applications — every App published by JOICE.AI CO., LIMITED on Google Play and the Apple App Store.

This policy does not cover third-party sites we link to. Each linked site has its own privacy policy; please read them.

This policy does not cover the Apple App Store or Google Play Store themselves. Their privacy practices are described in their respective privacy policies (Apple, Google).

§A.4 Personal data we collect

We do not knowingly collect sensitive categories of personal data — racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a person, health data, or data concerning a person's sex life or sexual orientation. If you choose to share such data with us (for example, in a support email), we delete it on receipt.

§A.5 How we use personal data

1. Provide and maintain the Service. Account creation, authentication, syncing, in-app purchases, crash diagnostics.
2. Respond to inquiries sent via the contact form, email, or in-app support.
3. Process in-app purchases and refunds via Apple App Store and Google Play. Billing is handled by the App Store Provider; we receive receipt validation tokens only.
4. Show advertising through the ad SDKs described in §A.6, in the ad formats described in §A.7.
5. Detect fraud, abuse, and security incidents. Including anomalous sign-in patterns, scraping attempts, and unauthorized access.
6. Comply with legal obligations. Tax, accounting, sanctions screening, law-enforcement requests, regulator correspondence.
7. Improve the Service via aggregated, de-identified analytics.
8. Send product updates — only where you have opted in. Every marketing email includes a one-click unsubscribe link.

§A.6 Third-party SDKs and ad platforms

JOICE.AI apps integrate the following third-party SDKs. For each: what it does · data collected · lawful basis · how to opt out · vendor privacy link.

1. Google AdMob

What it does: Ad mediation and waterfall serving of banner, interstitial, rewarded video, and splash ads. Collects: device identifiers (IDFA/GAID), IP, OS version, locale, coarse location (if granted), performance metrics. Lawful basis: consent where required (EU/UK/CA), legitimate interest elsewhere. Opt-out: in-app Settings → Privacy → toggle "Personalized ads"; OS-level "Limit Ad Tracking" (iOS) / "Opt out of Ads Personalization" (Android). Vendor privacy: policies.google.com/privacy.

2. Google Ad Manager (GAM)

What it does: Programmatic ad serving. Collects: device identifiers, IP, OS, locale, coarse location. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: as for AdMob. Vendor privacy: policies.google.com/privacy.

3. Meta Audience Network

What it does: Social-network-based ad serving. Collects: device identifiers, IP, OS, locale, advertising interactions. Lawful basis: consent. Opt-out: in-app toggle; OS-level; Meta's audience-based advertising opt-out. Vendor privacy: facebook.com/policy.php.

4. Unity Ads

What it does: In-app video ad serving. Collects: device identifiers, IP, OS, performance metrics. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: unity.com/legal/privacy-policy.

5. AppLovin

What it does: In-app ads and MAX mediation. Collects: device identifiers, IP, OS, locale. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level; applovin.com/optout. Vendor privacy: applovin.com/privacy.

6. ironSource (Unity LevelPlay)

What it does: Mediation. Collects: device identifiers, IP, OS, advertising interactions. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: is.com/privacy-policy.

7. Pangle (ByteDance / TikTok)

What it does: In-app video ads. Collects: device identifiers, IP, OS, locale, advertising interactions. Lawful basis: consent. Opt-out: in-app toggle; OS-level; pangleglobal.com/privacy. Vendor privacy: same link.

8. Vungle

What it does: Video ad serving. Collects: device identifiers, IP, OS, advertising interactions. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: vungle.com/privacy.

9. Chartboost

What it does: In-app ad serving. Collects: device identifiers, IP, OS. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: chartboost.com/legal/privacy-policy.

10. InMobi

What it does: Programmatic ad serving. Collects: device identifiers, IP, OS, locale, coarse location. Lawful basis: consent. Opt-out: in-app toggle; OS-level; inmobi.com/optout. Vendor privacy: inmobi.com/privacy.

11. Tapjoy

What it does: Offerwall and rewarded ads. Collects: device identifiers, IP, OS, advertising interactions. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: tapjoy.com/legal/privacy-policy.

