Last modified 2025-06-01
xMate takes your privacy seriously and we know you do too. This Privacy Policy ("Policy") describes how we collect, use, and share Personal Information, your Rights & Choices, and other important information about how we handle your Personal Information.
This Policy pertains to your ("you") use of the xMate website (the "Website"), including all Content available through the Website, the xMate mobile application for customers provided through Apple's App Store or the Google Play Marketplace (the "App(s)"), or by accessing any associated content such as email feeds, feeds through apps or other related services provided by XXXMate Limited (collectively the "Service").
You acknowledge (a) that you have read and understood this Privacy Policy; (b) that you accept this Privacy Policy and consent to the collection, use, and sharing of your personal information described in this Privacy Policy; and (c) that by consenting to this Privacy Policy, you consent to receive notifications regarding security incidents to the email address We have on file for You.
Please note that your use of our Service is also subject to our Terms of Use and Community Guidelines.
Please review the Privacy Policy each time you use the Service. BY USING THE SERVICE, YOU CONSENT TO THE MOST RECENT VERSION OF THE PRIVACY POLICY. If we materially change this Privacy Policy, we will notify you of any, if required, via notices on our Service. Your continued use of our Service constitutes your acknowledgement of any revised Policy.
General Inquiries: service@xxxmatehk.com
Regional Data Rights: service@xxxmatehk.com
Address: 721 Nathan Road, Mong Kok, Yau Tsim Mong District - Kowloon - HongKong
You must be at least 18 years old to use xMate.
XXXMate Limited does not knowingly collect any Personal Information about or market to children, minors, or anyone under the age of 18. If we become aware that a child, minor, or anyone under the age of 18 has registered with us and/or provided us with Personal Information, we will take steps to terminate that person's registration and promptly delete any such Personal Information if required by law.
To provide our Service, we may collect and use information that is defined as personal information under applicable privacy laws ("Personal Information"). We collect and use the following categories of Personal Information:
Audio/Visual Data - Video or image files and records, such as avatar images and character photos, as well as voicemails and other recordings. All Audio/Visual Data collected by us is actively uploaded by you.
Contact Data - Information about you and used to contact you, such as email address, mailing address, or phone number.
Device/Network Data - Personal Information relating to your device, browser, or application e.g. device identifiers, IP address, identifiers from cookies, session history and Service navigation metadata, and other data generated through applications and browsers, including via cookies and similar technologies.
Financial Data - Information such bank account details, or payment card information and relevant information in connection with financial transactions.
Identity Data - Information such as your name, E-mail address, gender, date of birth, age and/or age range, account login details, or other account handles/usernames.
Transaction Data - Information about transactions you make with us through our website, such as a paid subscription or bonus, and similar information.
User Content - Personal Information included in content provided by users of the Service in any free-form or unstructured format, such as in an AI chat session, a character design, a "contact us" box, or other free text field, file, document, or message to us.
We collect Personal Information from various sources based on the context in which the Personal Information will be used:
Data we collect from you - We collect Personal Information from you directly, for example, when you create your User Profile, create a character, chat with any character, the rating of the character or contact us directly.
Data collected automatically - We may collect certain Personal Information automatically. For example, we collect Device/Network Data automatically using cookies and similar technologies when you use our Service, access our Service, or when you open our communications.
Data we receive from service providers - We receive Personal Information from service providers performing services for XXXMate Limited.
Data we receive from social media platforms - We receive Personal Information from Apple, Google, Discord and Line when you use such third-party platforms to sign on. We also collect certain Personal Information from such third-party platforms as authorized by you for the purpose of using our Service.
Data creation and inference by third parties - Certain third parties (such as advertising platforms) may create and infer Personal Information based on the observations or analysis of other Personal Information submitted by you.
While our company is registered in Hong Kong, our services are provided from the United States. We adhere to data protection principles that align with both Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) and applicable U.S. privacy laws:
We are committed to protecting your personal information and the rights set out in this Policy reflect your rights under applicable laws.
Applicable laws for the purpose of this Policy means: (a) the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") to the extent applicable to our Hong Kong registered entity; (b) applicable U.S. federal and state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA), the Children's Online Privacy Protection Act (COPPA), and other relevant U.S. privacy regulations; (c) the Data Protection Principles under the PDPO; (d) any regulations, guidelines, and codes of practice issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong; and (e) to the extent applicable, any other data protection laws or regulations that may apply to our operations in the jurisdictions where we provide services.
We use Device/Network Data, Audio/Visual Data including Contact Data, Identity Data, Financial Data, Transaction Data, User Content, and General Location Data when you visit our website. Which type of the foregoing data will be used by us depends on the specific Service or function you use when you visit our website.
We use this Personal Information as necessary to operate our Service, such as keeping you logged in, age screening, delivering pages, providing AI chats with characters, content screening, etc., for our Business Purposes, and our other legitimate interests, such as:
We use Device/Network Data, Identity Data, Transaction Data and User Content in connection with our use of cookies and similar technologies on our Service. We may collect such data automatically.
We and authorized third parties may use cookies and similar technologies for the following purposes:
If you use our mobile app, we may use Device/Network Data, Audio/Visual Data including Contact Data, Identity Data, Financial Data, Transaction Data, User Content, and General Location Data.
We use this Personal Information to provide our mobile app, for our Business Purposes, and our other legitimate interests, such as:
We use Identity Data, Contact Data and User Content when you register and create an account for our Service. We use Audio/Visual Data if you upload a user profile avatar. We collect Financial Data if you associate payment information with your account.
We use Audio/Visual Data, User Content, and any Personal Information contained within any User Content when you create a character through the Service.
We use Device/Network Data, User Content, and any Personal Information contained within any User Content when you chat with a character through the Service.
We use Transaction Data, Identity Data, Financial Data, and Contact Data when you purchase a membership, redeem coins, purchase diamonds, purchase messages quota, or complete other transactions. We do not store your Financial Data.
When you contact us though the Service using a contact us box, via phone or email, we use Contact Data, Device/Network Data, User Content, and any Personal Information contained within any User Content. We use Contact Data and User Content as necessary to communicate with you about the subject matter of your request and related matters.
In addition to the uses described above, we generally use Personal Information for several common purposes in connection with our business ("Business Purposes") as stated below:
Operate our Service and Fulfill Obligations - We use any Personal Information as is necessary to provide the Service, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and services you request.
Internal Processes and Service Improvement - We may use any Personal Information we process through our Service in connection with training our models, understanding how the Service is used or functions, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to Service use, and for ensuring the security and stability of the Service.
Analytics - We use Personal Information as necessary in connection with our creation of analytics relating to how our Service is used, the pages and content users view, and the creation of reports regarding the use and performance of our Service and other similar information and metrics.
Compliance, Safety & Public Interest - Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, use any Personal Information subject to this Policy for purposes determined to be in the public interest or otherwise required by law.
We and certain third parties use Personal Information to further our commercial or economic interests ("Commercial Purposes") depending on the context of collection and your rights and choices.
Online Marketing - Third-party advertising platforms may, through third-party SDKs in mobile applications, collect your Personal Information and engage in online advertising on our Service ("Online Advertising") to increase engagement on our platform.
Marketing Communications - We may send you marketing and promotional communications pursuant to applicable laws. These communications may be personalized based on your user profile.
Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with Business Purposes, as described below.
Vendors and Service Providers - In connection with our general business operations, service improvements, enablement of certain features, and other lawful business interests, we may share Personal Information with vendors, service providers, and subprocessors who provide certain services to us or process data on our behalf.
Corporate Events - Your Personal Information may be disclosed to a third party in the event that we consider or go through a business transition, such as a merger, acquisition, liquidation, or sale of substantially all of our assets.
Affiliates - To the extent necessary, to streamline certain business operations and develop services that better meet the interests and needs of our customers, we may share your Personal Information with any of our current or future affiliated entities, subsidiaries, and parent companies.
Legal Disclosures - In limited circumstances, we may, without notice or your consent, access and disclose your Personal Information, our correspondence with you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use or Community Guidelines, or in the interests of us or any person.
Applicable law may grant you rights in your Personal Information. These rights vary based on your location and state/country of residence and may be limited by or subject to our own rights in your Personal Information. You may submit requests to exercise rights you may have by contacting us at service@xxxmatehk.com.
All rights requests we receive directly must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Information.
You may have the following choices regarding the Personal Information we use, to the extent required under applicable law:
Changing Your Information - To change your information, please contact us at service@xxxmatehk.com.
Closing Your Account - To close your account, please email us at service@xxxmatehk.com.
Consent - If you consent to our use of Personal Information, you may withdraw your consent at any time. You may be required to close your account to withdraw consent where your consent is necessary to perform essential aspects of our Service.
Email Marketing - You have the choice to opt-out of or withdraw your consent to email marketing communications. You may exercise your choice via the links in our communications.
Cookies & Similar Technologies - If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies and certain similar technologies using your browser's settings menu.
We implement and maintain commercially reasonable security measures to secure your Personal Information from unauthorized use. While we endeavor to protect our Service and your Personal Information against unauthorized access, use, modification and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.
In accordance with applicable data protection laws, including Data Protection Principle 4 of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and relevant U.S. privacy regulations, we take all practicable steps to ensure the security of your personal data, including:
We retain Personal Information for so long as it is reasonably necessary to achieve the relevant purposes described in this Policy, or for so long as is required by law. What is necessary may vary depending on the context and purpose of use. We generally consider the following factors when we determine how long to retain data:
In accordance with applicable data protection laws, including Data Protection Principle 2 of the PDPO and relevant U.S. privacy regulations, we ensure that personal data is not kept longer than is necessary for the fulfillment of the purpose for which the data is or is to be used.
Your Personal Information is primarily stored and processed in the United States, where our main data centers and service infrastructure are located. While our company is registered in Hong Kong, the actual provision of our services and data processing activities occur in the United States. This means that your data is subject to U.S. laws and regulations, including potential access by U.S. government authorities under applicable U.S. laws.
By using our Service, you consent to the transfer, storage, and processing of your Personal Information in the United States and acknowledge that your data will be subject to U.S. jurisdiction and laws.
This Policy applies only to the Service. The Service may contain links to other websites or apps or may forward users to other websites or apps that we may not own or operate and to which this Policy does not apply. The links from the Service do not imply that we endorse or have reviewed these websites or apps. The policies and procedures we describe here do not apply to these websites or apps.
While our company is registered in Hong Kong, our services are provided and data is stored in the United States. Your Personal Information may be transferred to and processed in the United States, where our primary operations and data centers are located. The United States has been recognized by the European Commission as providing an adequate level of data protection for certain transfers. Our services are supported by certain operating and maintenance vendors based in the United States and other jurisdictions. As applicable, your Personal Information may be transferred to these jurisdictions in accordance with applicable data protection laws and regulations.
By using our Service, you acknowledge and consent to the transfer of your Personal Information to the United States and other jurisdictions where our service providers are located, and you understand that your Personal Information will be subject to the laws of those jurisdictions.
We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Service following notice of any changes indicates acceptance of any changes. Unless explicitly stated otherwise, any new features that augment or enhance the current Service shall be subject to this Policy.
While our company is registered in Hong Kong, our services are primarily provided from the United States. However, to the extent applicable under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, you may have the following rights regarding your personal data:
To exercise any of these rights, please contact us at service@xxxmatehk.com. We will respond to your request within 40 days as required by the PDPO.
As our services are provided from the United States, U.S. residents have specific rights under various state and federal privacy laws. These rights may include:
To exercise these rights, please contact us at service@xxxmatehk.com.
If you are located in the European Economic Area (EEA), you may have additional rights under the General Data Protection Regulation (GDPR), including the right to erasure, right to data portability, and right to restrict processing. To exercise these rights, please contact us at service@xxxmatehk.com.
Since our services are provided from the United States and your data is stored in the United States, California residents have specific rights under the California Consumer Privacy Act (CCPA) and Section 1798.83 of the California Civil Code. California residents may request from us certain information about the types of Personal Information we have shared with third parties for their direct marketing purposes, and the names and addresses of those third parties during the immediately preceding calendar year. If you are a California resident, you may make one request each year by emailing us at service@xxxmatehk.com.
Additionally, California residents have the right to know what personal information we collect, use, disclose, and sell, the right to delete personal information, and the right to opt-out of the sale of personal information. To exercise these rights, please contact us at service@xxxmatehk.com.
This Privacy Policy was last updated on 2025-06-01