Privacy Policy

Privacy Policy

Effective: May, 2026

We, GLOCAL REACH PTE. LTD. ("we", "us", or "our") are committed to protecting the privacy of our users' data and have taken all the necessary measures to protect. This Privacy Policy ("Policy") explains how we collect, use and disclose your data when you request, obtain and use our EchoFamily ("App" or "Services") or interact with us. We also explain your data privacy rights and how you can exercise them.

By visiting or using the App or Services, you agree to be bound by this Policy and consent to the collection, use and processing of your personal data as described below. If you do not agree with these terms, please do not use the App or Services.

A. Data We Collect

We may collect below personal data depending upon the nature of the Service offered:

Account data. We will collect your name, email address, birth date, phone number, password and so on when you create an account with us. If you use third party platform's (such as Apple or Google) account to login our App, we may also collect data about your third party platform's account such as your account name, profile picture, etc.
Transaction and subscription data. When you place an order to subscribe our Services, we may collect data such as the order amount, the Services content you choose to buy, the duration of your subscription, subscription cancellation request data, and any in-app purchases you make. Note that your payment information will be processed by the relevant payment or billing processor.
Location and movement data. We collect precise geolocation data (including GPS coordinates and latitude/longitude data) and data about your location such as city or zip code inferred through your IP address and data through technologies like Wi-Fi and Bluetooth.
Optional data. If you need to customize features within the App, we may collect the related individual's emergency data such as the individual's gender, height, weight, race, ethnicity, medications, allergies, and medical conditions including whether the individual is special needs and the category of such special needs.
Device data. This includes your device types and settings, device make/model, device identifiers (such as IDFA, IDFV for iOS, GAID for Android), browser information (including browser type and language preference), mobile, wireless, operating system, IP address, another network information (such as internet service provider name, carrier name and signal strength), application version numbers, Wi-Fi connection, battery status, and advertising identifiers.
Driving activity and motion activity data. This includes data about where and how you are moving, for example, your speed, altitude, and heading. This data represents things like if you are moving and if so, how you are moving, such as are you driving, running, cycling or walking, how fast or slow you are moving, and whether you are slowing down or speeding up.
Usage data. This includes the pages of our App you visit, the time and date of your visit, the time spent on those pages, unique device identifiers another diagnostic data.
Messages data. When you send messages to other users using the App, we may collect your messages, and any photos or videos you send via the App. We may also access your photo or camera roll on your mobile device with your consent.
Data provided to us by third parties. If you connect another third parties' account to your account created on our App, we receive data from the companies providing you these services.
Voice data. When you use our AI voice input and recognition Services, we will collect the voice data you input, process it in real-time according to your demand and provide feedback to you, in order to offer features such as voice-to-text conversion and recognition of user voice commands.

According to the features of the App, we may also need to obtain your relevant permissions on your device, including but not limited to: permissions about location data, permissions about notification, permissions about sports, fitness and permissions about Bluetooth, permissions about voice recognition (for iOS) and permissions about microphone.

B. Purposes for Collecting and Using Data

We collect and use data about you for the purposes listed below:

To provide you with our App and Services, such as to record the movements and location of your devices linked to our App.
To communicate with you, such as asking for your feedback, send you with personalized information about the App or our business partner's products and services that may be of interest to you, as allowed by applicable law.
To manage your account of the App, such as to keep record of your choices and preferences, to authentic your access.
To manage and process payments and transactions.
To conduct individual or market research and analytics.
To know how you engage with our App, such as to monitor which features are popular.
To ensure quality, maintain safety, improve our App and Services and develop new apps and services.
To make sure the security and integrity of our App.
To protect our App, our users, and the public and to prevent potentially prohibited, harmful, or illegal activities.
To fix problems of our App, such as by monitoring, debugging, repairing, and preventing issues.
To comply with applicable laws and regulations and to enforce our Terms of Use.

C. Sharing Data

For avoidance of doubt, we do not rent, trade, sell, or share your data with others. We will only share your data if we have to obey our legal obligations, for example in response to a subpoena, court order, or other governmental request or when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of us, third parties, or the public at large.

Please note that although we do not share your data with third parties, other third parties may collect your personal data in some circumstances.

D. Children's Data

Protecting children's privacy is important to us. We do not direct the App to, nor do we knowingly collect any personal data online from children under the age of 13 (or the minimum legal age required to provide consent for processing of personal data in the country where the child is located). Children may not access or use the App unless their use is directly authorized by their parent, guardian or another authorized adult who agrees to be bound by this Policy.

