Privacy Policy

Effective as of April 21, 2025

Last updated: April 21, 2025

Version No.: [1.0]

 

Seedpace operates as a provider of children’s audio player and related services, enabling children to safely explore and enjoy hundreds of audio titles suitable for various ages and developmental stages.

This Privacy Policy describes how [Guangzhou Xibeisi Intelligent Technology Co., Ltd] (the operator of our mobile application “Seedpace” for iOS and Android (the “App”), and our audio players devices Seedpace Players) (collectively referred to as “Seedpace”, “we,” “us,” or “our”) collect, use, disclose, transfer, and store your and your children’s “Personal Data” when you or your children access or use our services via our App and devices, or otherwise interact with us (collectively, the “Services”). Additionally, this Privacy Policy explains your choices regarding our processing of your Personal Data.

At Seedpace, we recognize the importance of and are committed to safeguarding the privacy and security of the Personal Data we obtain from consumers and their children, and , and other individuals we interact with as a business including our partners and affiliates. We adhere strictly to applicable data protection regulations, including but not limited to the Children's Online Privacy Protection Act (COPPA) and the California Consumer Privacy Act (CCPA), as described in this Privacy Policy. 

Please read this Privacy Policy carefully and thoroughly, along with our Terms of Use to ensure you fully understand our practices and can make informed decisions regarding your and your children's Personal Data before using our Services. Your access to and use of the Services is governed by these documents. If you have any questions or wish to exercise your data protection rights, please contact us via email as detailed in Section 11 (Contact Details).

Our Services may include links to third-party websites. Please note that Seedpace is not responsible for the privacy policies or practices of these external websites.

The Privacy Policy only applies to the Personal Data we collect. 

 

Children Under 13

We take children's privacy seriously. At Seedpace, protecting children's privacy is of utmost importance to us. The Seedpace Player is specifically designed to provide children with a safe and engaging experience while listening to audio content. We have intentionally minimized the collection of Personal Data from children under the age of 13 and ensure that you, as the parent or guardian, maintain control over any such information.

Account creation and management on the Seedpace App are strictly limited to parents (you or your spouse). If we become aware that a child under the age of 13 has created an account on the Seedpace platform, we will promptly deactivate and close this account.

For detailed information about how we collect, use, and protect children’s Personal Data, please refer to Section 3 (Children's Privacy) of this Privacy Policy. By default, we do not collect any Personal Data from children under 13 without explicit parental consent.

 

The Privacy Policy will help you understand the followings:

Index

1. Definitions

2. Collecting and Using Your Personal Data

3. Children’s Privacy

4. How We Use Tracking Technologies

5. How and When We Share Your Personal Data

6. How We Store Your Personal Data

7. Your Rights and Choices

8. Security

9. Other Sites and Services

10. How We Make Changes to This Policy

11. Contact Details

Annex I. Supplemental Terms and Conditions for California Residents

Annex II. Supplemental Terms and Conditions for Residents in Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire and New Jersey

 

1. Definitions

“Collect” refers to the behaviour of gaining control over Personal Data, including voluntary provision by the data subject, automatic collection by interaction with the data subject or recording the behaviour of the data subject, and indirect acquisition by sharing, transferring and collecting public information.

“Controller” refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Children” is a term defined differently under various jurisdictions. For the purpose of this Privacy Policy, example, it refers to an individual under the age of 13 under the COPPA in the United States.

“Delete” refers to the behaviour of removing Personal Data from the system involved in the implementation of daily business functions, so that it cannot be retrieved and accessed.

“Parent” refers to the child's parent or legal guardian.

“Personal Data” refers to any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” refers to any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Sell” refers to the act of selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating Personal Data to another business or third party for monetary or other valuable consideration.

“Share” refers to the process of Personal Data controller providing Personal Data to other controllers, and both sides have independent control over Personal Data.

“Transfer” refers to the process of transferring Personal Data control from one controller to another.

“You” or “your” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.

