DW DearWith

DearWith Privacy Policy

Version: v1.0
Effective Date: June 21, 2026
Last Updated: June 21, 2026

This Privacy Policy explains how UNIUME PTE. LTD., a Singapore company ("DearWith," "we," "us," or "our"), collects, uses, discloses, transfers, stores, and protects personal data when you use DearWith.

DearWith is a privacy-first AI companion product. We know that Presence settings, memory inputs, Time Capsule materials, and conversations may be deeply personal. We design our data practices around minimization, user control, limited access, and clear disclosure.

Important Notice and Key Privacy Summary

This summary highlights important privacy terms, but it does not replace the full Privacy Policy. Please read the full Policy carefully. If this summary conflicts with the full Policy, the full Policy controls to the extent permitted by law.

1. Scope and Relationship to Terms

1.1 This Privacy Policy applies to DearWith apps, web products, websites, APIs, support channels, and related services.

1.2 This Policy should be read together with the DearWith Terms of Service.

1.3 If we publish regional privacy notices, those notices apply to users in the relevant jurisdictions and control where required by law.

2. Age and Children Privacy

2.1 DearWith is intended only for users aged 16 and above.

2.2 Users under 16 may not create an Account or use the Service.

2.3 DearWith is not directed to children under 13, and we do not knowingly collect personal information from children under 13.

2.4 If we learn that a user is under 16 or that we have collected personal data in violation of applicable child privacy law, we may delete the Account and related data or take other legally required action.

2.5 Parents or guardians who believe a child has provided personal data to DearWith may contact us using the details at the end of this Policy.

3. Privacy-First Data Principles

DearWith follows these principles:

3.1 We collect data only where reasonably needed to provide, secure, maintain, improve reliability of, or comply with legal obligations for the Service.

3.2 We do not sell personal information.

3.3 We do not share personal information for cross-context behavioral advertising.

3.4 We do not and will not use user personal data, Presence settings, uploaded materials, Time Capsule materials, memory inputs, Private Conversation Content, or chat content to train any AI models.

3.5 DearWith does not operate its own foundation model or large language model.

3.6 We limit access to Private Conversation Content to authorized situations such as service delivery, user request, technical support, security, abuse prevention, legal compliance, or safety review, as further described in Section 13. This does not mean routine human review of private chats.

3.7 Processing conversation content to provide the Service is not the same as routine human reading of private chats, and our access controls are designed around that distinction.

3.8 We use third-party providers only as needed to operate the Service and subject to appropriate safeguards.

3.9 We aim to provide meaningful user rights, including access, correction, deletion, and portability where required or reasonably available.

4. Categories of Personal Data We Collect

Depending on how you use DearWith, we may collect:

4.1 Account data
Email address, username, account ID, authentication method, password hash or credential metadata, registration time, account status, and language settings.

4.2 Profile and Presence data
Display name, Presence name, Presence description, personality settings, relationship context, memory inputs, dialogue examples, permission settings, and other configuration data you choose to provide. Depending on what you provide, this category may contain sensitive information and is handled subject to Section 5.

4.3 Private conversation content
Messages you send to Presences, AI Outputs generated in response, conversation context needed to provide replies, and relationship-specific memory where enabled. We collect and process this content only as necessary to: (a) generate requested replies; (b) maintain conversation continuity and relationship memory where enabled; (c) synchronize, store, and restore conversation history across supported sessions and devices; (d) run automated safety, abuse-prevention, fraud, and security checks; and (e) support user-requested troubleshooting, legal compliance, safety review, or enforcement in limited authorized cases. Depending on what you include in conversations, this category may contain sensitive information and is handled subject to Section 5. This does not mean routine human review of private chats.

4.4 Uploaded content and Time Capsule materials
Text, images, files, pre-recorded voice clips, pre-recorded videos, or other materials you choose to upload if supported by the Service. This may include Time Capsule media configured for contextual delivery in conversations with authorized Visitors, together with related timing or trigger metadata. Depending on what you upload, this category may contain sensitive information and is handled subject to Section 5. Version 1 does not include voice cloning, voice synthesis, or biometric voice modeling unless separately launched and disclosed.

