LIMINA Privacy Policy

Version: V1.0-en Published, updated and effective: October 12, 2026 Controller: Shenzhen Xingyiyuan Technology Co., Ltd. (深圳星义元科技有限公司) Unified Social Credit Code: 91440300MAKATE3C6F

1. Scope and who we are

This policy explains how we handle personal information for the international English-language LIMINA app, website and related services. Shenzhen Xingyiyuan Technology Co., Ltd. is the English translation of our registered Chinese name, 深圳星义元科技有限公司, and identifies the same operator and data controller. Our registered and mailing address is Room 521B, 5th Floor, Building 8, Bagualing Industrial Zone, No. 18 Bagua 1st Road, Pengsheng Community, Yuanling Subdistrict, Futian District, Shenzhen, Guangdong, China. Contact us in English at hjy@limina.me for privacy questions and rights requests.

This is the operative international English privacy policy, not merely a translation of the mainland China policy. Regional mandatory rights apply where their legal conditions are met. Our Terms of Service explain the service contract. Accepting those Terms does not waive privacy rights or constitute every consent described here.

Our international service is for adults aged 18 or over. Our principal service infrastructure and storage are in mainland China. AI features may send necessary inputs and context to third-party providers. Publicly posted content can be seen and copied by others. Please consider these facts before submitting information.

2. Information, purposes and sources

We receive information you provide, information created by your use of the service, and information from authentication, payment and technical providers when you use those functions. Optional features and sign-in methods vary by build and region.

| Category | Information and source | Purpose | |---|---|---| | Account and authentication | Your email address or phone number, verification status, account ID, password credentials, login and session records; third-party account identifiers and authorized profile data where that sign-in method is offered | Account creation, authentication, recovery and security | | Profile and preferences | Nickname, avatar, cover image, biography and optional gender, region, language and time zone supplied by you | Profile display, localization and preferences | | Exploratory experiences | Answers, birth date and time, calendar and region you submit, and generated personality, BAZI or life-simulation results | Your requested entertainment and self-exploration features | | AI conversation and memory | Messages, prompts, attachments, relevant conversation context and profile information, feedback, replies, and memory summaries, embeddings and associated identifiers when memory is used | Responses, continuity, personalization, safety and troubleshooting | | AI creation and processing | Prompts, lyrics, parameters, selected reference files, recordings, scripts, storyboards, task identifiers, generated media and moderation records | Music, speech, image and video generation, adaptation, recognition, mixing, separation, storage and downloads | | MEMO and storage | Your diaries, photos, audio, files, titles, metadata, timestamps, storage references and synchronization records | Saving, syncing, playback, downloads and capacity accounting | | Community and communications | Published works, posts, selected prompt visibility, comments, follows, likes, favorites, shares, reports, private or group messages, attachments, participants and delivery records | Sharing, discovery, messaging and community safety | | Purchases | Products, amounts, currency, order and provider transaction identifiers, status, entitlements, refund and invoice information | Payment verification, delivery, accounting, refunds and support | | Device, usage and diagnostics | IP address, network status, device and operating-system information, app version, language, time zone, request times, interactions, errors and security logs | Connectivity, compatibility, service operation, abuse prevention, troubleshooting and updates | | Support and consent records | Contact details, request content, proportionate evidence, correspondence, agreement version, confirmation time and channel, and necessary client information | Requests, complaints, rights protection, dispute resolution and proof of choices |

We do not need your complete payment-card number or payment password to receive a payment result; your chosen billing provider handles its payment credentials. Do not send passwords or verification codes in support requests.

Birth details, diary entries, voices, faces and messages can be highly personal. Certain information may be legally sensitive depending on its content and purpose. An ordinary recording or photograph is not automatically biometric identification data. If a function uses voice or facial characteristics for biometric identification, the necessary specific notice and lawful permission must apply before that processing. Avoid submitting health, financial, government-ID or other sensitive data that a feature does not need, and obtain the necessary authority before providing someone else's information.

3. Permissions and device storage

Microphone access is requested for recording or supported voice functions when you choose to use them. File and photo selection reads the files you select through the system picker; some selected files begin uploading or preprocessing immediately after selection, while others are uploaded after a further action. Canceling selection does not upload a file. The current Android design uses selected-file access rather than scanning the entire media library. Notification and background playback capabilities support service notifications and music playback where available.