 

2. Collecting and Using Your Personal Data

Seedpace collects Personal Data to ensure efficient operation, enhance user experience, and deliver high-quality products and services. We collect your Personal Data through various channels when you interact with our Services, including:

 Our App: Parents may use the Seedpace App to create and manage their accounts, set up and control Seedpace Players and audio content, create personalized profiles for their children, and monitor their children's usage of the devices; and

 Our Devices (Seedpace Players): Our Seedpace Players are designed to work seamlessly with Seedpace audio crafts, providing children with an engaging, interactive, and enjoyable storytelling experience.

When you use the Seedpace Player or the Seedpace App, we collect certain device data or usage data (as described below) to enhance your experience, improve our products and services, and provide effective troubleshooting support (including diagnosing and informing you about any issues with the App or your Seedpace Player).

The device data and usage data collected may include device identifiers (such as unique device IDs) and can be linked to user account IDs. Depending on the purpose of our subsequent processing, this information may or may not be directly associated with you or your child (i) when the purpose is to provide personalized recommendations, analyze user behavior, or troubleshoot issues, we need to associate such data with your account or device to deliver tailored services and support; (ii) when the purpose is to conduct macro-level data analysis (e.g., researching on what type of stories are most popular for children of certain age), the usage data is anonymized and aggregated into analytics data. This anonymized data does not include any Personal Data and cannot be traced back to you or your child.

2.1. Data Collection When Using Our Seedpace App

a. Creating Your Seedpace Account

To access our App and connect a Seedpace Player to the App, you need to create a Seedpace account. Please use the same email address for your Seedpace account on both the App and our online shop, enabling us to associate your purchases directly with your account.

• Information Required:  Provide a valid email address or phone number and create a secure password. Upon registration, you will receive an email prompting you to verify your account. You can optionally upload a profile photograph or picture, and set your user preferences.

• Parental Gate Verification: During account creation, you must complete our “Parental Gate” by providing your date of birth. This helps us ensure compliance with child protection laws. If we become aware or are informed that a child under 18 has improperly created a Seedpace account, we will promptly cancel the account and remove the child's Personal Data from our systems.

Creating a Seedpace account is required for using and configuring your Seedpace Player, including connecting it to a new Wi-Fi network or via Bluetooth. When your Seedpace Player successfully establishes a connection with the App, it transmits its unique device certificate ID (used for authentication) and your IP address.

If you choose to close or cancel your Seedpace account, all associated content in your audio library and uploaded files will be deleted (if immediate deletion is not possible, the data will be securely stored and isolated from further processing until deletion is feasible). Please note that transferring this information to another user before account cancellation is not possible.

After cancellation of your Seedpace account, your formerly linked Seedpace Player may still retain cached audio content that has been previously played. However, the cached content typically does not include any Personal Data.

b. Creating Your Child's Profile

When setting up your account, you may choose to provide your child’s information to create a personalized profile. This can include your child's name, age, gender, and your educational goals or preferences for your child.

When you place Imagine crafts on your Seedpace Player, we utilize AI-driven technology to generate personalized “Magic Stories”, which are tailored specifically to your child's profile information. This ensures your child becomes the main character, enjoying a unique and immersive storytelling experience.

Providing your child’s actual Personal Data (such as their real name, age, and other details) is entirely optional. However, please note that if you choose not to provide your child’s information, Magic Stories cannot be generated as this information is essential for creating a personalized storytelling experience; additionally, choosing not to provide accurate information may affect the accuracy and personalization of Magic Stories, as well as other age-appropriate content recommendations provided by our Services.

c. Audio Recording, Uploading, and Linking to "Make Your Own" crafts

Our App allows you to record stories or other audio content. When you create and upload audio content through the App, you can link it to a “Make Your Own” (MYO) craft on your Seedpace Player. Additionally, you can name your playlists and set custom cover images.

If you use the App to record or upload your own audio content, or allow your child to record audio content for playback on your Seedpace Player, you need to place consent to Seedpace collecting and storing any Personal Data that may be contained within these audio recordings on our online servers as part of your playlist. This includes the audio recordings themselves and any information shared verbally by you or your child within the recordings. Seedpace does not directly collect Personal Data from children during such process; therefore, any Personal Data we hold concerning your child is provided exclusively by you.

