Soulkin Privacy Policy

This Privacy Policy applies to users who access or use Soulkin outside the mainland of China. If you access or use Soulkin in the mainland of China, a separate domestic privacy policy may apply. Where mandatory laws of your country or region of residence provide stronger privacy or consumer protections, those mandatory protections will apply to you.

Owleap (Hainan) Technology Co., Ltd. and, where applicable, its affiliates (collectively, “Soulkin”, “we”, “us”, or “our”) respect your privacy. This Privacy Policy explains how we collect, use, store, disclose, transfer, and protect personal information when you use the Soulkin mobile application, website, and related services (collectively, the “Services”).

Please read this Privacy Policy carefully. By using the Services, creating an account, or otherwise interacting with Soulkin, you acknowledge that you have read and understood this Privacy Policy. Where applicable law requires consent for a particular processing activity, we will ask for your consent separately.

This Privacy Policy does not apply to third-party websites, services, stores, payment channels, or platforms that may be linked from or integrated with Soulkin. Those third parties are responsible for their own privacy practices.

Summary

This summary is provided for convenience only. The full Privacy Policy below controls.

• We collect information you provide, information generated when you use Soulkin, device and log information, transaction status information, customer support information, and information processed through device permissions you choose to grant.
• We use personal information to provide, maintain, secure, improve, and personalize the Services; process subscriptions and purchases; communicate with you; moderate content; comply with legal obligations; and protect users, pets, households, and the platform.
• We do not sell your personal information. We do not use your pet records, photos, or private household content for external advertising or marketing without an appropriate legal basis and, where required, your separate consent.
• We may process and store personal information in the mainland of China and other locations where we or our service providers operate. When personal information is transferred across borders, we use appropriate safeguards where required by applicable law.
• You may have rights to access, correct, delete, export, restrict, or object to certain processing of your personal information, withdraw consent, and appeal certain decisions, depending on your location and applicable law.

1. Who We Are and How to Contact Us

The controller or responsible entity for the processing described in this Privacy Policy is:

• Owleap (Hainan) Technology Co., Ltd.
• Address: Room 407, 4/F, Building 12, Area A, Phase I, Poly Xiuying Port Project, No. 17 Lijing Road, Haixiu Subdistrict, Xiuying District, Haikou, Hainan Province, China.
• Email: Soulkin_Support@owleap-world.com

For privacy-related requests, please include “Soulkin Privacy Request” in the subject line and provide sufficient information for us to verify your account and process your request. We may ask for additional verification information where necessary to protect your account and personal information.

2. Personal Information We Collect

We collect personal information only where it is reasonably necessary for the Services, where you provide it voluntarily, where it is generated through your use of Soulkin, or where we are required or permitted to do so by law.

3. Device Permissions

Certain features require access to device permissions. You can allow or deny these permissions through your device settings. If you deny or later revoke a permission, the related feature may not work, but other parts of the Services may remain available.

4. How We Use Personal Information

We use personal information for the following purposes:

• To provide and maintain the Services, including account registration, login, pet records, Pet Spaces, household collaboration, content posting, messaging, comments, likes, follows, reminders, expenses, subscriptions, and customer support.
• To secure the Services, verify identity, detect abnormal activity, prevent fraud, abuse, spam, unauthorized access, and other harmful or unlawful behavior.
• To store, sync, back up, and restore pet records, household records, photos, drafts, user content, and other information across authorized devices and accounts.
• To process transactions, verify App Store or other payment-channel purchases, manage subscription entitlements, refunds, cancellations, and customer support for paid services.
• To send service-related communications, including security alerts, account notices, policy updates, collaboration notifications, feature notices, and support responses.
• To moderate content, enforce our Terms of Service and Community Guidelines, review complaints or reports, protect minors and other users, and maintain a safe community.
• To improve and develop the Services, including debugging, analytics, performance monitoring, usability improvement, feature planning, and aggregated statistical analysis.
• To comply with laws, regulations, court orders, law-enforcement requests, tax, accounting, audit, and other legal obligations.
• To protect the rights, property, safety, and legitimate interests of Soulkin, users, pets, households, service providers, and the public.

