Orselle Privacy Policy

Last updated: 2026-07-15

Controller: Qingdao Pinxiaoyi New Energy Co., Ltd.

Contact: zosoiro8794@gmail.com

Orselle Privacy Policy

Effective date: July 15, 2026

This Privacy Policy describes how Qingdao Pinxiaoyi New Energy Co., Ltd. ("we," "us," or "our") processes information when you download, install, or use the Orselle mobile application distributed through Google Play on Android devices ("App"). Orselle is a quiet English-language AI mood diary that offers gentle companionship, expression support, and emotional buffering through text conversations and optional voice sessions with selectable AI characters.

This document applies to users worldwide. It explains what information may be collected, why it is processed, how it may be shared, how long it is kept, and what choices and rights may be available depending on where you live. By continuing to use the App after the effective date shown above, you acknowledge that you have read this Privacy Policy. If you do not agree with our practices, please discontinue use of the App and uninstall it from your device.

We do not sell personal and sensitive user data.


Permissions

Orselle requests certain Android permissions only when a feature you choose requires them. You may grant or deny each permission through your device settings or through the system prompt when the App first asks for access. Denying a permission may limit related features but does not block access to parts of the App that do not depend on that capability.

Camera

The Camera permission is used when you choose to capture a new image within the App—for example, when selecting or updating a visual element associated with your in-app experience. The camera is activated only while you are actively using a camera-related feature in the foreground. Camera access is not used in the background. If you revoke Camera permission, you may still use text-based features, but you will not be able to capture new photos through the App until permission is restored.

Microphone

The Microphone permission is used when you initiate a voice conversation with an AI character. Audio is captured only during an active voice session that you start and while the App is in the foreground. Microphone access is not used in the background for listening, recording, or ambient monitoring outside your initiated voice interaction. If you withdraw Microphone permission, voice-call features will be unavailable, while text-based dialogue may continue to function.

Photos and Videos (Read Access)

The Photos and media read permission allows you to select existing images or media from your device when you choose to attach or use stored visual content within the App. Access occurs only when you actively open a picker or similar interface. Photos and media are not accessed in the background. Revoking this permission prevents selection of existing gallery content through the App but does not affect unrelated App functions.

Photos and Videos (Write / Media Library) and External Storage

Where supported by your Android version, the App may request permission to save content you generate or export to device storage or the media library, consistent with Android scoped storage rules. Write access is triggered only by an action you take, such as saving an image. This permission is not used for background scanning or bulk collection of your files. On devices where scoped storage limits broad external storage access, the App relies on system-provided media APIs rather than unrestricted file browsing.

Managing Permissions on Android

You can review and change permissions at any time through Settings → Apps → Orselle → Permissions on your Android device. Changes take effect according to your device manufacturer’s implementation. We encourage you to review permissions periodically and enable only those aligned with how you use the App.


Rights and U.S. Notices

Depending on your location, you may have statutory rights regarding personal data or personal information we process. This section summarizes general rights and provides specific notices for residents of certain U.S. states. To exercise applicable rights, contact us at zosoiro8794@gmail.com. We will respond to privacy-related requests within a reasonable period after verification.

Your General Privacy Rights

Subject to applicable law, you may have the right to:

We may need to verify your request before acting on it. We will not discriminate against you for exercising privacy rights permitted by law.

Request Correction

If personal data or personal information we maintain about you is inaccurate or incomplete, you may request correction or rectification by emailing zosoiro8794@gmail.com with a description of the information you believe should be updated and sufficient detail for us to locate relevant records. We will review verified correction requests and update records where appropriate, subject to legal retention requirements and technical limitations of locally stored App data.

Right to Know (Data Sharing)

You may ask what categories of personal data or personal information we collect, the purposes of processing, categories of recipients, and whether data is shared with third parties. We provide structured disclosures in the Data Inventory and Sharing Matrix sections of this Privacy Policy. California and Virginia residents have additional rights described below.

California Consumer Privacy Act (CCPA) / CPRA

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding personal information, including the right to know about personal information collected, used, disclosed, or shared; the right to delete personal information; the right to correct inaccurate personal information; and the right to limit use and disclosure of sensitive personal information where applicable.

