Effective Date：2025.12.09
We, 【CUBEE GROWTH PTE. LTD. 】("we," "us," or "our"), believe your privacy is very important. To fulfill our commitment to respecting and protecting your privacy, we will adhere to our basic principles as explained in detail below, and crafted this Privacy Policy("Policy") in accordance with these basic principles:
This Policy explains how we collects, uses, stores, protects, and shares your personal information when you use our App("Sami") and services (collectively "Services"), including core features like sound collection, emotion analysis, and voice chat room matching. It also outlines your rights regarding your personal information and our data handling practices.
By accessing or using our Services (including account registration and in-app interactions), you confirm that you have read, fully understood, and agreed to be bound by all the provisions of this Privacy Policy. If you disagree with any part of this Policy, you must immediately cease accessing or using our Services. Your continued use of the Services after any updates to this Policy are posted will be deemed your acceptance of the revised terms.
To comply with global data protection laws and regulations, we strictly prohibit individuals under the age of 18 (or the higher age of majority specified by the laws of your jurisdiction) from creating accounts or using our Services. We do not intentionally collect, use, or disclose personal information from minors. If we inadvertently collect personal information from an individual who does not meet the minimum age requirement, we will promptly delete such personal information in accordance with applicable data protection laws and regulations.
We collect only necessary personal information to provide, optimize, and secure our Services, adhering strictly to the principle of information minimization. The personal information we collect is obtained through the following channels:
We may collect limited personal information from trusted third parties with your explicit consent or as permitted by applicable law. Such personal information includes: basic profile information from third-party login providers (e.g., Facebook, Google); anonymized aggregated usage information from analytics partners (e.g., Google Analytics); and personal information from regulatory or security partners for the purposes of compliance with laws and regulations or anti-fraud efforts.
We use your personal information solely for legitimate, necessary, and transparent purposes directly related to the provision and improvement of our Services. The key purposes of using your personal information include the following:
We will not use your personal information for unstated purposes without your explicit consent. You may withdraw consent for non-essential uses (e.g., personalization) at any time, though this may affect certain features.
We will never sell, rent, lease, or otherwise commercially disclose your personal information to any third party. We only share your personal information in the following limited circumstances, and we implement strict technical and contractual safeguards to ensure the confidentiality, integrity, and security of your personal information throughout the sharing process:
Authorized Service Providers: We may share limited, necessary personal information with trusted third-party service providers that act on our behalf to support the operation and improvement of our Services (e.g., cloud storage providers for information hosting, payment processors for transaction processing, content moderation services for compliance, and analytics providers for service optimization).
Legal Obligations & Protection of Rights: We may disclose your personal information if we reasonably believe that such disclosure is necessary to: (i) comply with applicable laws, regulations, judicial orders, or mandatory government/regulatory requests; (ii) protect or defend our legitimate rights, property, or safety, as well as the rights, property, or safety of our users or the public (e.g., in response to fraud, cybersecurity threats, or potential harm to individuals); (iii) enforce our TERMS OF USE, this Policy, or other agreements with you; or (iv) participate in legal proceedings (e.g., responding to subpoenas or court orders). We will limit such disclosure to the minimum amount of personal information necessary to fulfill the legal obligation.
Business Transfers or Restructurings: In the event of a merger, acquisition, consolidation, sale of all or substantially all of our assets, bankruptcy, liquidation, or other corporate restructuring (collectively, "Business Transfer"), your personal information may be transferred to the successor entity or acquiring party as part of the business assets. We will notify you of such a Business Transfer via prominent means at least 30 days in advance, unless applicable law prohibits such notification. The successor entity or acquiring party will be required by contract to comply with the terms of this Privacy Policy with respect to your personal information; if it intends to use your personal information in a manner materially different from that stated in this Policy, it will obtain your explicit consent before doing so.
Your Explicit Consent: We will only share your personal information with third parties other than those described above if we have obtained your clear, explicit, and voluntary consent (e.g., when you choose to link your account with a third-party application, share content to a third-party platform, or authorize a third party to access your information through our Services).
Except for the circumstances outlined above, we will not share your personal information with any third party without your prior authorization.
You must be at least 18 years of age to access or use our Services. If you are located in a jurisdiction (including any state, country, or region) that mandates a higher minimum age for consenting to the collection, use, or processing of personal information (hereinafter "Applicable Age Threshold"), you may only use our Services if you meet or exceed such higher threshold. By accessing or using our Services, you warrant and represent that: (i) you are at least 18 years old (or the Applicable Age Threshold in your jurisdiction); and (ii) you have the legal capacity to consent to the processing of your personal information as outlined in this Privacy Policy.