5. Legal Bases for Processing

Depending on your location, we may be required to identify legal bases for processing personal information. Where the GDPR, UK GDPR, or similar laws apply, our legal bases may include:

Where we rely on consent, you may withdraw your consent at any time. Withdrawal does not affect processing that occurred before withdrawal or processing based on other valid legal bases.

6. User Content, Visibility, and Sensitive Information

Soulkin allows you to create and store pet-related records and to share content with different audiences depending on the product settings available to you. Your user content may include personal information about you, other people, household members, minors, or third parties, and may include sensitive information such as photos, location information, health-related notes, or personal communications.

• You control the information you choose to provide, upload, publish, or share, subject to the functionality of the Services and applicable laws.
• Content you make public or share with other users may be viewed, copied, saved, or further shared by those users or the public, depending on the visibility setting and platform functionality.
• Please avoid uploading or sharing sensitive information about yourself, minors, household members, or third parties unless you have a lawful basis and the necessary permissions to do so. Examples of sensitive information may include health information, precise location data, biometric information, identity documents, financial information, or information relating to a child or minor.
• If you delete user content, we will remove it from active display where technically feasible. Some copies may remain temporarily in backups, logs, or moderation records as permitted or required by law.

7. Personalized Recommendations, Analytics, and Automated Processing

Soulkin may provide content display, ranking, search, recommendation, or feed features. These features may use information such as your interactions, content visibility settings, region, language, followed users, Pet Space context, or other service data to display content or improve relevance.

We do not use automated decision-making to make decisions that produce legal effects concerning you or similarly significant effects, unless permitted by applicable law and with the safeguards required thereby. If automated decision-making significantly affects your legal rights or contractual relationship with us, you may request human review through the channels described in this Privacy Policy or the relevant in-app settings.

Where applicable law grants you a right to object to or opt out of personalized recommendations, profiling, targeted advertising, or certain automated processing, we will provide appropriate controls through in-app settings or other accessible channels.

8. Local Storage, Authentication Information, and Similar Technologies

Soulkin is primarily an iOS native application and does not rely on traditional browser cookies as the main method for user identification or session management. We may use local app storage, secure system storage such as iOS Keychain, access tokens, refresh tokens, device-local configuration, cache, drafts, and similar technologies.

We use these technologies to maintain login status, protect account security, support offline use, store preferences, improve continuity of use, reduce repeated input, identify abnormal activity, and improve performance. We do not use cookies or similar technologies for cross-app or cross-site tracking unless separately disclosed and, where required, consented to by you.

You may manage certain local storage through device settings, in-app logout, cache clearing, or deleting the app. Some storage is necessary for authentication, security, and normal operation; disabling or deleting it may prevent the Services from functioning properly.

9. How We Share Personal Information

We do not sell your personal information. We share personal information only as described in this Privacy Policy, as directed by you, as needed to provide the Services, or as required or permitted by applicable law.

9.1 Service Providers

We may share personal information with trusted vendors and service providers that process information on our behalf, such as cloud hosting, storage, content delivery, database operations, SMS or email delivery, crash diagnostics, customer support, fraud prevention, security monitoring, payment verification, and professional advisers. These service providers may process personal information only as instructed by us and for the purposes described in this Privacy Policy, unless they have an independent legal basis.

9.2 Payment Platforms and App Stores

If you purchase subscriptions or paid features through the App Store or another payment channel, the payment platform may process your payment information according to its own terms and privacy policy. We generally receive purchase status, order identifiers, entitlement status, renewal status, refund or cancellation status, and related transaction information necessary to provide paid features. We do not directly collect or store full payment card numbers or equivalent sensitive payment credentials.

9.3 Pet Spaces and Other Users

If you join, invite others to, or collaborate within a Pet Space, information within that Pet Space may be visible to other authorized members according to their roles and permissions. This may include pet profiles, photos, to-dos, health records, expense records, comments, and other shared household content. Please invite only trusted members and review permissions carefully.

9.4 Legal, Safety, and Rights Protection

We may disclose personal information if we believe in good faith that disclosure is necessary to comply with applicable law, legal process, regulatory requests, court orders, law-enforcement requests, or to protect the rights, property, safety, and legitimate interests of Soulkin, users, minors, third parties, or the public.

