Privacy Policy

Last Updated: 【October , 2025】

I. Introduction

1. This privacy policy (“Privacy Policy”) is issued by 【】 and its affiliates (“we”, “us,” “our,” or “uCloudlink”) and covers our practices regarding the collection, use, storage, transfer, and other processing of individually identifiable information about you (“Personal Information”) when you contact us, purchase, install, access or use our Pet Phone products, Pet Phone services in our Pet Phone apps and website (collectively the “Services”).
2. There may be jurisdiction specific provisions of this Privacy Policy for certain countries or regions. Please refer to Local Privacy Terms in Exhibit A for more information. If the Local Privacy Terms conflict with this Policy, the Local Privacy Terms prevail for the relevant jurisdiction.
3. By using the Services, you agree to be bound by our Terms of Service and acknowledge that you have read and understood this Policy. Where this Policy conflicts with mandatory local law, the applicable law prevails.

II. How uCloudlink Collects Your Personal Information

4. In order to provide our Services, we collect and process your Personal Information in several ways, including when you:
   • register for an account or use our Services;
   • visit our website/app or correspond with us by mail, telephone, or email;
   • provide your contact details to our marketing department requesting relevant and useful information about our Service through submission forms, or by telephone or e-mail;
   • make a purchase or otherwise conclude a transaction with us; or
   • contact us or provide information on social media channels.
5. Cookies and similar technologies (e.g. pixels and ad tags) (collectively “Cookies”) are small files which, when placed on your device, enable us to collect certain information, including Personal Information, from you in order to provide certain features and functionality. We and our service providers use Cookies to collect data and recognise you and your device(s). We do this to better understand the effectiveness of our Services and to enhance your user experience. To learn more about our use of Cookies, please find the Cookies Table at the end of this Privacy Policy.
6. Feature-specific collection for Pet Phone App. Only when you enable the relevant features, we collect the minimum data necessary to provide those features, including:
   • Pet tracking & geofencing (if you pair the App with compatible devices): pet device location, geofence settings and alerts, and location history;
   • Audio/video calls & live streaming: technical session metadata required to establish and maintain sessions (e.g., session IDs, timestamps, relay or routing information); unless you actively choose to record/save, we do not store the content of calls or live streams;
   • Pet-owner social posting/chat: posts, comments, images, short videos, live streams, and related interactions you choose to create or share;
   • Relaxing-music playback: playback events and preference settings to enable features and personalization;
   • Attribution & analytics (e.g., Appsflyer SDK): limited device/app identifiers and in-app events to measure performance and marketing effectiveness, consistent with your settings and applicable law.
   We collect such data only when necessary to deliver the feature you choose to use, and always in accordance with your device permissions and privacy settings.

III. The Types of Personal Information We Collect

7. Depending on the nature of your interaction with uCloudlink, we may collect, store, and use the below categories of information:
   • Account details: Name, area of permanent residence, telephone number, email address (where required) and optional pet profile information you provide (such as pet name, species, age, photo). If you do not provide the relevant information, you may not be able to register for an account and enjoy our services, as well as achieve the specific purpose for some particular services;
   • Transaction details: information relating to what you have purchased, spend history and details of payment method. We will also collect address and contact details for delivery. We do not collect payment card or account details;
   • Log information: when you use our Services and with your consent, the system may collect information such as mobile phone sim card permission (for the purposes of the international area code), positioning of the terminal, mobile phone model, mobile phone system version, mobile phone manufacturer, app log, MAC address, AndroidID, app log, and the IMEI number of your mobile device.
   • Location Information: we receive information from you and other third parties that helps us approximate your location, such as an IP address received from your browser or your device. The location may information may be collected from devices in accordance with the settings of your device.
   • Microphone: for audio connectivity and data transfer. If you do not provide the relevant information, you may not be able to use the video function.
   • Camera: for video calling, live streaming and creating video content within the App (only with your permission).
   • Community or UGC information: posts, comments, likes, messages and other content you choose to share publicly or within groups.
   • Media transmission data: where you initiate a video, voice call or live stream, we may process media data transiently for routing, quality and security purposes; we do not retain the media content unless you explicitly choose to record or upload.
   • Device identifiers and push tokens: device advertising identifiers (e.g., IDFA/AAID), app instance IDs, and push notification tokens used to deliver service messages and notifications, in accordance with your device settings.
   • Feature-specific signals for relaxing-music playback: Playback events and preference settings (e.g., volume, playlist, loop, favorites) to enable and personalize calming-music features for pets.
   • Social interactions and moderation metadata: Follows/followers, reports/blocks, and moderation logs maintained to ensure community safety.
   • Diagnostics and crash reports: Optional app diagnostics, crash logs, and performance metrics (de-identified where feasible) to troubleshoot and improve stability.
   • Support communications: The content of your inquiries to customer support and related attachments or metadata.
   • Third-party login and payment processors: If you choose to sign in via a third-party account or make payments through third-party processors, we may receive limited account or transaction status information from those providers (we do not receive your full payment card details).
   • Attribution and analytics SDK data: Limited device or app identifiers and in-app events to measure service performance and marketing attribution, consistent with your privacy settings and applicable law.
   • (If applicable) Pet tracking and geofencing: Pet device location, geofence settings, and alerts—collected only if you pair a compatible device and enable these features.
   Data associated with device permissions (camera, microphone, location, or notifications) will be collected only when you grant permission and activate the related feature. You may manage or revoke permissions at any time in your device settings, though this may affect feature availability.

