Privacy Policy

1. What this policy covers

Clumpi (“we”) provides the Clumpi mobile app and its website (together, the “Service”). Clumpi turns your selfie into a clay character, records each day’s mood as its expression, and shares it only with the circles you choose. This policy explains what personal data we collect, why, how we use and protect it, and the rights you have.

Under Article 8 of Taiwan’s Personal Data Protection Act, this policy tells you:

• who collects the data: section 1;
• the purposes of collection: section 4;
• the categories of personal data: sections 2 and 3;
• the period, region, recipients and manner of use: sections 5, 6 and 7;
• your rights and how to exercise them: section 8;
• what happens if you do not provide data: section 8.

2. Data we collect

What you give us

• Account data. Email and password (stored only as a hash; we never see the original). If you sign in with Apple or Google, the account identifier and email that provider shares with us.
• Profile. Name, date of birth (including year), personal color and app language. Your birthday confirms you are 13 or older and appears on your circles’ calendars (you can turn this off per circle).
• Selfie. Used only to create your character; see section 3.
• What you record. Daily moods and one-line notes, your photo of the day and its caption, events and board notes.
• Circles. Circles you create or join, their names, your sharing settings in each, and the invites you create.
• Consent records. The version and time of your consent to have your selfie processed by our AI partners.
• Messages to us. The content of emails you send us.

What is created as you use the Service

• Your character and its expressions. Generated from your selfie and kept in your account.
• Device data. A push notification token, operating system, app version and time zone. The time zone is used only to send reminders at your local time.
• Server logs. For security and troubleshooting: request time, URL, IP address and result.
• Error reports. Technical details when the app or server fails; never photos or what you record.
• Usage statistics. Which features are used (for example, that a circle was created). Moods, notes, photos and other content never enter any statistics.

What we do not collect

We do not collect precise location, contacts or advertising identifiers, we use no advertising SDKs, we do not track you across other apps or websites, and we do not build advertising profiles.

3. Your selfie and AI generation

To create your character you take or choose a selfie. Before it is used, the app asks for your consent to have it processed by our AI partners. Here is what happens:

• Metadata is removed first. The app strips EXIF data (such as where the photo was taken); our server re-encodes the image and keeps no attached information.
• The photo is checked. Anthropic (Claude) checks that it is clear and shows only you.
• Your character is generated. OpenAI generates candidate characters from a photo cropped to your face. Expressions are later made from the generated character only, never from your selfie again.
• Deleted when done. The selfie is kept only in temporary storage and deleted from our systems as soon as generation succeeds or fails; a daily automatic clean-up means it never stays with us longer than 1 day. It never appears in your account or in any circle.
• Our partners’ retention. Anthropic and OpenAI keep it for at most 30 days for abuse monitoring and, under their commercial terms, do not use it to train their models.

You can withdraw your consent at any time. After that you can no longer create a character from a selfie; characters already created are not affected.

4. How we use your data

We use personal data only for these purposes (with the specific purposes defined under Taiwan’s Personal Data Protection Act):

• Providing the Service: accounts, character generation, recording and showing your content, push notifications and reminders (069 contractual relationships; 135 information and communication services).
• Sharing your content with the circles you choose (135 information and communication services).
• Sending necessary service emails such as sign-in codes, and answering your questions (090 consumer and customer management and services).
• Security, preventing abuse and fraud, fixing errors (136 information and database management).
• Understanding how features are used in order to improve them, never including the content itself (157 surveys, statistics and research analysis).
• Meeting legal obligations.

We do not sell your personal data, do not use it for advertising, and do not use your content to train AI models.

5. Who can see your content

• Only the circles you choose. Clumpi has no public feed. Your mood, note and photo of the day are shown only to members of the circles you share them with.
• Set per circle. In each circle you can separately turn “Today’s mood”, “Daily photo”, “Events I create” and “My birthday” on or off. Turning one off also withdraws what you shared before.
• Leaving a circle. After you leave, its members no longer see what you add.
• Basics circle members can see. Your name, character and personal color.

6. Services we work with

These providers help us run the Service. They may process data only on our instructions and only to provide the Service:

When you sign in with Apple or Google we never see your password there; we receive only a sign-in credential and basic details. Otherwise we disclose data to authorities only when the law requires it or to protect our users’ safety.

7. How long and where we keep data

• While your account exists. Your data is kept until you delete your account.
• Deleting your account. You have 30 days to change your mind after asking to delete it; after that, the account and its data (including character images and what you recorded) are permanently deleted, with no copies kept.
• Selfies. See section 3: at most 1 day with us, at most 30 days with our AI partners.
• Completed board notes. Deleted automatically 30 days after completion.
• Server logs and error reports. Deleted on our providers’ retention schedules.

We and our providers may process your data outside Taiwan (including in the United States), with reasonable safeguards in place.

8. Your rights

Under Article 3 of Taiwan’s Personal Data Protection Act you may:

• ask whether we hold your data, and review it;
• request a copy;
• request that it be completed or corrected;
• request that we stop collecting, processing or using it;
• request its deletion.

Most data can be changed directly in the app, and you can delete your account under Me → Account → Delete account. For anything else, email privacy@clumpi.app from the address you signed up with; we may need to confirm your identity. Depending on where you live you may have further rights, and you can complain to your local authority.

If you do not provide data. Account data, your name and your birthday are needed to use the Service; without them we cannot create an account. Without a selfie we cannot create your character. If you leave out other data, the related features will not work.

9. Children

You must be 13 or older to have a Clumpi account. If the birthday given at sign-up shows someone under 13, we delete that account and its data immediately. If you learn that someone under 13 is using the Service, please contact us.

10. Security

Data is always encrypted in transit (TLS), passwords are stored only as hashes, sign-in credentials live in your device’s secure storage, and our internal access is permission-controlled and logged. No system is perfectly secure; if a breach affects your data, we will notify you as the law requires.

11. Changes to this policy

We may update this policy and will change the “Last updated” date at the top. We will tell you about significant changes in the app or by email before they take effect.

12. Contact us

• Privacy: privacy@clumpi.app
• Support: support@clumpi.app