This is a review draft of the Privacy Policy for the Nana App and website and is not yet effective. The operator is 米诺拉（武汉）人工智能应用软件有限公司. Customer support and privacy requests can be sent to contact@minola.com.cn. The draft covers planned services in the United States, Japan, South Korea, Macao, Taiwan, and Hong Kong. AWS is planned for overseas hosting, but has not been purchased and no region has been selected; actual providers, data flows, and retention periods remain to be confirmed. Viewing this draft does not authorize data processing. The final version will state its effective date separately.
1. Scope
This draft explains the personal information processing that may be involved in Nana App accounts, interactions with AI characters, voice features, character creation, sharing, and paid services. Available features depend on the version actually offered to you. Listing an inactive feature here does not require you to provide information for it.
The website presents the product and agreements. After signing in to a Nana account, you can also browse characters and have text conversations. Sign-in credentials are used to request existing Nana services, and the current browser session maintains your sign-in. Account information, messages, and related service logs you submit are processed according to the features you use. Paid purchases are not currently available on the website. Actual hosting access logs and retention rules still need to be disclosed at official launch. Third-party payments and other third-party services are subject to their own rules.
This policy applies to the App and Web features actually provided. The supplementary provisions for the United States, Japan, South Korea, Macao, Taiwan, and Hong Kong apply according to the scope of the respective local laws. Applicable rules depend on users' locations, the markets targeted by the service, and actual processing activities; the page language and server market code do not determine which laws apply. Mandatory local protections prevail over conflicting general terms. Mainland Chinese rules do not automatically replace local requirements.
2. Features and information
The following is based on the existing App and server code. Apart from information necessary for the relevant feature, you can choose whether to provide an avatar, gender, or custom content. Please avoid entering unrelated identity documents, health or financial information, or other people's private information in conversations, character settings, or shared content.
| Use case | Information that may be processed | Purpose |
|---|---|---|
| Registration and sign-in | Email address, verification code, and Apple, Google, or other sign-in identifiers for your chosen method; phone number and authentication information for existing phone-based accounts | Verify identity, maintain sign-in, and protect account security |
| Profile | User ID, nickname, avatar, optional gender, voice preferences, and account settings | Display your profile and save preferences |
| Text and voice interactions | Conversation text, voice recordings and transcripts, AI replies, conversation history, and preferences and contextual memories derived from interactions | Generate replies, maintain conversation continuity, and synchronize chat history |
| Identity verification and protection of minors | Birth date you declare for overseas services and eligibility computed for the current service market; name, identity-document number, verification result and teen-mode settings where identity verification is actually available | Determine service age eligibility from the declared birth date; verify identity and apply safeguards where identity verification is actually offered |
| Voice and character creation | Images and audio samples you choose to upload; character names, settings, descriptions, voice identifiers, and visibility settings | Create characters, transcribe speech, synthesize speech, and customize voices |
| Content sharing | Conversation excerpts you actively select and confirm, redacted text, public character profiles, and sharing records | Generate share cards or public character links |
| Purchases and assets | Products, orders, Apple transaction IDs and signed transaction data, membership status, Candy or Voice Card balances, and spending records | Confirm payments, grant entitlements, restore purchases, and reconcile accounts |
| User feedback and character reports | Signed-in user ID, feedback ID, category and content, optional contact details, platform and App version; selected character ID and name snapshot for character feedback, submission time and processing status | Register and investigate issues and character reports, and allow authorized administrators to review and process feedback |
| Notifications and service operation | Notification device tokens, installation identifiers, client platform, language and region settings, network requests, and error logs | Send authorized notifications, adapt services, protect security, and troubleshoot problems |
3. You control device permissions
Relevant features request system permission when needed. You can turn permissions off in your device settings. This may disable the corresponding features without affecting features that do not need those permissions. When using the system photo or file picker, only the content you actively select is read.
- Microphone: record voice messages, participate in voice interactions, or record voice samples you choose to provide.
- Camera: take photos you choose to use as your avatar.
- Save photos: save share cards you confirm to your photo library.
- Notifications: send new-message and other notifications after you authorize them. You can manage both system permissions and in-App notification settings.
