隐私政策

TEST 2026-06-16

Privacy Policy


Welcome to SenseRobot Chess!

SenseRobot (Hong Kong)Technology Limited (“we”, “us”, and/or “our”) operates the SenseRobot Chess mobile application and the device (the “Services”). This Privacy Policy (the “Policy”) describes how we collect, store, use, and share information through our Services.
We care about the protection and confidentiality of your information. We process your personal information only as described in this Policy. If you have any questions regarding this Policy, please contact us according to the information listed below under the Section “Contact Us”.

1 PERSONAL INFORMATION WE COLLECT
2 HOW WE USE YOUR INFORMATION
3 HOW WE SHARE YOUR PERSONAL INFORMATION
4 HOW WE TRANSFER YOUR DATA AROUND THE WOLRD
5 HOW WE SECURE YOUR INFORMATION
6 HOW DO WE RETAIN YOUR PERSONAL INFORMATION
7 YOUR RIGHTS AND CHOICES
8 ADDITIONAL DISCLOSURES FOR SPECIFIC JURISDICTIONS
9 USE BY MINORS
10 CHANGES TO THIS PRIVACY POLICY
11 CONTACT US

1. PERSONAL INFORMATION WE COLLECT
For the purpose of this Policy, “personal information” means any information relating to an identified or identifiable individual. In certain jurisdictions, this may be referred to as “personal data”. However, for the sake of consistency, this Policy will use the term “personal information” throughout to refer to such data. To the extent that our processing of your personal information is subject to certain data privacy protection laws (including but not limited to the General Data Protection Regulation (“GDPR”), California Consumer Privacy Act of 2018 (“CCPA”), California Privacy Rights Act of 2020 (“CPRA”), etc., collectively hereafter “applicable laws”), we will also notify you about the legal basis on which we process your personal information and your rights under such laws.
1.1. Information you provide
Upon powering on the device, you will be prompted to connect to a network and create your account. You may choose to remain offline. In offline mode, you can play chess without registration and no personal information will be collected or processed.
If you choose to connect to a network and create your account, through your use of the Services, you may provide us with the following information:
a. Account Data. Depending on your registration choice, this includes your date of birth, phone number and verification code, or e-mail address and password.
Register via Email: date of birth, valid email address and password;
Register via Mobile Number: date of birth, mobile number and verification code.
When you use our Service, you may create an account with your information to complete the registration and become our user. If you refuse to provide Account Data for registration and login, we may be unable to offer you our Services in online mode.
b.  Profile Data. This includes your profile photo and nickname. After you have created and logged into your account, you can further edit your Profile Data. We will use your Profile Information to provide you with personalized image exhibition. You have the option to choose which information to share with us. If you refuse to provide these information, it will not affect your use of our basic services.
c. Transaction Data. This includes transaction details（item name, order number, transaction date, amount）, form of payment, payment confirmation and other payment details. The Transaction Data is necessary to offer you the paid services. If you refuse to provide this information, you will be unable to use such features.
1.2. Information we collect from third parties
a. Third-party Account Data: When you use our Services to interact with other players through third-party platform, such as Lichess, we will collect your account information to bind your SenseRobot account. If you refuse to provide these information, it will not affect your use of our basic services.
1.3. Information we collect automatically
We automatically log the following information about you, your network, your interactions over time with our Services and your order information:
a. Device and Network Data. This includes your IP address, WIFI SSID list and password, location information, device SN information, clipboard data.
b. Service Interaction Data. This includes your behavior information while using the Services, including your chess game settings, game records, game level information.
c. Service Order Data. This includes your order number, the Services you choose to purchase, time when you place the order, the amount of payment.