Please note that Seedpace has no control over the Personal Data your child may include in audio recordings. We do not access, listen to, or share these playlists or audio recordings with third parties. It is entirely your decision whether your child records or uploads audio content via the App and with whom such content is shared. You retain full control, including the ability to delete these playlists at any time.

We strongly encourage you to carefully review the contents of any audio recordings created or uploaded by you or your child, as well as to monitor who has access to these recordings. By submitting audio content through our App, you acknowledge and consent to the practices described above.

d. Notifications, Newsletters, Marketing Emails, and Promotional Activities

We may occasionally send you push notifications, including alerts, sounds via the App, or banner notifications on our platforms. To receive these notifications, you must explicitly confirm the request from your App or browser settings.

We reserve the right to periodically inform customers who have created a Seedpace account about special offers and promotions via email or other electronic means, provided they have not opted out. You may withdraw your consent at any time by clicking the unsubscribe link included in every marketing message we send or by contacting us directly at support@seedpace.com.

To subscribe to our newsletter via email, we require your email address. You may also voluntarily provide additional details, such as your first and last name, preferred form of address, and the month and year of birth of one or more children you entertain. Providing this optional information helps us deliver tailored offers suitable for the specific age group you entertain, thereby enriching your user profile.

e. Customer Comments and Feedback

You can submit your comments, feedback, or enquiries through the feedback interface within the App or by contacting us via email. When you send us an enquiry, the details you voluntarily provide—including your contact information, Seedpace account details, name, email address, your communication with our customer support services —will be securely stored by us. We retain this information solely for the purpose of addressing your enquiry and handling any follow-up questions until the matter has been fully resolved. We will not share your personal data with any third parties without your explicit consent.

f. Technical Information When You Use and Interact with Our Services

When you access and interact with our App and related services, we automatically collect certain technical information necessary to provide, maintain, and improve our services, as well as to ensure their proper functionality and security. This technical data may include:

• Device Information: We collect details about the device you use to access our App, such as device type, operating system and version, unique device identifiers, network service provider, device settings, and the specific version of the App installed on your device. This information helps us optimize your experience and troubleshoot potential technical issues.

• Log Data: Our App automatically records log data each time you access or interact with our services. This includes your Internet Protocol (IP) address, date and time stamps of your interactions, and usage activity within the App. We use this log data to monitor service performance, analyze usage patterns, and improve overall reliability.

• Usage Data: To better understand how you engage with our App, we collect information about your interactions, including the duration of your App usage sessions, playback details (such as which audio content you played, when it was played, and how frequently it was accessed), and other usage metrics. This information helps us enhance our content offerings and personalize your user experience.

• Diagnostic and Error Logs: We collect and monitor diagnostic logs, error reports, and associated usage data to identify, diagnose, and resolve technical issues or bugs within our App. This information is retained only for a reasonable period necessary to effectively address and prevent future technical issues.

All technical information collected is used solely to ensure the optimal functionality, security, and continuous improvement of the Seedpace App and associated services. This data is handled securely and is not shared with third parties without your explicit consent.

2.2. Data Collection When Using Our Seedpace Player

Specifically, we collect the following categories of information when you or your child use our Seedpace Player:

• Connectivity Information: We collect information regarding the Wi-Fi connection status of your Player, including whether it is connected to a Wi-Fi network, the network's name, and signal strength. This information allows you to easily view your Player’s connectivity status within the App and helps us troubleshoot connection issues.

When you use your Seedpace Player, certain events will trigger attempts to establish a connection with the Seedpace App. These events may include initial setup, powering on the device, placing a Seedpace audio craft on the Player that has not been previously recognized, and starting a search for new content. Upon successfully connecting with the App, the Seedpace Player transmits its unique client certificate ID (used for authentication) and your IP address to the App. Additionally, during setup or when adding a new Wi-Fi network, information about available networks and the connected network (SSID) is also transmitted.

The data collected during these processes is primarily used to improve our services and products, ensuring a seamless user experience. To protect your privacy, the transferred data is anonymized and stored securely in server log files. This anonymized data is analyzed exclusively for legitimate business purposes, such as optimizing connectivity performance and troubleshooting technical issues, without being linked directly to you or your child.

