Privacy Policy

This Policy applies to all personal information collected, used, stored and disclosed by us, and the relevant operations, when you use Tola AI and its related services.

This Policy does not apply to the following scenarios: services provided by third parties through this App (e.g., third-party payment, social sharing functions) — their information processing rules are independently formulated by third parties, and we assume no corresponding liability; third-party websites or applications accessed by you through this App — their privacy policies are unrelated to this Policy, and we recommend that you carefully read the privacy policies of such third parties.

"Personal Information" refers to any information related to an identified or identifiable natural person, including but not limited to identity information, contact details, usage behavior information, and user content.

"User Content" refers to all digital content uploaded, shot, edited or generated by you in the course of using this App, including but not limited to pictures, videos, audio, text, etc. (including personalized videos generated through AI templates, i.e., "User-Generated Content/UGC").

"Free Basic Services" refers to basic services provided by this App that can be used without registration, including basic AI video templates, ordinary resolution video export, and basic editing functions.

"Paid Premium Services" refers to value-added services provided by this App that require registration and subscription for use, including exclusive AI video templates, watermark-free export, HD/4K resolution video generation, and commercial use rights.

"Third-Party Service Providers" refers to third-party entities that provide support for the realization of the App's functions, including but not limited to payment processors, cloud storage service providers, and data analysis tool providers.

To provide you with stable and high-quality services, we only collect the necessary information required to deliver the services, including the following:

3.1 Personal Identity Information — Information voluntarily provided by you: mobile phone number, email address and name submitted when registering for Paid Premium Services; basic information such as nickname and avatar shared by your authorization when logging in/paying through third-party social or payment platforms. Automatically collected information: device-related information such as the device IP address, device model, operating system type and version, device identifiers (e.g., IMEI, IDFA), and network type when you use this App.

3.2 Usage Behavior Information — Service usage records: your access time, frequency and duration of this App, template selection preferences, editing operation settings, export records, subscription type and validity period, etc. Source information: the name of the third-party website or application that directed you to download or access this App.

3.3 User Content Information — Original materials uploaded or shot by you: including but not limited to pictures, videos, audio, etc., used to generate personalized content through AI templates. Generated User Content: UGC content such as videos and pictures edited and synthesized by you through the App's templates.

3.4 Other Relevant Information — Communication records between you and us: such as inquiries, complaints, feedback sent through customer service channels, and our response content. Information required for compliance: necessary verification information related to your usage behavior that we may collect to comply with Singaporean laws or mitigate risks (e.g., age verification-related data).

Direct Collection: Information voluntarily provided or shared by your authorization when you register an account, subscribe to services, upload content, submit inquiries, or use third-party login/payment functions.

Automatic Collection: Device information and usage behavior data automatically recorded by the system through technical means when you use this App, with no additional action required from you.

Third-Party Collection: Necessary information obtained from legally compliant third-party service providers (e.g., payment platforms, social login platforms) with your authorization. Information processing by third-party service providers shall comply with their own privacy policies.

We only use the collected information within the following legal scope:

To provide and maintain services: generate personalized videos according to your operations, ensure the normal operation of the App's functions, and process transactions such as payments and subscription renewals.

Account management: verify your account identity, maintain account security, and send you important information such as subscription expiration reminders and service update notifications.

Customer support: respond to your inquiries, complaints or feedback, and resolve problems you encounter during use.

Product optimization: analyze user behavior trends based on de-identified and anonymized usage data, improve template design, optimize AI generation effects, and enhance App performance and user experience.

Compliance and security: comply with relevant Singaporean laws and regulations, prevent security risks such as fraud and cyberattacks, and protect the legitimate rights and interests of you, other users and the Company.

Other purposes with your explicit consent: such as content sharing authorized by you, notifications related to commercial cooperation, etc.

Important Note: We will not use your personal information or user content to train general AI models, nor will we use your original materials or generated content for unauthorized purposes such as authentication and advertising promotion.

We strictly protect your personal information and will not sell, rent or trade your personal information to third parties. We will only disclose or share your information in the following circumstances:

6.1 With Your Explicit Consent — Share relevant information with third parties designated by you with your active authorization (e.g., when you choose to share generated videos on social platforms).

