EasyClaw Privacy Policy

"EasyClaw" (including the channel version of EasyClaw; specific product names shall be based on each channel version, and include PC, mobile and cloud versions, hereinafter referred to as "the Product" or "the Service") is developed and operated by DocuAgile Pte. Ltd. (hereinafter referred to as "us" or "the Company"). We respect the privacy of users and protect the security of personal information throughout the process of developing and operating EasyClaw. We are committed to protecting the security of your personal information in accordance with the law and mature security standards of the industry.

This Privacy Policy will introduce to you how we process personal information in different scenarios. When you open or use EasyClaw, we process any personal information relating to it in order to use the function or service that you choose to use or to comply with the requirements of laws and regulations. You may refuse to allow us to process personal information other than that necessary under the laws and regulations, but this may make it impossible for us to provide the corresponding function or service to you. We explain relevant situations item by item in our Privacy Policy. Important clauses regarding your personal information rights and interests have been highlighted in bold form, and sensitive personal information has been highlighted in bold or underlined. Please pay special attention to them.

In addition to this Privacy Policy, in certain scenarios, we also inform you of the purpose, scope and use of personal information by means of instant notification (including pop-up window, page prompt, etc.) and explanation of function updates. Such instant notification and explanation of function updates shall constitute a part of this Privacy Policy and shall have the same effect as this Privacy Policy.

This Privacy Policy will help you to understand the following:

1. How we collect and use your personal information;
2. Third-party products and services;
3. How we entrust, share, transfer or publicly disclose your personal information;
4. How we process the personal information of minors;
5. How you manage your personal information;
6. How we store and protect your personal information;
7. Links to other websites;
8. Updates to this Privacy Policy;
9. Special information for US residents; and
10. How to contact us.

I. How We Collect and Use Your Personal Information

We collect and process your personal information for the following purposes:

1.1 Account Registration/Log-in

When you register an EasyClaw account, we will collect your Google authorization code/token for the purpose of completing the account registration and log-in.

1.2 Value-added Services

You can choose to recharge members to use more rich functions. In the process, in order to help you recharge members, we will collect your order information (order number, order amount), transaction time, and transaction status.

1.3 Information Processing in Core Functional Scenarios

(1) AI Conversation Assistant

When you use the Product Default Model:

• Types of information collected: unsolicited question text, uploaded picture, clipboard content, file, voice, conversation interaction record (with context information you supplement), feedback (satisfied or dissatisfied) on what was generated/what was done.
• Use of information: AI algorithm to analyze your requirements, generate corresponding answers, provide you with accurate knowledge query services, and help you to manage your Q&A history.
• Information processing: The information you input will be encrypted and uploaded to a third-party cloud server for processing, and the generated results will be immediately returned to your device. All conversation records will be stored in your account and only available to you. All conversation records will be deleted when you log out and will not be retained or used for other purposes.

When you use Custom Models: When you configure and use a third-party Big Model acquired by you, you will be required to input your Model API Key, but the above information will only be kept on your local Device. When you use it, your Input Content will be directly sent to the third-party Big Model, and the third-party Big Model will process the Input Content and return output Content directly to you. You and the third-party Big Model shall agree on the specific data processing rules.

(2) AI Auxiliary Operation Function

• Types of information collected: Input Content, Screenshot of the current screen (including the coordinate information), screen resolution, window display state, screen content related to the execution of tasks, click coordinate set by you, click frequency, identification of the window triggered by the operation.
• Purpose of Information: Only when you trigger the function actively, we will temporarily obtain such information and automatically complete the operation task to meet your operation instructions.
• Information processing method: The screenshot data and screen content are only temporarily stored locally and automatically erased after you complete any operation (e.g. saving screenshot, closing function or ceasing operation). The screen content will not be uploaded to the server. The function will be started only after you give express authorization; all operation instructions are only executed locally and the input text is only used temporarily for simulation and will not be uploaded to the server. After completion of the operation, the default instructions and input content will be erased automatically and will only be used with your active authorization.

