Privacy Policy for Dactor

Dactor collects and processes data necessary to operate the Platform and provide our services. The types of data we collect include:

• Account Information: When you create a Dactor account, we collect your name, email address, a unique user ID (shareId), your role (e.g., student, parent, teacher, employed, or prefer not to state), and, optionally, your date of birth.
• User Inputs: You may provide data such as text prompts or preferences to generate content using AI features.
• Usage Data: We collect data related to your interactions with the Platform, including feature usage, preferences, and progress tracking, to personalize your experience.
• Payment Details: Payment information is processed securely through our third-party provider, Airwallex. This may include metadata, such as user IDs, to facilitate transactions.
• Technical Data: We may collect technical information, including IP addresses, device identifiers, or cookies, for analytics, personalization, security, and compliance with applicable laws.

Dactor uses secure storage solutions to manage your data effectively:

• Azure Cosmos DB: Backend data, including user accounts, usage progress, subscription details, applied rewards, and default attributes (such as user level and limits), is stored in Azure Cosmos DB. During account creation, we save your details and initialize your profile.
• Local Storage on Your Device: Some user preferences and inputs may be stored locally on your device using mechanisms like localStorage to maintain continuity across sessions.
• Dactor’s Servers: User inputs provided for AI features may be analyzed or stored on Dactor’s servers to operate and improve Platform functionalities.

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, or misuse, in compliance with applicable data protection laws.

By using the Platform, you grant Dactor and its API providers a worldwide, non-exclusive, royalty-free license to use, store, and process your data for the following purposes:

• Operating the Platform: To provide and personalize services, including content generation, review, and account management.
• Improving the Platform: To enhance AI functionalities, develop new features, and optimize user experience.
• Legal Compliance: To comply with applicable laws, regulations, and legal obligations, including data protection laws.

We process your data in accordance with this Privacy Policy and applicable laws to ensure transparency and accountability.

Dactor may share your data with third parties under the following circumstances:

• API Providers: User inputs and data may be shared with third-party API providers (Grok by xAI, OpenAI, and DeepSeek) to power AI-driven features. Data shared is governed by their respective privacy policies, and Dactor ensures compliance with applicable laws.
• Payment Processor: Payment details are processed securely through Airwallex. Airwallex’s terms and privacy policies apply, and Dactor does not store your full payment information. Metadata may be included to facilitate transactions.
• Legal Requirements: We may disclose your data to comply with legal obligations, respond to lawful requests, or protect our rights, property, or safety.

Dactor is committed to complying with applicable data protection laws, including:

• Hong Kong’s Personal Data (Privacy) Ordinance: Governing personal data in Hong Kong.
• U.S. Children’s Online Privacy Protection Act (COPPA): Ensuring protections for U.S. users under 13 (see Section 6).
• General Data Protection Regulation (GDPR): Where applicable, for users in the European Union or other relevant jurisdictions.
• Other Relevant Laws: Compliance with additional local or international regulations as applicable.

We implement safeguards to protect your data and respect your privacy rights under these laws.

The Platform is intended for users aged 13 and older:

• U.S. Users:
  • In compliance with COPPA, Dactor does not knowingly collect personal information from U.S. users under 13. If we discover such data, we will promptly delete it.
  • For U.S. users aged 13 to 15, verifiable parental consent is required to create an account.
• Non-U.S. Users:
  • We recommend users be 13 or older. For users aged 13 to 15 (or under 16 in certain jurisdictions), verifiable parental consent is required.
  • Where local laws permit, users under 13 may use the Platform if compliant, but Dactor reserves the right to require consent or restrict access.
• General:
  • Users aged 16 and older may use the Platform independently.
  • We may request proof of age or consent at any time. Failure to provide may result in account suspension.
  • Parents may contact support (see Section 8) to manage or delete child data.

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of your data.
• Correction: Request fixes to inaccurate data.
• Deletion: Request data removal, subject to legal obligations.
• Restriction: Limit how we process your data.
• Portability: Transfer your data to another provider.
• Objection: Object to certain uses (e.g., marketing).

Contact us (Section 8) to exercise these rights. We respond per applicable laws.

Dactor may update this Privacy Policy to reflect changes in practices or laws. Updates are posted on the Platform and take effect immediately. Continued use constitutes acceptance. We encourage periodic review.