• Device Usage Information: We collect technical usage data related to the operation of your Seedpace Player, including:

- Power on/off status

- Button brightness settings

- Volume adjustments

- Device storage and cache management

- Available memory (RAM) and storage capacity (including SD craft usage)

This data helps us monitor device performance, diagnose technical issues, and continually improve the Player's functionality.

• Audio Content Usage: When audio crafts are placed on the Seedpace Player, we collect information about the audio content played, including which content is assigned to your Player at a given time, when it was played, and the frequency of playback. We also monitor system performance metrics, such as remaining memory, to optimize your experience.

• Imagine crafts: If your child uses Imagine crafts, we collect the following information to generate personalized Magic Stories for your children:

- Story elements selected by your child

- Your child's name (used as the main character in the story)

- Educational goals set by you (used as story themes)

We also maintain a history of generated Magic Stories accessible in the App, limited to stories listened to within the past three (3) months.

• Interactive crafts: If your child engages with Interactive crafts, we collect data regarding your child's interactions with the Seedpace Player such as selection interactions.

• Error Logs and Diagnostics Information: We collect and monitor error logs and associated usage data to help us identify, diagnose, and resolve technical issues or bugs related to your Seedpace Player. We retain this data only for a reasonable period necessary to effectively address and prevent future technical issues. If we detect a potential issue with your Player based on these error logs and usage data, we may inform you via appropriate communication channels, such as email, notifications within the Seedpace App (using the contact details you previously provided), or directly through audio messages on the Player itself.

To the extent that the data involved in this processing constitutes Personal Data, our lawful basis for processing is our legitimate interest in protecting the health, safety, and optimal experience of our users.

2.3. Information We Receive from Third Parties

In addition to the data you provide directly to Seedpace or we automatically collect during your interactions with our Services, we may also receive information about you and your activity from third-party sources, including our affiliates, partners, advertisers, and other service providers we work with. This information helps us enhance our services, improve user experiences, and ensure compliance with applicable laws. Examples of such third-party information include:

• Third-Party Platforms: If you register for or log into our services using a third-party platform (e.g., Google Sign-In or Apple ID), these platforms may share certain information with us to facilitate your account creation or login. This may include details like your name, email address, and profile picture, depending on the permissions you grant to the third-party platform.

• Technical Service Providers: We may receive technical information from service providers that support the functionality of our services. For instance, country-level location data derived from your IP address or app usage statistics provided in compliance with privacy regulations.

• Marketing and Analytics Partners: Our marketing and analytics partners may provide us with statistical data to help us measure and improve the performance of our advertising campaigns. This may include compliance-mode analytics, such as anonymized app usage statistics, or aggregated data about user engagement with our ads.

All third-party data we receive is handled in line with our commitment to protecting your privacy and is used solely for legitimate business purposes, such as enhancing your experience, improving our services, or ensuring compliance with applicable laws.

2.4. How We Use Your Information for Compliance and Protection

We may also process your Personal Data to ensure the safety and functionality of our Services at Seedpace, protect interests of our customers and the Company, and comply with legal and regulatory requirements. Specifically, we may use your personal information for the following purposes:

• Monitoring Device and Account Usage: We may review activity related to your account, including interactions with shared devices and audio content, to detect any unauthorized or harmful behavior that could impact the safety or functionality of our Services.

• Investigating Suspicious Activity: By analyzing log data and device information, we aim to identify and investigate behavior that may violate our policies, terms of service, or other agreements, such as unauthorized account access or misuse of shared features.

• Legal Compliance: We process your information to comply with applicable laws, respond to lawful requests, and fulfill legal obligations. This may include responding to subpoenas, investigations, or requests from government authorities.

• Legal Proceedings: Your information may be accessed or used in relation to legal claims, litigation, or regulatory proceedings, as necessary to protect our rights or to comply with judicial or administrative processes.

• Safeguarding Rights and Property: We may process your information to protect our own rights, privacy, safety, or property, as well as those of our users or others. For example, we may take action to address unauthorized access to shared accounts or devices.

• Internal Audits: To ensure compliance with applicable laws, contractual obligations, and our internal policies, we may audit our internal processes and systems.

