YunGrace App Privacy Policy

Version: V20260224 Last Updated: February 24, 2026 Effective Date: February 24, 2026

Introduction

YunGrace (hereinafter referred to as "we", "us", or "our") recognizes the importance of Personal Information to you and will use commercially reasonable efforts to protect your Personal Information in a secure and reliable manner. We are committed to maintaining your trust and, in processing your Personal Information, adhere to the following principles: accountability and consistency of rights and obligations; purpose specification and limitation; informed consent and user choice; data minimization and necessity; security safeguards; participation and control by the data subject; and openness and transparency.

Accordingly, we have formulated this YunGrace App Privacy Policy (the "Policy") and undertake to adopt industry-recognized and mature security solutions and corresponding reasonable and appropriate security measures to protect your Personal Information. Before using our products or services, please read this Policy carefully and ensure that you fully understand its contents.

Scope of Application

This Policy applies to the services you use in connection with the YunGrace translation earbuds and their companion mobile application (the "YunGrace App") (collectively, the "Services").

Where any of our affiliated entities (including, without limitation, wholly-owned subsidiaries, controlled subsidiaries, joint ventures, and other entities having commercial affiliation with us) provides products and/or services that incorporate the Services and has not promulgated a separate privacy policy, the portions of such products and/or services involving the Services shall be governed by this Policy. Where an affiliated entity has issued an independent privacy policy applicable to its products and/or services, such independent privacy policy shall prevail to the extent of any inconsistency.

This Policy does not apply to products or services provided to you by other third parties acting independently. Prior to using any third-party services, you should carefully review the privacy policies and/or related terms of such third parties.

If you do not agree to any provision of this Policy, you must immediately cease using the Services. By accessing or continuing to use the Services, you acknowledge that you have read and fully understood this Policy and consent to our collection, use, storage, sharing, transfer, and other processing of your Personal Information in accordance with this Policy.

Policy Overview

This Policy is intended to provide you with a clear and comprehensive understanding of the following matters:

The categories of information we may collect;
How we use cookies, web beacons, and other similar tracking technologies;
How we store and retain information;
How we implement security measures to protect Personal Information;
How we use the Personal Information we collect;
How we share, transfer, or disclose your Personal Information to third parties;
How we process Personal Information relating to minors;
How you may access, manage, correct, delete, or otherwise exercise your rights with respect to your Personal Information;
How your Personal Information may be transferred across international borders;
Statements regarding third-party responsibility and limitations of liability;
How this Privacy Policy may be amended or updated;
Definitions and explanations of key terms used in this Privacy Policy; and
How you may contact us regarding privacy-related inquiries or requests.

I. Categories of Information We May Collect

We adhere to the principles of lawfulness, legitimacy, necessity, and proportionality, and collect only such information as is reasonably necessary to achieve the purposes of providing and improving the functionality of our products and services. The categories of information we may collect include, without limitation, the following:

1.1 Information You Provide Voluntarily

(1) Account and Identity Information (where an account system is used)

Where you register for or use an account, we may collect:

Mobile phone number and/or email address;
Login credentials;
Nickname and avatar (optional);
Country or region;
Native language or language preference (optional); and
Other information voluntarily provided by you in connection with account registration or profile completion.

If you choose to log in via a third-party account (such as Apple or Google), we may, within the scope of your authorization, obtain certain account identifiers and related information provided by such third party (typically including a unique user identifier, nickname, and/or avatar).

(2) Information Submitted Through Customer Support or Activities

When you contact us, submit a service request, participate in promotional activities, surveys, or questionnaires, we may collect:

Contact details;
Records of communications;
Descriptions of issues or inquiries;
Screenshots, diagnostic data, or log files voluntarily provided by you.

(3) Information Submitted Through Other Means

Where you provide supporting documentation for purposes such as account recovery, dispute resolution, or verification, such documentation may contain:

Name;
Contact information;
Order details;
Device-related information; or
Other relevant identifying information.

Such information shall be processed solely for the specific purpose for which it was provided.

