Privacy Policy

Effective date: 2025-09-10

Your privacy and data security are extremely important to us. We are committed to the responsible management, protection, and use of your personal information.

This Privacy Policy (“Policy”) explains how Cygnus Space (Hong Kong) Company Limited (“Artguru,” “we,” “our,” or “us”) collects, uses, shares, and protects your personal data when you use our mobile applications (“Apps”) and website located at www.artguru.ai (the “Website”), together with any related features, content, or services we may provide (collectively, the “Services”).

By using the Services, you acknowledge that you have read and understood this Policy.

This Privacy Policy may be translated into other languages for reference. If there is any discrepancy between the English version and any translated version, the English version shall be deemed the official and controlling version.

1. DATA WE COLLECT AND HOW WE USE IT

We collect both personal information (data that can directly identify you) and non-personal or technical information (data that by itself does not identify you). In some cases, technical information may become personal information if combined with other data.

1.1 Personal Information

We collect the following types of personal information when you use the Services:

(a) Account Information

If you sign up or log in (including via Google, Apple, Facebook, or VK), we collect your login credentials, name, email address, and profile picture (if available).

We use this to create and manage your account and authenticate your access.

(b) Payment Information

When you make purchases, we process billing email, transaction IDs, and limited payment details through our third-party processors (Stripe, PayPal, DukPay, Apple App Store, Google Play).

We use this to complete transactions, comply with financial rules, and prevent fraud.

(c) Communications

If you contact us (e.g., via support@artguru.ai), we process your message and contact details to respond to your inquiries.

From time to time, we may also invite you to participate in user research, surveys, or feedback programs. Participation is entirely voluntary. If you choose to take part, we will process the information you provide for the purposes of understanding user needs and improving our Services.

(d) Marketing Information (optional)

If you opt in, we may use your email address and preferences to send promotional materials. You may withdraw consent at any time.

Legal basis (GDPR): contract, legal obligation, consent (for marketing); Business purpose (CCPA): providing services, payment processing, customer service, marketing.

To know how we process your personal information through the use of cookies and similar technologies, see 5. COOKIES AND TRACKING TECHNOLOGIES below.

1.2 Non-Personal / Technical Information

We also collect data that does not directly identify you, such as:

(a) Input Data

Content you upload (images, text prompts) to use the Services. Depending on the content, Input and Output may contain personal information, and we will treat such information in accordance with this Policy. We use Input to provide core functionality (enhancing or generating images) and, where applicable, to improve AI models. Training use is irreversible once incorporated into a model.

(b) Output Data

AI-generated results based on your Input. Depending on the content, Input and Output may contain personal information, and we will treat such information in accordance with this Policy. We use this to deliver results and improve the Services, including refining our AI models.

(c) Device & Usage Data

Technical details like IP address, device type, device model, functional attributes, operating system, browser type, logs, and SDK/cookie data. We use this to secure the Services, detect misuse, troubleshoot errors, perform analytics, and improve performance.

Legal basis (GDPR): contract, legitimate interests, consent (cookies/training where required); Business purpose (CCPA): service delivery, product improvement, security, analytics.

1.3 Additional Purposes

In addition to the purposes described above, we may process any of the categories of information set out in this Section where it is necessary to:

• comply with our legal obligations or respond to lawful requests from public authorities;
• establish, exercise, or defend legal claims; or
• carry out corporate transactions or operations (such as mergers, acquisitions, reorganizations, or asset transfers).

2. RETENTION OF YOUR INFORMATION

We retain your personal information only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law (for example, to meet tax, accounting, or anti-fraud obligations).

You may at any time delete your account or use the "Clear your data" option in the Services. When you do so, we will delete or anonymize the associated personal information within a reasonable period of time (typically within 30 days), unless we are legally required to retain certain records or retention is necessary to establish, exercise, or defend legal claims.

Some usage or technical information (such as logs) may be stored for a limited period for security, analytics, or troubleshooting purposes before being automatically deleted or anonymized. We may also continue to use non-personal or aggregated information, which no longer identifies you, for analytics, service improvement, and business reporting.

If you would like details on the specific retention periods applied to different types of data, please contact us at support@artguru.ai.

Most of the information we collect is stored and processed on servers located in the United States. Depending on your location and the services you use, your information may also be accessed or processed in other regions where we or our service providers operate. If we transfer personal information outside your country of residence, we will take steps required by applicable law to ensure an adequate level of protection.

3. HOW WE SHARE INFORMATION

We do not sell your personal information. We only share it in the limited circumstances described below:

(a) Service Providers

We may share information with trusted service providers who support the operation, security, and improvement of the Services. These providers are allowed to access personal information only as necessary to perform their tasks on our behalf and are contractually required to protect it.

(b) Third-Party Login Providers

If you choose to sign in via Google, Apple, Facebook, or VK, we receive limited profile information such as your name, email address, profile picture (if available), and an authentication token. This information is used only to authenticate your access and link your account. We do not access your third-party credentials or full profile data.

These third-party providers may independently process your data according to their own privacy policies. We encourage you to review their policies to understand what information they may collect and how they use it:

• Apple: https://www.apple.com/legal/privacy
• Google: https://policies.google.com/privacy
• Facebook: https://www.facebook.com/privacy/policy
• VK: https://vk.com/privacy

(c) Payment Providers

When you make purchases, we share transaction data (such as payment amount, billing email, and masked card details) with payment processors including Stripe, PayPal, DukPay, Apple App Store, and Google Play. These processors handle the transaction securely on our behalf. We do not store your full payment details.

