Privacy Policy

Last Updated: February 01, 2026

1. OVERVIEW

Welcome to UniUme (the "App"), an AI-powered chat application developed by UNIUME PTE. LTD., a company incorporated and registered in Singapore with our principal place of business at 68 Circular Road, #02-01, Singapore, 049422. Our servers are located in the United States. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our App and related services (collectively, the "Services"). The Services allow users to create AI avatars (virtual chat entities customized based on relationships with others), engage in chats with these avatars, and interact with others through their avatars.

We are committed to protecting your privacy and handling your personal data in a transparent and secure manner. This Privacy Policy applies to all users of the App, regardless of your location, including users in Singapore, the United States, the European Union (EU), Australia, etc. We comply with applicable data protection laws, including but not limited to:

For the purposes of this Privacy Policy:

UniUme acts as the data controller for your personal data under the GDPR and similar laws. If you are an EU resident, we have appointed an EU Representative for GDPR compliance you can contact for any data protection inquiries.

By using the Services, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the App. This Privacy Policy is incorporated into our Terms of Service, and any capitalized terms not defined here have the meanings given in the Terms of Service.

This Privacy Policy is effective as of December 25, 2025. We may update it from time to time, and we will notify you of material changes as described in Section 10.

2. INFORMATION WE COLLECT

We adhere to data minimization principles, collecting only data essential for Services (e.g., relationship descriptions for avatar customization). Explicit consent is required for sensitive processing.

We collect information from you in several ways when you use our Services. This helps us provide, maintain, and personalize the App experience, including creating and customizing AI avatars and facilitating interactions between users.

We categorize the information we collect as follows:

2.1 INFORMATION YOU PROVIDE DIRECTLY

  1. Account and Profile Information: When you register or create an account, we collect your email address, username, password (stored securely in hashed form), and any optional profile details you choose to add (e.g., display name, profile picture, or bio).
  2. AI Avatar Customization Data: To create and personalize AI avatars, you may provide relationship descriptions (e.g., "best friend," "colleague," or specific details about your relationship with another person), personality traits, preferences, sample chat examples, text prompts, uploaded images, voice recordings, or other content used to customize the avatar's behavior.
  3. Chat Content: All messages, texts, images, voice notes, or other media you send or receive in chats with AI avatars (including your own or others' avatars).
  4. Optional Information: Any additional details you voluntarily provide, such as feedback, support requests, or survey responses.

2.2 INFORMATION COLLECTED AUTOMATICALLY

  1. Device and Usage Data: When you access or use the App, we automatically collect information such as your device type, operating system version, unique device identifiers (e.g., UDID, advertising ID), IP address, browser type (if accessing via web), time zone, language settings, and App usage patterns (e.g., features accessed, session duration, chat frequency, and interaction timestamps).
  2. Log Data: Server logs that record actions in the App, including crash reports, error logs, and diagnostic information to help us troubleshoot issues.
  3. Cookies and Similar Technologies: We use cookies, pixels, and local storage to remember your preferences, maintain your session, and analyze how you use the Services. You can manage cookie preferences through your device settings.

2.3 LOCATION INFORMATION

  1. We may collect approximate location data derived from your IP address or device settings (if you enable location services) to improve features such as relationship-based recommendations or regional content personalization. We do not collect precise GPS location without your explicit consent.

2.4 INFORMATION FROM THIRD PARTIES

  1. If you sign in using third-party services (e.g., Apple Sign In, Google, or other OAuth providers), we may receive basic profile information such as your name, email address, and profile identifier, subject to your privacy settings with that provider.

2.5 SENSITIVE PERSONAL DATA

  1. The Services may process information you voluntarily share in chats or avatar customizations that could be considered sensitive (e.g., information revealing racial or ethnic origin, political opinions, religious beliefs, health, or sexual orientation). We do not intentionally collect or request such data, but if you choose to include it, you consent to our processing it as described in this Policy. We strongly recommend avoiding sharing sensitive information in chats or customizations.
  2. We will not intentionally use your biometric data (e.g., voice for avatars) for any purpose. It's isolated to your account. We will not use your data for AI model training. All aggregated data is anonymized to prevent re-identification.