To exercise these rights, email zosoiro8794@gmail.com with the subject line "California Privacy Request" and describe your request. We will respond to privacy-related requests within a reasonable period after verification.

California disclosure paragraph: Under the CCPA, you have the right to know whether we collect, use, or share your personal data or personal information, including whether personal data has been shared with third parties, the categories involved, and the business purposes. This Privacy Policy is intended to satisfy those disclosure obligations. Contact zosoiro8794@gmail.com to submit a verified request.

Meaning of "share" under California law: Under the CCPA, the terms "share" and "sharing" have a specific definition under California law that differs from ordinary English usage. Sharing includes making personal information available to a third party for cross-context behavioral advertising, whether or not money is exchanged. We do not sell personal and sensitive user data. For a full description of recipients and purposes, see the Sharing Matrix section. California residents may exercise the right to know by emailing zosoiro8794@gmail.com. We will respond to privacy-related requests within a reasonable period after verification.

Virginia Consumer Data Protection Act (VCDPA)

If you are a Virginia resident, the Virginia Consumer Data Protection Act (VCDPA) grants rights including access, correction, deletion, portability, and opt-out rights related to certain processing activities. Submit VCDPA requests to zosoiro8794@gmail.com with sufficient detail for verification. We will respond to privacy-related requests within a reasonable period after verification.

How to opt out under the VCDPA:

  1. Targeted advertising: We do not use personal data for targeted advertising as defined under the VCDPA. If you believe otherwise or wish to confirm your status, email zosoiro8794@gmail.com with "VCDPA Opt-Out — Targeted Advertising" in the subject line to opt out or receive confirmation.
  2. Sale of personal data: We do not sell personal data. If you wish to opt out of any future sale or receive written confirmation that no sale occurs, contact zosoiro8794@gmail.com with "VCDPA Opt-Out — Sale."
  3. Profiling with legal or similarly significant effects: We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. If you have concerns or wish to opt out of profiling for such purposes, email zosoiro8794@gmail.com with "VCDPA Opt-Out — Profiling."

EEA, UK, and Swiss Users

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may have additional rights under applicable data protection law, including rights of access, rectification, erasure, restriction, objection, and data portability. Where processing is based on consent, you may withdraw consent at any time. Contact zosoiro8794@gmail.com to exercise these rights. You may also lodge a complaint with your local supervisory authority.


Security

We implement administrative, technical, and organizational measures designed to protect information processed through the App against unauthorized access, alteration, disclosure, or destruction. These measures include access controls for internal systems, encryption in transit where supported for network communications, and contractual safeguards with service providers that handle data on our behalf.

No method of electronic storage or transmission is completely secure. While we work to protect information, we cannot guarantee absolute security. You can support security by keeping your Android operating system updated, using device lock features, and avoiding sharing sensitive personal details in AI conversations beyond what you are comfortable having processed for App functionality.

If we become aware of a security incident that materially affects personal data and is likely to require notification under applicable law, we will take steps to investigate, mitigate harm, and notify affected individuals or regulators as required.


Eligibility and Access Mode

Orselle is intended for users aged 18 and above. The App does not include comprehensive in-app age verification beyond an initial user confirmation step. If you are under 18, you must not use the App. By using the App, you represent that you are at least 18 years old and legally permitted to use the App in your jurisdiction.


Controller

The data controller responsible for personal data processed in connection with the App is:

Qingdao Pinxiaoyi New Energy Co., Ltd.

Household 1102, Building 1, No.10 Middle Hongkong Road, Shinan District, Qingdao City, Shandong Province

For privacy inquiries, contact: zosoiro8794@gmail.com

Data Protection Officer (DPO)

We have designated Privacy Officer to oversee data protection compliance for the App. Privacy Officer serves as our contact for data protection matters and handles inquiries relating to the processing of personal data and applicable privacy rights. Users may contact the DPO regarding data protection and privacy matters at zosoiro8794@gmail.com. The DPO coordinates responses to rights requests, regulatory inquiries where applicable, and internal reviews of privacy practices connected to Orselle.


