Privacy Policy

ASI X Inc. and its affiliates (“Fellou,” “we,” “us,” “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how your personal data is collected and processed by us. This Privacy Policy applies to our website (fellou.ai; fellou.online), and its associated subdomains alongside our application, Fellou and Eko (collectively, our “Services”).

If you are under the age of 18 or do not meet the age requirements for using or accessing the Services in your country, or if your use of the Services does not comply with local laws, you must either (A) refrain from using the Services or (B) review this Privacy Policy with your legal guardian and only use the Services after they have agreed to its terms, as required by law. If you are a parent or guardian and believe your child has shared personal information with us, please get in touch. If we learn that we have collected personal data from a child under 18 (or the applicable age limit in your region) without proper parental consent, we will take steps to delete that information from our systems.

Please read carefully and fully this Privacy Policy before using or continuing to use our Services and, if necessary, make appropriate choices in accordance with the guidelines in this Privacy Policy. If you do not provide certain personal data to us, we may not be able to provide the Services to you, or the use of the Services may be restricted, or the Services may not function to achieve the results we intend to provide.

1 How We Collect and Use Your Personal Data

We will collect data you actively provide when using the service, as well as data generated during your use or receipt of the Services through automated means in the following ways:

1.1 Account Registration

When you create an account with us, we will collect data associated with your account, such as your username, email address, phone number, and account credentials. We may also collect a verification code to verify your user identity. We may further collect your real name, date of birth and government ID number to verify your age and your identity as required by applicable laws.

1.2 Fellou Services

You can provide input to our Services (“Content”), including prompts and other content you upload, such as files, images⁠ and audio, or directly send operation instructions by your interaction with the Services. We will also collect user actions and environment status to facilitate your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take.

1.2.1 Service Permissions

When you use our Services, according to the functional needs, we will request you authorize the camera, photo album (storage), microphone, screenshot and screen record, accessibility, file management, command line or other operating system-related permissions based on the type of information you input. If you refuse to authorize, you will not be able to use certain functions such as taking photos or inputting image and voice information, but this will not affect your use of other functions of the Services.

1.2.2 Specialty Scenarios

When you use the Services in health, financial, legal or other specialty-related scenarios, we may collect your health-related information, financial information or other information you voluntarily input to our Services. Based on the content you input, we will generate responses, answers and consultation summaries or reports (which do not constitute medical, financial, legal or other professional advice) for your reference.

1.2.3 Location Information

When you issue a search request during a conversation with AI, we will automatically receive the information you actively input to provide you with real-time search results. For example, when you ask us about nearby locations, in order to answer your question, we may collect your precise geographical location. This geographical location may include precise location information obtained through GPS sensors, WLAN access points, Bluetooth, and base station sensors. We only collect your precise geographical location when you have a clear need to find nearby locations or provide other location based services. Precise geographical location information is sensitive personal data. If you refuse to provide it, we will not recommend the nearby location-related information or provide other location based services based on the geographical location obtained through GPS sensors, but this will not affect the normal use of other functions we provide. We will only display content or services that may be relevant to you based on the district-level geographical location obtained through network location information (such as base stations, IP addresses, and WLAN).

1.2.4 Third-Party Personal Data

If the prompt you input or the information you submit contains personal data of others, you must obtain the legal authorization of others before providing such information to avoid improper disclosure of others’ information.

1.2.5 Service Improvement

To provide you with continuous and high-quality services, we may use your Content collected from the Services and the corresponding output content for the improvement and optimization of the Services’ quality, under the premise that the information has been processed with secure encryption technology, strictly de-identified, and cannot be re-identified to a specific individual. If you refuse to allow us to process your personal data in the above-mentioned way, you can provide feedback to us through the methods described in section 5 of this Privacy Policy.

1.2.6 Sensitive Information Warning

We will not collect sensitive information such as identification documents and numbers, bank accounts, passwords, etc. However, due to technical limitations and the way you use our Services, we may unwittingly collect other personal data that you voluntarily input into the Services, which may include the said sensitive information. We will immediately delete or anonymize such information once noticed by us. For your security, please do not input sensitive information into our Services.