2.6 AI-SPECIFIC DATA

  1. Data used to customize your personal AI avatars is stored separately and associated only with your account.
  2. Data of your chatting record with AI avatar will only be stored in your account. Data of another person's chatting record with your AI avatar will only be stored in that individual's personal account. You will not gain access to another person's chatting record with your AI avatar.

We only collect data that is necessary to maintain and provide the Services. You can choose not to provide certain information.

3. HOW WE USE YOUR INFORMATION

We use the information we collect to provide, maintain, and personalize the Services, as well as to comply with our legal obligations. Specifically, we use your information for the following purposes:

3.1 TO PROVIDE AND OPERATE THE SERVICES

  1. Create and manage your account.
  2. Generate, customize, and maintain your AI avatars based on the relationship descriptions, personality traits, prompts, images, voice data, and other inputs you provide.
  3. Facilitate real-time chats between you and AI avatars (your own or those created by other users with whom you interact).
  4. Enable interactions where other users can chat with your AI avatars, and you can chat with theirs', in accordance with your privacy and visibility settings.
  5. Deliver notifications, updates, and responses within the App.

3.2 TO IMPROVE AND DEVELOP THE SERVICES

  1. Analyze usage patterns (in anonymized and aggregated form) to enhance user experience, and feature development.
  2. Conduct research and development to improve avatar personalization, conversation naturalness, and overall App functionality.
  3. Test new features and troubleshoot technical issues using diagnostic and log data.

3.3 TO COMMUNICATE WITH YOU

  1. Send service-related communications, such as account verification, security alerts, updates to our Terms or Privacy Policy, and responses to your support inquiries.
  2. With your consent (where required by law), send promotional materials, newsletters, or information about new features.

3.4 FOR SECURITY, FRAUD PREVENTION, AND LEGAL COMPLIANCE

  1. Detect, prevent, and address fraud, abuse, security incidents, or other harmful activity (e.g., monitoring for inappropriate content in chats).
  2. Comply with legal obligations, respond to lawful requests from authorities, enforce our Terms of Service, and protect the rights, property, or safety of our users, the public, or ourselves.

3.5 LEGAL BASES FOR PROCESSING (APPLICABLE TO EU AND SIMILAR JURISDICTIONS)

Where required by laws such as the GDPR, our processing of your personal data is based on the following legal grounds:

  1. Performance of a contract: To provide the Services you request, such as creating AI avatars and enabling chats (most core uses fall under this).
  2. Consent: For optional processing, such as marketing communications or use of certain sensitive data you voluntarily provide.
  3. Legitimate interests: For improving the Services, analytics (in anonymized form), security, and fraud prevention, provided these interests are not overridden by your rights.
  4. Legal obligation: To comply with applicable laws and regulations.

3.6 AI-SPECIFIC USES

  1. Your direct inputs (e.g., relationship descriptions, chat examples) are used solely to customize and operate your personal AI avatars. These custom models are isolated to your account and not shared with other users unless you explicitly allow interaction with your avatar.
  2. We will not use any of your anonymized and aggregated data from chats and interactions for AI model training.

3.7 EXIT OPTION

  1. Full deletion removes all data (except legal holds). Contact support@uniume.com for details.

We do not use your personal data for automated decision-making that produces legal or similarly significant effects on you without your consent or as required by law.

We process only the minimum data necessary for these purposes and encourage you to limit sharing unnecessary personal details.

4. SHARING AND DISCLOSURE OF INFORMATION

We share your information only in limited circumstances, as described below, and always with appropriate safeguards to protect your privacy.

4.1 WITH SERVICE PROVIDERS AND PARTNERS

  1. We share personal data with trusted third-party vendors and service providers who help us operate the Services. These include:
  2. These providers are contractually obligated to use your data only for the purposes of providing services to us, to maintain confidentiality, and to comply with applicable data protection laws.

4.2 WITH OTHER USERS (USER-TO USER INTERACTIONS)

  1. When you make your AI avatar discoverable or allow interactions, certain information (such as your avatar's name, customized personality traits, relationship context, and chat responses generated by your avatar) may be visible to or shared with other users who interact with it.
  2. Similarly, when you chat with another user's AI avatar, you may see information they have chosen to make available through their avatar.
  3. You control the visibility and sharing settings for your AI avatars in the App. We encourage you to review and adjust these settings carefully.

4.3 FOR BUSINESS TRANSFERS

  1. In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction. We will notify you (via email or prominent notice in the App) if such a transfer occurs and provide information about your choices.

