Privacy Policy

Updated: 09/01/2025

Galaxion Limited (doing business as Cumulo) (“Cumulo,” “we,” “our,” or “us”) values your privacy and emotional safety. This Privacy Policy explains how we collect, use, and protect your personal information when you use our mobile application, website, and related services (collectively, the “Services”).

By creating an account and using our Services, you agree to this Privacy Policy. Your use of Cumulo is also subject to our [Terms of Service].

1. Personal Information We Collect

We collect information directly from you, automatically through your device, and from certain third parties to provide and improve our Services.

A. Information You Provide to Us

Account & Profile Information
To use Cumulo, you must create an account. We collect:

Your name or username
Email address or phone number used for login and verification
Password or authentication credentials
Your chosen Cumulo’s name, appearance, and customization settings
Personality test responses used to match you with your Cumulo

Interactions & Conversations
When you chat with Cumulo, we process:

Text messages, emotional reflections, and responses you exchange with your Cumulo
Audio recordings if you use voice chat
Images or videos you upload through “cloud-sharing” or daily tasks

These interactions (“Prompts”) are used to generate personalized replies (“Outputs”) and may contain personal information you choose to share.

Microphone Access
If you enable voice chat, Cumulo accesses your microphone to capture your voice input.
Your audio is processed securely—typically in real time—to generate responses and may be temporarily stored for improving voice accuracy or model quality.
You can disable microphone access anytime in your device settings.

Photo & Media Access
When you participate in “cloud-sharing” or complete visual tasks, Cumulo may request access to your device’s photo library or camera.
Uploaded images are stored securely and used only for in-app features, emotional reflections, or user-shared community posts (if you choose to post publicly).

Communications with Us
If you contact us for support or feedback, we collect your name, email address, and message contents.

Payment Information
If you subscribe to Cumulo Premium or purchase in-app items, payment processing is handled by third-party platforms (e.g., Apple App Store, Google Play, Stripe). We may receive limited payment details such as transaction ID or billing confirmation.

B. Information We Collect Automatically

When you use the app, we automatically collect:

Device Information: IP address, device type, operating system, and app version
Usage Data: Session duration, interactions, in-app events, error logs
Location Data: Approximate region inferred from IP address (not precise GPS data)
Cookies and Analytics: We and our partners (e.g., Firebase, PostHog) use cookies and analytics tools to understand how users engage with Cumulo and improve experience.

C. Information from Other Sources

If you interact with Cumulo on third-party platforms (such as Discord, TikTok, or community events), we may receive limited information such as your username, display name, or profile photo.
These services have their own privacy policies that govern how they handle your information.

2. How We Use Your Information

We use the personal information we collect to:

Provide, maintain, and improve Cumulo’s Services
Personalize your Cumulo’s dialogue, emotions, and visual appearance
Generate and store emotional journals based on your conversations
Offer interactive activities like daily tasks, reflections, and cloud-sharing
Process payments and manage subscriptions
Understand usage trends and improve app performance
Train, evaluate, and enhance our AI models (in aggregated, de-identified form)
Communicate with you about product updates, new features, and customer support
Detect, prevent, and respond to fraud or misuse
Comply with legal obligations and enforce our Terms of Service

We may also create aggregated or de-identified data for analytics and product development.

3. Legal Bases for Processing (EEA & UK Users)

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), we process your information under the following legal bases:

Consent — for actions like microphone, photo, or analytics data collection.
Contractual Necessity — to provide the Services you registered for.
Legal Obligation — to comply with applicable laws.
Legitimate Interests — to improve, secure, and analyze our Services, provided these interests are not overridden by your rights.

4. How We Disclose Information

We may share your personal information with:

Vendors & Service Providers: For hosting, analytics, AI processing, and customer support.
AI Processing Partners: To support conversational and emotional analysis features.
Analytics Providers: Including Firebase and PostHog, for performance and usage metrics.
Legal & Safety Reasons: When required by law or necessary to protect rights and safety.
Business Transfers: If Cumulo is involved in a merger, acquisition, or sale.
With Your Consent: When you choose to share photos, posts, or feedback publicly within the app.

5. Your Rights and Choices

If you are in the EEA or UK, you have the right to:

Access, correct, or delete your personal data
Withdraw consent for data processing (e.g., revoke microphone or camera permissions)
Restrict or object to processing
Request data portability
File a complaint with your local data protection authority

You can contact us at privacy@cumulo.app to exercise these rights.
We may verify your identity before processing your request.

6. Data Retention

We retain your account and interaction data for as long as you have an active account.
When you delete your account or request removal, we take steps to delete or anonymize your personal data within a reasonable period, unless retention is required by law.

7. Security

We use encryption, access controls, and secure servers to protect your personal information.
Despite these measures, no online transmission or storage system is completely secure.

8. Children’s Privacy

Cumulo is intended for users aged 13 and above (or 16 in certain jurisdictions).
We do not knowingly collect data from children under 13.
If you believe a child has provided personal data, please contact elainezhou@cumuloai.com, and we will promptly delete it.

9. International Data Transfers

Your information may be processed in countries other than your own, including the United States.
We rely on Standard Contractual Clauses and equivalent mechanisms to safeguard international data transfers.

10. Deleting Your Account or Data

To permanently delete your account or personal data, please email elainezhou@cumuloai.com with:

Your registered email
Your Cumulo’s name
The date of your last login

We will confirm once your data has been deleted from our systems and backups (except where retention is legally required).

11. Changes to This Policy

We may update this Privacy Policy periodically.
If significant changes occur, we will notify you in-app or via email before they take effect.
The latest version will always be available at https://cumulo.app/privacy.

12. Contact Us

If you have questions, feedback, or privacy concerns, please contact:

Galaxion Limited (d/b/a Cumulo)
📧 Email: elainezhou@cumuloai.com
🌐 Website: https://cumuloai.com