1. Overview
Unide ("We", "Us", "Our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your data when you use the Unide Polite Refusal Generator App (the "App"), including data processed by our AI service provider. This Policy complies with the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region ("Hong Kong PDPO").
By using the App, you acknowledge that you have read and understood this Privacy Policy, and consent to the collection and use of your data as described herein.
2. Data We Collect
We collect the following categories of data to provide and improve the App's functionality:
- Account Data: Email address (for account registration and communication) and basic profile information (if voluntarily provided).
- Usage Data: Information about how you use the App, including relationship types selected, tone preferences for refusal responses, and interaction history with the App's interface.
- AI Service Data: Text input (e.g., request context for refusal response generation) and image files (if uploaded to assist the AI in generating contextually appropriate responses).
- Device Data: Basic device information (e.g., device type, operating system) to ensure the App functions properly across platforms (collected in anonymized form where possible).
3. AI Service Provider & Data Processing
Important Notice About Gemini AI Processing
The AI-powered functionality of the App (including the generation of polite refusal responses) is provided by Gemini AI, a service of Google LLC. When you use the App's AI features:
- Your text input (e.g., details of the request you need to decline) and uploaded images (e.g., context for the refusal scenario) will be transmitted to Gemini AI for processing to generate tailored responses.
- Gemini AI's privacy practices are governed by its official Privacy Policy: https://ai.google.dev/gemini-api/docs/privacy.
- Gemini AI maintains strict privacy protections for user data and does not use your text or image data for model training under any circumstances.
We do not store the text or image data sent to Gemini AI on our servers beyond what is necessary to complete the AI response generation process (typically no longer than 24 hours).
4. How We Use Your Data
We use your collected data for the following legitimate purposes:
- To provide and operate the App's core functionality (e.g., generating AI-powered polite refusal responses).
- To improve the App's performance and user experience (e.g., optimizing AI response accuracy based on anonymized usage data).
- To communicate with you (e.g., responding to support inquiries or notifying you of important App updates).
- To ensure the security of the App (e.g., detecting and preventing fraudulent or unauthorized use).
- To comply with legal obligations under Hong Kong Law (e.g., responding to court orders or regulatory requests).
5. Data Sharing & Disclosure
We respect the confidentiality of your data and adhere to the following rules for data sharing:
- We will not share your personal data with third parties without your explicit consent, except as specified in this section.
- We may disclose your data if required to do so by Hong Kong Law, court order, or regulatory authority (e.g., responding to a lawful request from law enforcement).
- We may disclose your data to protect the security and integrity of the App, prevent fraud or harm to users, or defend our legal rights (in compliance with Hong Kong PDPO).
- Data shared with Gemini AI is only for the purpose of providing the App's AI functionality and is governed by Gemini AI's Privacy Policy (linked above).
We do not sell, rent, or trade your personal data to third parties for commercial purposes under any circumstances.
6. Data Security & Retention
We implement industry-standard security measures to protect your data from unauthorized access, loss, alteration, or disclosure, including:
- Encryption of data in transit (e.g., HTTPS) and at rest (for stored account data).
- Access controls to limit employee access to personal data (only authorized personnel may access data for legitimate business purposes).
- Regular security audits and updates to protect against emerging threats.
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by Hong Kong Law. Once data is no longer needed, it is securely deleted or anonymized.
7. Your Rights Under Hong Kong PDPO
Under the Hong Kong PDPO, you have the following rights regarding your personal data:
- Right to access: Request a copy of the personal data we hold about you.
- Right to correction: Request correction of inaccurate or incomplete personal data.
- Right to erasure: Request deletion of your personal data (subject to legal retention requirements).
- Right to withdraw consent: Withdraw your consent to data processing (may limit access to certain App features).
To exercise these rights, please contact us using the details provided in Section 8.
8. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy, your personal data, or our data processing practices (including data sent to Gemini AI), please contact our Data Protection Officer:
We will respond to your inquiry within 14 business days in accordance with Hong Kong PDPO requirements.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices or applicable laws (including Hong Kong PDPO and Gemini AI's privacy standards). Updated versions will be posted on the App's interface with a new effective date.
We will notify you of material changes to this Policy via email (if you have provided an email address) or prominent notice within the App, at least 7 days before the changes take effect.