• Stripe: https://stripe.com/privacy
• PayPal: https://www.paypal.com/myaccount/privacy/privacyhub
• DukPay: https://dukpay.com/page/privacy.html

(d) Support Providers

We use third-party tools such as Zendesk to provide customer support. When you contact us, Zendesk may process your contact details and support messages on our behalf, in accordance with their own privacy policy:

• Zendesk： https://www.zendesk.com/company/agreements-and-terms/privacy-notice/

(e) Affiliates

We may share information with our affiliates and subsidiaries to deliver and improve the Services.

(f) Legal Compliance

We may disclose information if required by law, legal process, or government request. We may also share information to enforce our terms, protect our rights, prevent fraud or abuse, or ensure the safety of our users.

(g) Corporate Transactions

If we undergo a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.

(h) With Your Consent

In any other situation not covered above, we will share your information only with your explicit consent. You may withdraw your consent at any time.

4. YOUR RIGHTS AND HOW TO EXERCISE THEM

Depending on where you live, you may have certain rights under applicable data protection laws. You can exercise these rights by contacting us at support@artguru.ai. We may need to verify your identity before fulfilling your request.

4.1 General Rights (All Users)

• Withdraw consent: If we rely on your consent, you may withdraw it at any time.
• Access: You can request a copy of the personal information we hold about you.
• Correction: You can request that we correct or update your personal information.
• Deletion: You can delete your account or ask us to delete your personal information, subject to legal or legitimate retention requirements.
• Restriction and objection: You may request that we restrict processing or object to certain processing activities.
• Complaint: You can lodge a complaint with a data protection authority in your jurisdiction.

4.2 Additional Rights For EEA, UK, And Swiss Users (GDPR)

• Data portability: Request that your information be provided in a structured, commonly used, machine-readable format, or transferred to another controller where technically feasible.
• Object to processing based on legitimate interests: You can object where we rely on legitimate interests.
• Automated decisions: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects.

4.3 Additional Rights For U.S. Residents (CCPA/State Laws)

• Know: Request the categories and specific pieces of personal information we collect, use, and disclose.
• Sources and purposes: Request information about the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom information is shared.
• Correction and deletion: Request correction or deletion of your personal information, subject to exceptions.
• Opt out of sale/share: Request that we do not sell or share your personal information as defined under state laws.
• Limit use of sensitive personal information: Where applicable, request that we limit the use or disclosure of sensitive data.

We will not discriminate against you for exercising these rights.

4.4 How To Make A Request

• Only you or your authorized agent may make a verifiable request related to your personal information.
• Requests must provide sufficient detail for us to verify your identity and understand what you are asking for.
• You may make up to two requests within a 12-month period free of charge.

4.5 Our Response

• We aim to respond to verifiable requests within 30 days (or up to 45 days where permitted by law, with notice of the extension).
• If your request is complex, we may extend the response period up to 90 days, and we will notify you within the first 30 days.
• We do not charge a fee unless the request is excessive, repetitive, or manifestly unfounded. If we determine a fee applies, we will explain why and give you a cost estimate before proceeding.

5. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies, such as SDKs, tracking pixels, and local storage, to operate and improve our Services. Cookies are small text files placed on your device when you use our Apps or visit our Website. Similar technologies may also be embedded in our mobile applications.

Some of these technologies are essential to the basic functioning of the Services, for example by keeping you signed in, maintaining security, and enabling payment processing. Others help us understand how the Services are used, so that we can measure performance, fix problems, and improve the user experience. For this purpose, we use providers such as Google Analytics, Firebase, and Appsflyer, which collect aggregated usage statistics and attribution data. In addition, certain third-party partners, including Meta (Facebook), may use cookies or SDKs to provide analytics and to deliver more relevant advertising.

You can manage or delete cookies and similar technologies at any time through your browser or device settings. On mobile devices, you may also control tracking preferences through your system settings. Please note that disabling certain cookies may affect the availability or functionality of parts of the Services.

Related policies of our partners:

• Google: https://policies.google.com/privacy
• Firebase: https://firebase.google.com/support/privacy
• Appsflyer: https://www.appsflyer.com/legal/services-privacy-policy/
• Meta (Facebook) https://www.facebook.com/privacy/policy

6. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your privacy rights under this Policy or applicable law. This means, for example, that we will not deny you access to our Services, charge you different prices, or provide a different level or quality of Services simply because you have chosen to exercise your rights. We may, however, offer financial incentives (such as discounts or promotions) that are reasonably related to the value of your personal information, as permitted by law.

7. CHILDREN'S DATA

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that a child under 13 has provided us with personal information, we will delete it as soon as reasonably possible.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us so we can take appropriate action. For users between the ages of 13 and 16, certain laws (such as the GDPR and the CCPA) may require us to obtain consent from the user or their parent/guardian before processing personal information. If this applies to you, you or your parent/guardian may contact us to provide or withdraw consent.

8. CHANGES TO THE POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by posting an updated version on our Website or within the Apps, and, where required by law, by providing additional notice or requesting your consent.

The date at the top of this Privacy Policy shows when it was last updated. Your continued use of the Services after the effective date of an updated Policy means that you acknowledge and agree to the changes.

9. CONTACT US

If you have any questions or concerns about the Policy, you may contact us at email: support@artguru.ai. We will review your message carefully and respond within a reasonable timeframe.