If we become aware that a user is under the Applicable Age Threshold (whether through self-disclosure, parental/guardian notification, or other verification), we will promptly: (a) terminate the user's account; (b) cease all further collection and use of the user's personal information; (c) delete or anonymize the user's personal information in accordance with applicable data protection laws and our information retention policies; and (d) notify the parent or legal guardian of such action upon request (provided the requester can verify their parental/guardian status and relationship to the minor).
Parents or legal guardians who believe their child (under the Applicable Age Threshold) has inadvertently provided personal information through our Services may contact at 【support@cubeegrowthpte.com】 to request account termination and information deletion. To process such requests, we may require reasonable proof of parental/guardian status (e.g., government-issued identification) and confirmation of the child's association with the account. We will respond to valid requests within the timeframe required by applicable law.
Our Services may include links to unaffiliated third-party websites, applications, or software development kits (SDKs) (e.g., analytics tools, advertising platforms, payment processors, or social media plugins). These third-party services are independent of our control, and their collection, use, storage, and disclosure of your personal information are governed solely by their own privacy policies and terms of service—not this Policy. We strongly recommend that you review the privacy policy and terms of any third-party service/SDK before accessing, using, or providing any personal information to them. Your interaction with third-party services is at your own risk.
We may update the integrated third-party SDKs from time to time to enhance service functionality, address technical requirements, or comply with regulatory changes. If a material change to our third-party integrations affects how your personal information is processed, we will notify you through prominent means where required by applicable law.
Under applicable data protection laws and relevant local data protection legislation), you have the following rights in relation to your personal information processed by use our Services. To exercise these rights, please contact us via 【support@cubeegrowthpte.com】:
You may exercise each of the aforementioned data subject rights free of charge once per calendar year (January 1 to December 31). Any subsequent request to exercise the same right within the same calendar year (i.e., exceeding one request per specific right per calendar year) shall be classified as an "excessive request." For the avoidance of doubt, this restriction applies on a per-right, per-calendar-year basis—separate rights may each be exercised once free of charge within the same year. For excessive requests (as defined above), we reserve the right to charge a reasonable administrative fee of USD 10 per excessive request, which is proportionate to the actual costs incurred (including personnel, technical, and operational expenses) in processing such requests. We will provide you with a transparent breakdown of the fee calculation and specified payment methods prior to initiating processing of the excessive request. Processing of the excessive request will commence only after you have confirmed acceptance of the fee and completed payment (where required).
To safeguard your privacy and prevent unauthorized access to or disclosure of your personal information, we may require you to provide reasonable, verifiable evidence to confirm your identity prior to processing your request. If you fail to provide sufficient, verifiable information to confirm your identity, we may decline your request to mitigate the risk of data breaches or misuse. We will notify you of the additional information required if your initial verification is insufficient.
We further reserve the right to decline requests that are: (i) unfounded or malicious; (ii) excessive request,even if the USD 10 fee is offered; or (iii) excessively burdensome to process (e.g., requests that require disproportionate time, resources, or would interfere with our legitimate business operations, compliance obligations, or the rights of other users). Where required by applicable law, we will provide you with a written explanation of the grounds for declining your request, including reference to the relevant legal provisions. You may submit a new request with additional information or clarification if you believe the decline was erroneous.
We implement multi-layered security measures (administrative, technical, physical) to protect your personal information from unauthorized access, disclosure, or destruction. However, no security system is 100% foolproof. Despite these robust protections, evolving cyber threats and human error can sometimes create gaps. You are responsible for protecting your account credentials (e.g., using a unique password that combines uppercase letters, lowercase letters, numbers, and special characters, changing passwords regularly) and not sharing them with others, even if approached by individuals claiming to be from our organization. By taking these steps, we collectively enhance the security of your personal information and minimize risks.
We use cookies, web beacons, pixel tags, SDKs, and other similar tracking technologies (collectively referred to as "Cookies") when you access or use our Services. These technologies help us deliver, optimize, and protect our Services, and we only use them in compliance with applicable data protection laws. You have the right to manage your Cookie preferences, subject to the limitations of essential Cookies (as they are necessary for Service functionality). If you previously consented to non-essential Cookies (e.g., marketing cookies), you can withdraw your consent at any time by updating your browser or device/In-App settings. Withdrawal of consent will not affect the lawfulness of Cookie usage prior to the withdrawal, but this may affect some features.
We may revise this Policy to adapt to legal changes, Service updates, or emerging risks. The "Effective Date" date will be updated to reflect the effective date of changes. Your continued use of the Services after the effective date constitutes acceptance of the revised Policy.
For questions, concerns, or requests related to this Policy or your personal information, please contact us at 【support@cubeegrowthpte.com】.