Privacy Policy

Last updated May 6, 2026

This privacy notice for ECHO ELEPHANT TECHNOLOGY PTE. LTD. (“Company”, “We”, “Us”, or “Our”) describes how and why we might collect, store, use, and/or share and process your information when you use our services. Services such as when you:

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at eesg@huishengyunxiang.com.

SUMMARY OF KEY POINTS
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Echo Elephant. and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We may process sensitive personal information when necessary, with your consent or as otherwise permitted by applicable law.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Google Pay and Apple Pay. You may find their privacy notice link(s) here: https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB and https://www.apple.com/legal/privacy/data/en/apple-pay/.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, for the provision of AI interactive services and generative AI model development, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate—including personal information of a deceased individual provided by their next of kin, who warrants that they are authorized to submit such data and that the data is accurate. You must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To create a virtual personality. Creating a virtual personality is what Echo Elephant is all about. Information collected to create a virtual personality for a loved one may involve text conversations, audio call files, video call files. The original source files will no longer be retained and will be permanently deleted upon the termination or deletion of your account.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests

We process your personal information only to the extent permitted by and in compliance with U.S. privacy laws, which impose strict limits on the collection, use, sharing and cross-border transfer of personal information—especially voice biometric data. The specific legal bases we rely on under U.S. law are set forth below, and all processing activities are subject to the requirements of the applicable laws.

3.1 Express Written Consent (Primary Basis for Sensitive Data)

Our primary legal basis for collecting, using, sharing and transferring voice biometric data, portrait information, audio recordings, and other sensitive personal information is your unambiguous, express written consent—including valid electronic consent as required by the applicable laws. For deceased individuals, this consent must be provided by their authorized next of kin, who represents and warrants that they have the legal authority to provide such data. We reserve the right, at our sole discretion, to request additional documentation or proof of authority if deemed necessary to ensure compliance with legal or safety standards.

Your consent is voluntary, revocable at any time, and cannot be tied to the provision of basic Services (we will not deny you access to our core Services if you decline to provide consent for non-essential processing).

Consent is obtained only after full, clear disclosure of the purpose of processing, data retention periods, cross-border transfer to Singapore, and third-party sharing with Alibaba Cloud (Singapore) Private Limited—no hidden or blanket consent is used.

Revocation of your consent will result in the immediate suspension of processing of your sensitive data and permanent deletion of all voice biometric data (pursuant to BIPA’s data destruction requirements), with no discrimination against you for exercising this right (per CCPA’s anti-discrimination rules).

3.2 Performance of a Contract

We process non-sensitive personal information (e.g., your name, email address, account details) to fulfill our contractual obligations to you in providing the Echo Elephant Services—including account creation, service delivery, troubleshooting, and responding to your service requests. This processing is limited to the information necessary to perform the contract and is consistent with FTC Act requirements for transparency and data minimization.

3.3 Compliance with Legal Obligations

We process your personal information when we are required to do so under applicable U.S. federal/state law—including:

All legal processing is conducted in accordance with U.S. law, including limiting data disclosure to the minimum necessary for the legal request.

3.4 Protection of the Security of Our Services and Users

We process personal information to protect the security of our Services, prevent fraud, and safeguard our users—a permissible basis under U.S. federal and state law. This processing is limited to fraud monitoring, security testing, and responding to unauthorized access attempts, and does not include the processing of biometric data for this purpose without your explicit consent.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Cross-Border Data Transfer

We may transfer your personal information, including voice biometric data, from the United States to Alibaba Cloud (Singapore) Private Limited for the sole purpose of AI model training and inference. Transfer of a deceased individual’s voice biometric data is permitted only with the express written consent of the authorized next of kin, who is fully informed of the cross-border transfer destination and purpose.

We have entered into a Data Processing Agreement (DPA) with the Singapore-based provider that complies with applicable laws. All cross-border data transfers are conducted with end-to-end encryption, and no data is stored locally in Singapore during model inference.

We obtain your express written consent — or the next of kin’s express written consent for deceased individuals’ data — prior to any such cross-border data processing.

Technical Service Providers

We use Firebase Crashlytics to collect detailed logs and technical information upon application crashes. This data is used solely for troubleshooting and optimizing performance, and it is typically processed in an anonymized form.

We utilize Alibaba Cloud RUM to monitor real-time efficiency and response speeds. It collects anonymous performance data related to app interactions to help us continuously improve user experience.

We confirm that Alibaba Cloud (Singapore) Private Limited, as our third-party AI provider, provides the same or equal protection for your personal data as outlined in this policy and in accordance with applicable data protection laws.

5. HOW DO WE HANDLE YOUR THIRD-PARTY LOGINS ?

In Short: If you choose to register or log in to our services using a third-party account , such as Apple or Google, we will only access limited and necessary information to create your account.

Our Services offer you the ability to register and log in using your third-party account details (specifically your Apple or Google logins, collectively referred to as "Social Logins"). Where you choose to do this, we will only receive basic profile information about you from Apple or Google. This information is limited to your name, email address, and profile picture.

We will use the information we receive only for the purposes that are described in this privacy notice, such as account management and authentication. Please note that we do not control, how your third-party providers (Apple or Google) use your other personal information. We recommend that you review their privacy notice to understand how they manage your data.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

In the event of a personal data breach involving your sensitive information, we will notify the applicable regulatory authorities and affected users within 72 hours of discovery, in compliance with applicable laws.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In the United States, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In the United States, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) to withdraw your express consent for cross-border data transfer at any time, and (v) for California residents, to opt out of the sharing of your personal information. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by eesg@huishengyunxaing.com

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at eesg@huishengyunxiang.com.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

The personal information we collect includes information provided directly by you about yourself and, where applicable, about the individuals for whom you are creating 'Echo Elephant' AI agents. By providing such information, you represent that you have the legal authority to do so.

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, and account name

NO

B. Personal information categories listed in the California Customer Records statute

Contact information, education, employment, employment history, and financial information

NO

C. Protected classification characteristics under California or federal law

Gender and date of birth

YES

D. Commercial information

Transaction information, purchase history, financial details, and payment information

YES

E. Biometric information

Fingerprints and voice prints

NO

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

YES

G. Geolocation data

Device location

NO

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recordings created in connection with our business activities

YES

I. Professional or employment-related information

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

NO

J. Education Information

Student records and directory information

NO

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

NO

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” your personal information.

Echo Elephant has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Echo Elephant will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data. Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed. Request to know

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.


Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.

Verification Process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other Privacy Rights

To exercise these rights, you can contact us by email at eesg@huishengyunxiang.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

11. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at eesg@huishengyunxiang.com.

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us by email at eesg@huishengyunxiang.com.