12. Mintegral

What it does: Programmatic and video ads. Collects: device identifiers, IP, OS, locale. Lawful basis: consent. Opt-out: in-app toggle; OS-level; mintegral.com/en/privacy. Vendor privacy: same link.

13. Digital Turbine

What it does: Mediation and on-device delivery. Collects: device identifiers, IP, OS, advertising interactions. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: digitalturbine.com/privacy-policy.

14. Liftoff

What it does: Programmatic ad serving. Collects: device identifiers, IP, OS. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: liftoff.io/privacy-policy.

15. Moloco

What it does: ML-driven ad monetization. Collects: device identifiers, IP, OS, advertising interactions. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: moloco.com/privacy-policy.

16. Yahoo Ads (Verizon Media)

What it does: Programmatic ad serving. Collects: device identifiers, IP, OS, locale. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level; Yahoo Ad Interest Manager. Vendor privacy: legal.yahoo.com/us/en/yahoo/privacy/index.html.

17. Smaato

What it does: Header bidding. Collects: device identifiers, IP, OS, advertising interactions. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: smaato.com/privacy.

18. Start.io (Startapp)

What it does: In-app ad serving. Collects: device identifiers, IP, OS. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: start.io/policy/privacy-policy.

19. Appodeal

What it does: Mediation. Collects: device identifiers, IP, OS, advertising interactions. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: appodeal.com/privacy-policy.

20. BidMachine

What it does: Header bidding. Collects: device identifiers, IP, OS. Lawful basis: consent where required, legitimate interest elsewhere. Opt-out: in-app toggle; OS-level. Vendor privacy: bidmachine.io/privacy-policy.

§A.7 Ad formats — what we show and your choices

§A.8 Cookies and similar technologies on joicettech.com

We use a minimal set of cookies on joicettech.com. We do not run advertising cookies or third-party tracking pixels on this website.

What cookies are used

• Strictly necessary — a session cookie that remembers your acceptance of this policy. Expires when you close the browser.
• Preferences — a cookie that remembers your "reduce motion" preference if you toggled it. Expires after 30 days.
• Analytics — only after explicit consent. We use a privacy-respecting analytics provider that does not require cookies. We do not currently run third-party analytics on this site; this entry is reserved.
• Marketing — none. We do not run advertising or marketing cookies on this website.

Do Not Track / Global Privacy Control

We honor Do Not Track (DNT) and Global Privacy Control (GPC) where legally required. If your browser sends a GPC signal, we treat it as a valid opt-out of any "sale" or "sharing" of personal information as defined by CPRA.

How to clear cookies in major browsers

• Chrome: Settings → Privacy and security → Cookies and other site data → See all cookies and site data → Remove all.
• Safari: Preferences → Privacy → Manage Website Data → Remove All.
• Firefox: Preferences → Privacy & Security → Cookies and Site Data → Clear Data.
• Edge: Settings → Cookies and site permissions → Cookies and site data → See all cookies and site data → Remove all.

§A.9 Children's privacy

Our apps and the website are not directed to children under the age of 13, and we do not knowingly collect personal data from children under 13.

COPPA (United States)

We do not target children under 13. If we learn we have collected data from a child under 13 without verifiable parental consent, we delete it within a reasonable timeframe.

GDPR-K (European Union / United Kingdom)

For users under 16 (default; member-state law may lower to 13), we require parental consent. We make a reasonable effort to verify.

UK AADC (Age-Appropriate Design Code)

Where any feature is plausibly accessible to children, we apply high-privacy defaults: geolocation off by default, no profiling, no nudge techniques, no third-party tracking in child-directed contexts.

Brazil LGPD — children and adolescents

For users under 18, processing requires verifiable parental consent; we apply the highest protection standard available.

What happens if a child signs up

The account is suspended, associated data is purged from production systems within 30 days, backups within 90 days, and we notify the parent or guardian if we can contact them. Contact: dpo@joicettech.com.