1.3 Feedback

When you want to provide feedback to us, we will collect your problem description information, supporting material attachments, mobile phone number, email address, and contact person’s name to understand the content and needs of your feedback. This kind of information is necessary for the feedback function service. To verify your identity, clarify your needs and the solutions for related issues, or help you solve other problems, we may use your mobile phone number or email address. To provide you with feedback services related to your usage information, we will query your usage information, including conversation records, like records, and problem feedback records. If you directly contact us through the methods described in section 5 of this Privacy Policy to provide feedback, make complaints, appeals, or inquiries, to ensure the security of your account and the system, you need to provide us with your account information so that we can verify your user identity. This kind of information is necessary for identity verification in user feedback. During the feedback, complaint, or consultation process, to help you solve problems or record the solutions and results of related issues, you may need to provide us with corresponding supporting material attachments, and the system may record communication between you and us, so as to better help you solve the problems you have consulted and improve service quality. If you do not provide the above-mentioned information, we may not be able to provide you with the results of your inquiries in a timely manner, but this will not affect your normal use of the Services.

1.4 Notification

You acknowledge and agree that for the contact information (such as phone number) you provide during the use of the product and/or service, we may send various types of notifications to one or more of them during our operations for purposes such as user message notification, identity verification, security verification, user experience research, and dispute resolution. In addition, we may also send you commercial information about services, features, or activities through SMS or emails to the phone number collected in the process. However, please rest assured that if you do not wish to receive such information, you can unsubscribe through the method provided, or you can directly contact us to unsubscribe.

1.5 Safeguarding

To safeguard your account security and provide you with better quality services, we will automatically collect the following information generated during your use of the Services:

1.5.1 Device and System Information

To ensure the secure operation of the software and services, as well as the quality and efficiency of operations, we will collect information about your hardware model, operating system version number, device identifiers (for Android, such as AndroidID, OAID; for iOS, such as IDFV; different identifiers may vary in terms of validity period, whether they can be reset by users, and the methods of obtaining them), IP address, software version number, network access method, type, status, network quality data, operations, usage, service logs, and device sensor data (such as accelerometer sensor, gyroscope sensor).

1.5.2 Security and Performance Monitoring

To prevent malicious programs and ensure the quality and efficiency of operations, we may collect information about running processes, overall operation and usage of pages, frequency of use, page crashes, overall usage, and performance data. To determine account and transaction security, conduct identity verification, identify illegal or non - compliant situations, detect and prevent security incidents, and take necessary recording, analysis, and disposition measures in accordance with the law, we may use your account information, device information, and service log information.

1.5.3 Usage Analytics

To analyze statistical indicators such as app acquisition, activation, retention, and performance, we collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.

1.5.4 Log Information

We may use the log information to help us analyze the usage of our Services, to troubleshoot problems, and to conduct operational analysis through data statistics to improve and optimize the product interaction experience. Log information includes your IP address, browser type and settings, the date and time of your request, and how you interact with our Services.

1.6 Information from Other Sources

We also collect information from other sources, like information from our business partners or information that is publicly available on the Internet.

1.7 Aggregation and De-identification

We may also aggregate or de-identify your personal data so that it no longer identifies you and use this information for the purposes described above, such as to analyze the way our Services are being used, to improve and add features to them, and to conduct research. We will maintain and use de-identified information in de-identified form and not attempt to reidentify the information, unless required by law.

2 How We Use Cookies and Other Similar Technologies

2.1 About Cookies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. This data typically includes a unique combination of letters and numbers to identify your device, though it may contain additional information as well. Some cookies are set by third parties who work on our behalf. We utilize cookies and related technologies to remember your preferences and settings, support sign-in functionality, deliver targeted advertising, help prevent fraudulent activity, evaluate the performance of our services, and achieve other lawful objectives outlined below. In a similar manner, our Services may also incorporate web beacons or other comparable tools, as further detailed in the sections that follow.

2.2 Our Use of Cookies and Similar Technologies

Our Services uses cookies and similar technologies for several purposes, depending on the context, function or service, including:

2.2.1 Remembering Your Preference

We may use cookies to store your preferences and settings on our Services and to improve your experiences. For example, depending on your settings, we may save your preferred language with cookies, preventing you from having to set your preferences repeatedly. If we obtain your consent to place cookies on your device, we will also store your choice in a cookie.

2.2.2 Sign-in

We may use cookies to help you stay signed in and authenticate your identity. When you sign in to our Services, we store relevant information such as a unique ID number and the time you signed in in an encrypted cookie. Such cookies save your sign-in information so that you do not have to sign in each time you use our Services.

