Souleasy Privacy Policy ("privacy policy" or "policy")
Last updated: 28/07/2025
***Important instructions for deleting your account
If users need to delete your account and related information, please send your User ID and deletion
request to the following email address:zhonglian.industrial@gmail.com
Note: Souleasy also supports users to delete their accounts by themselves. The steps are as follows:
① Open the Souleasy app, enter the Profile page, and click the "Settings" button in the upper right
corner. ② On the Settings page, find the "Delete account" option. ③ Click "Delete account", a pop-up
window will appear to confirm the deletion, click Confirm.
About us
This app is supplied by ZHONG LIAN INDUSTRIAL HOLDINGS LIMITED ("we", "us", and "our"). We
build virtual companion apps.
Our registered office and our place of business is Rm 1802 BEVERLY HSE 93-107 LOCKHART RD
Wan chai, HongKong. However, please direct all correspondence related to the App to
zhonglian.industrial@gmail.com.
"app" means the Souleasy: AI Chat app that you download and install onto your device, and includes
and all updates to such app that we make available or provide to you from time to time.
The app provides virtual companion and virtual chat functionality.
Purpose
We take your privacy very seriously. Please read this privacy policy carefully as it contains important
information on how and why we collect, store, use and share any information relating to you (your
personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant
regulator in the event you have a complaint.
We are the controller of personal data obtained via the app, meaning we are the organisation legally
responsible for deciding how and for what purposes it is used.
If you are aged under 17 you must not use the app as it is not designed for you. We do not intend
to collect the personal data of anyone under 17. If you are aware that any personal data of anyone
under 17 has been shared with the app please let us know so that we can delete that data.
What this policy applies to
This privacy policy relates to your use of the app only.
The app may link to other apps, websites or services owned and operated by us or by certain trusted
third parties to make additional products, information and services available to you. These other apps,
websites or services may also gather information about you in accordance with their own separate
privacy policies. For privacy information relating to these other apps, websites or services, please
consult their privacy policies as appropriate.
Personal data we collect about you
The personal data that we may collect about you broadly falls into the following categories:
• Information that you provide voluntarily
Certain parts of our app may ask you to provide personal data voluntarily: for example, we may ask you
to provide your contact details in order to register an account with us, to subscribe to marketing
communications from us, and/or to submit enquiries to us. In chatting with your AI Succubus, you will
inevitably be including your personal data. The personal data that you are asked to provide, and the
reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide
your personal data.
• Information that we collect automatically
When you download and access our app, we may collect certain information automatically from your
device. In some countries, this information may be considered personal data under applicable data
protection laws.
Specifically, the information we collect automatically may include information like your IP address,
device type, unique device identification numbers, other internal identifiers (integers), browser-type,
broad geographic location (e.g. country or city-level location) and other technical information. We may
also collect information about how your device has interacted with our app.
Collecting this information enables us to better understand the users of our app, where they come from,
and what content or functionality in our app is of interest to them. We use this information for our internal
analytics purposes and to improve the quality and relevance of our app to our users.
• Information that we obtain from third party sources
From time to time, we may receive personal data about you from third party sources (including Apple,
Google, and Facebook), but only where we have checked that these third parties either have your
consent or are otherwise legally permitted or required to disclose your personal data to us.
The types of information we collect from third parties include name, email address, external tokens/ids
and we use the information we receive from these third parties to maintain and improve the accuracy of
the records we hold about you.
• For users of the APP, when you use the software, for the purpose of providing, processing, maintaining,
improving, developing our products and/or services provided to you, the software may obtain the
following permissions for your terminal device:
(1) In order to achieve the normal operation of the software, you need to use network permissions.
• User Generated Content (UGC) & Media Access
To provide specific features of the App, such as the Creation Studio, LiveRoom, and community
interactions, we may collect and process the following content you upload or transmit:
(1) Images and Photos: We collect images you upload from your device's gallery or take via the camera
to enable AI character creation, video generation, and profile customization features.
(2) User Comments and Interactions: We collect text comments, messages, and other interactions you
post in public areas (e.g., LiveRoom) to facilitate community engagement.
(3) Camera & Gallery Permissions: The App requires access to your device's camera and photo gallery
to function. We only access these with your explicit consent. You can revoke this permission at any time
in your device settings.
(4) Content Moderation: To maintain a safe environment, all User Generated Content is subject to
automated and manual review. We reserve the right to remove content that violates our policies.