§A.10 International data transfers

Data may be transferred from the EEA / UK to the United States, Singapore, Hong Kong, and other jurisdictions where our vendors operate. The mechanisms we rely on:

• EU → UK: EU adequacy decision for the UK (in force from 28 June 2021, subject to periodic review).
• EU / UK → United States: Standard Contractual Clauses (EU 2021/914) and the UK International Data Transfer Addendum. Where a vendor is certified under the EU–US Data Privacy Framework, we rely on that certification. We conduct transfer impact assessments for each vendor.
• EU / UK → Hong Kong / Singapore: Standard Contractual Clauses plus supplementary technical measures.
• PIPL (China): Because the controller is Hong Kong-based, PIPL applies where processing concerns mainland China natural persons. We apply PIPL cross-border transfer mechanisms (security assessment / SCC / certification) where required.
• Singapore PDPA: Cross-border transfer notification. We notify the PDPC where required.
• Brazil LGPD: International transfer on a lawful basis (standard contract clauses or cooperation agreement with a Brazilian authority).

List of countries where major vendors process data is published in our vendor list, available on request to dpo@joicettech.com.

§A.11 Data retention

We retain Personal Data only as long as necessary for the purposes for which it was collected, plus the periods below. After the retention period ends, data is deleted from production systems and backups.

• Account data: Account life + 30 days, then deleted from production. Backups: 90 days.
• Contact-form data: 24 months from last interaction.
• Device & usage: 13 months from collection.
• Advertising identifiers: Per vendor, maximum 13 months.
• Purchase / IAP receipts: 7 years (tax and accounting obligations).
• Support correspondence: 24 months after ticket closure.
• Cookies: Per §A.8 (session to 30 days).

Where we are legally required to retain data for longer (for example, tax records), the data is isolated from marketing and analytics systems and only accessed to comply with the legal obligation.

§A.12 Security

We apply industry-standard security controls to Personal Data:

• TLS in transit. All web and API endpoints enforce HTTPS.
• Encryption at rest where commercially reasonable, including full-disk encryption on production databases and encrypted backups.
• Access controls. Least-privilege role-based access to production systems. Production access requires hardware-backed multi-factor authentication.
• Audit logging. Production access is logged and reviewed.
• Vendor due diligence. Every vendor that processes Personal Data on our behalf is bound by a Data Processing Agreement and answers a security questionnaire before onboarding.
• Incident response. In the event of a Personal Data breach affecting your rights, we notify the relevant supervisory authority within 72 hours (GDPR Art. 33) and notify affected users where required by applicable law.

No security measure is perfect. We do not guarantee absolute security. If you discover a vulnerability, please email dpo@joicettech.com with the subject "Security disclosure".

§A.13 Your rights — by region

EU / UK (GDPR / UK GDPR)

You have the right to: access your personal data, rectify inaccurate data, erase your data (right to be forgotten), restrict processing, portability (machine-readable export), object to processing based on legitimate interest, opt out of automated decision-making, withdraw consent at any time, and lodge a complaint with a supervisory authority.

To exercise any of these rights, email dpo@joicettech.com. We acknowledge within 7 days and respond substantively within 30 days.

California (CCPA / CPRA)

You have the right to: know what personal information we collect and how it is used, delete your personal information, correct inaccurate personal information, opt out of sale or sharing (we do not sell; we share for advertising — see §A.6), limit use of sensitive personal information (we do not collect), and non-discrimination for exercising your rights.

We honor Global Privacy Control (GPC) as a valid opt-out signal.

Brazil (LGPD)

You have the right to: confirmation of the existence of processing, access to your data, correction of incomplete or inaccurate data, anonymization, blocking, or elimination of unnecessary or excessive data, portability of your data, deletion of data processed with consent, and information about sharing with third parties.

Canada (PIPEDA + Quebec Law 25)

You have the right to: access your personal information held by us, correction of inaccurate information, withdraw consent at any time (subject to legal or contractual restrictions), and lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC).

Australia (Privacy Act 1988 + AU Children's Online Privacy)

You have the right to: access your personal information, correction of inaccurate information, and lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

Singapore (PDPA)

You have the right to: access your personal data, correction of your personal data, withdraw consent, opt out of marketing communications, and lodge a complaint with the Personal Data Protection Commission (PDPC).

China (PIPL, where applicable to mainland users)

You have the right to: 知情权 (right to be informed), 决定权 (right to decide), 查询权 (right to query), 复制权 (right to copy), 更正权 (right to correct), 删除权 (right to delete), and 解释权 (right to an explanation of processing rules).