We take special precautions to collect only as much information as is reasonably necessary for the child to use our App and or Services. If we learn that a child has provided personal data online through the Services without his or her parent's or guardian's approve or consent, we will use reasonable efforts to delete such data. If you are a parent or guardian of a child and you believe that we may have collected personal data from your child without your approve or consent, please contact us.

E. How Long We Keep Data

We will retain your personal data for as long as is necessary to complete the purposes for which it was collected, or as may be required by law. If we no longer require retaining your personal data, we will use best efforts to destroy or delete such data. If we destroy or delete your data, we will take commercially reasonable and technically feasible measures to make your personal data unretrievable or unrecoverable.

F. How We Secure Data

While no online service is 100% secure, we take measures and work hard to protect or secure your data because we care about the security of your data. We maintain physical, electronic and procedural security measures to guard against unauthorized access to systems and uses safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings and we authorize access to your data only for those employees or agents who require it to fulfill the responsibilities of their jobs.

Please note that we will not reach you through telephone or send you unsolicited messages to ask for your sensitive data or information, such as your password, payment, account ID, or national ID numbers. The emails or other communications you send to us are not encrypted, therefore we suggest you not to share any sensitive data or information by these means.

If a security breach results in the disclosure of data under our control, we will notify the affected individuals as soon as possible, investigate the situation, and take appropriate measures in accordance with applicable laws and regulations.

It is your responsibility to keep your password confidential and to ensure the email address you provide associated with your account is correct. We suggest you that should choose a strong password unique to our Services. We will contact you by using your email address to inform you about App updates, policies or terms changes and account activities such as requests for your data. If you find that your account has been misused, stolen or compromised, please change your password as soon as possible. We don't take responsibility for data transmitted to a third party since you providing wrong phone number or email address.

G. Your Privacy Rights

We value your privacy rights and we offer you choices to make decisions about how your data is processed, used and stored. At the same time data protection laws give you certain rights with respect to your personal data, including the rights to:

Request access to your personal data. This means you have the right to check whether we hold any personal data about you and request access to or copies of such data.
Request portability of your personal data. This means you have the right to request your personal data in a portable format to facilitate a transfer of personal data to another service provider.
Request correction or deletion of your personal data. This means you have the right to request the correction or deletion of inaccurate, incomplete, outdated, unnecessary, excessive, or other applicable personal data about you.
Object to our use and processing of your personal data. This means in specific situations, you have the right to object to the processing of your personal data for legitimate reasons.
Request that we limit our use and processing of your personal data.
Withdraw your consent at any time. This means you have the right to withdraw previously granted consent without affecting the lawfulness of processing prior to the withdrawal.
Request to file a complaint. This means you have the right to lodge a complaint with the relevant authority.

You may request to exercise your privacy rights by emailing us through wangqi@glocalreach.com. Please note that we may take steps and measures to verify your identity before you access to data or acting on your request to exercise your rights as required or permitted under applicable law. As permitted under applicable law, we may limit our response to your exercise of the above rights.

H. Links to other Websites

The App may contain links to websites of other organizations which are not owned by us. Any data that is collected by the third party websites, or that you provide on or to a third party websites, is provided directly to the operator or owner of the third party websites and is subject to their privacy policies, not our Policy. This Policy does not cover how those organizations process your personal data and we are not responsible for the privacy practices of those organizations. We encourage you to read the relevant privacy policy on the other websites that you may visit.

Vungle: https://liftoff.io/privacy-policy/
Applovin/Max: www.applovin.com/privacy
Appsflyer: www.appsflyer.com/legal/privacy-policy
Google Admob/Firebase: policies.google.com/privacy?hl=en
Facebook: www.facebook.com/privacy/policy/?entry_point=comet_dropdown
Mintegral: www.mintegral.com/cn/privacy
Inmobi: https://www.inmobi.com/privacy-policy
Pangle: www.pangleglobal.com/zh/privacy/partner-en

I. How to Reach Us

If you have a question about this Policy, or you would like to contact us about any of the rights mentioned above, please contact us via email: wangqi@glocalreach.com

J. Policy Changes

Although most changes are likely to be minor, we may change this Policy from time to time. We encourage you to frequently check this page for any changes to this Policy. Your further use of the App after a change to our Privacy Policy will be subject to the updated Policy.

K. Additional Privacy Terms in Europe

This section applies to the individuals who are located in Europe and jurisdictions with similar legal privacy requirements.

Data Privacy Framework

The EU-U.S. Data Privacy Framework ("EU-U.S. DPF") and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") (collectively "DPF") are set forth by the U.S. Department of Commerce and regarding the collection, use, and retention of personal data transferred from the European Economic Area ("EEA") and the United Kingdom ("UK") and Switzerland to the United States. We will comply with the requirements of the above DPF. If the DPF applies to your data and there is any conflict between the principles of DPF and this Policy, the principles of DPF shall govern. We may also use other legally valid methods to protect personal data such as international data transfer agreements.