(3) PowerShell Scripting Function

• Type of information collected: PowerShell script content that you input or upload, script execution log, execution result data returned by the system.
• Information use purpose: Parse and execute your script instructions, complete system management, file processing and other custom operations.
• Information processing method: The script content is executed locally only, and the execution log is only used for you to view the operation result, and the script content or file data in the process of execution is not uploaded. The script file is controlled by you, and we do not store or tamper with your script content.

(4) Timed Task Function

• Type of information collected: You input the task name and icon, execution time, AI instructions.
• Purpose of information use: Timed execution of the related tasks you set.
• Information processing method: Only stored and scheduled for execution, not uploading your task content, operation instructions or execution results to a third-party server, not for other purposes.

(5) Mobile Phone Remote Function

• Type of information collected: App ID of Feishu, DingTalk, App Secret, and record of your interaction with the mobile phone robot.
• Information use purpose: By using a mobile phone to send messages, to remotely control a computer to complete instructions.
• Information processing method: The App ID and App Secret of the third-party platforms you provide will be encrypted and stored and used to establish a legally authorized connection. The interactive instructions and records will be encrypted and transmitted to the server for parsing the remote operation instructions and delivering them for execution. Relevant information will only be used to implement the mobile phone remote control the computer function, and will not be used for other purposes or provided to a third party.

This function needs to rely on the mobile side of this product to support.

(6) Cloud Bot Service

• Type of information collected: User ID, cloud device ID bound to the cloud bot service, device model, and operating system version and name.
• Purpose of information use: Your user ID is matched with the cloud device ID to realize a connection with the cloud bot service. According to your operation instructions, the cloud bot executes the task and returns the result to your mobile phone.
• Information processing method: The above information will be encrypted and stored and used to establish the connection. The interactive instructions and records will be encrypted and transmitted to the server for parsing the remote operation instructions and delivering them for execution. Relevant information will only be used to realize the cloud bot service, and will not be used for other purposes or provided to a third party.

When you use the QR code to log in, take a photo and send a picture, upon your authorization, the application will call the device's camera for scanning the QR code or taking a photo. The relevant photo or image is only used to complete the function initiated by you, and the camera will not be called in the background or without authorization. When you enter the scanned login page and authorize the use of the camera, the scanned component mobile_scanner and its underlying AndroidX CameraX camera component used by the application will query the device's acceleration sensor through the Android system interface during the camera initialization process for detecting the camera direction adaptation capability. The access involves the availability of the acceleration sensor and the corresponding system sensor object, and does not involve the collection or upload of real-time acceleration measurement values as the scanned login information. The application will not set a silence or background regular collection task for the query.

1.4 Personal Information Provided by You

• Customer service: When you consult us, feedback problems or complain through online customer service and complaint channels, in order to quickly locate the problem, effectively communicate with you and provide solutions, we may need you to provide device model, system version, software version number, feedback content, contact information (mobile phone number, WeChat number), screenshots you uploaded, and chat records between you and customer service. If you refuse to provide the above information, we may not be able to solve the problem for you in a timely and accurate manner, which will not affect your use of other functions.
• Authorization for networking services: In order to determine whether your device is capable of networking, so as to provide the networking functions (e.g. AI assisted operations), we will obtain your network status authority (e.g. Wi-Fi/mobile network connection status) for the sole purpose of determining function availability, and will not collect network communication contents.
• Product data analysis: When you log in, complete the payment, and use the membership functions for the first time, we will collect your IP address and device model for the purposes of calculating the number of products downloaded, installed and active degree. The data will be used for summary analysis only, not for personal identification, and only to optimize the product experience.
• We will automatically obtain your device identification information through Android system API, i.e. Android ID (Android system will allocate the unique identifier to each device), device brand, model and system version information. It is used for statistical analysis of user behavior, product optimization and problem troubleshooting. Data is collected only after you agree to this Privacy Policy. Data will be used for anonymous statistics and will not be used to identify you.

2. Other Rules for Collection and Use of Personal Information

2.1 We will not use your information for any purpose other than the aforementioned functions. If we need to use it for any other purpose, we will obtain your prior consent. Once you give such consent, you are deemed to have acknowledged that the processing of such personal information will also be governed by this Privacy Policy.

