Data Privacy Policy

Last Updated: October 22, 2025

This Data Privacy Policy outlines how “DxLab Limited” (“we,” “us,” or “our”) collects, processes, stores, and protects your personal data when you use “dthinkr.ai” (the “Service”). We are committed to respecting your privacy and ensuring the security of your personal information in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.

1. Information We Collect

We may collect and process the following types of personal data in relation to your use of our Service:

1.1 Personal Information

• Identity Data: Name, email address, and any other details you provide when creating your account or interacting with the Service.
• Interaction Data: Data generated from your interactions with the AI agent, including user prompts and responses.

1.2 Technical Data

• Usage Data: Information about how you use our Service, including your IP address, browser type, and operating system.
• Device Data: Information about the device you use to access the Service, such as device identifiers and settings.

1.3 Third-Party Data

• Data received from third-party sources, which may include AI models (where applicable), cloud service providers, and analytics services that help us understand user behavior and improve our Service.

2. Purposes of Data Collection

We collect and process your personal data for the following purposes:

• Service Provision: To provide, maintain, and improve our Service, including AI-driven responses to your prompts.
• User Support: To respond to your inquiries and provide customer support.
• Research and Development: To analyze usage patterns and develop new features, functionalities, and service improvements.
• Compliance and Legal Obligations: To comply with applicable laws and regulations, including data protection laws.

3. Data Processing and AI Transparency

We utilize AI models, including third-party AI services. We commit to ensuring transparency in our AI usage. We strive to:

• Provide Clear Information: To offer explanations on how AI-generated responses are produced and the logic behind AI decisions.
• Maintain Accountability: To uphold standards for responsible AI usage and ensure compliance with ethical guidelines and relevant regulations.

4. Data Storage and Security

We adhere to the following practices to ensure your data is securely stored and processed:

• Encrypted Storage: Personal data is encrypted at rest using secure cloud services.
• Access Control: We implement strict access controls to limit personnel access to your data.
• Data Retention: We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Policy or as required by law.

5. Data Sharing and Third Parties

We may share your personal data with third parties under the following circumstances:

• Service Providers: We may share data with third-party vendors who provide services to us, but only under strict contractual conditions to uphold your data privacy.
• Compliance with Laws: We may disclose information when required to do so by law or in response to valid requests by public authorities (e.g., a court, regulatory agency).
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred as part of that business transaction.

6. Your Rights

Under the Personal Data (Privacy) Ordinance (Cap. 486), you have certain rights regarding your personal data, including:

• Access: You can request access to personal data we hold about you.
• Correction: You can request corrections to any inaccuracies in your personal data.
• Erasure: You can request the deletion of your personal data in certain circumstances.

To exercise these rights, please contact us using the contact information provided below.

7. Cookies and Tracking Technologies

Our Service may use cookies and similar tracking technologies to enhance user experience, analyze usage, and improve our offerings. You can manage your cookie preferences through your browser settings.

8. Changes to This Policy

We may update this Data Privacy Policy from time to time. When we do, we will notify you by posting the new Policy on our website and updating the “Last Updated” date. We encourage you to review this Policy periodically for any changes.

9. Contact Us

Please contact our Data Protection Officer if you have questions about this Privacy Policy. We are pleased to provide you with more information about our privacy and data protection practices, including how to exercise your privacy rights.