• Enforcing Terms and Policies: Your information may be used to enforce the terms, conditions, and policies that govern the use of our Seedpace Services.

• Preventing Fraud and Harm: We are committed to preventing, identifying, and addressing fraudulent, harmful, unauthorized, or illegal activities. This includes efforts to combat identity theft, unauthorized use of shared devices, or attempts to compromise the security of Seedpace.

 

3. Children’s Privacy

We take children’s privacy seriously. While our Services are designed to be enjoyed by users of all ages, we prioritize safeguarding children’s personal information. 

For our App and Story Players, we only collect personal information from adult users and do not knowingly collect personal information directly from children under 13 (or the minimum age required under applicable law).

Parents are encouraged to supervise their children’s use of our Services at all times.

3.1. Core Privacy Protection for Children's Information

To safeguard children’s privacy, we have implemented strict measures as follows:

• Parental Gate Verification: We use a Parental Gate with an age screen and email verification process to ensure that only adults can access the App or create accounts.

• Account Creation Restrictions: Children cannot sign-up (create an account) into our App or provide Personal Data. Accounts can only be created by verified adults.

• Credential Restrictions: Users cannot provide their credentials or proceed with account creation until they complete the age screen and email verification process, explicitly consent to our Personal Data collection practices, and finalize the account setup.

• Parental Support Requests: If a child contacts us for support, we may ask them for a parent's email address to notify their parents about their request. This is the only personal data as defined by COPPA, that we collect from children prior to verifiable parental consent.

3.2. Parental Rights

Our services are designed to be used by children only with the permission of a parent. Parents have the following rights:

• Install the App: Only parents are authorized to install the App.

• Account Creation and Management: Only parents can create accounts, manage settings, and provide child-related information.

• Provide Child-Related Information: Parents can create a profile for their child within the App by providing details such as the child’s name, age, gender, and educational goals. This enables personalized recommendations, such as age-appropriate content and generating interactive Magic Stories. Parents can also choose whether to upload their child’s audio recordings to associate them with the Make Your Own (MYO) crafts. These choices are entirely at the parent’s discretion.

• Access Privacy Settings and Controls: Parents can review, update, or delete their child’s Personal Data through the App’s settings or by contacting us directly. Parents can also grant or withdraw consent for data collection at any time.

• Monitor Usage of the Player: Through the App, parents can view their child’s usage history, including which story crafts were played, the duration of playtime, the frequency of use, and other activity records. This allows parents to supervise, understand, and control their child’s use of the Player.

3.3. Privacy Controls for Parents

Parents have full control over their child’s Personal Data and privacy settings. You may:

• Access or Delete Information: Contact us at support@seedpace.com to request access to or deletion of any Personal Data collected about your child.

• Manage Consent: Withdraw consent for data collection at any time via the App’s feedback settings or by contacting us.

By implementing these measures, we aim to protect children’s privacy while delivering engaging and interactive experiences through Seedpace. For any questions or concerns, please contact us at support@seedpace.com.

 

4. How We Use Tracking Technologies

We may use tracking technologies and other similar technologies (such as Software Development Kits (SDKs), analytics tools, and device identifiers) to enhance your experience with our Services and to provide you with a more personalized, efficient, and secure experience and ensure our smooth operations. We may partner with third-party service providers that use these tracking technologies to assist us in analyzing user behavior and improving the App and devices.

The tracking technologies we use in our Services may include:

• SDKs (Software Development Kits): Embedded tools provided by third-party service providers that enable features such as analytics, crash reporting, or push notifications.

• Device Identifiers: Unique identifiers assigned to your device (e.g., IDFA for iOS) to help us understand user activity and deliver personalized experiences.

• Sensors on Devices: Built-in sensors, such as accelerometers, gyroscopes, that are used to enable specific features or gather usage data from the players.

• App Event Tracking: Tools that monitor in-app interactions, such as button clicks, time spent on specific screens, or purchases made within the App.

We use tracking technologies in the App and connected devices for the following purposes:

• To ensure the App functions properly, such as remembering your settings, preferences, or login status.

• To monitor the performance of connected players, ensure compatibility with the App, and provide firmware updates when necessary.