2.2.3 Security

We may use cookies for security purposes to protect you against cybersecurity threats, such as helping ensure that only you can access your account, or preventing malicious sites from acting on behalf you without your knowledge.

2.2.4 Storing Information You Provided

We may use cookies to store information you voluntarily provided to our Services.

2.2.5 Analytics and Performance

We may use cookies for analytical purposes to understand how you interact with a particular service, including collecting data that allows us to measure audience engagement and site statistics. This helps us to understand how our Services are used, and to enhance their content, quality and features, while also allowing us to develop and improve new services.

2.2.6 Advertising

We may use cookies for advertising purposes, including to show personalized ads, serving and rendering ads, and personalizing ads. These cookies also are used for, limiting the number of times an ad is shown to a user, muting ads you have chosen to stop seeing, and delivering and measuring the effectiveness of ads.

2.2.7 Personalization

We may use cookies to help enhance your experience by providing personalized content and features. Personalized content and features include but not limited to things like more relevant results and recommendations, or ads that are tailored to your interests. Even if you reject cookies and similar technologies used for personalization, the non-personalized content and features you see may still be influenced by contextual factors, like your location, language, device type, or the content you’re currently viewing.

2.3 Your Consent

Where required, we obtain your consent prior to placing or using optional cookies that are not strictly necessary to provide the website or for the purpose of facilitating communication. Please see the sections below for more information.

2.4 Third-party Cookies

Other than cookies set by us, we may also use third-party cookies to enhance our Service. For example, companies we engage to provide service on our behalf, such as site analytics, may place cookies when you use our Services. These companies use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across websites, apps, or online services.

2.5 How to Manage Cookies

Our Services automatically accept cookies but provide controls that allow you to block or delete them. Where required, we obtain your consent before placing or using optional cookies that are not strictly necessary to provide the website or for the purpose of facilitating communication. We separate these optional cookies by purpose, such as for advertising and social media purposes. You may consent to certain categories of optional cookies and not others. You also may adjust your choices by clicking “Manage cookies” or other similar wordings in the footer of the website or through the settings made available on the Services. Certain features of our Services depend on cookies. If you choose to block cookies, you cannot sign in or use some of those features, and preferences that are dependent on cookies will be lost. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, are deleted and will need to be recreated.

3 How We Share, Transfer, or Disclose Your Personal Data

3.1 Business Partners

To assist us in meeting our business operation needs and performing certain services and functions, we may share personal data with business partners, including providers of hosting services, customer services, cloud services, content delivery services, support and security monitoring services, email communication software, web analytics services, payment and transaction processors, and other information technology services. These business partners will access, process, or store personal data only as necessary to perform their duties for us, as directed by us.

3.2 Advertising and Statistical Analysis Partners

In order to assist with advertising or decision advice, improve effective reaching of advertising and further understand user needs, we may share information with partners who entrust us with information promotion and advertising services or statistical analysis partners.

3.3 Business Transactions

If we engage in a strategic transaction, reorganization, bankruptcy, takeover, or transition of services to another provider (collectively referred to as a “Transaction”), your personal data may be disclosed during the due diligence process with the counterparty and other persons assisting in the Transaction and may be transferred to a successor or affiliate, together with other assets, as part of the Transaction.

3.4 Government Agencies or Other Third Parties

We may share your personal data with government agencies, industry peers, or other third parties, including data about your interactions with our services, (i) if required to do so to comply with a legal obligation, or if in good faith we believe that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine in our sole discretion that you have violated our terms, policies, or the law, (iv) to detect or prevent fraud or other illegal activities, (v) to protect the safety, security, and integrity of our products, employees, users, or the public, or (vi) to avoid legal liability.

3.5 Affiliates

We may disclose personal data to our affiliates. Our affiliates may use this personal data in a manner consistent with this Privacy Policy.

3.6 Other Users and Third Parties with Whom You Interact or Share Information

Certain features allow you to interact with other users or third parties or share information with them. For example, you can share output from the Services with other users via shared links. You can also send information to third-party applications, such as through Fellou’s custom actions, or to search the web to help answer questions that require more information. Information you share with third parties is subject to their own terms and privacy policies, and you should familiarize yourself with these terms and policies before sharing data with them.

4 How We Store and Protect Your Personal Data

4.1 Data Retention

We will retain your personal data for only as long as we need in order to provide our Services to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain personal data will depend on a number of factors, such as:

• Our purpose for processing the data (such as whether we need to retain the data to provide our Services);
• The amount, nature, and sensitivity of the information;
• The potential risk of harm from unauthorized use or disclosure; and
• Any legal requirements that we are subject to.