4. Sensitive information and AI processing
Identity document information, and audio or conversations containing biometric characteristics, health conditions, or similar information, may constitute sensitive personal information. Processing it requires a specific purpose, sufficient necessity, and strict protection. Where the law requires separate consent or a guardian's consent, it must be obtained before processing; agreeing to this policy cannot replace it.
AI replies require processing the content you send and the necessary conversation context. Voice features may also involve speech recognition, speech synthesis, or voice services. Please upload only voices, photos, and other materials that belong to you or that you are legally authorized to use.
Interaction data that constitutes sensitive personal information may be used for model training only where applicable law permits and all statutory conditions are met. Where consent is relied on, applicable separate or written consent requirements must be satisfied. Consent cannot replace requirements of necessity, special security measures, or statutory notification or authorization. This preview has not confirmed every model provider’s training, retention, and subcontracting arrangements and does not constitute consent to such uses. The final version will clearly distinguish inference processing needed to provide replies from separately conducted training uses.
Conversations and memories may contain or infer private matters such as health, emotions, and sex life. An ordinary voice recording is different from a voiceprint used to identify someone. Whether information receives special protection depends on local law and the actual processing. Microphone permission authorizes recording; it does not constitute consent to voice cloning, voiceprint extraction, training, or public sharing. Any additional prior permission, written authorization, or regulatory procedure required by applicable law must be completed first.
6. Retention and security
Chat history is stored locally in the App and on the server to support continued conversations and synchronization. Some preferences and interaction summaries may be stored as memories. Uploaded files such as avatars and voice samples may be stored separately from database records. Signing out does not automatically delete this information.
Information should be retained for the shortest period necessary to achieve its processing purpose, while legally required retention is handled in accordance with the law. This preview has not confirmed specific production retention periods, backup rotation, or cloud file cleanup arrangements. The official policy will include actionable retention rules.
The current implementation includes account authentication, encryption of certain sensitive fields, and access controls. Official operation also requires continued improvements to permission management, log protection, and incident response. We do not promise absolute security through technical measures.
The planned overseas AWS deployment has not been purchased. Its country or region, contracting entity, backup locations, and remote-access arrangements have not been determined. The current preview site and model options in the code do not establish the data locations or provider list for the final overseas service. Before transferring, storing, or allowing remote access to data in another country or region, the recipients, locations, purposes, data categories, retention periods, and applicable safeguards should be disclosed, and the legal procedures required locally should be completed. Where separate consent is required, it must be obtained before the transfer.
7. Your personal information rights
Under applicable law, you have rights to information, access, copies, correction, and other personal-information rights. The conditions for deletion, cessation of processing, withdrawal of consent, portability, objection, appeals, and other rights are determined by local law and the regional provisions below. You can edit profile information made editable in the App and withdraw corresponding permissions in system settings.
Privacy questions or rights requests can be sent to contact@minola.com.cn or submitted through Other in User Feedback in the App. Please provide information identifying your account, the request, and a way to reply; do not send passwords or complete identity documents directly. Verification should be limited to necessary information. If all or part of a request cannot lawfully be fulfilled, the reasons and available remedies should be explained. The verification and fulfillment procedures still need to be implemented before official launch; this draft does not extend statutory deadlines. If your birth date was entered incorrectly, use this channel to request a review. You cannot repeatedly change it yourself to bypass age restrictions.
Withdrawing consent does not affect processing lawfully carried out before withdrawal, nor does it automatically require deletion of information that must legally be retained. Refusing information that is necessary for a particular feature may make that feature unavailable. Refusing optional information or unnecessary processing should not affect unrelated features. Account deletion and requests to delete specific data should be assessed separately; closing an account must not be the only way to exercise all rights.
8. Account deletion
In the App's Me section, open the relevant account management page, select Delete User, read the notice, and confirm. The current action sends an account deletion request to the server. After success, it clears that account's local chat data and sign-in state on the current device. Deletion is generally irreversible, so first review any entitlements and records you still need.
The scope and completion time for deleting related database information, uploaded cloud files, backups, and copies processed by third parties still need to be verified individually before official launch. This preview does not promise immediate removal of every copy after deletion. Information that must legally be retained should have its use restricted and be handled when the statutory retention period ends.