• To analyze how users interact with the App and devices, such as which features are most used, how often the App or devices are accessed, and how users navigate through the interface. This helps us improve the design and functionality of both the App and devices.

• To detect and prevent fraud, unauthorized access, or other malicious activities within the App and devices.

You have control over how certain tracking technologies are used in our Services. Through your mobile device’s settings, you can control which permissions the App has access to, such as location, sensors, or notifications. Please note that disabling certain tracking technologies may affect the functionality of the App or devices, such as firmware updates, or real-time notification features.

 

5. How and When We Share Your Personal Data

At Seedpace, we do not sell your or your child’s Personal Data for monetary consideration. However, certain of our disclosures may constitute a “sale” under the CCPA. For more details, please refer to Annex I. Supplemental Terms and Conditions for California Residents.

We work with trusted third-party service providers and partners to operate Seedpace, deliver the Services you request, and continually improve your experience. All third parties are required to comply with applicable privacy laws and implement robust safeguards to protect your Personal Data. Below, we outline the categories of third parties with whom we share your Personal Data and the purposes of such sharing:

5.1. Service Providers and Third-Party Vendors

We rely on trusted and reputable third parties to provide essential services for Seedpace. These include: 

 Cloud Storage: All data generated through your or your child's interactions with Seedpace is securely stored on Microsoft Azure cloud services.

 Magic Story Generation: When generating Magic Stories, Seedpace would transmit the child’s profiles which are provided by parents via our App, to ElevenLabs to synthesize customized audio narration, ensuring your child becomes the main character in the stories. This information is transmitted to the model provider solely to enable this feature and enhancing the immersive quality of the Magic Stories.

 Data Analytics: Device serial numbers (SN), user IDs (UID), and demographic data (e.g., age, gender) are shared with Friday to analyze user interactions and improve our Services..

 Customer Support, Email Delivery, and Marketing: We may also share Personal Data with service providers that assist in customer support, email communications, and marketing campaigns to provide a seamless user experience.

5.2. Our Affiliates for Cross-Platform Analysis

To enhance the overall user experience and improve our Services, we may share certain usage data through the Seedpace App and device operations with our affiliates, including the operator of our website/online shops. This data sharing allows us to conduct cross-platform analysis, linking such app usage data (e.g. user account activity, interaction patterns, etc.) with website information (e.g., order history, purchase preferences, and browsing behavior) to better understand your preferences, personalize recommendations, align insights from different platforms and optimize our Services.

If you do not wish for your Personal Data to be shared with our affiliates for cross-platform analysis, you may contact us to opt out of this data sharing. Please note, however, that opting out may limit certain features or functionalities, such as personalized recommendations or cross-platform services.

5.3. Regulators, Authorities, and Legal Obligations

We may disclose Personal Data to law enforcement agencies, regulators, government agencies, researchers, or other authorized parties if required by law or when we believe it is necessary to comply with applicable laws, rules, or regulations. Such disclosures are made under the following circumstances:

 Compliance with Legal Obligations: We may share personal information to comply with legal requirements, such as responding to subpoenas, court orders, or other lawful requests from authorities.

 Protecting Safety, Rights, or Property: We may disclose information to protect the safety, rights, or property of Seedpace, its users, or the public. This includes situations where disclosure is necessary to prevent harm, fraud, or unauthorized access to our systems.

 Fraud, Security, or Technical Issues: Personal information may be shared to detect, prevent, or address fraud, security threats, or technical issues that could compromise our services or user data.

 Law Enforcement Requests: For example, we may receive requests for account information from law enforcement authorities, such as the police or courts. We only disclose such information when we believe that the disclosure is reasonably necessary to comply with a legal request or requirement.

 Emergency Situations: In cases where we believe it is necessary to prevent imminent and serious bodily harm to a person, we may share information with relevant authorities or emergency responders.

We carefully evaluate all requests to ensure they comply with applicable laws and regulations. We also strive to protect user privacy by limiting the scope of information disclosed to what is strictly necessary for the purpose of the request.

5.4. With Your Consent

We may share your Personal Data with third parties when you have explicitly instructed us or provided your consent to do so.