4.4 FOR LEGAL REASONS

  1. We may disclose personal data if required by law, such as in response to a subpoena, court order, or lawful request from government or law enforcement authorities.
  2. We may also disclose information to protect the rights, property, or safety of our users, the public, or ourselves, including to prevent fraud, abuse, or illegal activity.

4.5 AGGREGATED OR ANONYMIZED DATA

  1. We may share aggregated or anonymized data that does not identify you individually (e.g., general usage statistics or trends derived from chat interactions) with partners, researchers, or the public for analytics, research, or marketing purposes.

4.6 INTERNATIONAL DATA TRANSFERS

  1. Since our company is based in Singapore and our primary servers are in the United States, your personal data may be transferred to and processed in countries outside your country of residence.
  2. For transfers from the EU, UK, or other regions with similar restrictions, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other mechanisms permitted under applicable law.
  3. By using the Services, you consent to such transfers where required by law.

We take reasonable steps to ensure that any recipient of your personal data provides an adequate level of protection and processes it only in accordance with this Privacy Policy and applicable laws.

5. DATA STORAGE, SECURITY, AND RETENTION

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, or destruction.

5.1 DATA STORAGE

  1. For users outside EU, your personal data is primarily stored on secure servers located in the United States, with possible backups or secondary processing in Singapore or other locations where our trusted service providers operate. Personal data from EU users is processed/stored in EU-compliant servers via standard contractual clauses (SCCs).
  2. Chat logs, AI avatar customizations, and related data are stored in encrypted databases, isolated by user account to prevent unauthorized cross-access.
  3. Data of your chatting record with AI avatar will only be stored in your account. Data of another person's chatting record with your AI avatar will only be stored in that individual's personal account.

5.2 SECURITY MEASURES

  1. Encryption: Data in transit is protected using industry-standard encryption (e.g., TLS/HTTPS). Sensitive data at rest, such as passwords and certain avatar inputs, is encrypted.
  2. Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis, with multi-factor authentication and regular security audits.
  3. Monitoring and Incident Response: We maintain systems to detect and respond to potential security threats. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and relevant authorities as required by law (e.g., within 72 hours under GDPR where applicable).
  4. AI-Specific Security: Custom AI data of your avatars are stored separately and not commingled with other users' data unless you explicitly enable sharing through interactions.

While we strive to use commercially reasonable measures to protect your data, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

5.3 DATA RETENTION

  1. We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to provide the Services, or as required or permitted by law.
  2. You can request deletion of your data at any time (see Section 6). Upon such a request, we will delete the requested data promptly, except for Memorial AI Avatar data retained under the special provision above (unless you specifically request its deletion) or where retention is required by law. Residual copies may remain in backups for a limited period (typically up to 90 days) before permanent removal.
  3. We regularly review our retention practices to ensure data is not kept longer than necessary.

6. YOUR RIGHTS AND CHOICES

You have certain rights and choices regarding your personal data, depending on your location and applicable laws. We provide tools in the App to help you exercise these rights, and we respond to requests promptly and in accordance with legal requirements.

6.1 ACCESS, CORRECTION AND PORTABILITY

  1. You can access, review, and update most of your personal data directly in the App settings (e.g., profile information, AI avatar customizations, chat history).
  2. You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format (data portability, where applicable under GDPR or similar laws).
  3. If any information is inaccurate, you can request correction.

6.2 DELETION AND RESTRICTION

  1. You can delete individual chats, AI avatars, or your entire account at any time through the App settings. Upon account deletion, we will delete or anonymize your personal data as described in Section 5.
  2. You have the right to request deletion of your personal data ("right to be forgotten" under GDPR, "right to delete" under CCPA, or similar rights in other jurisdictions), subject to legal exceptions (e.g., for compliance or dispute resolution).
  3. You may also request restriction of processing in certain circumstances (e.g., while verifying accuracy).

6.3 OBJECTION AND WITHDRAWAL OF CONSENT

  1. You can object to processing based on legitimate interests (e.g., anonymized analytics) or withdraw consent where we rely on it (e.g., marketing communications or use of optional data).
  2. Withdrawing consent does not affect the lawfulness of prior processing.