Deleting your Nana account or removing the App does not cancel an Apple subscription. If you have an auto-renewing subscription, manage it separately in your Apple account's subscription settings. Account deletion does not automatically remove your lawful refund or other consumer rights.
9. Protection of minors
The overseas AI companion services described in this draft are available only to users who meet both the local age-of-majority requirements and the service age threshold. The current threshold is age 19 for GLOBAL and the South Korean market, and age 18 for other overseas markets. Any stricter local age-of-majority requirement also applies. You declare and submit your birth date to the server to calculate eligibility. This is not identity-document verification, and you cannot edit the date yourself after submission. Language or region settings cannot lower the threshold. Age-appropriate features in mainland China and processing of personal information of children under 14 are separately subject to local requirements.
The current version includes youth mode and certain content and spending restrictions. This does not mean that all age identification, guardian consent, and appeal measures are complete. Until these capabilities have been verified as complete, this preview cannot serve as a basis for opening services to minors.
10. Updates and contact
Material changes to the official policy affecting your rights should be communicated prominently. Where renewed consent is required, it should be obtained before the relevant processing. The date on this page is the draft's update date, not its effective date.
Operator: 米诺拉（武汉）人工智能应用软件有限公司. Customer support, privacy rights requests, complaints, and appeals: contact@minola.com.cn. User Feedback in the App and Report or Seek Help in character conversation settings can also record issues. The company contact address, the role of its privacy officer, and local representatives, where applicable, still need to be added. The email address was provided by the operator; receipt and handling procedures must be verified before official launch. Neither feedback nor email is a real-time emergency assistance channel.
11. Third-party AI and separate choices
To provide AI replies, the content you submit and the necessary context are processed by the model services actually enabled. Speech recognition, synthesis, and custom voices may be handled by different providers. Before a service is enabled, its legal entity, contact details and privacy rules, information received, purposes, storage or processing locations, and retention periods should be explained individually in understandable terms. Listing AWS or a model brand alone is insufficient notice.
Acceptance of service terms, privacy notices, permission to send personal information to third-party AI, consent required for sensitive information or cross-border processing, optional training, marketing, and voice authorization should be handled separately according to their actual purposes. Where the law or a platform requires explicit permission, it should be obtained before the first relevant processing, with applicable withdrawal methods provided. A general login checkbox cannot replace these choices. This draft itself grants no right to use data for training, marketing, sale, or unrestricted onward disclosure.
If providers or purposes change materially, the notice should be updated first, and any required new consent or other legal conditions should be satisfied under applicable law. Data controllers, contracted processors, and independent recipients should be distinguished according to their actual roles. Rights requests and deletion procedures should cover applicable processors and subsequent processing.
12. Browser sessions and data sources
Web login uses an email verification code. Access tokens, refresh tokens, and minimal account display information are stored in sessionStorage in the current tab to maintain the session. Verification codes are not persistently stored; signing out clears the local session. The current static pages do not include third-party analytics SDKs, advertising-tracking SDKs, or remote fonts. This does not mean that servers do not process network requests or access logs.
Information mainly comes from content you submit, necessary results returned by the login or payment services you choose, device and network requests, and replies and memories generated through interactions. Public character information may also come from creators. Before introducing nonessential analytics, advertising, or other tracking, the actual technologies, purposes, and choices required by law should be disclosed. Viewing this page must not be treated as consent.
The current Web implementation does not automatically change data processing in response to a browser Do Not Track (DNT) signal. DNT and a Global Privacy Control (GPC) opt-out signal, where legally applicable, are different mechanisms; this draft does not represent that GPC handling has been implemented. Current pages do not include an advertising cross-site tracking SDK. Whether actual providers independently collect information across sites remains to be verified and disclosed in the final policy.