2.2 You are fully aware that, under the following circumstances, our collection and use of your personal information are not subject to your express consent:

1. relating to the performance of legal duties or legal obligations;
2. necessary in order to cope with a public health emergency, or in the case of an emergency, in order to protect the life, health and property of natural persons;
3. processing personal information within a reasonable extent to carry out activities such as news report and supervision by public opinion for the public interests;
4. the personal information collected is public information self-disclosed by the person or other information that has already been legally disclosed to the public;
5. it is necessary to enter into and perform a contract at your request; and
6. other circumstances provided by laws and regulations.

If we use the personal information for any purposes not described in this Privacy Policy, or we use the personal information we have collected for any specific purpose for any other purpose, we shall obtain your express prior consent, and this Privacy Policy will apply to the collected personal information after you agree.

Special Notice: If the information cannot be identified to you alone or in combination with other information, it shall not be considered as personal information for the purpose of law. If the personally identifiable information can be combined with other information but can be identified to you, such information will be handled and protected in accordance with this Privacy Policy during the combined use.

II. Third-Party Products and Services

Some functions of EasyClaw need to access third-party SDKs or services (collectively, "third-party services") in order to enable login, payment and AI processing. We have established a mechanism to manage access to the third-party services and will conduct necessary assessment of their information security capabilities prior to access. However, we cannot control the operation behaviors of the third-party services and we make no express or implied warranty of the compliance of their data processing. As an independent data controller, the third-party services will process your personal information in accordance with their own privacy policy. Please read the third-party privacy policy before use.

1. ThinkingData SDK

Provider: ThinkingData Information Technology (Shanghai) Co., Ltd.

Type of Information Collected: Equipment ID, client version, operating system of members.

Purpose of Use: Product use analysis.

Privacy Policy link: https://www.thinkingai.cn/privacy/

2. Stripe SDK

Provider: Stripe, Inc.

Type of Information Collected: Business Administrator logo, Stripe Customer/PaymentIntent/Subscription/Invoice logo, order number, package, seat/usage, amount, currency, type of payment method, payment and refund status.

Purpose of Use: To realize the payment function.

Privacy Policy link: https://stripe.com/privacy

In addition to the above third-party SDK, EasyClaw also has a built-in model adaptation service, which is used to connect with third-party big model service providers. This function is turned off by default, and requires companies to start it on the basis of their needs. When a company member selects the corresponding big model to initiate a dialogue or task, the product will encrypt and upload the member's logo, prompt, dialogue/task context, as well as documents, images and other information included in the task to the selected third-party big model service provider for deduction. Third-party big model service provider shall process relevant information according to its own privacy policy.

III. How We Use the Information We Collect

We will only use your personal information as permitted by applicable law. Our lawful basis for the collection and use of the personal information described in this Policy depends on the personal information we collect and the specific context in which we collect the information:

• Our need to perform contracts with you;
• You have given our consent to do so;
• Our processing of your personal information in certain jurisdictions may be consistent with our legitimate interests, including:
  • Detecting, preventing and enforcing breaches of our User Agreements, including service misuse, fraud, abuse and other security agreements; and
  • Protecting our lawful rights and the rights of others.
• If lawful interest is not an available legal basis in a particular jurisdiction, we will pursue the above processing on the basis of the laws available in that particular jurisdiction;
• We are subject to statutory obligations imposed by applicable law.

IV. How We Disclose Your Information

For the purposes explained in this Policy, we may disclose your personal information to third parties if:

We will disclose your personal information only where it is lawful, justified, necessary, specific and express and we will share only such personal information as is necessary to provide the services. By agreement, we will require our partners to retain data only for as long as necessary and to implement adequate security measures to protect the security of the data.