1.2 Information Collected During Your Use of the Services

(1) Device and Application Information

We may automatically collect certain technical information, including but not limited to:

Device model;
Operating system version;
Application version;
Language settings;
Time zone;
Network type;
Device identifiers (such as IDFV; IDFA only where authorized by you and used in compliance with applicable laws);
Crash reports;
Performance and diagnostic information.

(2) Service Log Information

We may collect log and usage data generated during your interaction with the Services, including:

Access timestamps;
Feature usage records;
Page views and button interactions;
Error logs and error codes;
Request duration and system response times.

Such information is generally processed in a de-identified or aggregated form and does not, by itself, directly identify an individual. Where such information is combined with other data to identify a specific individual, it shall be treated as Personal Information and protected accordingly.

(3) Information Related to Translation Earbud Connectivity (Bluetooth / Audio)

In order to provide connectivity and device-related services, we may process:

Earbud device model;
Firmware version;
Connection status;
Pairing information (including Bluetooth identifiers, subject to operating system restrictions);
Audio routing status;
Battery level and device status information reported by the device.

Purpose: To enable device pairing, firmware updates, troubleshooting, and optimization of user experience.

(4) Voice and Translation Processing Data (Core Functional Scenario)

When you use real-time translation, speech recognition, or simultaneous interpretation features, we may process:

Voice audio input (your speech);
Voice commands;
Environmental audio characteristics (for purposes such as noise reduction and echo cancellation);
Speech recognition output text;
Translated text results;
Selected language preferences and pronunciation/accent parameters (if applicable).

Important Notice:

We endeavor to apply a "processing-on-demand" approach, whereby voice and textual data are processed solely for the purpose of providing the requested translation or speech recognition service.

The storage of voice or translation records depends on your settings:

If you enable the "Translation History" function, we will store the recognized and/or translated text in accordance with your settings, together with necessary metadata such as timestamps and language selections.
If you do not enable such functionality, we will not retain content data by default and will only retain necessary service logs and de-identified statistical data for security and system stability purposes.

If we intend to use voice or textual data for purposes such as model improvement or participation in a "Product Improvement Program," we will obtain your explicit and informed consent in advance and provide a clear opt-out mechanism.

(5) Location Information (Where Necessary)

Where you activate features requiring location capabilities—such as automatic local language detection, time zone adjustment, nearby device identification, or travel mode—we may, subject to your authorization, collect approximate or precise location information, depending on the functional requirements.

If you decline to grant location permissions, the core translation functionality will not be affected, except where a specific feature inherently depends on location data.

1.3 Information Obtained from Affiliates or Business Partners

Where you purchase, activate, or obtain devices through authorized partners, distributors, or affiliated entities, or participate in co-branded promotional activities, we may receive relevant information from such parties, including:

Order numbers;
Activation status;
After-sales or warranty status.

Such information shall be used solely for the purpose of providing customer support and ensuring proper service performance. We require such affiliates or partners to provide and process information in compliance with applicable laws and data protection requirements.

1.4 Circumstances Where Consent Is Not Required

In accordance with applicable laws and regulatory standards, we may process your Personal Information without obtaining your prior consent under the following circumstances:

Where directly related to national security or national defense security;
Where directly related to public security, public health, or significant public interests;
Where directly related to criminal investigation, prosecution, trial, or enforcement of judgments;
Where necessary to protect the life, health, or property of you or others and obtaining consent is impracticable;
Where the Personal Information has been voluntarily disclosed to the public by you;
Where the Personal Information is collected from lawfully and publicly disclosed sources (such as government publications or lawful news reports);
Where necessary for the conclusion or performance of a contract to which you are a party;
Where necessary for maintaining the safe and stable operation of the Services (such as fault detection or anti-fraud measures);
Where otherwise provided by applicable laws and regulations.

II. Use of Cookies, Web Beacons, and Similar Technologies

In order to ensure the proper functioning of our website and Services and to enhance user experience, we may use cookies, web beacons, entity tags (ET Tags), local storage, and other similar tracking or storage technologies to collect certain device and usage information.