4.5 Visitor and permission data
Invitation links or codes, access grants, access revocations, visitor relationship settings, and authorization records.

4.6 Transaction and entitlement data
Product IDs, order IDs, purchase status, subscription status, entitlement records, renewal status, platform transaction metadata, and purchase-time entitlement snapshots.

4.7 Device, log, and technical data
IP address, device type, operating system, app version, browser type, timezone, locale, crash logs, diagnostic events, security logs, and usage events.

4.8 Support and communication data
Support requests, feedback, survey responses, email communications, and administrative messages.

4.9 Safety and compliance data
Fraud signals, abuse reports, moderation metadata, account integrity signals, legal request records, and enforcement history.

4.10 Authority verification and dispute evidence data
Declarations, consent confirmations, relationship claims, rights-holder authorizations, and supporting documents or metadata submitted during Time Capsule, identity-rights, memorial-governance, or safety/compliance review.

4A. Data Category-to-Handling Cross-Reference

This Section maps each category in Section 4 to the primary downstream handling Sections of this Policy.

4A.1 Account data
Primary handling Sections: 7.1, 10, 11, 16.1, 17, 18.

4A.2 Profile and Presence data
Primary handling Sections: 5, 7.2, 7.4, 13, 14, 16.2, 17, 18.

4A.3 Private conversation content
Primary handling Sections: 7.3, 7.4, 7.8, 7.10, 9, 12, 13, 16.3, 17, 18.

4A.4 Uploaded content and Time Capsule materials
Primary handling Sections: 5, 7.4, 7.12, 9, 12, 13.10-13.12, 14.6-14.11, 16.10, 17.9-17.12, 18.

4A.5 Visitor and permission data
Primary handling Sections: 7.5, 14, 16, 17, 18.

4A.6 Transaction and entitlement data
Primary handling Sections: 7.6, 7.11, 10.3, 11.3, 16.5, 17.5, 17.8, 18.

4A.7 Device, log, and technical data
Primary handling Sections: 6.2, 7.8-7.10, 10.1, 10.5, 11.5, 16.6, 16.8, 17.2-17.7, 28.2-28.5.

4A.8 Support and communication data
Primary handling Sections: 7.7, 7.10, 10.4, 10.6, 11.4, 16.7, 17.1-17.7, 18.

4A.9 Safety and compliance data
Primary handling Sections: 7.8, 7.10, 7.12, 10.5, 10.7, 11.5, 13, 14.7-14.11, 16.6, 16.11, 17.10, 17.12, 28.2, 28.3, 28.5, 28.8.

4A.10 Authority verification and dispute evidence data
Primary handling Sections: 6.7, 7.12, 10.7, 13.10-13.12, 14.7-14.11, 16.11, 17.11, 17.12, 18.

5. Sensitive and AI-Specific Data

DearWith does not require you to submit sensitive personal data. However, because the Service is about memory, relationships, and companionship, you may choose to provide sensitive information in Presence settings, memory fields, uploaded materials, Time Capsule media, imported text records, and private conversations. This may include information about grief, family, relationships, health, religion, identity, emotional state, or personal history.

Where you voluntarily provide sensitive information:

5.1 We process it only for the purposes described in this Policy, including Sections 7.1-7.12 (How We Use Personal Data), Section 13 (Private Conversation Access Controls), Section 16 (Data Retention), Section 17 (Account Deletion and Data Deletion), and other legally required obligations described in this Policy, and not for unrelated purposes.

5.2 We do not sell it or use it for cross-context behavioral advertising.

5.3 We do not use it for model training.

5.4 We restrict access according to role, purpose, and operational need.

5.5 You should avoid submitting sensitive information about another person unless you have a lawful basis or appropriate consent.

6. Sources of Personal Data

We collect personal data:

6.1 Directly from you when you register, configure Presences, upload Time Capsule materials, build memory, chat, purchase, or contact support.

6.2 Automatically from your device and interactions with the Service.

6.3 From platform providers such as Apple where needed for login, purchases, subscriptions, fraud prevention, or entitlement verification.