For the purposes explained in this Policy, we will disclose your personal information to the following categories of third parties:

• Affiliates and corporate partners. We may disclose these personal information among our affiliates and related entities for legitimate business purposes and in connection with the operation of the services, in accordance with applicable law.
• Service providers and business partners. Third-party service providers who provide us with information technology services (e.g., cloud storage services) and business support services (e.g., statistical analytics and/or advertising service providers) may be required to process your data. These third parties will process your personal information on our behalf in accordance with the applicable agreements.
• Law enforcement agencies, public authorities or other judicial authorities and organizations. We may disclose your personal information if we are required by law to do so or if we in good faith believe that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our User Agreement and other terms, policies and standards, including investigating any potential breaches; detect, prevent or otherwise resolve security, fraud or technical problems; or protect our, our users', third parties' or the public rights, property or security, as required or permitted by applicable law (including exchanging information with other companies and organisations for the purpose of fraud prevention).
• Change in our ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, sale of assets or other transaction, we may disclose your personal information as part of such transaction.

V. How We Protect Minors

Our services are not targeted at, and we do not knowingly collect personal information from, children under the age of 18, except as permitted by applicable law. If we become aware that we have unknowingly collected personal information from a child, we will use commercially reasonable efforts to remove that information from our database.

VI. Security

We are committed to ensuring the security of your personal information. We have appropriate physical, technical and administrative safeguards in place to protect the confidentiality of your personal information. In addition, we require our service providers who process personal information to also maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of personal information that you provide to us.

While we will take all reasonable steps to protect your personal information, we cannot guarantee the absolute security of your personal information or the protection against loss, misuse, unauthorized access or alteration of your personal information. Nor are we able to protect any personal information about you that is not within our control, such as any information transmitted via email or a wireless connection.

It is also your responsibility to keep your personal information secure. When we request that you open an account, you should choose a passcode of adequate length and complexity and you should keep your passcode confidential. Do not leave your device unlocked so that other individuals can access it. Ensure that you trust the wireless connection you are using to access or use our services.

VII. Retention of Personal Information

We maintain a retention policy with respect to the personal information that we collect to ensure that we do not retain it longer than necessary to perform its intended purpose. We store different periods of time for different kinds of personal information collected according to our service needs and regulatory requirements.

Upon expiry of the retention period, we will delete or anonymize your personal information. We will take measures so that the information cannot be retrieved or duplicated.

In assessing the length of time your personal information will be retained, we will take into account the following criteria: (i) the nature of the personal information and the activities involved with it; (ii) the time and duration of your use of our services; and (iii) our legitimate rights and obligations.

VIII. Your Data Subject Rights and Options

Subject to applicable law, and depending on your place of residence, you may have certain rights in relation to your personal information, which are set out below. Please contact us if you have any other requests regarding access to your personal information.

A. Data Access

You may be entitled to know what personal information we process about you, including the categories of personal information we process, the business or business purposes for which it is collected, the categories of third parties and other information we disclose to them pursuant to applicable law. If you request a copy of the personal information that we hold about you, we will provide it to you promptly at no charge, except where we are permitted by law to make a fee.

B. Correction of Data

In some exceptional circumstances, you may be entitled to request us to correct inaccurate personal information that we retain about you.

Please note that we cannot guarantee the actual accuracy of the output. If the output contains inaccurate personal information about you, you can submit a correction request. We will use reasonable efforts to correct the information but may not always be able to do so due to the technical complexity of the AI models integrated into the product.

C. Data Portability

You may contact us to request provision of the personal information that you provide to us in a structured, common and machine-readable format and transfer to another controller where applicable.

D. Data Deletion

You have the right to delete your account and to erase your personal information. When you delete your account, all personal information will be deleted. Alternatively, you may contact us to request deletion of personal information that you have provided. If certain personal information about you cannot be deleted, we will communicate the reasons why you are unable to take the relevant action.

Please note that we reserve the right to retain certain personal information about you as long as reasonably permitted by applicable law.

E. Withdrawal of Consent

If we process your personal information on the basis of your consent, you may withdraw your consent by contacting us. The withdrawal of consent will not affect the legality of a process made based on the consent that was prior to the withdrawal.