Such technologies may be used for the following purposes:

Maintaining login sessions and authentication status;
Storing user preferences (including language and interface settings);
Implementing security controls and risk management measures;
Conducting statistical analysis and performance optimization;
Preventing fraudulent activities, abuse, and malicious attacks.

You may manage or disable cookies through your browser or device settings. Please note that disabling certain cookies or similar technologies may affect the availability or functionality of certain features of the Services.

III. Data Storage and Retention

3.1 Storage Location

As a general matter, we store information on servers or cloud infrastructure provided by Google Cloud Platform, and we process such information in compliance with applicable laws and regulations.

Depending on your location and operational requirements, data may be stored and processed in different geographic regions to improve service quality, operational efficiency, and regulatory compliance.

3.2 Retention Period

We retain your Personal Information only for the minimum period necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law.

Specifically:

Account Information: Generally retained until you delete your account or we cease providing the Services.
Translation Records: Retained in accordance with your account settings; you may delete such records at any time through the available functionality.

If the Services are terminated or cease operations, we will notify you through announcements, in-app notifications, or other reasonable means, and will, within a reasonable period, delete or anonymize your Personal Information, unless otherwise required by applicable laws and regulations.

IV. How We Protect Personal Information

4.1 Technical Safeguards

We implement industry-recognized and commercially reasonable technical security measures designed to protect Personal Information against unauthorized access, disclosure, alteration, destruction, or other unlawful processing. Such measures include, without limitation:

Encryption in Transit: Use of HTTPS and TLS protocols to protect data transmitted over public networks;
Encryption at Rest and Access Controls: Application of data encryption mechanisms, role-based access controls, least-privilege principles, and hierarchical authorization management;
Security Auditing and Monitoring: Maintenance of access logs, anomaly detection systems, and ongoing monitoring to identify and mitigate suspicious or unauthorized activities;
Data Minimization and De-identification: Use of de-identified, anonymized, or pseudonymized data for statistical analysis, diagnostics, and troubleshooting wherever practicable;
Secure Development Practices: Implementation of secure coding standards, code reviews, vulnerability remediation, and periodic penetration testing in accordance with established security protocols.

4.2 Organizational and Administrative Measures

In addition to technical safeguards, we adopt appropriate organizational measures, including:

Establishing internal policies for data classification, graded protection, and access approval procedures;
Implementing confidentiality obligations and access restrictions for employees and personnel with access to Personal Information;
Providing regular data protection and security awareness training to relevant personnel;
Entering into data protection agreements with business partners and service providers and monitoring their compliance with applicable data protection obligations.

4.3 Risk Acknowledgment

While we endeavor to protect Personal Information using commercially reasonable safeguards, you acknowledge that the internet is not an absolutely secure environment. You are responsible for safeguarding your account credentials, verification codes, and devices, and for avoiding sensitive operations on unsecured networks.

4.4 Security Incident Response

In the event of a Personal Information security incident, we will, in accordance with applicable laws and regulations:

Promptly notify affected users of the nature of the incident, its potential impact, and the categories of data involved;
Inform you of measures already taken or to be taken to mitigate risks;
Provide recommendations for risk prevention and remediation; and
Report the incident to relevant regulatory authorities where required by law.

V. How We Use Collected Personal Information

We may process the Personal Information we collect for the following purposes. If we intend to use your Personal Information for purposes beyond those specified below, we will obtain your consent where required by applicable law:

Provision and Performance of Core Functions: Enabling device connectivity, real-time translation, speech recognition, display of translation results, and storage of translation history (where enabled by you);
Account and Customer Support Services: Identity verification, account recovery, ticket handling, after-sales services, and customer assistance;
Product Development and Optimization: Performance analysis, fault diagnosis, service improvement, and feature enhancement, preferably using de-identified or aggregated data;
Security and Risk Control: Fraud prevention, abuse detection, system security management, and audit compliance;
Software Updates and Device Management: Firmware upgrades, compatibility management, and technical maintenance;
Optional Product Improvement Programs: Subject to your explicit and informed consent, collection of limited usage data for the purpose of improving models, features, or user experience, with a clear opt-out mechanism;
Service Notifications: Sending necessary communications regarding service updates, policy changes, security alerts, or other essential notices;
Compliance with Legal Obligations: Processing required by applicable laws, regulations, or governmental authorities.