9.5 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, asset transfer, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction. We will take reasonable steps to require the recipient to protect personal information in a manner consistent with this Privacy Policy or provide notice where required by law.

9.6 With Your Direction or Consent

We may share personal information with third parties when you direct us to do so, when you use a sharing function, when you connect Soulkin with a third-party service, or when you provide consent where required by applicable law.

10. Third-Party Links, Services, and SDKs

Soulkin may contain links to third-party websites, content, services, or platforms. If you click a third-party link or use a third-party service, that third party may collect and process information under its own privacy policy. We are not responsible for the privacy practices of third parties.

At the time of this Privacy Policy, Soulkin does not use third-party advertising SDKs to track you across apps or websites for targeted advertising. If we introduce third-party SDKs, analytics tools, advertising services, maps, social login, or similar services that process personal information, we will update this Privacy Policy and provide notice or obtain consent where required by applicable law.

11. International Transfers and Storage Locations

Soulkin is operated by a company established in the mainland of China. Your personal information may be processed and stored in the mainland of China and in other countries or regions where we, our affiliates, or our service providers operate. These locations may have data protection laws that differ from those in your country or region.

If personal information is transferred across borders, we will comply with applicable data transfer laws and use appropriate safeguards where required. Such safeguards may include, where applicable, the European Commission’s Standard Contractual Clauses or equivalent approved mechanisms; you may contact us for more information about applicable transfer safeguards.

Where applicable law requires your separate consent for certain cross-border transfers, we will obtain such consent or rely on another lawful transfer mechanism permitted by applicable law.

12. How Long We Retain Personal Information

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Retention periods may vary depending on the type of information, the purpose of processing, legal requirements, security needs, dispute resolution, and backup practices.

When personal information is no longer needed, we will delete, anonymize, or otherwise process it in accordance with applicable law. If deletion is not immediately possible due to backup, technical, security, or legal reasons, we will restrict further processing where required and delete or anonymize the information when feasible.

13. How We Protect Personal Information

We use reasonable technical, organizational, and administrative safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction. These safeguards may include encryption in transit, access controls, authentication controls, secure storage mechanisms, logging, monitoring, vulnerability management, staff confidentiality obligations, and internal privacy and security procedures.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we will continue to improve our safeguards and respond to security risks. If we become aware of a personal information security incident that requires notification under applicable law, we will notify affected users and relevant regulators as required.

You are responsible for maintaining the confidentiality of your account credentials, verification codes, device access, and third-party account authorizations. Please contact us promptly if you suspect unauthorized access to your account or a security issue involving Soulkin.

14. Your Privacy Rights and Choices

Depending on your location and applicable law, you may have rights regarding your personal information. These rights may include the right to:

• access the personal information we hold about you and receive a copy;
• correct inaccurate or incomplete personal information;
• delete personal information, subject to legal exceptions;
• restrict or object to certain processing;
• withdraw consent where processing is based on consent;
• receive personal information in a portable format where required by applicable law;
• object to or opt out of certain profiling, targeted advertising, sale, sharing, or personalized recommendation activities where applicable;
• appeal certain privacy-rights decisions where applicable law provides such a right;
• lodge a complaint with a competent data protection authority or regulator.

You may exercise many choices through Soulkin settings, device permissions, notification settings, account settings, or by contacting us at Soulkin_Support@owleap-world.com. We will respond to requests within the timeframe required by applicable law. If no specific legal timeframe applies, we will use reasonable efforts to respond within 30 days after verifying your request.

To protect your privacy and security, we may need to verify your identity before fulfilling a request. We may refuse or limit a request where permitted by law, such as where the request is excessive, fraudulent, technically infeasible, would adversely affect the rights of others, would reveal trade secrets, or would conflict with legal obligations.

15. Region-Specific Privacy Notices

15.1 European Economic Area, United Kingdom, and Switzerland

If you are located in the EEA, the United Kingdom, or Switzerland, you may have additional rights under applicable data protection laws, including the rights described above, the right to object to processing based on legitimate interests, the right to restrict processing, the right to data portability, and the right to lodge a complaint with your local data protection authority.