6.4 From Service Providers acting on our behalf.

6.5 From other users only where they invite you, configure permissions, report abuse, or provide relationship context involving you. Other users are responsible for having an appropriate legal basis, authority, or consent where required, and must not submit sensitive information about you without lawful authority.

6.6 If we receive personal data about you from another user and you are entitled to rights under applicable law, you may contact us to request access, correction, deletion, restriction, or objection. We may restrict, delete, or de-identify disputed third-party-submitted information where legally required, where consent or authority cannot be reasonably supported, or where needed to protect privacy and safety.

6.7 From Creators, representatives, family claimants, rights holders, or other parties who submit verification or dispute materials for memorial governance, consent verification, or safety/legal review.

7. How We Use Personal Data

We use personal data to:

7.1 Create and manage Accounts.

7.2 Provide Presence creation, configuration, and access-control features.

7.3 Generate AI responses for authorized conversations.

7.4 Structure, store, and retrieve memory or relationship context where enabled, including delivery of configured Time Capsule materials where available.

7.5 Enforce Creator and Visitor permissions.

7.6 Process purchases, subscriptions, renewals, refunds, and entitlements.

7.7 Provide customer support and service notices.

7.8 Maintain security, prevent abuse, detect fraud, and protect users.

7.9 Debug, monitor, and improve reliability of the Service.

7.10 Comply with legal obligations, respond to lawful requests, and enforce our Terms.

7.11 Maintain business records, audit records, and accounting records where required.

7.12 Verify authority/consent claims, review Time Capsule or identity-rights disputes, and operate memorial governance safeguards.

8. Legal Bases for Processing

Where legal bases are required, we rely on:

8.1 Contract performance, to provide the Service you request.

8.2 Legitimate interests, such as security, fraud prevention, service reliability, user safety, and internal administration.

8.3 Consent, where required for specific optional processing.

8.4 Legal obligations, such as tax, accounting, consumer protection, privacy compliance, and lawful requests.

8.5 Vital interests or public interest, only where legally applicable and necessary for emergency or safety situations.

9. Model Training Policy

DearWith's model-training policy is a permanent privacy commitment for this Service:

9.1 DearWith does not and will not use your personal data, Presence settings, uploaded materials, Time Capsule materials, memory inputs, Private Conversation Content, or chat content to train any AI models.

9.2 DearWith does not operate its own foundation model or large language model.

9.3 Service Providers acting on our behalf are not permitted to use your personal data, Presence settings, uploaded materials, Time Capsule materials, memory inputs, Private Conversation Content, or chat content for their own model training when processing data for DearWith.

9.4 AI model providers may process prompts, context, and related metadata only to provide AI functionality to DearWith, subject to applicable provider settings, contracts, technical controls, retention controls, and no-training restrictions where available.

9.5 We will not ask AI model providers to use DearWith user data for model training, fine-tuning, evaluation datasets, or similar model-improvement purposes.

9.6 Aggregated, de-identified operational metrics may be used only for security, reliability, billing, abuse prevention, capacity planning, and service-quality monitoring, and not to train AI models.

10. Disclosure to Service Providers

We disclose personal data only where reasonably necessary and subject to appropriate safeguards. Categories of Service Providers may include:

10.1 Cloud infrastructure and hosting providers.

10.2 AI model API providers.

10.3 Payment processors and app store platforms.

10.4 Email, SMS, push notification, and communications providers.

10.5 Security, monitoring, diagnostics, and anti-abuse providers.

10.6 Customer support tools.

10.7 Professional advisors, auditors, accountants, and legal counsel where necessary.

Service Providers may only process data for authorized purposes and not for their own independent advertising or model-training purposes where acting on our behalf.

We apply safeguards for Service Provider disclosures, including data processing agreements, confidentiality requirements, purpose limitation, least-privilege access controls, encryption in transit and at rest where appropriate, role-based access review, logging and audit controls, incident response obligations, transfer safeguards where required, and deletion/return commitments at the end of services where required. Where a provider cannot meet these safeguards for the data category involved, we will avoid using that provider for that category or apply additional controls.