VI. Sharing, Transfer, and Disclosure of Personal Information

6.1 Sharing

We do not sell your Personal Information to unrelated third parties.

We may share Personal Information only under the following circumstances and solely to the extent necessary:

Where we have obtained your explicit consent;
Where sharing is necessary for the provision of core functionality (for example, where cloud infrastructure or essential technical service providers are required to support the Services);
Where required by applicable laws, regulations, legal processes, or binding governmental requests;
Where necessary to protect the vital interests, lawful rights, or safety of you, us, other users, or the public;
With affiliated entities, provided that such sharing is limited to what is necessary and subject to data protection obligations consistent with this Policy.

6.2 Public Disclosure

We will publicly disclose your Personal Information only under the following circumstances:

With your explicit consent or at your direction;
Where disclosure is required by applicable laws, regulations, court orders, or administrative or judicial authorities;
Where necessary to protect the lawful rights, property, or safety of us, our users, or the public.

VII. Processing of Minors' Personal Information

We attach great importance to the protection of minors' Personal Information.

As a general rule, the Services are intended for individuals who are at least fourteen (14) years of age.
If you are a minor under the applicable age of majority in your jurisdiction, you should review this Policy together with your parent or legal guardian and use the Services only with the consent and supervision of such parent or legal guardian.
If we become aware that we have collected Personal Information from a minor without obtaining verifiable consent from the minor's parent or legal guardian where required by applicable law, we will take reasonable steps to promptly delete or anonymize such information in accordance with applicable legal requirements.

VIII. Your Rights and How You May Manage Your Personal Information

Subject to applicable laws and regulations, you may exercise the following rights through the functionalities provided within the App or by contacting us directly:

Right of Access and Rectification: To access, review, and correct your account information, language preferences, and other Personal Information maintained by us;
Right to Deletion: To delete translation history, clear cached data, or request deletion of account-related Personal Information within the limits permitted by law;
Right to Withdraw Consent: To withdraw previously granted consent by disabling system permissions (such as microphone, Bluetooth, or location access) through your device settings, or by disabling optional features such as participation in product improvement programs within the App. Withdrawal of consent does not affect the lawfulness of processing conducted prior to such withdrawal;
Right to Account Deletion: To request account deletion via the in-App function under "Settings - Account & Security - Delete Account". Upon account deletion, we will cease providing the Services and process or delete your Personal Information in accordance with applicable legal requirements;
Right to Obtain a Copy (where applicable): To request a copy of your Personal Information in a structured and commonly used format, to the extent technically feasible and legally required.

We will respond to your request within fifteen (15) business days or within such other timeframe as required by applicable law. For repetitive, manifestly unfounded, excessive, or technically impracticable requests, we reserve the right to charge a reasonable administrative fee or to decline the request in accordance with applicable laws.

IX. Cross-Border Transfers of Personal Information

Where it is necessary to transfer your Personal Information across national borders (for example, where we utilize overseas cloud service providers or where you access the Services from outside your country of residence), we will:

Conduct any required compliance assessments, filings, or approvals in accordance with applicable data protection laws;
Implement appropriate technical and organizational safeguards, including encryption, de-identification, and access control measures;
Where required by law, obtain your separate and explicit consent prior to such transfer; and
Ensure that the receiving entity provides a level of data protection that is not lower than that required under this Policy and applicable law.

X. Statement Regarding Third-Party Responsibility

Except as expressly provided in this Policy, we shall not be liable for the following circumstances:

Any unauthorized disclosure, loss, theft, or alteration of Personal Information resulting from your voluntary disclosure of account credentials or sharing of devices or accounts with others;
Any service disruption, data risk, or loss arising from force majeure events, including but not limited to cyberattacks, computer viruses, system failures, governmental actions, or other events beyond our reasonable control;
Any processing of Personal Information conducted independently by third parties through links or services accessed via the Services, for which such third parties bear sole and independent responsibility.