6.2 Sharing with Third-Party Service Providers — To realize service functions, we may share necessary information with third-party service providers, and such sharing shall meet the following conditions: only share the minimum scope of information required to deliver specific services; sign a confidentiality agreement with third-party service providers, requiring them to strictly comply with Singaporean privacy-related laws and not use the shared information for other purposes. Relevant third parties include but are not limited to: payment processors (e.g., Stripe, Apple Pay, Google Pay) for processing subscription payment transactions; cloud storage service providers (e.g., Amazon Web Services) for the secure storage of your user content and account data; data analysis tool providers (e.g., Google Analytics) for analyzing App usage to optimize services (only anonymized data is obtained).

6.3 Based on Legal or Compliance Requirements — Respond to legitimate requests from Singaporean judicial and law enforcement authorities, or comply with legal documents such as court judgments and subpoenas; protect the legitimate rights and interests, privacy or safety of you, other users, the Company or the public, and prevent acts such as fraud and illegal crimes; fulfill our legal obligations or protect our legitimate commercial interests (e.g., responding to complaints, arbitration, litigation, etc.).

6.4 Information Sharing Related to Refunds — If you apply for a refund through third-party platforms such as the Apple App Store or Google Play, we may provide the platform with necessary anonymized usage data (e.g., subscription duration, content generation records, whether a free trial was used, etc.), solely to assist the platform in making refund decisions and in compliance with relevant privacy laws. You may apply to opt out of such data sharing through official channels.

7.1 Storage Methods and Locations — Your personal information and user content will be stored on third-party cloud servers authorized by us (e.g., Amazon Web Services), in locations including Singapore, the United States and other regions that meet data protection standards. We ensure the security and compliance of cross-border data transmission through legal measures such as Standard Contractual Clauses and encrypted transmission.

7.2 Retention Period — We only retain your information for the shortest period necessary to achieve the service purposes, as follows:

Account data: Retained for the duration of your active account; after you cancel your account, we will delete or de-identify your account information within 30 days (except where retention is required by law, e.g., payment records need to be retained for 7 years to comply with Singaporean financial compliance requirements).

User Content: Free Basic Service users — your original materials and generated content will be retained until the date you actively delete them or uninstall the App. Paid Premium Service users — your generated content will be retained for 90 days after the subscription expires, during which you may export it at any time; original materials will be immediately deleted from the server upon completion of content generation (except for those stored on your local device).

Usage behavior data: Retained for no more than 90 days, and will be automatically anonymized upon expiration, with no ability to link to specific users.

Communication records: Retained for no more than 2 years for subsequent inquiries or handling potential disputes.

When the information is no longer needed for retention, we will dispose of it through secure means (e.g., encrypted deletion, physical destruction) to ensure that the data cannot be recovered.

Pursuant to the Personal Data Protection Act (PDPA) of Singapore, you are entitled to the following data-related rights, and we will provide you with convenient channels to exercise such rights:

Right of Access: Request to view your personal information and usage records collected and stored by us.

Right of Rectification: Request to correct inaccurate or incomplete personal information.

Right of Erasure: Request to delete part or all of your personal information and user content (except where retention is required by law).

Right to Restrict Processing: Request to restrict our use of your personal information (e.g., suspend account data processing).

Right to Data Portability: Request to obtain the personal information you provided in a machine-readable format for transmission to other service providers.

Right to Withdraw Consent: Withdraw your consent to the collection or use of non-essential information at any time (without affecting the legality of information processing based on consent prior to withdrawal).

How to Exercise Your Rights: You may submit a request to exercise your rights through the customer service channel in this App or by sending an email to our official privacy email address. To protect the security of your account, we may require you to provide necessary identity verification information (e.g., registered mobile phone number, email verification code, etc.). We will respond to your request within 30 working days upon successful verification.

Note: A single user may submit a maximum of 2 requests for the right of access or the right to data portability within a 12-month period; if your request is repetitive, excessive or without reasonable basis, we may charge a reasonable fee or reject the request and explain the reasons to you.