IV. How uCloudlink may use Personal Information

8. In accordance with our contract with you and to perform the obligations under such contract, uCloudlink will use your Personal Information to:
   • provide and improve the Pet Phone Services, including features such as pet tracking, communication, relaxing-music playback, and pet-owner community interaction;
   • enable you to login and register an account with uCloudlink;
   • notify you about changes to our Service, communicate with you via in-app notifications, push messages, or emails, and provide you with user support or customer service;
   • operate app features including pet music playback, video/voice calls, and live streaming that you choose to use;
   • enforce our terms and conditions and policies, and maintain the integrity of our Services;
   • administer and secure the services, including troubleshooting, authentication, fraud monitoring, archiving, and backup purposes;
   • personalize your experience, such as providing content or music recommendations, customized feed displays, or localized service suggestions;
   • analyze and improve our products and user experience, and optimize functionality and performance;
   • conduct surveys, contests, or promotional campaigns, with your consent where required;
   • ensure community safety, prevent misuse of communication or live streaming functions, and moderate inappropriate content or behavior;
   • comply with applicable legal obligations, regulatory requests, or judicial orders; and
   • where applicable, distribute hardware devices or accessories linked to the Services.
   uCloudlink will use your Personal Information for the purposes described above and for any other purposes that are compatible with those originally stated, or as otherwise disclosed to you at the time of collection, and always in accordance with applicable law.
9. In accordance with our legitimate interests to provide an effective and dynamic service, we may use your information to:
   • ensure the security and integrity of Services provided to you by uCloudlink including authentication, security, fraud monitoring, archiving and backup purposes;
   • help uCloudlink analyze and improve app performance, reliability, and user experience, including through aggregated and de-identified data analytics;
   • personalize your experience by providing recommended pet-related content, calming music, posts, or events that may be relevant to your interests and region;
   • enabling uCloudlink to show you recommended packages in accordance with your area of residence;
   • analyze your geographical location to provide better network coverage, recommended packages and to understand data traffic status of your location; and
   • support internal business operations, such as audits, compliance reviews, and customer engagement analysis; and
   • exercise or defend legal claims, where necessary to protect our rights or comply with applicable laws.
10. With your consent, we may process your Personal Information for optional or enhanced features — such as participating in surveys, receiving marketing communications, enabling community or social functions (e.g., posting, commenting, or live streaming), or allowing camera/microphone access for related services. You can withdraw this consent at any time; however, some features that rely on such consent may become unavailable.