Where we rely on legitimate interests, we balance our interests against your rights and interests, and you may object to such processing as permitted by applicable law by contacting us through the channels described in this Privacy Policy. Where we rely on consent, you may withdraw consent at any time. Cross-border transfers will be protected by appropriate safeguards where required by applicable law.

15.2 United States State Privacy Notices

If you reside in a U.S. state with an applicable privacy law, you may have rights to access, delete, correct, obtain a copy of, or opt out of certain processing of personal information, depending on your state. We do not sell personal information for money. We do not knowingly sell or share personal information of children for targeted advertising. If we engage in activities that applicable law defines as “sale,” “sharing,” or targeted advertising, we will provide the required notices and opt-out mechanisms.

We will not discriminate against you for exercising privacy rights, except as permitted by law. Authorized agents may submit requests where permitted by applicable law, but we may require proof of authorization and verification of the user’s identity.

15.3 Other Regions

If privacy or consumer protection laws in your country or region grant you additional rights, we will respect those rights as required by applicable law. You may contact us if you have questions about how this Privacy Policy applies to you.

16. Children and Minors

Soulkin is not designed primarily for children. We do not knowingly collect personal information from children under the age at which applicable law allows them to consent to personal information processing on their own, unless we have obtained appropriate parental or guardian consent or another lawful basis applies.

The relevant age may vary by jurisdiction. For example, certain laws may set the relevant age at under 13, under 16, or another age. Where required by applicable law, we will implement age-screening, parental or guardian consent, or other child-protection mechanisms. The age-screening mechanism will respect the age of consent for data processing as defined by the applicable law of the user’s habitual residence.

If you are a parent or legal guardian and believe that a child has provided personal information to Soulkin without appropriate consent, please contact us. After appropriate verification, we will take reasonable steps to delete, restrict, or otherwise handle the information as required by applicable law.

If you upload or share content involving minors, including images, names, birthdays, schools, locations, health information, or other identifying information, you must have a lawful basis and any required consent. Please consider the privacy, safety, and long-term interests of minors before sharing such content.

17. Account Deletion and Data Export

You may request account deletion through in-app settings where available or by contacting us. Account deletion is generally irreversible. After deletion, you may lose access to your account, Pet Spaces, pet records, user content, subscriptions or entitlements linked to the account, and other data, subject to applicable law and App Store or payment-channel rules.

Before deleting your account, we recommend exporting or saving information you wish to keep where export or download functionality is available. Except as required by applicable data protection laws, including any right to data portability, we do not promise to continue providing restoration, return, or export of all historical data after account deletion or service termination.

We may retain certain information after account deletion where necessary to comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, protect security, process refunds or chargebacks, maintain backup integrity, or protect the rights of users and third parties.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, technology, legal requirements, or business operations. We will notify you of material changes by appropriate means, such as in-app notice, email, push notification, website notice, or other reasonable methods.

Material changes include, without limitation, changes that substantially reduce your rights, increase your obligations, significantly modify the purposes or categories of personal information processing, materially change sharing or transfer practices, introduce materially different automated decision-making, or change how you may exercise your privacy rights.

For material changes that adversely affect your rights or obligations, we will provide reasonable prior notice and, where practicable, at least 30 days’ prior notice. Where applicable law requires your consent, we will obtain consent before the relevant change applies. If you do not agree to the updated Privacy Policy, you should stop using the Services and may delete your account, subject to applicable law and service rules.

19. Contact Us

If you have questions, requests, complaints, or concerns about this Privacy Policy or our handling of personal information, please contact us:

• Email: Soulkin_Support@owleap-world.com
• Mailing Address: Room 407, 4/F, Building 12, Area A, Phase I, Poly Xiuying Port Project, No. 17 Lijing Road, Haixiu Subdistrict, Xiuying District, Haikou, Hainan Province, China. Attn: Soulkin Privacy Officer.

We will respond within the timeframe required by applicable law. If you are not satisfied with our response, you may have the right to contact a competent data protection authority, consumer protection authority, or other regulator in your country or region.

20. Language and Interpretation

This Privacy Policy may be made available in multiple languages. For users outside the mainland of China, the English version shall prevail unless a separate localized version expressly states otherwise or mandatory law requires a different result. Nothing in this Privacy Policy limits any mandatory privacy, data protection, or consumer rights that cannot be waived by contract.