11. Current Third-Party Provider Categories

DearWith may use:

11.1 Cloud infrastructure: Amazon Web Services, with planned deployment in the United States, including in or around the Los Angeles region.

11.2 AI model providers, as configured: OpenAI, Anthropic (Claude), Google (Gemini), xAI (Grok), or other mainstream providers disclosed in a maintained provider list.

11.3 Platform and payment providers: Apple for Sign in with Apple, App Store distribution, in-app purchases, subscriptions, refunds, and payment verification.

11.4 Communications providers: email, SMS, or push providers if enabled.

11.5 Security and diagnostics providers: monitoring, logging, crash reporting, and abuse-prevention tools if enabled.

We maintain a separate sub-processor list with provider name, purpose, data category, region, and update date. Before the Service is made publicly available, this list may be provided upon request through contact@dearwith.ai. Once our official legal notice page is publicly available, we will publish or make available the current list there and aim to update it at least every 6 months and before material provider changes where reasonably practicable.

12. No Sale and No Cross-Context Behavioral Advertising

12.1 DearWith does not sell personal information.

12.2 DearWith does not share personal information for cross-context behavioral advertising or cross-site targeted advertising.

12.3 DearWith does not use private chat content, Presence settings, memory inputs, uploaded materials, or Time Capsule materials for ad targeting.

13. Private Conversation Access Controls

Private Conversation Content Rules

13.1 Private Conversation Content is treated as confidential user content.

13.2 DearWith personnel do not routinely read Private Conversation Content.

13.3 Access may occur only for limited reasons, such as user support, debugging, security, abuse investigation, legal compliance, enforcement, user-requested export/deletion, safety review, consent or rights disputes, or lawful requests from competent authorities.

13.4 Access should be limited to authorized personnel or Service Providers with a legitimate need and follow a least-necessary scope.

13.5 System processing of Private Conversation Content for storage, routing, and response generation is necessary to provide the Service and is different from routine manual reading by personnel.

General User Content Rules

13.6 User Content outside Private Conversation Content (including profile, memory, relationship, and uploaded materials) is also handled under need-based access controls.

13.7 We do not conduct unnecessary routine manual review of such User Content. Access may occur for limited reasons including user support, technical troubleshooting, security, abuse investigation, legal compliance, rights disputes, or enforcement.

13.8 We may use technical logs and metadata to troubleshoot issues without reviewing full content where feasible.

13.9 We may apply automated safety systems to detect prohibited content, abuse, or security risks.

Time Capsule-Specific Rules

13.10 Time Capsule-specific handling, consent-risk controls, and dispute workflows apply in addition to the General User Content Rules above.

13.11 Because Time Capsule materials may include sensitive voice/image content, we may apply additional access controls, authenticity checks, authority verification, and proportionate restrictions where necessary in dispute or safety scenarios.

13.12 For uploaded materials, user inputs, and AI interactions (including Time Capsule media), we may run risk-based automated safety screening and use resulting risk signals to trigger temporary content-level restrictions and, where necessary, limited human-assisted review under least-necessary access controls.

14. Creator and Visitor Privacy

14.1 A Creator controls access to the Creator's Presence through available permission settings.

14.2 A Visitor's private conversation with a Presence is not automatically shown to the Creator unless the product expressly provides that feature with notice and appropriate consent.

14.3 Relationship-specific memory may be used to provide the Visitor's future conversations with that Presence where enabled.

14.4 When a Creator revokes access, future access may be restricted, subject to product rules, legal retention, safety, and dispute needs.

14.5 Users must not submit private information about others without appropriate authority.

14.6 Where Time Capsule is enabled, Creator-uploaded Time Capsule media is delivered only within authorized conversation contexts and according to Creator-configured controls and product rules.

14.7 If we receive a claim that a Creator is deceased or legally incapacitated, we may apply temporary protective restrictions while verification is pending.

14.8 After verification, we may permit limited representative actions and continue to restrict high-impact edits (including core identity, memory, or Time Capsule edits) where needed for safety, authenticity, legal compliance, or dispute control.

14.9 The Time Capsule-specific controls in Section 13 apply in addition to this Section.

14.10 Where product controls support it, Creator-configured pre-authorized representative permissions during the Creator's lifetime are processed under this Section and remain limited by product controls, safety checks, and applicable legal requirements.