2. HOW WE USE YOUR INFORMATION
We will only use your personal information when the applicable laws allow us to. Our legal bases for collecting and using the personal information described in this Policy depends on the personal information we collect and the specific context in which we collect the information:
  • We need to perform a contract with you;
  • You have given us consent to do so;
  • In specific jurisdictions, processing your personal information is in our legitimate interests, including
  • providing, maintaining and marketing our Services;
  • detecting, preventing and enforcing violations of our Terms of Use including misuse of services, fraud, abuse, and other trust and safety protocols; and
  • protecting our legal rights and the rights of others.
  • We need to comply with our legal obligations under the applicable laws.
The purposes for which we process personal information, subject to applicable laws, and the legal basis on which we perform such processing, are as follows:
Purpose
Type of Personal Information
Legal Basis
To provide you with functions related to user account management, such as account registration, account deletion, and account login
  • Account Data
  • Device and Network Data
Performance of contract
To provide the core functionality of the Services, including Chess AI, Endgame, Courses & Exercises, Online chess, Self-set chess game
  • Service Interaction Data
  • Device and Network Data
  • Third-party Account Data
Performance of contract
To provide you with the paid Services
  • Account Data
  • Identification Data
  • Service Order Data
  • Service Interaction Data
  • Device and Network Data
Performance of contract
To provide the additional functionality of the Services, including personalized account configuration, illuminated mode
  • Profile Data
  • Live Image Data
Consent
To monitor and protect the Services to ensure the normal operation of the Services you use, including preventing fraud, criminal activity, and misuse of our Services
  • Account Data
  • Device and Network Data
  • Service Interaction Data
Performance of contract & Legitimate interests
To comply with legal obligations, and defend against legal claims and disputes
  • Account Information
  • Third-party Account Information
  • Profile Information
  • Device and Network Data
  • Service Interaction Data
Legal Obligations, Legitimate interests, Consent, where required by applicable laws

3. HOW WE SHARE YOUR PERSONAL INFORMATION
In order to provide you with more comprehensive and high-quality Services, we will authorize our commercial partners to provide certain services to you. In such cases, we may share some of your personal information with our partners.
We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and we will only share the personal information required to provide the Services. We will require our partners, through agreements, to retain data only for the necessary period and to implement adequate security measures to protect data security.
We will disclose personal information to the following categories of third parties for the purposes explained in this Policy:
  • Affiliates and corporate partners. We disclose the categories of personal information described above between and among our affiliates and related entities, for legitimate business purposes and the operation of the Services, in accordance with applicable laws.
  • Service providers and business partners. Third-party service providers who provide us with technology services (such as cloud storage service, cybersecurity provider) and business support (such as payment service provider) may need to process your data. These third parties will process your personal information on our behalf under relevant contracts.
  • Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose your personal information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our Terms of Use and other terms, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by applicable laws (including exchanging information with other companies and organizations for the purposes of fraud protection).
  • Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