If carrier-assisted login is offered and selected, its authentication SDK may use phone-state, carrier, network and device information. You can choose another available login method. Denying an optional permission prevents the function that needs it, without disabling unrelated features. You may change system permissions in device settings.

The app or website stores necessary session information, drafts, preferences, recovery state, playback queues and caches on your device. Signing out or clearing local data can remove local state, but does not itself delete server data or cancel subscriptions. We do not use advertising identifiers for cross-app advertising tracking. Any future non-essential analytics or advertising use requires appropriate notice and choice before activation.

4. Legal grounds and choices

Where a law requires a legal basis, we identify it for the relevant purpose. Under applicable European or UK data-protection rules, necessary account operation, requested AI processing, storage, messaging and purchased services rely on performance of the service contract; mandatory accounting, valid legal orders and required compliance records rely on legal obligations. Proportionate security, fraud prevention, service reliability and handling claims may rely on legitimate interests after balancing your rights. Optional permissions and processing for which consent is required rely on consent. These grounds are not interchangeable permission to collect unnecessary information; sensitive data needs an additional legally valid condition where required. Where mainland Chinese law applies, we use the grounds permitted by that law, not an imported general legitimate-interests ground.

You can decline optional data collection and withdraw consent through relevant settings, operating-system permissions or hjy@limina.me. Withdrawal does not affect earlier lawful processing or processing that must continue on another valid basis. A feature cannot complete a task without data essential to that task, but unrelated features are not conditional on unnecessary consent.

5. AI processing and training

AI processing is not limited to your device. Depending on the selected function, necessary prompts, text, conversation context, relevant profile information, selected media, parameters and generated results are processed on our systems and by external model or media-processing providers. Do not assume that a private input remains solely on your device. Section 6 identifies currently disclosed providers and data categories. Private messages and group chats are not end-to-end encrypted services.

Acceptance of this policy alone is not explicit permission for a new third-party AI disclosure. Where personal data is shared with third-party AI, the feature must clearly explain the recipient, necessary data and purpose and obtain the required explicit permission before sharing. You may decline that processing. A permission to run a task is not permission to use it for unrelated advertising or general-purpose training.

This policy does not authorize LIMINA to use private diaries, private messages, unpublished inputs or outputs, voices or likenesses for general-purpose model training, independent advertisements or brand case studies. Any such additional use requires separate disclosure and an appropriate lawful basis, including consent where required. External providers may have different processing terms; we do not promise identical retention periods or zero provider retention. We are responsible for assessing and controlling processing we engage providers to perform and for supplying additional notices when processing changes.

6. Recipients and disclosures

We use providers for infrastructure, storage, authentication, payment, AI processing and service delivery. They receive the data needed for their function. A payment provider or other independent service may have its own legal obligations and privacy policy; a provider's notice does not remove our obligations. The following reflects disclosed integrations; availability depends on the feature, platform and region. A domestically integrated SDK is not a claim that it is included or used in every international build.