14.11 Unless explicitly enabled by the Creator, such pre-authorized representative permissions are generally limited to low-risk account-management actions and do not transfer account ownership.

15. International Transfers and Storage Location

DearWith is operated by a Singapore company and may serve users globally. Your personal data may be transferred to, processed in, or stored in jurisdictions other than your country of residence.

15.1 We expect to use cloud infrastructure in the United States, including in or around the Los Angeles region.

15.2 AI model providers and other Service Providers may process data in the United States or other countries depending on their infrastructure.

15.3 For Singapore users, we take steps intended to provide a comparable standard of protection for transferred personal data as required by the Singapore PDPA.

15.4 For users in the EEA, UK, or Switzerland, we may rely on appropriate safeguards such as Standard Contractual Clauses, the UK International Data Transfer Addendum, adequacy decisions, or equivalent transfer mechanisms where required.

15.5 We also use operational safeguards such as data minimization, access controls, encryption where appropriate, provider due diligence, contractual purpose limits, and retention/deletion controls.

15.6 For users in other jurisdictions, we apply transfer safeguards required by applicable law where relevant.

15.7 Cross-border processing may expose data to lawful requests by courts, regulators, or law enforcement in the relevant jurisdictions.

15.8 Unless otherwise required by law or expressly stated in product-specific terms, DearWith does not guarantee data localization in a specific country or region.

16. Data Retention

We retain personal data only as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.

Typical retention principles (unless a longer period is required by law, dispute hold, or security need):

16.1 Account data: retained while your Account is active. After account deletion, we generally retain only limited account-level records (such as account ID, registration/deletion timestamps, security and consent logs, and essential fraud/dispute audit records) for up to 24 months for security, legal, accounting, or dispute purposes. This does not extend the retention of Presence settings, memory data, Private Conversation Content, or Time Capsule materials, which are handled under their respective retention rules below.

16.2 Presence settings and memory data: retained while the relevant Presence or Account remains active, and generally deleted from active systems within 30 days after eligible deletion requests, subject to product-specific retention commitments.

16.3 Private Conversation Content: retained to provide conversation history and memory features; when deleted by the user or after account deletion, deletion from active systems generally occurs within 30 days, with residual backup deletion aligned with backup cycles.

16.4 Memorial Service data: retained according to the purchase page, Entitlement Snapshot, and applicable product terms, such as a stated 15-year service or retention period. Unless required otherwise by law, safety, fraud prevention, or enforcement needs, memorial data is generally retained for the committed memorial service period unless the user requests deletion.

16.5 Payment and transaction records: retained for up to 7 years where required for accounting, tax, platform, fraud prevention, chargeback, and legal compliance.

16.6 Security logs and diagnostic logs: generally retained between 180 days and 24 months, depending on security, debugging, fraud prevention, and system integrity needs.

16.7 Support records: generally retained up to 24 months after ticket closure unless longer retention is required by law or dispute handling.

16.8 Backups: deleted or overwritten on scheduled backup cycles, generally within 90 days, unless preserved for legal, security, or disaster recovery reasons.

16.9 Plan downgrade and Presence-limit changes: where a downgrade reduces allowed Presence quantity, affected excess Presences are generally moved to an archived or inactive state before deletion. We generally provide a transition period (for example, 30 to 90 days depending on product rules) to restore eligibility, export data where available, or request deletion.

16.10 Time Capsule materials: retained while the related Presence or Account remains active; when you delete the related Presence, related media, or your Account, these materials generally follow the same deletion workflow as uploaded content, subject to backup cycles, legal retention requirements, safety controls, and dispute-handling needs. Uploaded content (other than Time Capsule materials) generally follows the retention and deletion workflow of the corresponding content category and product functionality, subject to backup cycles, legal retention requirements, safety controls, and dispute-handling needs.

16.11 Authority verification and dispute evidence data: generally retained only for as long as needed to review and resolve the relevant case, and typically deleted or de-identified within 180 days after closure unless legal hold, security, anti-fraud, or mandatory compliance requirements require longer retention.