To exercise any of these rights across any region, email dpo@joicettech.com. We acknowledge within 7 days and respond substantively within 30 days. We will not charge you for exercising your rights unless the request is manifestly unfounded or excessive.

§A.15 Account deletion

In line with Apple App Store Review Guideline 5.1.1(v), JOICE.AI apps provide account deletion inside the app.

How to delete your account

• In-app: Settings → Privacy → Delete Account (path may vary slightly per app).
• By email: Email dpo@joicettech.com with the subject "Delete my account".

What is deleted

Account and associated personal data are deleted from production within 30 days; backups within 90 days. Where we are legally required to retain specific data (for example, purchase receipts for tax), the retained data is isolated from marketing and analytics systems and used only to comply with the legal obligation.

Confirmation

A confirmation email is sent when deletion from production completes.

§A.16 Apple App Store disclosures

Our apps comply with the following Apple App Store Review Guidelines:

• Guideline 1.4.3 / 5.1.4 — Kids Category. JOICE.AI apps are not currently in the Designed for Families (Kids) category. If we later add a Kids-category app, we will use only neutral age gates and only approved SDKs.
• Guideline 5.1 — Privacy. We collect only data necessary for the functionality of the app and disclose it accurately on the product page.
• Guideline 5.1.1(v) — Account deletion. We provide account deletion inside the app. See §A.15.
• Guideline 5.1.2 — Data used to track you (ATT). We request user permission via Apple's App Tracking Transparency prompt before accessing IDFA for tracking purposes. If the user declines, we serve contextual ads only.

Privacy nutrition labels

For each app, we accurately declare the data types collected (contact, identifiers, usage data, diagnostics, purchases), the purposes (analytics, advertising, product personalization), and whether the data is linked to the user or not. We update the nutrition labels whenever our data practices change.

§A.17 Google Play disclosures

Our apps comply with the following Google Play policies:

• Developer Program Policy — Data Safety form. Every data type declared, every purpose declared, sharing vs. collection declared, security practices declared. We update the Data Safety form whenever our data practices change.
• Families Policy. JOICE.AI apps are not currently in the Designed for Families program. If we later add a Designed for Families app, we will use only neutral age gates and only approved SDKs.
• Ads policy. Ads are not deceptive, are appropriate to the audience, allow opt-out, and clearly disclose when an ad is being shown.
• User Data policy. We access, collect, use, and share personal and sensitive information only as necessary for the functionality of our apps and the purposes disclosed in our Privacy Policy.

§A.18 "Do Not Sell or Share My Personal Information"

JOICE.AI does not sell personal information as that term is defined by the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). We may share limited information with the ad vendors listed in §A.6 for the purpose of serving advertising. You can opt out of such sharing at any time:

• In-app: Settings → Privacy → toggle "Personalized ads" off.
• OS-level: iOS Settings → Privacy → Tracking → toggle off; Android Settings → Google → Ads → Opt out of Ads Personalization.
• Global Privacy Control: We honor GPC as a valid opt-out signal where your browser or extension sends it.
• By email: dpo@joicettech.com with the subject "Do Not Sell or Share".

§A.19 Third-party links

This website and our apps contain links to third-party sites (for example, links to vendor privacy pages in §A.6, links to the Apple App Store or Google Play Store, links to social profiles). We do not control those sites. Their privacy policies apply, not ours. We encourage you to read the privacy policies of every site you visit.

§A.20 Changes to this policy

We post updates with a new "Last updated" date at the top of this page. For material changes, we will show an in-app notice and email you at the address on file (if any). An archive of prior versions is available on request to dpo@joicettech.com.

§A.21 Contact & DPO

Privacy / DPO: dpo@joicettech.com (operational alias routing to support@joicettech.com)

General support: support@joicettech.com

Key accounts: shaoyixin@joicettech.com

Postal: JOICE.AI CO., LIMITED, Rm 701(108B) 7/F NEW MANDARIN PLZ TWR B, 14 SCIENCE MUSEUM RD, Tsim Sha Tsui East, HK

Response target: We acknowledge within 7 days and respond substantively within 30 days.

This Privacy Policy is governed by the laws of Hong Kong SAR, without prejudice to mandatory consumer protection laws of your country of residence.