4. HOW WILL WE TRANSFER YOUR DATA AROUND THE WOLRD
Your personal data may be processed or transferred outside the country or region where you reside. Currently, your personal information will be stored in our servers located in Japan. For users from the EU, such transfers are made on the basis of an adequacy decision.
Besides, in the event of an international transfer of personal information, when required by applicable laws, we will provide an adequate level of protection for your personal information using various means, including implementing Standard Contractual Clauses or data transfer agreements that comply with applicable laws between our affiliates and third parties or any other lawful approach that permits the lawful transfer of personal data from those countries.
5. HOW WE SECURE YOUR INFORMATION
We place utmost importance on personal information security and implement stringent measures to protect user data. We have designated dedicated personnel responsible for personal information protection matters, having obtained ISO 27001 international certifications. We employ advanced security technologies including encrypted transmission and storage, access control, and HTTPS protocols.
Our server systems undergo rigorous security hardening, with regular audits and upgrades. Employees are subject to the principle of least privilege and receive comprehensive confidentiality training. The company has established cybersecurity emergency response protocols, conducts regular drills, and ensures timely incident response and user notification when necessary.
We also remind users to remain vigilant about network environment risks, recommending the use of strong passwords and exercising caution when sharing personal information. We are committed to continuously enhancing security safeguards. However, users should also strengthen self-protection awareness and provide personal information only when absolutely necessary.
6. HOW DO WE RETAIN YOUR PERSONAL INFORMATION
We adhere to retention policies for the personal information we collect to ensure that it is not retained longer than necessary for the intended purpose.
If you deactivate your account, delete personal information, or the retention period is expired, we will delete or anonymize your personal information, except in the following cases:
  • Compliance with legal requirements regarding data retention according to the applicable laws.
  • Extension of the period for financial, audit, dispute resolution, or other legitimate purposes.
When assessing how long your personal information is retained, we consider criteria such as: (i) the nature of the personal information and the activities involved; (ii) when and for how long you use the Services; and (iii) our legitimate interests and our legal obligations.
7. YOUR RIGHTS AND CHOICES
Subject to applicable law and depending on where you reside, you may have some rights regarding your personal information, as described below. If you have any other requests relating to the access of your personal information, please contact us using the contact details listed in the Section “Contact Us”.
  1. Data Access and right to obtain a copy
You may have the right to know what personal information we process about you, including the categories of personal information, the business or commercial purposes for collection, the categories of third parties to whom we disclose it and other information according to the applicable law.
You may have the right to access and obtain a copy of your personal information in accordance with the applicable laws. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
  1. Data Correction
You may have the right to request that we correct inaccurate personal information that we retain about you, subject to certain exceptions.
  1. Data Deletion
You have the right to delete your account and erase your personal information. Upon deleting your account, all your personal information will be deleted. Additionally, you may also request deletion of the personal information you provide by contacting us. If some of your personal information cannot be deleted, we will inform you of the reasons for not taking action.
Please note that we reserve the right to retain some of your personal information where there are valid grounds for us to do so under applicable laws.
  1. Withdrawal of Consent
Where we process your personal information on the basis of your consent, you may withdraw your consent by contacting us. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
  1. Objection to the Processing
Subject to applicable laws, you may object to the processing of your personal information based on our legitimate interests where there are grounds relating to your particular situation by contacting us. Please note that we may have an overriding legitimate interest to keep processing your personal information, but we will let you know where this is the case.
  1. Restriction to the Processing
If you would like to restrict our processing of your personal information, you may contact us. You have the right to restrict the processing of your data where one of the following applies:
  • the processing is unlawful and you oppose the erasure of relevant personal information;
  • for the purpose of establishment, exercise or defense of legal claims, you request us to retain your personal information that we were supposed to delete;
  • your objection regarding the accuracy of your personal information is pending our verification;
  • your request to object to the processing of your personal information is pending our verification.
  1. Data Portability
Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of the available information.
  1. Lodge a complaint with your local data protection authority
Subject to applicable data protection laws, you may have the right to submit your complaint to the local data protection authority where you reside if you consider that the processing of your personal information infringes any applicable data protection laws.
  1. Not to be subject to automated decision-making
You shall have the right not to be subject to automated decision-making, which will affect you to a substantial degree. You also have the right to review your personal data used for automated decision-making, to question the results, to be informed of the reasons of the resulting decision, and to be informed of what actions you can take to secure a different decision.
  1. Other Rights
Depending on your jurisdiction, you may be entitled to additional rights in relation to your personal information. If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in Section “Contact Us” below.
When submitting a right request, please specify the scope and basis of your request and provide us with the necessary information to verify your identity. We may contact you to confirm your identity in order to handle your request. We will typically respond to your request no later than the timeframe required by applicable laws.