You may exercise certain rights and choices under the DPF regarding how some of your personal data is used and disclosed, and may access, delete or correct certain personal data if you are an EEA, Swiss or UK citizen.

You may request to opt out of our use or disclosure of personal data received or transferred pursuant to the DPF, if we:

share such personal data with a non-agent third party in a manner not specified in this Policy.
use such personal data for a new purpose that is materially different from the purposes for which it was originally collected or subsequently authorized.

We will not process sensitive personal data (for example, data about race, health conditions or ethnicity) as described above without your opt-in consent.

Please contact us using the contact info provided above if you are a citizen of EEA, Swiss or UK and think that we disobey this Policy or are not in compliance with the DPF Principles.

You are suggested to contact the national data protection authority for your jurisdiction of residence if your request remains unsolved. You may invoke binding arbitration to resolve complaints with respect to personal data received or transferred pursuant to the DPF (available in: go.adr.org/dpfeufiling.html) if your DPF complaint has not been resolved.

Request of data subject

You may submit a request to exercise the following rights via email mentioned above:

The right to access your personal data and request to a portable format.
The right to delete your personal data.
The right to correct inaccurate personal data.
The right to object to certain processing or request we restrict certain processing.

You may be asked for additional data from you by us to make your request clearer and verify if you are authorized to make your request. We will respond to your data subject requests according to applicable laws. We suggest and encourage you to contact us in the first place if you have questions or concerns about our processing of personal data. However, if we are unable to resolve your problem after you get in touch with us, you have the right to lodge a complaint with your local Data Protection Authority. The following is the list of supervisory authorities in the EEA, Switzerland, and UK and their respective contact details are available in the links below:

EEA: edpb.europa.eu/about-edpb/board/members_en
Switzerland: www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
UK: ico.org.uk/global/contact-us/

Legal Basis for Processing Your Data

We process your data based on multiple legal basis or legal grounds if you are a resident of EEA or in a jurisdiction where similar legal requirements may apply, for example, Switzerland, Brazil and UK. We will process your data:

Where we have a legal obligation to process your data.
Where we have a legitimate interest to do so.
Where we have your consent.
Where the processing is necessary for the performance of an Agreement with you.

We usually rely on the following legal basis or legal grounds:

To fulfill our contractual obligations. When you download and create an account on our App, we need to meet an actual contractual obligation to enable us to provide you with our App or Services.
To comply with a legal obligation to which we are subject.
Our legitimate interests to process your data when we providing you with user service support, for security and fraud prevention purposes.
With your consent. You may withdraw such consent at any time when the consent is the legal basis for our processing your data.

L. Additional Privacy Terms in U.S. States and California

This section serves as our California notice at collection of personal data and also applies to the individuals who are located in California, Colorado, Montana, Nebraska, New Hampshire, Connecticut, Delaware, Iowa, New Jersey, Oregon, Texas, Utah, or Virginia.

Additional Disclosures

We may collect personal data directly from you, automatically when you use or interact with our App or Services, and from third-party sources. As required by certain State Privacy Laws, we use the table below to explain the collection and use of personal data for certain purposes.

Types of Personal Data:

Account data. We will collect your name, email address, birth date, phone number, password and so on when you create an account with us. If you use third party platform's (such as Apple or Google) account to login our App, we may also collect data about your third party platform's account such as your account name, profile picture, etc.
Transaction and subscription data. When you place an order to subscribe our Services, we may collect data such as the order amount, the Services content you choose to buy, the duration of your subscription, subscription cancellation request data, and any in-app purchases you make.
Location and movement data. We collect precise geolocation data (including GPS coordinates and latitude/longitude data) and data about your location such as city or zip code inferred through your IP address and data through technologies like Wi-Fi and Bluetooth.
Optional data. If you need to customize features within the App, we may collect the related individual's emergency data such as the individual's gender, height, weight, race, ethnicity, medications, allergies, and medical conditions including whether the individual is special needs and the category of such special needs.
Device data. This includes your device types and settings, device make/model, device identifiers (such as IDFA, IDFV for iOS, GAID for Android), browser information (including browser type and language preference), mobile, wireless, operating system, IP address, another network information (such as internet service provider name, carrier name and signal strength), application version numbers, Wi-Fi connection, battery status, and advertising identifiers.
Driving activity and motion activity data. This includes data about where and how you are moving, for example, your speed, altitude, and heading. This data represents things like if you are moving and if so, how you are moving, such as are you driving, running, cycling or walking, how fast or slow you are moving, and whether you are slowing down or speeding up.
Usage data. This includes the pages of our App you visit, the time and date of your visit, the time spent on those pages, unique device identifiers another diagnostic data.
Messages data. When you send messages to other users using the App, we may collect your messages, and any photos or videos you send via the App. We may also access your photo or camera roll on your mobile device with your consent.
Data provided to us by third parties. If you connect another third parties' account to your account created on our App, we receive data from the companies providing you these services.
Voice data. When you use our AI voice input and recognition Services, we will collect the voice data you input, process it in real-time according to your demand and provide feedback to you, in order to offer features such as voice-to-text conversion and recognition of user voice commands.