4.2 Data Security

We implement commercially reasonable technical, administrative, and organizational measures designed to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you provide to the Services. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.

5 How You Can Exercise Your Personal Data Rights

5.1 Statutory Rights

You have the following statutory rights in relation to your personal data:

• Access your personal data and information relating to how it is processed;
• Delete your personal data from our records;
• Rectify or update your personal data;
• Transfer your personal data to a third party (right to data portability);
• Restrict how we process your personal data;
• Withdraw your consent—where we rely on consent as the legal basis for processing at any time; and
• Lodge a complaint with your local data protection authority (see below).

5.2 Rights to Object

You have the following rights to object:

• Object to our processing of your personal data for direct marketing at any time;
• Object to how we process your personal data when our processing is based on legitimate interests; and
• Object to use your personal data to train our Services.

5.3 Exercise Your Rights

You can exercise these rights by submitting your request to privacy@fellou.ai.

5.4 Accuracy of Output

Services like Fellou generate responses by reading a user’s request and, in response, predicting the words most likely to appear next. In some cases, the words most likely to appear next may not be the most factually accurate. For this reason, you should not rely on the factual accuracy of output from our Services. If you notice that Fellou output contains factually inaccurate information about you and you would like to request a correction or removal of the information, you can submit these requests to privacy@fellou.ai, and we will consider your request based on applicable law and the technical capabilities of our Services.

6 How We Update the Privacy Policy

6.1 Policy Revisions

To provide you with better services, our Services will be updated and changed from time to time. We will revise this policy as appropriate, and these revisions form part of this policy.

6.2 Notification of Updates

After this policy is updated, we will post the updated version on our website and remind you to read the updated Privacy Policy again through the announcements of the new version, so that you can stay informed about the latest version of this policy in a timely manner. If you do not agree with this policy or have objections to the modifications or updates to this policy, you may choose to stop using this service or deactivate your account. However, please be aware that your actions and activities prior to account deactivation or cessation of use of this service are still subject to this policy.

6.3 Significant Changes

For significant changes that would substantially diminish your rights under this Privacy Policy, we will also provide more conspicuous notifications (we will notify you through various means, including but not limited to email or special prompts on browsing pages, specifying the specific parts of the policy that have been changed).

7 How to Contact Us

If you have any complaints, suggestions, or questions about personal data protection, or if you have any questions about this Privacy Policy, you can contact us in the following way. We will review the issues involved as soon as possible and respond within fifteen working days after verifying your user identity: privacy@fellou.ai.

8 EEA+ Addendum

If you are located in the European Economic Area (EEA), the United Kingdom or Switzerland (collectively, the “EEA+” areas), please see our EEA+ Addendum at this Section. We address this EEA+ Addendum to individuals located in the EEA+ only. This document supplements our Fellou Privacy Policy and describes how we process your personal data when you use or interact with our Services. If there are any inconsistencies between the Fellou Privacy Policy and this EEA+ Addendum, this Statement prevails.

A. Who is the data controller?

The data controller is ASI X Inc., registered address at 251 Little Falls Drive, Wilmington, New Castle, DE 19808 and its affiliates. To contact our EEA and UK GDPR representatives, please contact privacy@fellou.ai.

B. What types of personal data do we collect and how do we collect it?

Please see Section 1 above.

C. For what purposes do we process personal data?

Please see Section 1 above.

D. What lawful bases of processing and legitimate interests do we rely on?

If we have entered into a contract with you and the processing is necessary for us to perform our contract with you or take steps at your request prior to entering into the contract, the lawful basis is that it is necessary per Article 6(1)(b) GDPR.

If the processing is necessary for us to comply with an applicable legal obligation under EEA or UK laws, the lawful basis is that it is necessary per Article 6(1)(c) GDPR.

In some cases, the processing is necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests, including where we endeavour to provide you with a positive user experience, seek to comply with the laws or regulations outside of the EEA or UK, to maintain the security and integrity of our Services and related platforms and systems, operate and optimize our business, improve our Services, develop new services, manage our relationships with users, and administer communities of users. In these cases, the lawful basis is that it is necessary per Article 6(1)(f) GDPR. More information on our assessments of legitimate interests balanced against privacy and other fundamental interests is available on request.