Legal basis for processing personal data
Our legal basis for collecting and using the personal data described above will depend on the
personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data from you only where we have your consent to do so,
where we need the personal data to perform a contract with you, or where the processing is in our
legitimate interests and not overridden by your data protection interests or fundamental rights and
freedoms. In some cases, we may also have a legal obligation to collect personal data from you or
may otherwise need the personal data to protect your vital interests or those of another person.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with
you, we will make this clear at the relevant time and advise you whether the provision of your personal
data is mandatory or not (as well as of the possible consequences if you do not provide your personal
data).
Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of
any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect
and use your personal data, please contact us (see ‘How to contact us’ below).
Marketing
We may use your personal data to send you updates (by email, push notification and text message)
about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘Legal
basis for processing personal data ’). This means we do not usually need your consent to send you
marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by
contacting us at zhonglian.industrial@gmail.com.
For more information on your right to object at any time to your personal data being
used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with service providers we use to help us run our business or provide
the services or functionalities in the app, including:
• Apple, Google, and Facebook;
•Firebase Analytics, Apple Search Ads Attribution for the purposes of marketing performance
measurements, conversion tracking and retargeting.
We only allow our group companies and service providers to handle your personal data if we are
satisfied they take appropriate measures to protect your personal data. We also impose contractual
obligations on service providers to ensure they can only use your personal data to provide services to
us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
• external auditors, e.g. in relation to the audit of our accounts —the recipient of the information will be
bound by confidentiality obligations
• professional advisors (such as lawyers and other advisors)—the recipient of the information will be
bound by confidentiality obligations
• law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and
regulatory obligations
• other parties in connection with a significant corporate transaction or restructuring, including a potential
or actual merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually,
information will be anonymised but this may not always be possible, however, the recipient of the
information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see
‘How to contact us’ below).
Data retention
We retain personal data we collect from you where we have an ongoing legitimate business need to do
so (for example, to provide you with a service you have requested or to comply with applicable legal,
tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal data, we will either delete
or anonymise it or, if this is not possible (for example, because your personal data has been stored in
backup archives), then we will securely store your personal data and isolate it from any further
processing until deletion is possible.
Transferring your personal data out of the HK
Countries outside the HK have differing data protection laws, some of which may provide lower levels
of protection of privacy.
It is sometimes necessary for us to share your personal data to countries outside the HK. In those
cases we will comply with applicable HK laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the HK
where:
• the HK government has decided the particular country ensures an adequate level of protection of
personal data;
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies
for you;
• a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the HK we do so on the basis of an adequacy regulation
or (where such is not available) legally-approved standard data protection clauses recognised or issued.
In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we
will not transfer your personal data outside the HK unless we can do so on the basis of an alternative
mechanism or exception provided by HK data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we use
to transfer personal data internationally will be notified to you in accordance with the section on
‘Changes to this privacy policy’ below.
For further information about such transfers and the safeguards we employ, including to obtain a copy
of the standard data protection clauses, please contact us (see ‘How to contact us’ below).
Your rights
You generally have the following rights, which you can usually exercise free of charge:
● If you wish to access, correct, update or request deletion of your personal data, you can do so at
any time by contacting us using the contact details provided (see ‘How to contact us’ below).
● In addition, you can object to processing of your personal data, ask us to restrict processing of
your personal data or request portability of your personal data. Again, you can exercise these rights
by contacting us using the contact details provided (see ‘How to contact us’ below).
● You have the right to opt-out of marketing communications we send you at any time. You can
exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
To opt-out of other forms of marketing, then please contact us using the contact details provided (see
‘How to contact us’ below).
● Similarly, if we have collected and processed your personal data with your consent, then you can
withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any
processing we conducted prior to your withdrawal, nor will it affect processing of your personal data
conducted in reliance on lawful processing grounds other than consent.
When contacting us please:
• provide enough information to identify yourself (e.g. your full name, address and email address) and
any additional identity information we may reasonably request from you;
• let us know which right(s) you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used
or accessed unlawfully. We limit access to your personal data to those who have a genuine business
need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you
and any applicable regulator of a suspected data security breach where we are legally required to do
so.
How to complain
Please contact us if you have any queries or concerns about our use of your information (see below
‘How to contact us’). We hope we will be able to resolve any issues you may have.
Changes to this privacy policy
We may change this privacy policy from time to time. When we make significant changes we will take
steps to inform you, for example via the app or by other means, such as email.
How to contact us
You can contact us by email if you have any questions about this privacy policy or the information we
hold about you, to exercise a right under data protection law or to make a complaint.