6.4 OPT-OUT CHOICES

  1. Marketing: You can opt out of promotional emails or notifications via the unsubscribe link or App settings.
  2. Cookies and Tracking: Manage cookie preferences through your device or browser settings. Note that disabling certain cookies may affect App functionality.
  3. Do Not Sell or Share (CCPA/CPRA): We do not sell your personal data or share it for cross-contextual behavioral advertising. If this changes, we will provide an opt-out mechanism.

6.5 REGION-SPECIFIC RIGHTS

  1. EU/UK Residents (GDPR): In addition to the above, you have rights to object to automated decision-making, lodge a complaint with a supervisory authority (e.g., your local Data Protection Authority), and contact our EU representative (details in Section 1).
  2. California Residents (CCPA/CPRA): You have the right to know what personal data we collect, request deletion, opt out of sales/sharing (not applicable currently), and non-discrimination for exercising rights. Submit requests via support@uniume.com or through the App.
  3. Australian Residents: You can access, correct, or complain about breaches under the Australian Privacy Principles.
  4. Singapore Residents (PDPA): You can access, correct, or withdraw consent for personal data use.

6.6 HOW TO EXERCISE YOUR RIGHTS

  1. Submit requests via email to support@uniume.com, or through in-App support.
  2. We will verify your identity (e.g., via account credentials or additional information) before processing requests.
  3. We aim to respond within 30 days (or as required by law, e.g., one month under GDPR). Requests are free of charge unless manifestly unfounded or excessive.

If you have concerns about our privacy practices, please contact us first—we are committed to resolving issues amicably.

7. CHILDREN'S PRIVACY

We are committed to protecting the privacy of children and minors. Our Services are strictly intended for users who are 16 years of age or older.

7.1 AGE RESTRICTION

  1. The App and Services are not directed to, marketed to, or intended for individuals under the age of 16.
  2. During registration and throughout your use of the Services, you must confirm and represent that you are at least 16 years old.
  3. We do not knowingly collect, maintain, or process personal data from anyone under 16. If we discover or are notified that a user is under 16, we will immediately terminate the account and delete all associated personal data, subject only to legal retention obligations.

7.2 COMPLIANCE WITH APPLICABLE LAWS

  1. Australia: In compliance with the Online Safety Amendment (Social Media Minimum Age) Act 2024 (effective December 10, 2025), we prohibit access to users under 16 in Australia.
  2. European Union and United Kingdom: We comply with GDPR and the UK GDPR, where the minimum age for consent to information society services is between 13 and 16 depending on the Member State. Our 16+ restriction exceeds these requirements.
  3. United States: We comply with the federal Children's Online Privacy Protection Act (COPPA), which applies to children under 13, as well as state laws providing additional protections for minors (including age-appropriate design codes applicable to users under 18). By restricting access to users 16 and older, we ensure compliance with these requirements.
  4. Singapore: We comply with the Personal Data Protection Act (PDPA) and any applicable guidelines on protecting minors.
  5. App Store Requirements: The App is rated 16+ on the Apple App Store and Mature 17+ on Google Play Store, consistent with our 16+ age restriction and the nature of user-generated and AI-driven interactions that may include mature or sensitive content.

7.3 PARENTAL OR GUARDIAN CONCERNS

  1. If you are a parent or guardian and believe that a person under 16 has provided us with personal data (e.g., by misrepresenting their age), please contact us immediately at support@uniume.com. We will promptly investigate, terminate the account if necessary, and delete the information as required by law.

7.4 CONTENT AND SAFETY MEASURES

  1. Given the interactive, user-generated, and AI-driven nature of our Services (including potentially sensitive or adult-oriented conversations via AI avatars), we enforce this 16+ restriction to provide a safe and appropriate environment for our users.
  2. We implement robust content moderation, reporting tools, and filters to detect and address inappropriate, illegal, or harmful content.

By using the Services, you represent and warrant that you are at least 16 years old and agree to comply with all applicable laws and our policies.

8. INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to, stored, and processed in countries outside of your country of residence, including Singapore (where our company is based) and the United States (where our primary servers and certain service providers are located). These countries may have data protection laws that differ from those in your jurisdiction.