We use Cookies and similar tracking technologies (e.g., web storage, pixel tags) to enhance the App usage experience and service quality, as follows:

Necessary Cookies: Used to ensure the operation of the App's basic functions (e.g., account login verification, session management). No consent from you is required, and disabling them may result in the inoperability of some functions.

Functional Cookies: Used to record your preference settings (e.g., frequently used templates, language selection) to enhance the personalized experience. You may independently choose whether to enable them.

Analytical Cookies: Used to count App usage (e.g., template usage rate, function access frequency), only obtaining anonymized data to help us optimize services. You may independently choose whether to enable them.

You may manage the usage permissions of Cookies (e.g., disable non-essential Cookies) through the settings in the App or the device system settings. If you choose to disable some Cookies, it may affect the usage effect of some personalized functions.

We adopt multi-level security protection measures to prevent your personal information from accidental loss, unauthorized access, use, modification or disclosure:

Technical Security Measures: Adopt technologies such as encrypted transmission (HTTPS), storage encryption and Virtual Private Network (VPN) to ensure the security of data during transmission and storage; conduct regular security tests on servers to prevent risks such as viruses and cyberattacks; establish a multi-data center backup mechanism to ensure rapid data recovery in case of loss.

Administrative Security Measures: Strictly restrict employees' access to personal information, and only authorize necessary personnel to obtain relevant information; all employees who have access to user information are required to sign a confidentiality agreement, and those who violate the agreement shall bear corresponding liabilities; conduct regular data protection training to improve employees' awareness of privacy protection.

User Responsibility Reminder: Your account password is an important credential for protecting account security. Please keep it properly and do not disclose it to any third party; if you find that your account has been stolen or used without authorization, please contact us immediately, and we will assist you in freezing the account, retrieving the password or taking other security measures.

Although we have adopted the above measures, the internet environment has inherent risks, and we cannot fully guarantee the absolute security of data transmission. In the event of data leakage caused by factors beyond our control such as force majeure, cyberattacks and third-party malicious acts, we will take remedial measures in a timely manner and notify you and the relevant regulatory authorities in accordance with Singaporean legal requirements.

This App is intended for users aged 13 and above.

Free Basic Services: Only provided to users aged 13 and above. We will not intentionally collect personal information from children under the age of 13.

Paid Premium Services and commercial use: Only provided to users aged 18 (the legal age of majority in Singapore) or entities with full capacity for civil conduct.

If we discover that we have inadvertently collected personal information from children under the age of 13, we will immediately delete the relevant data and terminate the provision of services to them. If you find that a minor is using this App in violation of the rules, please contact us through official channels, and we will handle it in a timely manner.

We may revise this Policy in accordance with legal provisions, service upgrades or operational needs. The revised Policy will be notified to you through the following methods:

Publishing an update announcement in a prominent position within this App; sending a change notice to your registered email address; displaying a policy change prompt when the App is launched.

The revised Policy shall take effect on the date of publication or notification. Your continued use of this App and its related services after the policy change constitutes your acceptance of the revised Policy; if you disagree, you shall immediately cease using this App and its related services. We recommend that you review this Policy regularly to learn about the latest privacy protection measures.

The formation, validity, interpretation, performance and dispute resolution of this Policy shall be governed by the laws of Singapore.

Any dispute arising out of or in connection with this Policy shall first be resolved by the parties through friendly negotiation; if negotiation fails, either party shall have the right to submit the dispute to the Singapore International Arbitration Centre (SIAC) for arbitration in accordance with its arbitration rules in force at the time of the arbitration.

The place of arbitration shall be Singapore, the arbitration tribunal shall consist of a sole arbitrator, the language of arbitration shall be English, and the arbitral award shall be final and binding on both parties.

If you have any questions, complaints or suggestions about this Policy, or need to exercise your data-related rights, please contact us through the following methods:

Company Name: TopView PTE. LTD. Official Privacy Email: privacy@topview.ai. Registered Address in Singapore: 20 Collyer Quay #20-03, Singapore 049319. Contact Information of the Data Protection Officer: privacy@topview.ai.

We will respond within 30 working days upon receiving your feedback and make every effort to resolve your issues.