In some cases, we rely on your consent to process your personal data, per Article 6(1)(a) GDPR, including when we use non-essential cookies or other technologies to process your data. In these cases, you can withdraw your consent at any time with future effect by using the consent settings on our Services or by emailing us at privacy@fellou.ai with a description of what data processing activities of ours you would like to withdraw your consent from.

E. What categories of recipients receive personal data from us?

Please see Section 3 above.

F. Where is your personal data processed and on what basis do we transfer personal data across borders?

We may disclose personal data to third parties in locations including the United States, Japan and Singapore. We take measures to ensure that our processors provide an adequate level of data protection by ensuring appropriate safeguards are in place and performing data transfer arrangements as appropriate. If you have any questions or would like more information, you can contact us at privacy@fellou.ai.

G. How long do we process personal data?

We retain your personal data only as necessary for the purposes for which the personal data is processed or for legal requirements. The length of time for which we retain personal data depends on the purposes for which we collect and use it and how long we need to retain it to comply with applicable laws (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements). If we retain the personal data solely to satisfy legal requirements, we will implement measures to prevent data processing. Once the personal data is no longer necessary for the purposes for which we collected it, we will delete it.

H. What data protection rights do you have?

In the EEA, Switzerland and the UK you have the following rights, subject to the conditions under the GDPR and/or local data protection law:

• To object, on grounds relating to your particular situation, to the processing of your personal data by us. This includes the right to object to our processing of your personal data for direct marketing (also known as mass marketing under Swiss law) and the right to object to our processing of our personal data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. If we process your personal data based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. Where we use your personal data for direct marketing for our own Services, you can always object and opt out of future marketing messages using the unsubscribe link in such communications or through other means.
• To obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to details about how we process your personal data and copies of the personal data.
• To obtain from us the rectification of inaccurate personal data concerning you.
• To ask us to erase your personal data to the extent it is not required for legally required purposes or necessary for security and integrity purposes.
• To request restriction of processing of your personal data, in which case, it would be marked and processed by us only for certain purposes.
• To receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit the personal data to another entity without hindrance from us.
• To withdraw your consent at any time. This will not affect the lawfulness of our use of your personal data before your withdrawal.
• To lodge a complaint with a supervisory authority.
• In some jurisdictions such as France and Portugal, you also have the right to provide us with guidelines as to the processing of your personal data after your death.

I. Are you required to provide us with your personal data?

You are not legally required to provide personal data to us but we cannot provide our Services without receiving some personal data from you.

9 US Addendum

If you reside in Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey or California, please refer to the US Addendum in this Section.

We address this US Addendum to U.S. residents only. This Addendum does not reflect our collection and process of U.S. residents’ personal information where an exception under U.S. privacy laws applies.

VIRGINIA, COLORADO, CONNECTICUT, UTAH, OREGON, TEXAS, MONTANA, DELAWARE, IOWA, NEBRASKA, NEW HAMPSHIRE AND NEW JERSEY

The following is only addressed to residents of Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire and New Jersey.

Subject to the conditions under applicable laws, you have rights to request that a controller of your personal data:

• Confirm whether or not it is processing your personal data and provide copies of such data;
• Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of processing of the consumer's personal data, except this right is unavailable in Iowa and Utah;
• Delete personal data provided by or obtained about you;
• Opt out of the processing of your personal data for the purposes of: (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

When you use our Services, we may collect, use and disclose your personal data for targeted advertising purposes as described above. Some of the laws that apply to our processing of personal data qualify our collection, use and disclosure of personal data for targeted advertising purposes as “selling” personal data. You may opt out of targeted advertising and such selling in our Services by contacting us at privacy@fellou.ai.

CALIFORNIA

The following is only addressed to residents of California.

Notice of Collection

Please see Section 1 above for information about the types of personal information we collect. The categories of personal information correspond with the following categories of personal information enumerated under the California Consumer Protection Act (CCPA) definition of “personal information” and their respective letter grouping:

• (A)—Identifiers including name, phone number, unique personal identifier, IP address, email address and account name.
• (B)—Information that identifies or is capable of being associated with you.
• (F)—Internet or other electronic network activity information.
• (G)—Geolocation data.
• (H)—Audio, electronic, visual or similar information.
• (K)—Inferences drawn from any of the information identified above reflecting your preferences and characteristics.
• (L)(C)—Precise geolocation data.