| Provider | Purpose and information | Privacy information | |---|---|---| | Alibaba Cloud / 阿里云计算有限公司 | Object storage and content delivery: uploaded/generated files, object references, IP addresses and access records | Alibaba Cloud privacy policy | | MiniMax / 上海稀宇科技有限公司 | Supported AI creation: prompts, lyrics, selected reference media, parameters, task identifiers and outputs | MiniMax platform policy; contact@minimaxi.com | | MUREKA / 昆仑万维科技股份有限公司 | Supported music generation, recognition, analysis and related processing: prompts, lyrics, titles, selected audio, task identifiers and outputs | MUREKA platform policy | | DeepSeek / 杭州深度求索人工智能基础技术研究有限公司 | Supported text and conversation processing: questions, prompts, necessary context, retrieved text, parameters and replies | DeepSeek policy; privacy@deepseek.com | | Alibaba phone authentication / 阿里巴巴云计算（北京）有限公司; Unicom authentication / 联通在线信息科技有限公司 | Selected carrier login: masked or actual phone number, authentication tokens, SIM/carrier, IP, network, device and app information | Alibaba authentication policy; Unicom policy | | Umeng / 友盟同欣（北京）科技有限公司 | Support component of carrier authentication: device identifiers, model/system/app information, network and SDK diagnostics; not used by LIMINA for cross-app advertising | Umeng policy | | WeChat OpenSDK / 深圳市腾讯计算机系统有限公司 | User-selected sharing of public cards: title, description, thumbnail and public URL, app/client and necessary network information; domestic payment integration where offered | WeChat SDK policy | | Alipay / 支付宝(杭州)信息技术有限公司; WeChat Pay / 财付通支付科技有限公司 | Domestic payment methods where offered: order, product, amount, currency, transaction status and necessary app/network/security data | Alipay SDK policy; WeChat Pay notices shown by its payment client | | Apple or Google, when their authentication or store billing is used | Authorized account data for offered sign-in; store purchase identifiers, receipts or tokens, product and transaction status for purchases | Apple privacy policy; Google privacy policy |

Some provider notices are in Chinese. Contact hjy@limina.me for information about the recipients and processing involved in your request. If a feature uses another recipient or materially different processing, additional disclosure and any required permission must precede that processing; this list is not blanket authorization for undisclosed recipients.

Public posts, works and profile details you choose to publish can be accessed by other users and the public. Recipients of messages can retain their own copies. We may disclose necessary information for valid legal demands, protection against unlawful activity or a lawful business transfer, subject to applicable safeguards and notice duties. We do not sell personal information or share it for cross-context behavioral advertising. Service-provider processing is described above; it is not concealed by this statement.

7. International processing

LIMINA is operated from mainland China, and its principal service databases and file storage are located there. If you use LIMINA from another country, information you submit is transmitted to and processed in mainland China. Provider processing may involve additional locations depending on the actual service. Laws and government-access rules may differ from those in your country. We do not represent that China has an EU or UK adequacy decision.

Where applicable law requires a transfer mechanism or additional safeguards, they must be in place before the regulated transfer occurs. Simply accepting these Terms or this policy is not a substitute for that mechanism, a transfer assessment, or a valid separate consent where needed. We do not claim that a particular standard contractual clause, UK transfer instrument or representative appointment has already been completed for every country or provider. Ask hjy@limina.me about the locations, applicable mechanism and available safeguards for a specific processing activity. We must restrict processing where required safeguards cannot be provided.

8. Retention and account deletion

We retain information only for the relevant service, security and legal purposes. Retention depends on the type of record, your choices and legal obligations, rather than one fixed period for every category. Account and saved content are generally kept while needed for your account and requested storage, subject to deletion requests. Temporary results follow the period shown in the feature. When you request account deletion, the only continuing retention exception is for records that applicable law requires us to retain. We must identify their categories, legal grounds and retention period or the criteria determining it, restrict access to the required purpose and delete them when that requirement ends. General business convenience, a distribution license or merely possible future disputes is not a basis to keep account-associated content after deletion.

You can start account deletion in Settings > Account and Security > Delete Account. We must explain the effects, verify the request where necessary, and carry out the required cleanup of account data, connected conversation and memory services and stored objects. Necessary checks and cleanup may be performed in stages, with manual assistance or coordination with processors and distribution partners. We must explain the expected completion time, any delay and the result. A pending cleanup, disabled account or removal of account identifiers must not be treated as completion of all deletion duties. This policy sets out our obligations; it does not promise that every step is automatic or that every copy disappears instantly. Contact us if you cannot complete the in-app process or need help with a pending request.

When completing account deletion, we must delete account-associated data, including previously public works and posts, comments, messages and other user content, except records that must be kept by law. On an account-deletion request we must stop new distribution of the associated content; the public-work license does not justify continued retention or distribution. Deleting a work, making it private or requesting that distribution stop also ends permission to continue publicly distributing that work. Making content private without requesting deletion may leave it in private storage at your choice. Removing account identifiers alone is insufficient: names, faces, voices or text may still identify you. You may request additional removal or other rights action at hjy@limina.me; this does not shift our responsibility to finish an accepted deletion request to you. We must explain any lawful exception, refusal and available remedy.