V. How uCloudlink may share, transfer, disclose your Personal Information

11. Except for the following circumstances, uCloudlink and its affiliates will not share your Personal Information with any third party without your consent.
12. uCloudlink and its affiliates may share your Personal Information with our affiliates, partners, or trusted service providers (for example, Amazon Web Services for data hosting, payment gateways, logistics and customer support providers) strictly for the following purposes:
    • to provide, maintain, and improve the Services for you;
    • to carry out the purposes as described in section “How uCloudlink may use Personal Information”;
    • to fulfil uCloudlink’s responsibilities and obligations in the Terms and Conditions and this Privacy Policy; and
    • in connection with a merger, sale, or asset transfer.
13. If you pay for your Services using Paypal, Braintree, Paypal or Stripe, you acknowledge and agree that the processing of such payment shall be handled by that third party and will be subject to their terms and conditions and your data will be handled by them in accordance with their privacy policy. You must review these third party terms before proceeding.
14. We put in place contracts with third parties containing appropriate commitments regarding the handling and security of your personal data.
15. uCloudlink or its affiliates may save, store or disclose your Personal Information for the following purposes:
    • to comply with applicable laws and regulations and safeguard public interests;
    • to comply with court orders or regulations of other legal procedures;
    • to comply with regulatory requirements of relevant government departments; and
    • to protect the legal rights, personal/real property, or personal safety of our users and uCloudlink’s employees.
16. Where you voluntarily post, stream, or share content in the Pet Phone community (such as photos, comments, live sessions, or pet videos), this content and related metadata may be visible to other users or the public, depending on your sharing settings. Please exercise caution when sharing personal or pet-related information, as such content will be processed in accordance with Section III of this Policy.

VI. Where we store your personal information

17. Your Personal Information and documents are stored on uCloudlink’s servers and the servers of third-party providers we engage to provide services to us. uCloudlink will take appropriate steps to ensure that any such third party complies with appropriate confidentiality and security measures.
18. Personal Information is stored by Amazon Web Services (AWS), with EU and UK Personal Information being hosted in Ireland and non-EU Personal Information being hosted in Singapore, except for data relating to Chinese users, whose Personal Information being hosted in China.
19. Where cross-border transfers occur, we implement appropriate safeguards such as the European Commission’s Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA), or other mechanisms permitted under applicable law to ensure adequate protection of your Personal Information.

    If you are located in the EEA, the United Kingdom, or other jurisdictions that require specific data-transfer safeguards, please see Local Privacy Terms in Exhibit A for additional information about the safeguards we take to protect your Personal Information and how we comply with applicable local requirements.

VII. How you access and control your Personal Information

20. uCloudlink will do its utmost to take the appropriate technical measures to ensure that you can access, update, correct and delete your own registration information or other Personal Information provided when you use our services. For further information about the specific rights you have to access, update, correct or delete your Personal Information, please refer to the relevant local section of the privacy policy below for further information.
21. When you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security.
22. For users residing in specific jurisdictions, please refer to the Local Privacy Terms in Exhibit A for further details on exercising these rights.

VIII. How uCloudlink Protects Your Personal Information

23. Unfortunately, no security system or system for the transmission of information via the internet can be guaranteed as completely secure. uCloudlink maintains appropriate technical and organizational measures to protect against unauthorized or unlawful processing of Personal Information and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage to your Personal Information. To try to prevent unauthorized access, maintain data accuracy and ensure the correct use of information, uCloudlink maintains physical, electronic, standard security practices, including encryption, passwords and physical security measures, and managerial procedures to protect the security and confidentiality of Personal Information. Only a limited number of persons within our organization are authorized to access, delete or modify your data. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information. uCloudlink evaluates these measures on a regular basis to ensure the security of processing.
24. uCloudlink employees or any of uCloudlink’s contractual partners who have access to your data in order to provide services to uCloudlink or uCloudlink’s customers are contractually obligated to keep such information in confidence and may not use these data for any other purpose than performing their contractual missions for uCloudlink or uCloudlink’s customers.
25. If a data security incident occurs, we will take steps consistent with applicable law to notify you and relevant regulators where required.

IX. Protection of Minors’ Personal Information

26. The Pet Phone App and related Services are intended for use by adults. We do not knowingly collect Personal Information from children below the age of majority in their jurisdiction. If we recognize that you are not of the age of majority in your country, we will terminate the service and delete your information. We will notify you by app push, email and SMS before terminating the service.
27. If we discover that we have inadvertently collected Personal Information from a child without parental or guardian consent, we will promptly delete such information and, where appropriate, notify the parent or guardian.
28. We may request users to confirm their age at the time of registration or when using certain features, and we reserve the right to suspend or terminate accounts that do not meet the age requirement.