13. Privacy provisions for six markets
The following provisions preserve mandatory local rights; they do not mean that every local law applies unconditionally. The final service still needs to disclose specific providers, locations, retention periods, and workable request procedures. Until these are completed, this table must not be treated as a complete statutory notice.
| Market | Rights and requests | Processing and cross-border conditions |
|---|---|---|
| United States | Where state privacy laws apply, you may request access, copies, correction, deletion, or portability under their conditions; opt out of sales, certain sharing for cross-context behavioral advertising, or targeted advertising; and exercise applicable rights to limit sensitive-information use and to appeal. Unlawful discrimination for exercising rights is prohibited. Application of the California CCPA requires a separate assessment of business activities and statutory thresholds; these are not uniform nationwide rights. | The final notice needs to explain the actual categories collected and disclosed, sources, purposes, recipients, and retention periods or criteria. Whether a practice constitutes sale or sharing depends on actual provider contracts and purposes and has not yet been verified. Voiceprints or inferences about health or mental state may also trigger separate authorization, a dedicated health-data privacy policy, and deletion duties. Describing the service as a nonmedical product does not automatically exclude these laws. |
| Japan | Under the APPI and its statutory conditions, you may request notice of purposes of use, disclosure of retained personal data and third-party provision records, correction, and cessation of use, deletion, or cessation of third-party provision. The company identified above receives requests. Its address, representative, and actual request procedures still need to be added to the final version, together with actual security measures and any applicable request fees. | Purposes of use should be specific and clear. Acquisition of special care-required personal information and third-party provision are governed by applicable rules. Provision to a third party in a foreign country must follow an applicable consent mechanism or another lawful route. Where consent is relied on, statutory information, including the destination’s protection framework and the recipient’s safeguards, must be provided in advance. Where ongoing equivalent safeguards are relied on, they must be maintained and related information provided as required by law. |
| South Korea | Under the PIPA, you may lawfully request access, correction, deletion, suspension of processing, and withdrawal of consent. For fully automated decisions with significant effects that meet statutory conditions, you may exercise rights to refuse the decision or request an explanation. Ordinary AI chat is not automatically such a decision. The privacy protection officer and domestic representative, where the applicable conditions are met, must be identified in the final version. | The final version must distinguish entrusted processing from third-party provision and specify data items, purposes, retention periods, and destruction methods. Overseas provision, entrustment, or storage must follow a lawful route. Where consent is relied on, advance information must cover data items, countries, timing and methods, recipients and contact details, purposes and retention periods, and how to refuse and the consequences. Consent for information beyond what is necessary must not be bundled. |
| Hong Kong | Under the PDPO, you may request access to personal data, including a copy, and correction. Requests are generally handled within 40 days of receipt in accordance with the law. Statutory exceptions and written explanations of inability to comply or delay follow the Ordinance. Any fee for an access request must comply with the Ordinance and must not be excessive. No fee is charged for complying with a correction request. You may complain to the Office of the Privacy Commissioner for Personal Data. | At collection, the purposes, whether provision is obligatory and the consequences of not providing data, classes of transferees, and the title and address of the contact for access and correction should be stated. A new purpose requires applicable prescribed consent, and direct marketing is subject to separate rules. Cross-border processing still requires appropriate purpose, retention and security safeguards, and controls over processors; overseas hosting does not remove these duties. |
| Taiwan | Under the Personal Data Protection Act, you may request inquiry, review, copies, supplementation or correction, cessation of collection, processing or use, and deletion. These rights cannot lawfully be waived or restricted in advance. Decisions on inquiry, review, or copy requests are generally due within 15 days; a necessary extension of up to 15 days requires written reasons. Decisions on correction, supplementation, cessation, or deletion requests are generally due within 30 days; a necessary extension of up to 30 days requires written reasons. | The collector, purposes, categories, period, areas, recipients and methods of use, rights and how to exercise them, and the effects of not providing optional data should be disclosed. For indirect collection, sources should also be disclosed as legally required. Medical records, medical information, sex life, and other data listed in Article 6 require statutory conditions; consent-based processing must meet written-consent requirements. International transfers must be checked against restrictions imposed by the competent authority; blanket consent cannot override them. |
| Macao | Under Law No. 8/2005, you may lawfully request information about processing, access, rectification, erasure or blocking, and object under statutory conditions, including to direct marketing. Uniform portability rights or withdrawal deadlines from other markets must not simply be imported. You may complain to the Personal Data Protection Bureau. | Information concerning private life, health, and sex life may be sensitive data and requires appropriate grounds and special safeguards. Notification of automated processing, cases requiring prior authorization and exemptions, and appropriate protection or statutory exceptions, notification or authorization for transfers outside Macao must each be addressed. Even transfers based on explicit consent require assessment of applicable pretransfer notification duties; a general checkbox or an AWS contract cannot replace them. |