Privacy Policy

<p>Effective date: June 1, 2026 | Last updated: June 1, 2026</p> <p>Sagaway OÜ (brand name “Sagaway”, hereinafter “we” or “us”) takes your privacy seriously. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the “LightUp” application and related services (collectively, the “Service”), and the rights you have.</p> <p>Our stance is simple: <strong>we collect only what is necessary to provide the Service, we do not sell your personal data, and we do not serve ads.</strong> Please read this Policy carefully before using the Service.</p> <h2>1. Information We Collect</h2> <h3>1.1 Information you provide</h3> <ul> <li><strong>Account information:</strong> identifiers needed to register or sign in (such as phone number, third-party account identifier, nickname).</li> <li><strong>Your conversations with the AI:</strong> the text and voice you input and the life moments you choose to record. This content is the basis on which the Service builds your “long-term memory” and recognizes “achievements.”</li> <li><strong>Feedback you submit:</strong> information you provide when you contact us or send feedback.</li> </ul> <h3>1.2 Information collected automatically</h3> <ul> <li><strong>Device and log information:</strong> device model, OS version, app version, crash logs, used to keep the Service stable and secure.</li> <li><strong>Usage information:</strong> basic statistics about feature usage, used to improve the experience.</li> </ul> <p>For sensitive permissions such as contacts, photos, precise location, and microphone, we access them only to deliver a specific feature you actively initiate, and only after your separate authorization. You can revoke them anytime in your system settings.</p> <h2>2. How We Use Information</h2> <ul> <li>To provide and maintain the core features of the Service (companionship, long-term memory, achievement recognition);</li> <li>To build and continually refine your personalized memory and experience;</li> <li>To safeguard account and service security and to prevent and handle abuse and risk;</li> <li>To analyze and improve the product at a de-identified or aggregate level;</li> <li>To comply with applicable laws and regulations.</li> </ul> <h2>3. AI Processing and Third-Party Services</h2> <p>To enable conversational understanding and content recognition, the Service may call carefully evaluated third-party AI model and infrastructure providers when processing your input. We contractually require such providers to keep your information confidential and secure, <strong>and require that they not use your data to train their models</strong> unless you give separate, explicit consent. We transmit to them only the content necessary to deliver the relevant feature.</p> <h2>4. What We Will Not Do</h2> <ul> <li>We do not sell your personal information;</li> <li>We do not serve commercial ads based on your personal information;</li> <li>We do not use your information for purposes unrelated to the Service.</li> </ul> <h2>5. Storage and Retention</h2> <p>We store your personal information within the People’s Republic of China. While you use the Service, we keep the memory and achievement data built for you; upon account deletion or where required by law, we will delete or anonymize your personal information. For continuity of the companionship experience, some “memories” default to preservation within the product; you may exercise your rights anytime through deletion or account closure (see below).</p> <h2>6. Your Rights</h2> <p>To the extent permitted by law, you have the right to:</p> <ul> <li>access and obtain a copy of your personal information;</li> <li>correct or complete inaccurate information;</li> <li><strong>export</strong> your data;</li> <li>delete your information or close your account;</li> <li>change or withdraw consent previously given.</li> </ul> <p>You can do this in the relevant in-app settings, or contact us via the details at the end of this Policy.</p> <h2>7. Information Security</h2> <p>We use industry-standard measures such as encrypted transmission and access control to protect your information. However, please understand that no measure can guarantee absolute security; in the event of a personal data security incident, we will fulfill our notification and reporting obligations as required by law.</p> <h2>8. Protection of Minors</h2> <p>The Service is primarily intended for adults. If you are a minor, please use it under the guidance of a guardian and provide information only after your guardian’s consent. If we learn that we have collected a minor’s information without guardian consent, we will seek to delete it promptly.</p> <h2>9. Sharing and Disclosure</h2> <p>We do not share your personal information with third parties, except: with your explicit consent; with service providers necessary to deliver features and bound by confidentiality obligations (see Section 3); as required by laws, regulations, or lawful requests from judicial or administrative authorities; or as necessary to protect the life, property, or other major lawful interests of users or the public.</p> <h2>10. Changes to This Policy</h2> <p>We may update this Policy from time to time. For material changes, we will notify you through reasonable means such as in-app notices. Your continued use of the Service after a change constitutes acceptance of the updated Policy.</p> <h2>11. Contact Us</h2> <p>If you have any questions, comments, or complaints about this Policy or your personal information, please contact:</p> <ul> <li>Company: Sagaway OÜ (Sagaway)</li> <li>Email: privacy@sagaway.ai</li> </ul>