X. Data Retention

29. We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, and delete or anonymise your personal information after the aforementioned retention period, unless otherwise required by law or regulation.
30. We will delete your Personal Information within 60 days of you deleting your account unless we have a legal obligation to retain such data in which case we shall retain such data only for so long as we are required to do so by law.

XI. Updates to this Privacy Policy

31. We may amend or update this Privacy Policy from time to time, consistent with applicable privacy laws and principles. We will notify you of such changes by app push or in-app messaging. Your continued use of the Services constitutes your acceptance of our Privacy Policy.

XII. Contact Us

32. If you have any questions about this Privacy Policy or our products, please feel free to give us feedback. You can reach us by email at:
    • supportus@ucloudlink.com, if you are located in the US
    • glocalmeconnect@outlook.com, if you are located in the UK or EU
    • service@ucloudlink.com, if you are located in other countries or territories

Exhibit A
Local Privacy Terms

These Local Privacy Terms form part of the Pet Phone App Privacy Policy and apply only to users whose Personal Information is subject to the laws of the listed jurisdictions. Where there is any conflict between these Local Privacy Terms and the main Policy, the Local Privacy Terms shall prevail for that jurisdiction.

1. European Economic Area (EEA) and United Kingdom

Your Rights Under GDPR and the UK Data Protection Act 2018

Data Controller
For purposes of the General Data Protection Regulation of EU and Data Protection Act 2018 of the UK, the data controller responsible for processing of Personal Information described in this Privacy Policy is:

• to the extent such processing of data relates to purchase of a Device, Hong Kong uCloudlink Network Technology Ltd.,
• to the extent such processing of data relates to purchase of mobile WiFi data allowances, uCloudlink (Singapore) Pte. Ltd.

International Transfer of Personal Information
As described above, the Personal Information that we collect from you will be transferred to, and stored at, a destination outside of the UK and EEA. Where we transfer your Personal Information to countries outside of the UK and EEA (as applicable), we do so under:

• the European Commission’s Standard Contractual Clauses (Decision (EU) 2021/914),
• the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs,
• or any replacement mechanism approved under applicable EU or UK law.

2. United States (California and Other States)

Applicable Law
To the extent that uCloudlink is subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), or to comparable privacy legislation in other U.S. states (including but not limited to Virginia, Colorado, Connecticut, and Utah), the following applies:

Your Rights
You may have the following rights under applicable U.S. state privacy laws:

• The right to know what personal data we collect, use, disclose, and sell/share;
• The right to request deletion of personal data, subject to exceptions;
• The right to request correction of inaccurate personal data;
• The right to opt-out of the sale or sharing of personal data;
• The right to limit the use and disclosure of sensitive personal data (if applicable);
• The right to non-discrimination when exercising your privacy rights.

3. Singapore

Applicable Law
For users located in Singapore, the Personal Data Protection Act 2012 (PDPA), as amended in 2020, applies. The PDPA is regulated and enforced by the Personal Data Protection Commission (PDPC).

Your Rights
You may have the following rights under PDPA:

• Right to access personal data that we hold about you;
• Right to request correction of inaccurate or incomplete data;
• Right to withdraw consent for collection, use, and disclosure of your personal data;
• Right to data portability (once in force under PDPA amendments).

4. Malaysia

Applicable Law
For users located in Malaysia, the Personal Data Protection Act 2010 (PDPA) applies.

Your Rights
You may have the following rights under PDPA:

• Right to access your personal data;
• Right to request correction of your personal data;
• Right to withdraw consent to the processing of personal data, subject to contractual or legal restrictions;
• Right to prevent processing likely to cause damage or distress.

Please note that the Local Privacy Terms set out above are not exhaustive. If your country or region has specific data protection or privacy laws that are not reflected here, those laws will apply to the extent required. If you would like further information on how uCloudlink addresses compliance with local privacy regulations in your jurisdiction, please contact us at service@ucloudlink.com.

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