You may also request deletion of your LIMINA account or particular personal data without access to the app by emailing hjy@limina.me with the subject "LIMINA account deletion" or "LIMINA data deletion", your account email or phone number, and the scope of your request. We will use proportionate identity verification; do not send your password, verification codes or a full identity document unless a lawful and necessary verification process specifically requires additional evidence. We explain any legally justified retained categories and processing period when handling the request. This email route does not require a new account.

Where backup deletion is temporarily technically unavailable, copies must be isolated, restricted to necessary storage and security and cleared within the necessary backup rotation cycle, subject only to legally required preservation. They must not remain available for service use or distribution. We must instruct processors and necessary distribution partners to stop the relevant use and complete their required cleanup. Copies independently kept by recipients or third-party publishers may require a request to those parties; we assist where legally required. Those independent copies are not a reason to retain our own or our processors' copies. You can request further details about a particular retention category from us. Uninstalling LIMINA is not an account-deletion request; deleting a LIMINA account does not itself cancel Apple or Google subscriptions.

9. Your privacy rights

Depending on applicable law, you may request access and a copy, correction, deletion, restriction, portability, withdrawal of consent, objection to legitimate-interest processing, and information about recipients and safeguards. You may use available profile, content and permission controls or contact hjy@limina.me. Optional features are not a condition for exercising rights. We may request proportionate verification to protect your account, and may refuse only where law permits, explaining the reason and how to contest it. We do not unlawfully discriminate against you for exercising rights.

Where EU/EEA or UK law applies, you may object to processing based on legitimate interests and complain to your competent data-protection authority, particularly where you live, work or believe an infringement occurred. We normally respond within one month; a lawful extension requires notice within that period and an explanation. Consent may be withdrawn at any time without affecting the lawfulness of prior consent-based processing.

Where California or other applicable US state law grants rights, these can include access to categories and specific personal information, correction, deletion, portability, opting out of sale, sharing or targeted advertising, and limiting certain sensitive-data uses. We do not currently sell personal information or share it for cross-context behavioral advertising, and do not use sensitive information for unrelated advertising. You may use an authorized agent where permitted, subject to verification. If applicable law gives an appeal right, email hjy@limina.me with the subject "Privacy appeal"; we will review the decision and explain further remedies, including a regulator complaint where available. Applicable statutory response periods, including a generally applicable 45-day initial period for covered California requests, govern.

Elsewhere, local access, correction, deletion, consent and complaint rights apply as required. Our usual support target is 15 working days, without extending any shorter legal deadline. Where an extension is lawful and necessary, we explain the reason and timing. Reasonable requests are normally free; any permitted fee or refusal must meet applicable law.

10. Recommendations and automated processing

AI generates responses and creative media, and service features may sort or recommend content using follows, interactions, tags, language or region. You can reduce personalization through available settings and interactions or request assistance. Our exploratory and conversational features are not intended to make solely automated decisions with legal or similarly significant effects, such as employment, credit, medical diagnosis or insurance decisions. Where applicable law grants a right to human review or to contest such a decision, contact us to exercise it.

11. Security and children

We use measures such as access controls, encrypted transmission, limited permissions, logging and incident handling to protect information. No system is completely secure. Keep independent copies of important content and protect your credentials. We will assess incidents and notify affected people and authorities where required; this statement does not limit our security obligations.

The international service is not directed to people under 18. If we learn that a person below the applicable age threshold has supplied personal information in breach of this restriction, we will investigate, restrict the account as appropriate and delete or otherwise lawfully handle the information. A parent, guardian or affected person can contact hjy@limina.me. We do not rely on parental permission to open international accounts for minors.

12. Changes and contact

We identify policy versions and effective dates. Material changes require appropriate notice, and processing that needs fresh permission must not rely solely on continued use. This English policy governs the international English service; mandatory regional protections and any required local-language notices remain unaffected.

Contact our privacy team at hjy@limina.me, or write to the controller at the address in section 1. Current English policy: https://limina.me/legal/privacy-en. You can read this policy without signing in. For deletion requests, see section 8; for complaints and other rights, see section 9.