16.12 Retention handling may differ across Private Conversation Content, other User Content, and Time Capsule materials based on product functionality, safety controls, and legal requirements.

We may anonymize or aggregate data so it no longer identifies you, using de-identification measures and periodic review intended to prevent re-identification. Such data may be retained for analytics, security, product reliability, and business purposes.

17. Account Deletion and Data Deletion

17.1 You may request account deletion through in-app controls or by contacting us.

17.2 After verifying the request, we will start deletion or anonymization workflows for personal data associated with your Account, subject to legal exceptions.

17.3 Some data may be retained where necessary for legal compliance, fraud prevention, security, accounting, dispute resolution, enforcement, or platform requirements.

17.4 Deletion from active systems may occur before deletion from backups.

17.5 If your data is associated with a Memorial Service, deletion may affect the availability of that product and related entitlements.

17.6 We generally complete deletion from active systems within 30 days after successful verification, unless technical complexity or legal requirements justify a longer period.

17.7 Backup deletion generally follows scheduled cycles and is typically completed within 90 days.

17.8 For Memorial Service data, we may require additional confirmation steps before deletion to reduce accidental deletion risk; once completed, deletion may be irreversible and may end related visitor access or memorial entitlements.

17.9 Where Time Capsule materials are enabled for your account, deleting related Presence data or account data may permanently remove associated Time Capsule voice, video, image, and delivery metadata.

17.10 If DearWith suspends or terminates an account for violations, abuse, fraud, safety risk, or legal requirements, we may immediately restrict access, preserve relevant records for investigation and compliance, and then delete or anonymize remaining data according to this Policy and applicable law.

17.11 If a user does not provide reasonably requested authority or consent evidence in a dispute workflow, we may remove or restrict specific Time Capsule content and related features while retaining only the minimum records needed for safety, legal compliance, and review rights.

17.12 Deletion workflows may be implemented differently across Private Conversation Content, other User Content, and Time Capsule materials to reflect operational dependencies, safety controls, and legal retention obligations.

18. Your Privacy Rights

Depending on your location and applicable law, you may have rights to:

18.1 Access personal data associated with your account and use of the Service that we process.

18.2 Request correction of inaccurate or incomplete data.

18.3 Request deletion of personal data.

18.4 Request portability or export of certain data.

18.5 Object to or restrict certain processing.

18.6 Withdraw consent where processing is based on consent.

18.7 Appeal or challenge certain decisions where applicable.

18.8 Lodge a complaint with a competent privacy regulator.

We may verify your identity before responding. We generally aim to respond within 30 to 45 days unless a shorter or longer period is required or allowed by applicable law.

19. United States Privacy Notice

For users in the United States:

19.1 DearWith does not sell personal information.

19.2 DearWith does not share personal information for cross-context behavioral advertising.

19.3 Depending on your state, you may have rights to access, delete, correct, port, or opt out of certain processing.

19.4 We do not knowingly process personal information of children under 13.

19.5 We do not use sensitive personal information for purposes that require a "limit use" choice under California law unless disclosed in a regional notice.

19.6 We may provide additional state-specific notices if required.

19.7 Where applicable U.S. state AI laws require AI interaction disclosure, we provide clear and conspicuous notices when users are interacting with AI systems, including additional notices for legally defined high-risk or regulated scenarios.

19.8 If DearWith deploys covered automated decision-making technology in legally defined consequential-decision scenarios in a specific U.S. state, we may provide additional pre-use notices, post-decision disclosures, correction channels, and meaningful human review rights required by law.

20. California Notice

If California privacy law applies, California residents may have rights to:

20.1 Know categories of personal information collected, sources, purposes, and disclosures.

20.2 Access specific pieces of personal information.

20.3 Delete personal information.

20.4 Correct inaccurate personal information.

20.5 Opt out of sale or sharing. DearWith does not sell or share personal information for cross-context behavioral advertising.

20.6 Limit use of sensitive personal information where applicable.

20.7 Non-discrimination for exercising privacy rights.

Categories of personal information may include identifiers, account data, internet or device activity, transaction data, user-generated content, sensitive information voluntarily provided, and inferences used only for service functionality and safety.