8.1 TRANSFERS AND SAFEGUARDS

  1. We ensure that all international data transfers comply with applicable laws and are protected by appropriate safeguards.
  2. For transfers from the European Union, United Kingdom, Switzerland, or other regions with similar data export restrictions, we primarily rely on: Standard Contractual Clauses (SCCs) approved by the European Commission, Other approved mechanisms such as Binding Corporate Rules (where applicable) or adequacy decisions.
  3. We conduct transfer risk assessments where required and implement supplementary measures to maintain an equivalent level of protection.
  4. We use SCCs for EU/U.S. transfers. No China backflow for overseas users.

8.2 SPECIFIC CONSIDERATIONS FOR CERTAIN JURISDICTIONS

  1. EU/UK Residents: Transfers to non-adequate countries (such as the United States) are governed by SCCs between our company and recipients. If future adequacy decisions (e.g., EU-U.S. Data Privacy Framework) become applicable, we may also rely on those.
  2. Australian Residents: We ensure transfers comply with the Australian Privacy Principles, including reasonable steps to protect data overseas.
  3. Singapore Residents: Transfers are managed in accordance with the PDPA requirements for overseas disclosure.

8.3 YOUR CONSENT AND AWARENESS

  1. By using the Services, you acknowledge and, where required by law, consent to the transfer of your personal data to countries outside your jurisdiction for the purposes described in this Privacy Policy.

We regularly review our data transfer practices to ensure ongoing compliance with evolving international data protection standards.

9. THIRD-PARTY LINKS AND SERVICES

Our Services may contain links to third-party websites, applications, or services that are not owned or controlled by us. This includes, but is not limited to:

9.1 INDEPENDENT PRIVACY PRACTICES

  1. We are not responsible for the privacy practices, content, or security of these third-party sites or services.
  2. When you click on a third-party link or use a third-party service, you will be subject to that third party's own privacy policy and terms of service, which may differ significantly from ours.

9.2 THIRD-PARTY DATA COLLECTION

  1. Third parties may collect information about you independently (e.g., through cookies, trackers, or device identifiers) when you interact with their services via our App.
  2. For example, if you log in using a third-party provider, that provider may share certain profile information with us (as described in Section 2), but they will handle your data according to their own policies.

9.3 RECOMMENDATIONS

  1. We encourage you to carefully review the privacy policies and terms of any third-party services before using them or providing any personal data.
  2. Interactions with third-party content or services are at your own risk.

We do not endorse or assume any liability for third-party websites, applications, or services linked to or accessible through our Services.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We encourage you to review this page periodically for the latest information.

10.1 NOTIFICATION OF CHANGES

  1. If we make material changes to how we collect, use, or share your personal data, we will notify you by:
  2. For minor changes (e.g., clarifications or non-substantive updates), we will simply update the policy with a new effective date.

10.2 YOUR ACCEPTANCE

  1. Your continued use of the Services after any changes become effective constitutes your acceptance of the updated Privacy Policy.
  2. If you do not agree with the revised policy, you must stop using the Services and may delete your account.

10.3 EFFECTIVE DATA TRACKING

  1. The "Effective Date" at the bottom of this Privacy Policy indicates when the current version took effect.
  2. Previous versions are archived and available upon request by contacting us at support@uniume.com.

We will always handle your personal data in accordance with the version of the Privacy Policy in effect at the time it was collected, unless we obtain your consent for new uses.

11. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal data, or our privacy practices, please contact us using the details below. We are committed to addressing your inquiries promptly and effectively.

11.1 GENERAL CONTACT

  1. Email: support@uniume.com (Preferred method for privacy-related requests, such as exercising your rights under GDPR, CCPA, PDPA, or other laws.)
  2. In-App Support: Use the "Help" or "Support" section within the App to submit queries directly.
  3. Mailing Address: UNIUME PTE. LTD., 68 Circular Road, #02-01, Singapore 049422

11.2 DATA PROTECTION OFFICER (DPO)

  1. We have appointed a Data Protection Officer responsible for overseeing privacy compliance. You can reach our DPO at:

11.3 EU REPRESENTATIVE (FOR EU RESIDENTS)

  1. As required under Article 27 of the GDPR, we have appointed an independent EU Representative you can contact at support@uniume.com.

11.4 COMPLAINTS TO REGULATORY AUTHORITIES

  1. If you are not satisfied with our response or wish to lodge a formal complaint about our handling of your personal information, you have the right to contact the relevant data protection authority in your jurisdiction. Depending on your location, these may include:
  2. We will cooperate fully with any investigations by these authorities.