5.5. Business Transferees

We may disclose Personal Data in the context of actual or prospective business transactions (e.g., investments in Seedpace, financing of Seedpace, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers.

We may also disclose your Personal Data to an acquirer, successor, or assignee of Seedpace as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets. This ensures the continuity of services and compliance with applicable laws.

5.6. Business and Marketing Partners.

We may also share your Personal Data with third parties under the following circumstances:

 Co-Sponsored Events or Promotions: When we co-sponsor events or promotions with third parties, or jointly offer products or Services, your Personal Data may be shared as necessary to facilitate such activities.

 Products or Services of Interest: We may share your Personal Data with third parties whose products or Services we believe may interest you.

 Professional Advisors: Personal Data may be disclosed to professional advisors, such as lawyers, auditors, bankers, or insurers, as necessary in the course of the professional services they provide to us.

We would make commercially reasonable efforts to ensure that all parties with whom we share Personal Data provide a level of protection consistent with the practices outlined in this Privacy Policy. However, third parties such as co-sponsors or marketing partners may use Personal Data as described in their own privacy policies.

We prioritize the protection of your Personal Data, especially when it pertains to children. We strive to minimize data sharing and transmission wherever possible. If you do not agree to the data sharing practices described above, certain features of Seedpace may not function as intended.  For instance, declining to share child profiles may prevent access to features such as Magic Story Mode.

 

6. How We Store Your Personal Data

We are committed to ensuring that your Personal Data is stored securely and in compliance with applicable laws and regulations. Personal Data will only be retained for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law, regulation, or your explicit consent.

6.1. Data Processing After Retention Periods

When your Personal Data is no longer needed for the purposes for which it was collected, we will either delete it or anonymize it so that it can no longer be used to identify you. If immediate deletion is not possible (e.g., due to technical constraints such as backup archives), the data will be securely stored and isolated from further processing until deletion is feasible.

6.2. Legal Retention Requirements

Certain types of data may be retained for longer periods to comply with legal, regulatory, or contractual obligations, including but not limited to:

 Tax and Accounting Records: Retained to comply with applicable tax laws.

 Legal Compliance: Retained as required by local, state, or international laws.

 Evidence Preservation: Retained to comply with statutes of limitation or to resolve disputes.

 Service-Related Communications: Retained as necessary to provide ongoing customer support or respond to inquiries.

 

7. Your Rights and Choices

We offer you certain choices to control your data. Depending on your location, you may also have specific privacy rights under local laws. To exercise these rights, please visit your account settings or contact us directly.

7.1. General Rights

You have the following rights regarding your Personal Data:

 Right to Know: We publishes the Privacy Policy to inform you of how we handle your Personal Data. We are committed to the transparency of the use of your Personal Data.

 Access Right: You have the right to access your Personal Data and review the information we have collected about you and your children.

 Right to Rectification: If you find any of your Personal Data is inaccurate or incomplete, you are entitled to ask us to make rectifications. When your identity is confirmed, we will rectify accordingly.

 Right to Delete: You may make a request to us to delete your Personal Data under the following circumstances:

- Our processing of your Personal Data violates the applicable laws or regulations;

- We collect or use your Personal Data without your prior consent;

- Our processing of your Personal Data violates the agreement with you;

- You stop using our Services;

- We no longer provide you with Services;

- Other circumstances stipulated by the laws and regulations.

 Right to Restrict Processing: You are entitled to request Seedpace to restrict processing of your Personal Data under the following circumstances:

- You contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of the Personal Data;

- The processing is unlawful and you oppose the erasure of your Personal Data and requests the restriction of their use instead;

- We no longer need your Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

- You have objected to processing, pending the verification whether the legitimate grounds of us override those of you.

This means we can store your Personal Data but cannot process it.

 Right of Data Portability: To the extent permitted by laws and regulations, you are entitled to obtain your Personal Data in a structured, commonly used, and machine readable format. For instance, if you decide to change the service provider, this right enables you to reliably and safely move, copy or easily transfer your Personal Data between IT systems without affecting its use.

 Right to Refuse Automated Decision: You have rights not to be bound by automatic decisions (if any), including user profiling. If these decisions will significantly affect your legitimate rights, you can refuse to be subject to automated decisions. We will respond to your request and take appropriate measures when necessary.

