Hushee Privacy Policy

Version Effective Date: October 29, 2026

Hushee values and respects your privacy. We want to help you understand how we process your Personal Information. The following highlights key information on the data processing of Hushee:

To know how we process your Personal Information when using Hushee, please refer to the privacy policy.

This Privacy Policy explains how we collect, process, and use your Personal Information through the Hushee App. This Privacy Policy may change over time, and the last modifications to this Privacy Policy were made on October 29, 2026.

1. Who is Responsible for Processing Your Personal Information?

RIVEROLL LIMITED ("RIVEROLL", "we", "us" or "our") is responsible for the processing of Personal Information in the Hushee app. RIVEROLL is a technology company incorporated in Hong Kong (Company No. 3018164) with its registered office at Room 2914C, 29/F, Ho King Commercial Centre, 2-16 Fa Yuen Street, Mong Kok, Kowloon, Hong Kong, and you can contact us via [email protected].

2. What Kind of Personal Information Do We Process?

When you use Hushee, we process:

Please do not include sensitive personal information in your messages, public content or support requests.

3. How Do We Use Your Personal Information?

Your private conversations are not published. Content you choose to make public, such as public characters, comments, your profile name, avatar, banner and bio, likes and follows, can be seen by other users. Hushee does not display third-party advertising in the App.

4. Who Do We Share Personal Information with?

Service providers and partners process information needed to operate, measure and secure Hushee (see Section 10 regarding "sale" and "sharing" under California law). Their own privacy policies, which are available on their websites, describe how they handle information:

Links to external websites are governed by those websites' own policies. This policy does not assert that a third-party provider has zero retention or that every provider processes data in the same location.

5. Tracking, Attribution and Your Choices

On iOS, Hushee asks for your permission through Apple's App Tracking Transparency prompt before accessing your device's advertising identifier (IDFA). If you allow tracking, the IDFA may be stored with your device record and shared with Adjust and Meta, and through Adjust with advertising networks such as Google, to attribute installations and purchases to our advertising campaigns and to measure their effectiveness. If you decline tracking, the App does not read the IDFA. An IDFA that has already been recorded is not removed automatically when you later turn off tracking in iOS Settings under Privacy & Security > Tracking; you can ask us to delete it by contacting us as described in Section 9. Declining tracking does not stop your account identifiers and usage events from being sent to the attribution and analytics partners described in Section 4.

You can turn off push notifications in iOS Settings, and you can contact us at [email protected] to opt out of the use of your information for advertising measurement where applicable law gives you that right.

6. Where Do We Store Your Personal Information? How Do We Transfer Your Personal Information?

Data collected by us is stored in the United States. Our service providers and partners, including those described in Section 4, may process data in other countries. We provide services worldwide, so your Personal Information may be processed outside your country or jurisdiction. Some countries that are not members of the European Economic Area (EEA) are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not considered adequate by the European Commission, we take appropriate safeguards to require that your Personal Information remain protected in accordance with applicable law.

7. How Long Do We Retain Your Personal Information?

We retain personal information for as long as needed or permitted for the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

Applying these criteria, we retain information by category as follows:

If you delete an account that is signed in with Apple or Google, the account is scheduled for deletion and deleted after 7 days; signing in again during that period cancels the deletion. Deletion then removes your conversations and memories, profile, preferences, wallet and membership records, device records and authentication sessions, and the sign-in record held by Firebase Authentication, and characters you created are taken down and no longer visible to anyone. If you delete a guest account, your conversations, memories, profile and preferences are removed right away and characters you created are taken down and no longer visible to anyone, while the guest account identifier, device record and its Sparks, membership and reward records stay with that guest account so that rewards cannot be claimed again.

Once an account deletion is completed, any remaining Sparks balance and membership benefits of that account are forfeited and cannot be restored. Deleting your account does not cancel an App Store subscription; you must cancel it in your Apple ID subscription settings, otherwise Apple may continue to charge you. Comments, likes and follows you made may remain visible without your profile name or avatar unless you remove them before deleting your account.

Limited records are retained after deletion for abuse prevention, legal compliance, accounting and dispute handling, including account-deletion markers, usage and security records, reports and moderation logs, App Store transaction records and notifications, Sparks delivery records, attribution reporting records, and invitation and device reward records. Backups and operational logs are not necessarily erased immediately when an account is deleted. We do not promise a fixed deletion deadline that our retention systems have not established.

Guest accounts are tied to the device and its stored credentials. Unless you sign in with Apple or Google, changing devices or losing stored credentials may prevent recovery. Providing an old user ID or device ID alone does not authorize access to that account.

8. How Do We Protect Your Personal Information?

When you send prompts or messages to Hushee, we ensure that such data is transferred securely and encrypted to our server. We take technical and organizational measures to ensure that information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. For example, we use verified service providers that might have access to Personal Information with which the relevant data processing agreements are signed. We also guide and train our personnel to process your data securely according to our internal data protection policies.

9. Your Rights Relating to Your Personal Information

You may have certain rights relating to your Personal Information subject to applicable data protection laws. These rights may include the right to:

If you are a California resident, the following information applies to you. Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA), California residents have the following rights related to personal information:

To exercise your rights, please contact us by using the information in Section 1. You can also delete your data from our records by sending us a data request via email [email protected].

10. Additional Information for California Residents

The information categories processed by Hushee are identifiers (such as account, device and advertising identifiers and email address), commercial information (purchase and subscription records), internet or other electronic network activity (usage events and technical information), approximate geolocation derived from IP address, conversation and community content, inferences stored as conversation memories, profile characteristics you choose to provide, and support or safety reports. Sources include your use of the App, the Apple or Google account you sign in with, Apple's App Store, our attribution partners and communications you send us. The purposes and recipients are described in Sections 3 and 4, and retention periods for each category are described in Section 7. The only sensitive personal information we may process is your preference about who you would like to meet, described in Section 2, which we use only to recommend characters to you.

We do not sell your personal information for money, but providing identifiers, usage information and purchase events to Adjust, Meta and Google for advertising attribution and measurement, as described in Sections 4 and 5, may be considered a "sale" or "sharing" for cross-context behavioral advertising under California law. The App Tracking Transparency setting controls only the IDFA. To opt out of the sale or sharing of your personal information, contact us at [email protected]; we will then stop providing data associated with your account to our attribution and advertising partners and ask them to delete it. Applicable access, correction, deletion and other rights can be requested using the contact details in Section 1. We may need to verify ownership without exposing another user's data.

11. Age Requirement

Hushee is intended for users aged 18 and above. We do not knowingly collect personal information from users under the age of 18. If we learn that a user is under the age of 18, we will take reasonable steps to delete any processed data and close the associated account. If you are a parent or guardian and become aware that a user under 18 has provided us with personal information, please contact us at [email protected] and we will take reasonable steps to delete the processed data.

12. Changes to This Privacy Policy

We may update this Privacy Policy according to changes in our service functions and measures concerning the protection of Personal Information. If we make changes to this Privacy Policy, we will update it through our App. Thus, you are advised to review this page periodically for any changes.