Use of personal data:

To provide you with our App and Services.
To communicate with you, such as asking for your feedback, send you with personalized information about the App or our business partner's products and services that may be of interest to you, as allowed by applicable law.
To place and manage ads in our advertising program.
To conduct individual or market research and analytics.
To ensure quality, maintain safety, improve our App and Services and develop new apps and services.
To protect our App, our users, and the public and to prevent potentially prohibited, harmful, or illegal activities.
To fix problems of our App, such as by monitoring, debugging, repairing, and preventing issues.

We may process certain data that is considered "sensitive" under the Privacy Laws of US, for example, geolocation data, personal data of children, race and health conditions. Please note that we only process such sensitive data with your consent or with the consent of the child's parent or legal guardian regarding the children's data. We do not rent, trade, sell, or share your data with others as mentioned in the section "C. Sharing Data". Please note that we also do not engage in sales, sharing, or targeted advertising using personal data about anyone who are under the age of 18. We will store or retain personal data as mentioned in the section "E. How Long We Keep Data" above.

Your Rights Under State Privacy Laws

Under state privacy laws, you have the right to:

Request to delete your personal data.
Request to access and know more about personal, including in a portable format.
Request to correct the inaccurate personal data.

You may exercise your rights by contacting us using the contact method mentioned above. We take reasonable methods to verify your identity and request in order to protect your privacy and security.

If you exercise any of your rights including privacy rights, we warrant that we do not discriminate against you. Attention that for providing our App and Service to you, we may need certain data and if you request to delete your account or refuse to provide the data we need, we will no longer be able to provide the App or Services to you. You have the right to appeal our decision by contacting us at wangqi@glocalreach.com when we deny your request. You may contact the attorney general in the state where you locate if you have questions or concerns of the result of your appeal.

If you are a resident of or located in California, you have the right to designate an authorized agent to submit a deletion, access, or correction request on your behalf. The authorized agent has to submit the request to email wangqi@glocalreach.com and attach a signed letter or other valid proves confirming the permission to submit the request on the App user's behalf. We may also need to request additional information to verify the identity of the App user about whom the request is being made and/or to verify that the App user has provided the authorized agent permission to submit the request in certain circumstances. However, if we can not to verify the authorized agent's authority to act on your behalf, we may have to deny the request.

M. International Transfer of Data

Please note and you agree that all the data collected via or by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the USA, the EEA, the UK, on our servers or in the cloud. In order to pursuant to a lawful request, your data may be accessible to law enforcement or other authorities. You explicitly consent to the storage of your data in these locations by providing data to us and which means that in certain instances your personal data will be kept in jurisdiction that offers a level of protection that may be less protective of your personal data than the jurisdiction you are typically resident in. We will use appropriate methods to ensure that your personal data is treated securely and in accordance with this Policy.

If you reside in EEA, Switzerland or UK and when your personal data is transferred outside your jurisdiction, we will protect it by:

implementing appropriate safeguards to protect your personal data, such as entering into appropriate data transfer agreements based on the Standard Contractual Clauses or another lawful and approved transfer mechanism.
processing the data in compliance with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework.

We will take reasonable methods to make sure that such overseas recipients do not breach the Australian Privacy Principles in the Privacy Act 1988 (Cth) in relation to such data, except in some cases where we may rely on an exception under the Australian Privacy Act 1988 (Cth).

N. Additional Privacy Terms in Australia

This section applies to the individuals who are located in Australia.

We will only use your personal data for the purposes as mentioned in the Section "B. Purposes for Collecting and Using Data" above in Australia.

We are not liable for any consequences arising from unauthorized access, disclosure, misuse, loss, or damage to your personal data (including liability due to negligence) except to the extent liability cannot be excluded due to the operation of statute. Nothing in this Policy limits, excludes, or modifies, nor is it intended to limit, exclude, or modify, any statutory consumer rights granted to you under applicable law (including the Competition and Consumer Act 2010 (Cth)).