21. Singapore PDPA Notice

For Singapore users:

21.1 We collect, use, and disclose personal data for the purposes described in this Policy.

21.2 We may transfer personal data outside Singapore, including to the United States, with safeguards intended to provide comparable protection as required by the PDPA.

21.3 You may request access to and correction of your personal data.

21.4 You may withdraw consent where processing is based on consent, but withdrawal may affect service availability.

21.5 We will assess and notify relevant parties of notifiable data breaches as required by Singapore law.

21.6 Our data protection contact for PDPA-related requests is contact@dearwith.ai.

22. EEA, UK, and Switzerland Notice

Where GDPR, UK GDPR, or similar law applies:

22.1 The controller is UNIUME PTE. LTD., unless otherwise stated.

22.2 Processing bases may include contract performance, legitimate interests, consent, and legal obligations.

22.3 You may have rights of access, rectification, erasure, restriction, objection, portability, and complaint to a supervisory authority.

22.4 Cross-border transfers may rely on appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms.

22.5 You may object to processing based on legitimate interests where applicable.

22.6 DearWith has not appointed an EU representative at this time. If DearWith makes the Service available in the EEA in a manner that triggers GDPR Article 27, DearWith will appoint and publish details for an EU representative before or when legally required, unless an exemption applies.

22.7 Where EU AI transparency obligations apply to specific DearWith features, we may provide additional AI-interaction disclosures, synthetic-content labels, or detectability controls consistent with applicable law.

23. Canada Notice

For Canadian users:

23.1 You may request access to and correction of personal information.

23.2 You may withdraw consent, subject to legal or contractual restrictions and reasonable notice.

23.3 Personal information may be processed outside Canada and may be subject to foreign laws.

23.4 You may contact us with privacy questions or complaints.

24. Australia, New Zealand, Japan, and Korea Notice

For users in Australia, New Zealand, Japan, or Korea:

24.1 You may request access to and correction of your personal information.

24.2 We may process personal information outside your country of residence.

24.3 You may contact us to make a privacy complaint.

24.4 Nothing in this Policy limits non-waivable consumer or privacy rights.

24.5 For Japan users, additional disclosures under APPI may be provided where required.

24.6 For Korea users, additional disclosures under PIPA or related regulations may be provided where required.

25. Cookies and Similar Technologies

We may use cookies, local storage, device identifiers, and similar technologies to:

25.1 Keep you signed in.

25.2 Remember settings and preferences.

25.3 Maintain security.

25.4 Measure service reliability.

25.5 Diagnose errors.

Where required, we will provide consent controls or additional notices.

26. Security

We use technical, organizational, and administrative safeguards designed to protect personal data, including:

26.1 Access controls.

26.2 Authentication and authorization.

26.3 Logging and monitoring.

26.4 Encryption where appropriate.

26.5 Vendor review and contractual controls.

26.6 Incident response processes.

26.7 Internal confidentiality controls.

No system can be guaranteed to be absolutely secure. We work to reduce risk and respond appropriately to security incidents.

27. Data Breach Notification

If a notifiable data breach occurs, we will assess the incident and notify affected users, regulators, platforms, or other parties as required by applicable law and legal timelines.

28. Automated Processing and Safety Systems

DearWith may use automated systems to support:

28.1 AI response generation.

28.2 Abuse detection.

28.3 Fraud prevention.

28.4 Security monitoring.

28.5 Content safety and policy enforcement.

28.6 AI transparency notices and labeling workflows where required by applicable law.

28.7 Deepfake and synthetic-content disclosure workflows where required by applicable law.

28.8 Risk-based automated safety screening of uploaded materials, user inputs, and AI interactions (including Time Capsule media), with limited human-assisted review where needed.

We do not use automated processing to make legal or similarly significant decisions about you without appropriate safeguards where required by law.

29. Changes to This Privacy Policy

We may update this Policy from time to time. Material changes may be communicated through app notice, website posting, email, or similar reasonable means. Updated versions become effective on the stated date.

30. Contact

For privacy requests or questions: