Last Updated: [1 July 2025]
This Privacy Policy applies to all users of the LabuKey chatbot service ("the Service") owned and operated by LabuKey. Your access to and use of the LabuKey chatbot service, which may be provided through websites, mobile applications, and/or software applications ("the Service"), are also governed by the LabuKey Terms of Service (available at LabuKey Terms of Service) ("Terms of Service").
Your privacy is of great importance to us. This Privacy Policy provides information on why LabuKey collects your personal and non-personal data, and governs how LabuKey collects, uses, transfers, stores, and/or processes personal data that you share with LabuKey through the Service or any third-party sources (as applicable). This Privacy Policy also helps you make informed decisions before providing your personal data to LabuKey and/or giving your relevant consent (as applicable).
Any personal data of yours provided to us is at all times governed by the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"), and references to "personal data" shall have the meaning ascribed to it under the PDPO. This Privacy Policy should be read together with the Terms of Service. In the event of any inconsistency between this Privacy Policy and the Terms of Service in relation to matters concerning personal data, this Privacy Policy shall prevail.
We undertake to comply with the provisions of the PDPO regarding the management of personal data and to safeguard the privacy, confidentiality, and security of personal data in our possession. We are also committed to ensuring that all our employees and agents adhere to these responsibilities. Before using (including disclosing and transferring) your personal data for the purposes described in this Privacy Policy, we may be required by law to notify you and/or obtain your written consent for certain purposes. In the latter case, we may only use your personal data in the specified manner after obtaining such written consent.
This Privacy Policy applies to all personal data collected by LabuKey through:
(a) any and all parts of the Service, and your use and/or access thereto; and
(b) all services provided by LabuKey to users through any media (whether now known or hereafter available) in
respect of any information derived or obtained from or through the Service.
We will collect, use, process, and transfer your personal data in the manner and for the purposes specified in this Privacy Policy. Without your prior consent, we will not use your personal data for any new purpose (i.e., any purpose outside the scope of this Privacy Policy).
LabuKey is a "data user" in respect of personal data about you collected when you use the Service (or personal data about third parties provided by you to us, as applicable). This means that we control how personal data about you is collected in connection with the Service and determine how and why such personal data is used and/or processed for the purposes of the PDPO.
We may collect personal data and information from you from time to time when you:
(a) use and/or access the Service;
(b) submit data through the Service, including but not limited to when you create an account with us or provide
input (such as instructions or "Input Content" as defined in the Terms of Service) to or through the Service;
and/or
(c) communicate with LabuKey.
We may also collect information through:
(a) Cookies, event tracking, and/or similar technologies to automatically collect information about your browsing
activities and use of the Service, and/or the device you use to access the Service;
(b) trusted partners, including but not limited to security partners, to prevent fraud, abuse, and other security
threats to the Service.
When you use the Service, we will collect your personal data through, including but not limited to, the methods described in "3. How We Collect Personal Data and Other Information from You" above. The types of personal data may include the following:
(a) Identification and contact information: your phone number and any other account login details created for the
Service;
(b) One-time passwords: if you log in to your account for the Service, the system may generate a one-time password
that needs to be submitted before continuing to access and/or use the Service;
(c) Content input into the Service: instructions, text, input content, audio, chat logs, feedback, and any other
content you submit, transmit, input, and/or upload to the Service;
(d) Communication information: if you communicate with us, including but not limited to by letter and email, we
may collect personal data disclosed therein (such as your name and address), feedback, inquiries, and/or
complaints;
(e) Log files: Internet Protocol (IP) address used to connect your computer to the Internet; browser type and
version, time zone settings, browser plug-in types and versions; operating system and platform;
(f) Usage and location data: full Uniform Resource Locator (URL) clickstream to, through, and from the Service,
date, time, and location of access and use, page response times, errors, crash reports, performance logs, duration
of visits, page interaction data, including but not limited to the types of content you view or interact with, and
the functions you use and actions you take (such as scrolling and clicking), and language preferences;
(g) Device data: hardware model and operating system, version, unique identifiers, serial numbers, settings
configurations, and software and mobile configurations, Internet Protocol (IP) address (from which we may derive
your geographical location), browser type, and mobile device identifiers; and
(h) Other data: other data provided in connection with or for the purpose of providing the Service.
If you provide any personal data that does not belong to or is not related to you but belongs to or is related to a third party, you hereby agree and confirm that you have provided a copy of this Privacy Policy to such third party, that he/she has read and agreed to all terms of this Privacy Policy, and that you have effectively obtained his/her consent and authorization to provide his/her personal data to us for the purposes set out in this Privacy Policy.
To use the Service, you are obligated to provide certain personal data. Such data will be marked as "required" in the relevant personal data collection forms, and you must provide the required personal data if you wish us to provide the Service. If you provide us with any inaccurate/incomplete data, or choose not to provide any required data, you may not be able to access or be provided with any part or all of the Service. On the other hand, if personal data is requested on a voluntary basis, it will not be marked as "required", and you are entirely free to decide whether to provide such information to us.
We use your personal data submitted to us or collected by us about you for the following purposes:
(a) verifying your identity;
(b) providing you with access to the Service, including but not limited to sending you a one-time password for
such access;
(c) providing you with the Service, or functions, tools, or features that may be provided through or in connection
with the Service, including but not limited to enabling you to create an account, input information, interact with
the chatbot, create or generate "Output Content" as defined in the Terms of Service, and view chat logs;
(d) enabling us to provide you with the Service, functions, tools, or features available through our or our
affiliates' websites, mobile applications, and/or software applications, and/or transferring or otherwise sharing
or providing your personal data to our affiliates (as defined in clause 6(a) below) to enable them to provide you
with the Service, the aforesaid functions, tools, or features;
(e) communicating with you about the Service and managing our relationship with you, including notifying you of
changes to this Privacy Policy, the Terms of Service, and the Service;
(f) providing and improving the user experience, such as assisting us in responding to any inquiries and
complaints you may have, or handling any disputes that may arise in the course of providing the Service to
you;
(g) conducting promotional analysis to enable us to evaluate the trends and effectiveness of our advertising and
promotional activities (including using your input content, output content, and other personal data to assess,
analyze, or predict certain aspects related to you);
(h) conducting analysis to generate statistical or actuarial reports (containing aggregated data that may or may
not relate to any identified or identifiable individual);
(i) better understanding the demographics of our users;
(j) maintaining, improving, and developing the Service and any new services of ours, including but not limited to
training and improving our technologies, such as machine learning models and algorithms;
(k) performing accounting, auditing, and other internal functions, including training, legal, and administrative
purposes;
(l) managing the Service, including troubleshooting, data analysis, testing, system maintenance and upgrades,
support, reporting, and data hosting, as well as maintaining and developing our business systems and
infrastructure;
(m) conducting internal research or analysis to enable us to improve and optimize the Service available to
you;
(n) enabling us to comply with our legal obligations and to detect, prevent, and investigate any other actual or
suspected illegal acts or misuse of the Service. Please note that we will only use your personal data to the
extent necessary for this purpose;
(o) protecting our rights and property; and
(p) other purposes ancillary or related to the above purposes.
We will not use your personal data for any new purpose without first obtaining your explicit consent.
We may need to share your personal data with any of the following third parties to perform the Service:
(a) Affiliates of LabuKey: legal entities associated with LabuKey and involved in the research, development, and
provision of generative artificial intelligence technologies and/or solutions, together with their respective
researchers, employees, and technical personnel (collectively "Affiliates");
(b) Third-party service providers: for the purpose of operating, improving, and/or optimizing the Service, we may
need to share or transfer your personal data to our third-party service providers to process such data on our
behalf in accordance with our instructions to perform our business, including but not limited to service providers
of information technology, hosting, cloud or digital storage, third-party application programming interfaces,
search services, content delivery, customer support, communication and/or email services, security, development
and maintenance, administrative, data processing, or other similar services, as well as promotional agencies,
social media, and/or research and/or analysis companies. The aforesaid third-party service providers act as "data
processors" on our behalf under the PDPO and may be authorized to access your personal data to fulfill their
contractual obligations to us, but shall not use such data for any other purpose. They may process your personal
data within or outside Hong Kong. We will use our best efforts to appropriately establish and maintain relevant
contractual measures and/or other relevant non-contractual means to regulate and ensure compliance by our data
processors in processing personal data;
(c) Recipients arising from legal requirements or business transfers: we may share your personal data in the
following circumstances:
i. We are obligated to disclose or transfer your personal data to fulfill any applicable legal,
regulatory, or rule obligations, orders, and/or any legal obligations under any guidelines or directions issued by
any legal, regulatory, government, tax, law enforcement, or other authorities, or self-regulatory organizations or
industry bodies or associations that we are expected to comply with, and to fulfill any existing or future
contracts or other commitments with the aforesaid parties;
ii. To enforce or apply our other terms and conditions or other agreements, or to protect our rights, property, or
safety (or the rights, property, or safety of our customers/clients or others);
iii. In the case of a transfer, acquisition, or sale of assets or business, merger, reorganization, liquidation,
takeover, change of control, and/or transfer of services (collectively "Transaction") to another entity, we may
disclose your personal data to the counterparty to the Transaction (including but not limited to for due diligence
purposes); and
(d) Professional advisers of LabuKey: including but not limited to lawyers, accountants, and auditors.
Without prejudice to the Terms of Service, you may share your chat conversations, input content, output content, or other information related to the Service with any third party, including but not limited to social media platforms, third-party applications, and other users. Information you share with such third parties will be governed by their terms and conditions and privacy policies (if applicable), which are beyond our control. We encourage you to review these terms and policies before sharing your information with third parties.
Personal data we collect about you may be stored on servers located within or outside Hong Kong. Furthermore, for the purposes set out in this Privacy Policy, we may transfer personal data we hold about you to third parties identified in "6. To Whom Will We Transfer, Disclose, or Share Your Personal Data?" above outside Hong Kong.
If you are a minor under the age of 18, you should not use the Service or provide us with any of your personal data unless and until you have obtained the consent of your parent or legal guardian. Your use of the Service and provision of your personal data to us shall be deemed to constitute your parent's/legal guardian's consent as aforesaid. If you are a parent/legal guardian, you may at any time contact us through the contact details specified in "13. Your Right to Access and Correction" of this Privacy Policy to withdraw your consent.
Data we collect from you may be stored on servers located within or outside Hong Kong.
We use our best efforts to implement and maintain administrative, technical, or physical security measures designed to protect the personal data you provide from accidental or unauthorized destruction, deletion, loss, alteration, access, disclosure, processing, or use. However, you acknowledge that the transmission of information via the Internet is not completely secure.
With respect to any third-party service providers acting as data processors on our behalf to perform the Service in accordance with our instructions, we will not authorize them to use (including disclose and transfer) your personal data except as necessary to perform their services for us and/or for the permitted purposes described in this Privacy Policy, or to comply with applicable legal requirements.
From time to time, we may provide links to other websites operated by third parties and/or brief excerpts of website content (including but not limited to as part of the output content generated by your interaction with the chatbot in connection with the Service). Such information is provided solely for your general reference and convenience. We have no control over such websites and applications, which are independent of LabuKey and governed by separate privacy policies, terms, and conditions. We shall not be liable or responsible for any data about you that may be collected by third parties through their websites and applications.
The length of time we store your data will vary depending on the type of personal data, the purpose of use, and applicable legal and/or contractual requirements. We may anonymize your data, and after anonymization, we may continue to use the anonymized data for any purpose and may transfer any anonymized data to any third party.
You have rights in relation to your personal data, including:
(a) checking whether we hold any of your personal data;
(b) accessing your personal data held by us;
(c) requesting us to correct any inaccurate personal data; and/or
(d) ascertaining our policies and practices in relation to personal data (from time to time) and the types of
personal data we hold.
It is important to ensure that the personal data we hold about you is accurate and up-to-date. You confirm and agree that you will notify us if your personal data changes during your use of the Service.
You also confirm and agree that output content is generated using generative artificial intelligence based on your input content, requests, and instructions, as well as data from the Internet and/or past feedback and responses from you or other service users. Any output content may therefore contain factual or technical inaccuracies, typographical errors, or incomplete, inappropriate, and/or outdated information. In such cases, if you wish us to correct or remove any inaccurate personal data of yours, you may submit a request for access and correction of data.
If you wish to make a request related to clauses 13(a)-(d) above (or make any general inquiry or complaint), please send your request or inquiry by email to our Data Protection Officer (marked as confidential) at: labukey_support@dreamgallop.com, specifying your name, contact phone number, and/or email address to enable us to follow up on your request.
We may refuse to comply with your request for access to or correction of data if we are not provided with information that we reasonably require to identify the personal data to which the request relates or to determine in what respects the personal data to which the request relates is inaccurate.
Pursuant to the PDPO, we reserve the right to charge you a reasonable fee for processing any request for access to personal data.
We will review our policies, procedures, and processes related to the management of personal data from time to time.
We reserve the right to modify the terms of this Privacy Policy at our sole discretion. We will notify you of changes to this Privacy Policy by posting the revised policy and its relevant updated version date on the mobile application and/or website of the Service. Your continued access to and/or use of the Service after the latest updated version date of our Privacy Policy shall be deemed to constitute your reading and acceptance of our updated Privacy Policy. For any matters for which we may need to seek your further consent, we will contact you separately (if/when applicable). We encourage you to visit the mobile application and/or website of the Service from time to time to ensure that you are fully aware of our latest Privacy Policy. If you do not agree to our then-current Privacy Policy, please immediately cease accessing and using the Service.
The English version of this Privacy Policy shall prevail over the traditional/simplified Chinese versions, which are provided for reference only.