Where the General Data Protection Regulation (GDPR) or similar laws apply, we process personal data only when we have a valid legal basis (also referred to as a lawful basis) for doing so. The primary grounds we rely on are described below.

Performance of a contract (or equivalent): We process information necessary to provide the App’s core services you request— including delivering AI text and voice interactions, maintaining per-character conversation context during use, and operating features you actively invoke— because this processing is necessary to perform our service relationship with you as an App user.

Legitimate interests: We process certain device, diagnostic, and security-related information based on our legitimate interests in operating, securing, and improving the App. We balance these interests against your rights and expectations, limiting collection to what is reasonably necessary. Examples include crash diagnostics, fraud or abuse prevention, and understanding aggregate usage patterns to maintain stability.

Consent: Where Android permissions or optional features require your consent under applicable law— such as enabling the camera, microphone, or photos/media picker— we rely on your consent granted through the system permission dialog or in-App prompts. You may withdraw consent by changing device permissions or discontinuing use of optional features.

Legal obligation: We may process or retain information when required to comply with applicable law, regulatory requests, lawful orders, or to establish, exercise, or defend legal claims.

| Processing purpose | Legal basis |

|---|---|

| Core App service (AI chat, voice sessions, local conversation history) | Performance of a contract; legitimate interests |

| Media capture, selection, and optional saves | Consent |

| Analytics, diagnostics, and performance monitoring | Legitimate interests |

| Security monitoring and incident response | Legitimate interests; legal obligation where applicable |

| Engagement with service providers (hosting, analytics) | Performance of a contract; legitimate interests |


Sharing Matrix

We share information with third parties only as described below or when required by law. We do not sell personal and sensitive user data.

Cloud Hosting / CDN

Infrastructure partners may process chat content, optional profile-related selections, and diagnostic payloads strictly to host, transmit, store, and deliver Orselle’s core functionality. These providers act under contractual instructions and may not use the information for their own independent marketing purposes.

Analytics / Crash Reporting

Analytics and crash-reporting partners receive event and device metric data to help us understand stability, diagnose failures, and improve performance. We configure these services for operational analytics rather than cross-context behavioral advertising.

Other Disclosures

We may disclose information if we believe in good faith that disclosure is necessary to comply with law, respond to lawful requests from public authorities, protect users or the public, or protect our legal rights. If we are involved in a merger, acquisition, or asset sale, information may be transferred subject to continued protection consistent with this Privacy Policy.


Changes and Contact

We may update this Privacy Policy from time to time to reflect changes in the App, legal requirements, or our processing practices. When we make material changes, we will provide notice through reasonable means, such as updating the effective date at the top of this document or presenting an in-App notice where appropriate. Continued use of the App after the updated effective date constitutes acknowledgment of the revised policy.

For questions, concerns, or requests regarding this Privacy Policy or our data practices, contact:

Qingdao Pinxiaoyi New Energy Co., Ltd.

Email: zosoiro8794@gmail.com

Address: Household 1102, Building 1, No.10 Middle Hongkong Road, Shinan District, Qingdao City, Shandong Province

Privacy Officer (DPO): zosoiro8794@gmail.com


Additional Operational Details

How Orselle Works Without Accounts

AI Conversations and Voice Sessions

When you exchange text messages or initiate voice calls with AI characters, your inputs and the App’s responses are processed to generate conversational output. AI characters are designed for emotional companionship and expression support; they are not human and do not retain real-world memories beyond what is needed for session continuity and feature delivery. Do not rely on the App for medical, legal, or financial advice.

Free App; No In-App Purchases

Orselle is offered free of charge. The App does not include in-app purchases, subscriptions, or Google Play Billing transactions. We do not collect payment card or billing information through the App.

Support Requests

If you contact us by email for support, we process the information you choose to include in your message— such as device model, Android version, and description of an issue— to respond to your inquiry and maintain records of correspondence as needed.

Data Deletion Requests

Because there is no account to close, deletion requests relate to data linked to your use of the App, data you submitted through support channels, or residual server-side logs associated with your device or session identifiers. To request deletion, email zosoiro8794@gmail.com with "Data Deletion Request" in the subject line and describe what you want removed. We will respond to privacy-related requests within a reasonable period after verification. Local data can also be removed by uninstalling the App and clearing App data in Android settings.