XI. Updates to This Privacy Policy

We may revise or update this Privacy Policy from time to time in response to changes in legal, regulatory, operational, or business requirements.

Without your explicit consent, we will not materially diminish the rights you are entitled to under this Policy.

Where material changes occur—such as changes to the purposes of processing, categories of Personal Information processed, categories of recipients with whom Personal Information is shared, methods by which you may exercise your rights, or the location of data storage—we will provide prominent notice through appropriate means, which may include in-app pop-up notifications, push notifications, direct messages, announcements, or other reasonable communication channels, in accordance with applicable law.

XII. Definitions

For purposes of this Policy, the following terms shall have the meanings set forth below:

Personal Information: Information recorded electronically or by other means that identifies or can identify a natural person, either independently or in combination with other information.
Sensitive Personal Information: Personal Information that, if disclosed, unlawfully provided, or misused, may endanger personal or property safety, or may easily lead to reputational harm, physical or psychological harm, or discriminatory treatment. Examples include biometric data, precise location data, and the content of communications.
De-identification / Anonymization: Technical processing of Personal Information to remove or obscure identifying elements so that a specific individual cannot be identified without additional information. Anonymization is typically irreversible.
Device Identifier: A unique identifier associated with a device, such as IDFV. IDFA is used only where authorized by the user and in compliance with applicable laws and platform policies.
Cookies / Web Beacons / ET Tags / Log Files: Technical mechanisms used to support service functionality, conduct statistical analysis, enhance performance, and improve user experience.

XIII. Additional Provisions for Users in the European Economic Area (EEA), United Kingdom, and Switzerland (GDPR Compliance)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the following additional provisions apply to you in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

13.1 Data Controller

For the purposes of GDPR, the data controller of your personal information is:

YunGrace AI Tech Email: YunGrace@yungrace.com Website: https://www.yungracetech.com/

13.2 Legal Basis for Processing

We process your personal data only when we have a lawful basis under Article 6 of the GDPR, including:

Performance of a Contract

Providing real-time translation services
Managing your account
Delivering core product features

Legitimate Interests

Improving service stability and performance
Preventing fraud and ensuring system security
Conducting internal analytics using de-identified data

Consent

Saving translation history
Processing location data
Participating in optional product improvement programs
Sending non-essential communications

You may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

Legal Obligation

When required by applicable laws or regulatory authorities

13.3 Your GDPR Rights

Under GDPR, you have the following rights:

Right of Access - Request access to your personal data
Right to Rectification - Correct inaccurate or incomplete data
Right to Erasure ("Right to be Forgotten") - Request deletion of your data
Right to Restriction of Processing - Limit how your data is used
Right to Data Portability - Receive your data in a structured, machine-readable format
Right to Object - Object to processing based on legitimate interests
Right Not to Be Subject to Automated Decision-Making - We do not engage in automated decision-making that produces legal or similarly significant effects

To exercise your rights, contact: YunGrace@yungrace.com

We will respond within one month, as required by GDPR.

13.4 International Data Transfers

Since we use Google Cloud Platform servers located in the United States (us-central region), your personal data may be transferred outside the EEA.

When transferring data internationally, we implement appropriate safeguards, including:

Standard Contractual Clauses (SCCs) where applicable
Technical safeguards such as encryption and access controls
Data minimization and anonymization measures

13.5 Data Retention (EEA Users)

We retain personal data only as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law.

You may request deletion of your data at any time.

13.6 Supervisory Authority

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with your local data protection supervisory authority in the EEA, UK, or Switzerland.

XIV. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your Personal Data, you may contact us at:

Company Name: YunGrace AI Tech Email: YunGrace@yungrace.com Website / Support Page: https://www.yungracetech.com/

We will respond to your inquiry within fifteen (15) business days or within such other timeframe as required by applicable law.