If California residents upload videos to our Services, they may also disclose any type of personal information to us and others in the videos.

CCPA Privacy Policy

A. Right to Know About Personal Information Collected, Disclosed, or Sold

We describe here the personal information we collect, use, and disclose about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please email privacy@fellou.ai and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

B. Our Personal Information Handling Practices over the Preceding 12 Months

We have set out below the categories of personal information we have collected about California residents in the preceding 12 months, as enumerated in the CCPA’s definition of “personal information”.

• Identifiers including name, postal address, phone number, unique personal identifier, IP address, email address and Account name.
• Information that identifies or is capable of being associated with you.
• Internet or other electronic network activity information.
• Geolocation data.
• Audio, electronic, visual or similar information.
• Inferences drawn from any of the information identified above reflecting your preferences and characteristics.
• Precise geolocation data.

C. Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please contact us by mail or submit an email request to privacy@fellou.ai and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.

D. Notice of Right to Opt-Out of Selling/Sharing of Personal Information / Do Not Sell or Share My Personal Information

You have the right to opt-out of the sale or sharing of your personal information by a business. We disclose personal information to third-party advertising networks and advertising partners who may use such personal information for their own purposes, including to tailor their advertising to you. As such, we “sell” and “share” your personal information. You may submit an opt-out request by sending an e-mail to privacy@fellou.ai. Please note that we may need to verify your identity before acting on a request.

E. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You may not be discriminated against because you exercise any of your rights under the CCPA.

F. Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected, which will depend on your prior interactions with us and the sensitivity of the personal information being requested.

10 China Addendum

This China Addendum applies to you if you reside or are located in the People's Republic of China (“China”, which for the purposes of this China Addendum only shall exclude Hong Kong, Macau, and Taiwan) as required by the Personal Information Protection Law (“PIPL”) and other applicable laws and regulations in China. This China Addendum supplements the Fellou Privacy Policy. If any provision in this China Addendum is inconsistent with a provision in the Privacy Policy, this China Addendum shall prevail to the extent of the inconsistency regarding the processing of your Personal Information (as defined in this China Addendum). Unless otherwise specified, the definitions of the terms in this Addendum have the same meaning as in the Privacy Policy.

A. Types of Personal Information we collect and use

For more information on the categories of Personal Information we process, you may refer to section 1 of the Privacy Policy.

Under the PIPL, “Sensitive Personal Information” refers to Personal Information that, once leaked or illegally used, will easily lead to infringement of the human dignity or harm to the personal or property safety of a natural person, including ID card number, biometric recognition, religious belief, specific identity, medical and health, financial account, personal location tracking and whereabout of a natural person, as well as any Personal Information of children under the age of 14. In order to provide you with the appropriate service, we may need to collect information that is sensitive under the PIPL.

B. Purposes for which we use your Personal Information

For more information on the purposes for which we use you Personal Information, you may refer to section 1 of the Privacy Policy.

We may collect and use your Personal Information only if we have a legal basis for doing so. In many cases, the legal basis for processing your data is “necessary for the conclusion and performance of your contract”. If you have consented to the collection and use of your Personal Information (which consent you may withdraw at any time, see E. “How to exercise your rights” below), we will collect and use your data based on that consent.

C. Granting access to or sharing Personal Information with third parties

Fellou provides services all across the world. We will share your Personal Information with parties, in compliance with applicable laws and regulations in China, including obtaining your separate consent, if necessary. For more information on granting access to or sharing Personal Information with third parties, please refer to section 3 of the Privacy Policy.

D. Personal Information transferred outside China

For the purposes set out in section 1 of the Privacy Policy, your Personal Information will be stored outside China, including the United States and Singapore.

We will take all reasonable actions to ensure the compliance with applicable legal and regulatory requirements for cross-border transfer of your Personal Information, including to complete the Personal Information protection impact assessment, to pass the security assessment, and to sign standard contracts, if necessary. When the Personal Information cross-border transfer is based on your consent, we will also inform you of relevant information in accordance with the law and obtain your separate consent for processing.

E. How to exercise your rights

You may contact us to exercise any of the rights provided under the PIPL (including without limitation, the right to access and copy; the right of correction; the right of erasure; and the right to data portability) to the extent permitted by law, or if you have any question about this Chinese Addendum or how we use your Personal Information. For our contact information, you may contact us at privacy@fellou.ai.