Children

Orselle is not directed to individuals under 18 years of age, and we do not knowingly collect personal data from children. If you are under 18, you must not use the App. If we learn that we have inadvertently processed personal data from someone under 18 without appropriate authorization, we will take steps to delete that information where feasible. Parents or guardians who believe a minor has used the App may contact zosoiro8794@gmail.com.


Data Inventory

The following describes categories of information that may be collected or generated through the App. Collection varies based on features you use and permissions you grant.

Device and technical information: Android version, device model, language settings, app version, network status, and similar technical metrics used for compatibility, security, and diagnostics.

Usage and diagnostic information: Feature interaction events, session timestamps, crash logs, and performance metrics.

User-generated content: Text messages you send to AI characters, voice audio during active voice sessions, optional images you capture or select, and favorites or similar content you save within the App.

Local preferences: Character selections, interface choices, and conversation histories stored to support per-character dialogue continuity.

Support communications: Information you provide when emailing us.

Google Play Data Safety Alignment

We do not collect precise location, contacts, or SMS content through the App based on current permissions. No third-party advertising SDK inventory was provided for this release; if that changes, this Policy will be updated accordingly.


Supplementary Reviewer Transparency

This section provides additional clarity for app store reviewers, regulators, and users evaluating consistency between the App’s behavior and this Privacy Policy.

Permission-background statement: Camera, microphone, and photos/media access are not used in the background.

Monetization: The App is free and does not process payment or subscription data.

SDK disclosure: No specific third-party SDK list was provided for this build. Processing still occurs through standard Android components and infrastructure/analytics categories described in the Sharing Matrix.

Sensitive data caution: While the App supports emotional expression, please avoid entering government ID numbers, financial account details, or medical records in chat or voice sessions.

Regional scope: Global availability with region-specific rights described in the Rights and U.S. Notices section.


Retention

We retain information only as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required by law.

Locally stored App data (such as conversation history and preferences) remains on your device until you delete it, clear App storage, or uninstall the App.

Server-side processing data tied to delivering AI interactions and maintaining service continuity is retained for a limited operational period and then deleted or de-identified according to our internal schedules, unless retention is necessary for security, dispute resolution, or legal compliance.

Diagnostic and analytics records are generally retained in aggregated or pseudonymous form for a shorter period aligned with troubleshooting and product improvement needs.

Support email correspondence is retained as long as needed to resolve your inquiry and maintain appropriate business records.

When you submit a verified deletion request to zosoiro8794@gmail.com, we will delete or anonymize applicable server-side records within a reasonable period after verification, subject to exceptions for legal obligations or ongoing security investigations.


Platform Scope

This Privacy Policy applies to the Android version of Orselle distributed through Google Play. It is written for the Android permission model, including photos/media access and scoped storage behavior on modern Android releases.

This Policy does not describe iOS, Apple App Store, IDFA, or Apple-specific frameworks, because those platforms are outside the current distribution scope unless explicitly stated elsewhere by us. If you obtained the App from an unauthorized source or sideloaded build, protections described here may differ.

Device settings paths referenced in this Policy follow standard Android conventions. Manufacturer-specific variations may apply.


Transfers

We are based in China and may process or store information on servers located in China and in other countries where our service providers operate. These locations may have data protection laws that differ from those in your country of residence.

When we transfer personal data internationally, we implement appropriate safeguards as required by applicable law, such as standard contractual clauses or equivalent mechanisms, and we require processors to protect information consistent with this Privacy Policy.

If you are located in the EEA, UK, or Switzerland and your data is transferred to countries without an adequacy decision, you may contact zosoiro8794@gmail.com for more information about applicable safeguards.

By using the App, you acknowledge that information may be processed in jurisdictions outside your own, subject to the protections described in this Privacy Policy.

No Sale Statement

We do not sell personal and sensitive user data.

Third-Party Sharing Mapping

Data Safety Mapping

Sensitive Permissions Background Access