 Right to Withdraw Consent: If you previously consented to our processing of your Personal Data, you may withdraw your consent at any time, and we will stop processing your data by contacting us.

 Right of Refusal: To the extent permitted by the applicable laws and regulations, you have right to refuse our processing for these purposes.

 Right to Complaint: You have the right to file a complaint with your local data protection authority if you believe we are unlawfully processing your Personal Data.

7.2. Managing Your Choices

 Opt-out of Communications: You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. Push notifications can be managed through your device settings.

 Delete your content or close your account: You can delete your account, which will remove all associated data, or request account closure by contacting us. You can also initiate account deletion through your account settings.

 Linked third-party platforms. If you choose to connect to the Services through a third-party platform like Google, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

 

8. Security

The security of your and your children’s Personal Data is important to us. We have taken safeguarding measures in accordance with industry standards to protect the Personal Data you provided and prevent data from unauthorized access, public disclose, use, modification, damage or loss.  

With regard to the security control of data access and use, we have implemented a strict data authorization control mechanism, adopted multiple identity authentication technology, and monitored the processing of your personal information to prevent illegal access and unauthorized use of data. We also monitor the entire lifecycle of data to protect your personal information from unauthorized access, public disclosure, use, modification, and intentional or accidental damage or loss, etc.

However, please be attention, even if we undertake reasonable measures to protect your data, there is no website, internet transmission, computer system or wireless connection that are definitely safe. While we strive to use commercially acceptable means to protect your and your children’s Personal Data, we cannot guarantee its absolute security. In case of Personal Data security incident where it is likely to result in a high risk to the rights and freedoms of you, we shall communicate the Personal Data breach to you in accordance with the requirements of laws and regulations such as basic situations and possible influence of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc.

The safety and security of your and your children’s Personal Data also depends on you. Where we have given you (or where you have chosen) a password to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We also kindly recommend you to access the App only in secure environments and use strong authentication methods. Please follow device security best practices and regularly review privacy settings.

We will inform you in a timely manner by email, mail, telephone, push notification, etc., regarding the relevant situations of the incident. When it is difficult to notify each Personal Data subject individually, we will issue a notice in a reasonable and effective manner. In the meantime, we will take the initiative to report on the handling of Personal Data security incident in accordance with regulatory department’s requirements.

 

9. Other Sites and Services

The Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

 

10. How We Make Changes to This Policy

We may change this Privacy Policy from time to comply with applicable law to time and if we do, we’ll post any changes on this page and update the “Last updated” date at the top of this Privacy Policy. If the changes are significant, we may provide a more prominent notice, such as by sending you an email.

You are advised to review this Privacy Policy periodically for any changes. If you continue to use Seedpace after those changes are in effect, the new policy applies to you. If required under the law, we will obtain your necessary consent.

 

11. Contact Details

If you have any concerns, questions, or doubts about our Privacy Policy or practices, or if you wish to exercise your rights, you may contact us through the following channels:

(1) Feedback via the App: Log in to the Seedpace App and use the in-app feedback feature to submit comments, feedback, inquiries, or complaints directly to our customer service team.

(2) Email: Send an email to [*].

Only you, or someone legally authorized to act on your behalf (i.e., your authorized agent), may make a request related to your personal information. We may require an agent to provide verification that they are acting on your behalf when they submit a request related to your personal information.  

To process your request, we require:

 Verification Information: You must provide sufficient information for us to reasonably verify your identity. This typically includes two to three pieces of personal information that we will match with the data we maintain in our records.

 Request Details: Your request must include sufficient detail to allow us to properly understand, evaluate, and respond to it.

Any review and processing will normally be completed within thirty (30) days after verifying your user identity. If it takes more time to respond to your request or if we are unable to respond to your request if doing so would violate applicable laws, infringe on the rights of others, or if we cannot verify your identity to a reasonable degree of certainty, we will send you a notice and explain the reasons within the maximum timeframe required by law.

We are committed to addressing your concerns and ensuring that your rights are respected. If you have any further questions, please do not hesitate to contact us.