8. ADDITIONAL DISCLOSURES FOR SPECIFIC JURISDICTIONS
  1. California
We collect the following personal information from and about you in the preceding 12 months.
Categories
Examples
Personal identifiers
Such as phone number, profile photo, nickname, third-party platform account information
Personal information
Such as phone number
Internet or other electronic network activity information
Such as verification code, IP address, device SN information, clipboard data, chess game settings, game records, game level information
Commercial information
Such as your order number, the Services you choose to purchase, time when you place the order
Sensitive personal information
/
Geolocation data
Such as location information
We disclose personal information with third parties for business purposes as below:
Categories of personal information
Disclosed to which categories of third parties
All categories detailed in Section 1 above
Cloud storage services provider and our affiliates
Service Order Data
Payment processors
Account Data
Third-party platform, such as Lichess
To the extent provided for by local law and subject to applicable exceptions, you may have the following rights:
  • Limit the Use of Sensitive Personal Information. You also have the right to request limitation of use and disclosure of your sensitive personal information, subject to certain exceptions. If you would like to limit the use of your sensitive personal information, please contact us by using the contact details provided in the Section “Contact Us” below.
The telephone number and verification code for logging in and registration are sensitive personal information under certain State data protection laws. We do not “sell” or “share” (as defined under applicable State data protection laws) your sensitive personal information.
  • Do Not Sell or Share My Personal Information. Based on the definition of “sell” and “share” under applicable State data protection laws, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy. You have the right to opt-out of sale or sharing of personal data to third parties, targeted advertising, profiling, automated decision making, collection of sensitive personal data, or collection of personal data through the operation of a voice or facial recognition.
  • Appeal. You may appeal our refusal to take action on a request by contacting us using the contact details provided in Section “Contact Us” below.
  • Direct Marketing. We do not disclose personal information to third parties for their direct marketing purposes.
If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in the Section “Contact Us” below. According to applicable laws, we may request you provide documents such as application form and proof of identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under the applicable laws. We will not discriminate against you for exercising any of these rights.
  1. India
This supplement to this Policy which applies to the processing of personal information in India or of Indian residents and shall be read in conjunction with this Policy. We ensure compliance with the requirements of the Digital Personal Data Protection Act, 2023 (the Act) with regards to the collection, storage, processing and disclosure of personal information and is committed to upholding the core data protection principles.
  1. General
We may collect information from your use of our Services, which may also include your personal information or “sensitive personal information” or data, as defined under the applicable law. The sensitive personal information that we collect from you may include your password.
  1. Permission for collection of information
We collect and process your personal information, including sensitive personal information, under lawful bases, and with consent where required.
  1. Sharing of information
We may share, disclose and/or transfer such information (including sensitive personal information, as defined under the applicable law) to third parties in accordance with this Policy and this addendum. However, we will transfer your information to only such third-party companies which employ a level of data protection as may be required under the applicable law.
  1. Australia
  2. Transferring of personal information outside of Australia
If you are located in Australia, as part of the Services offered to you, the information that you provide to us will be transferred to, and potentially stored and/or processed in, countries and regions outside of Australia, including but not limited to Japan, Hong Kong and the PRC. By submitting your personal data, you’re agreeing to this transfer, storing and/or processing. Additionally, if you use our Services while you are outside of Australia, your information may be transferred outside of Australia to provide you with those services.
  1. Your Legal Rights
You may access or request correction of the personal information that we hold about you by contacting us using the contact details set out in this Policy. There are some circumstances in which we are not required to give you access to your personal information.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete.
  1. Complaints
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us using the contact details set out in this Policy.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
9. USE BY MINOR
We understand the importance of protecting minor's privacy. Our Services are not directed at, marketed to, nor intended for minors, especially for minors under the age of 14 are not permitted to register for our Services.
We do not knowingly collect, use, sell, share or disclose the personal data of minors. If we collect the personal data of minors on an occasional basis, we will delete the relevant information as soon as possible after verification. If you find that we have collected the personal data of minors during your usage of our products and services, please contact us through the contact information published in this Policy. Upon receipt of your notice, we will verify it in a timely manner and delete relevant information after verification.

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10. CHANGES TO THIS PRIVACY POLICY
The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Policy. we recommend that you regularly check the latest version of this Policy in the APP. If there are any substantial changes to this Policy, depending on the nature of such changes, we will notify you in advance through pop-ups, push notifications, and other appropriate means.
11. CONTACT US
For more information about your data subject rights, or how we process your personal information, please contact us by using the information below.
Controller: SenseRobot (Hong Kong)Technology Limited
Data Protection Officer: SenseRobot Privacy Team
Representative in the EEA: [DeTech International GmbH
].
Address: Rheinstrasse 35, DE-76776 Neuburg, Germany
Contact Details: info@detechi.com / [+49 176 70084317]