We are not currently using your personal information for marketing purposes. If we use your personal information for marketing purposes, you will have the right to utilize the opt-out mechanism provided under such communication or to withdraw your consent to receive direct marketing information by contacting us.

Objection to Processing

Subject to applicable laws, you may contact us if there are reasons relating to your particular circumstances. We have legitimate interests to object to our processing of your personal information. You are advised that we may have an overriding legitimate interest in the continued processing of your personal information, but will notify you of these circumstances.

Restriction on Processing

You may contact us if you would like to restrict the processing of your personal information. You have the right to restrict our processing of your data if:

• The processing is unlawful and you object to the deletion of the personal information concerned;
• You have requested us to retain your personal information which should have been deleted for the purpose of establishing, exercising or defending a legal claim;
• Your objection to the accuracy of your personal information is pending verification by us;
• Your objection to our processing of your personal information is pending verification by us.

Other Rights

You may have other rights in relation to your personal information to which you are entitled under your jurisdiction. For example, if you believe that the processing of your personal information is in breach of any applicable data protection legislation (e.g., the EU GDPR), you may be entitled to lodge a complaint with the relevant data protection authority. For residents of the United States, please find more details of your rights in Section 9 below.

If you wish to contact us to exercise one or more of the above rights, to ask questions about the above rights or about any other provisions of this Policy, or about our handling of your personal information, or to make a complaint about the manner in which we handle your personal information, you can contact us at support@EasyClaw.com. If you have a claim, please state the scope and basis of your claim and provide us with the necessary information to verify your identity. We may contact you to confirm your identity in order to process your request. We will respond to any request or complaint within a reasonable time in accordance with applicable data protection legislation.

IX. Special Information for US Residents

We have collected personal information since the launch of the product, as described more fully in Section 1 above. We will update this disclosure on May 1st of each year as requested by the CCPA.

As an introduction of a new service by us, we have also disclosed personal information to third parties since the launch of the product, as described more fully below. We will update this disclosure on an annual basis as requested by the CCPA. You are also entitled to a list of third parties to whom we are required to disclose your personal information in accordance with certain state data protection laws.

To the extent required by your local law and subject to applicable exceptions, you may have the following rights:

• Limiting the Use of Sensitive Personal Information. The definition and scope of "sensitive personal information" can vary based on applicable state data protection laws, but generally includes a person's race or ethnicity, religious affiliation, sexual orientation, personal health data, biometric data, financial data, credit data, online data for children under 13, and precise location information. Subject to certain exceptions, you have the right to limit the use and disclosure of your sensitive personal information. If you would like to limit the use of your sensitive personal information, please contact us using the contact information provided below.
• You are prohibited from Selling or Sharing My Personal Information. Consistent with the terms "sale" and "sharing" as defined in applicable state data protection law, it is our belief that we are not engaged in such activities and have not been engaged in such activities in the past 12 months from the effective date of this policy. Certain data collected on our websites and applications by third parties for the purpose of interest-based advertising and social media tools could be deemed to be "selling" or "sharing" under California privacy laws.
• Appeal. You may appeal our denial to take action by contacting us using the contact information provided below.
• Direct Marketing. We will not disclose personal information to third parties for their direct marketing purposes.
• Right of Non-Discrimination. You are entitled not to be discriminated against for exercising any of your rights.
• Rights of Authorized Agents. Under some state data protection laws, you may have the right to designate another person or persons to make requests on your behalf. We verify all requests by e-mail before taking any action and reserve the right to reject requests if we are unable to satisfactorily verify your identity. This right also applies to requests submitted on your behalf by others.

If you would like to contact us to exercise one or more of these rights, to ask questions about these rights or about any other provision of this policy, or about what we do with, or to make a complaint about, our handling of your personal information, you may use the contact information provided in section 10 below. Subject to applicable law, we may require documents from you, such as application forms and identification evidence. To process a request, we may contact you to confirm your identity. We will respond to any request or complaint promptly to the extent permitted by applicable law.

X. How to Contact Us

If you would like more information about your data subject rights or about what we do with your personal information, please contact us using the information below.

Contact Information: support@EasyClaw.com