Privacy Policy — xGenie

Last Updated: July 23, 2026  ·  Effective Date: July 23, 2026  ·  Version: 2.0

Important: xGenie's core features — speech-to-text transcription and AI-powered notes, summaries, and Q&A — require sending your audio recordings and text content to third-party AI service providers for processing. Details are provided in Section 5 (Who We Share Information With). Before any data is sent, the app obtains your explicit consent through an in-app permission dialog. You may withdraw this consent at any time in Settings.

Safey Technology Co., Ltd. ("xGenie," "we," "us," or "our") develops and operates the xGenie mobile application, the xGenie Pro recording device, and related cloud services (collectively, the "Services"). We take your privacy seriously and are committed to protecting your personal information in accordance with applicable laws including the GDPR, UK GDPR, and CCPA.

This Privacy Policy explains: what data we collect, how we collect it, why we use it, who we share it with, and the rights you have over your data. Please read this Policy carefully before using the Services. By checking the consent box or continuing to use the Services, you acknowledge that you have read and understood this Policy.

1. Information We Collect

1.1 Information You Provide

1.2 Information Collected Automatically

1.3 Payment-Related Information

1.4 Permissions We Request

iOS

Android

You may revoke any permission at any time in your device's system settings. Revoking essential permissions may prevent certain features from functioning.

2. How We Use Your Information

PurposeDescription
Provide core featuresAccount registration and login; audio recording, import, and playback; BLE device connection and file transfer; speech-to-text transcription; AI note generation, summarization, and Q&A; cross-device sync
Hardware connectivityBLE pairing and communication with xGenie Pro; firmware status synchronization; audio file import from device
Membership and billingSubscription management, order verification, quota tracking, benefit provisioning
Account security and anti-fraudDetecting abnormal login activity, preventing malicious registration, protecting account and transaction security
Service improvement and troubleshootingCrash analysis, performance monitoring, feature usage statistics (aggregated only; not linked to individual identity)
Legal complianceFulfilling record-keeping and reporting obligations required by applicable laws and regulations

We retain your personal information only for as long as necessary to fulfill the purposes described above, unless a longer retention period is required by law.

3. Cookies and Similar Technologies

The xGenie mobile app does not use browser cookies. On the server side, we use session tokens to maintain your login state and authenticate API requests. These tokens do not contain plain-text personal identifiers and are not used for any tracking purpose.

4. Legal Bases for Processing (GDPR)

We process your personal data based on the following legal grounds:

5. Who We Share Information With

We do not sell your personal information to any third party. We share your information only as necessary to provide the Services, in accordance with the purposes described in Section 2, with the following categories of service providers.

All third-party providers listed below process data solely on our instructions as data processors. They are contractually bound to protect your data and are prohibited from using it for their own purposes.

5.1 Speech Recognition (ASR) Providers

When you request transcription, your audio files are sent to the following AI service providers for speech-to-text processing:

ProviderData SharedPurpose
Alibaba Cloud
(Alibaba Cloud · DashScope / FunASR)
Audio recordings Convert speech to text (automatic speech recognition)
OpenAI, L.L.C.
(OpenAI · Whisper API)
Audio recordings Convert speech to text (automatic speech recognition) — alternative provider

5.2 AI Large Language Model (LLM) Providers

When you request AI notes, summaries, translations, or use Ask xGenie, your transcript text and your instructions are sent to the following AI service providers:

ProviderData SharedPurpose
Alibaba Cloud
(Alibaba Cloud · DashScope / Qwen)
Transcript text, user summary / Q&A / translation prompts Generate AI notes, summaries, translations, and intelligent Q&A responses
OpenAI, L.L.C.
(OpenAI · GPT)
Transcript text, user summary / Q&A / translation prompts Generate AI notes, summaries, translations, and intelligent Q&A responses — alternative provider

5.3 Cloud Storage and Communication Providers

ProviderData SharedPurpose
Alibaba Cloud
(Alibaba Cloud · Object Storage Service OSS)
Audio files, transcripts, user-uploaded attachments Cloud storage of user data; enables multi-device sync and data persistence
Alibaba Cloud
(Alibaba Cloud · DirectMail)
Email address Send verification codes for registration and login

5.4 Authentication Providers

ProviderData SharedPurpose
Google LLC
(Google Sign-In)
Email address, Google user ID Identity authentication when you choose Google Sign-In
Apple Inc.
(Apple Sign-In)
Email address, Apple user ID Identity authentication when you choose Apple Sign-In

5.5 Disclosures Required by Law

We may disclose your personal information when required to do so by applicable law, court order, or mandatory request from a government authority, or when necessary to detect, prevent, or address fraud, security, or technical issues, or to protect the rights, property, or safety of you, us, or the public.

5.6 Third-Party Data Protection Commitment

All third-party service providers listed above have entered into data processing agreements (DPAs) with us, under which they commit to protecting your information at a level no less protective than the standards set forth in this Privacy Policy. Each provider employs industry-standard safeguards including encryption in transit (TLS/HTTPS), access controls, and audit logging. We periodically evaluate the security capabilities and compliance status of our third-party providers. If we determine that any provider can no longer provide equivalent or superior protection, we will cease transferring data to that provider and switch to an alternative.

Servers of the above third-party providers are located in the United States and Singapore. For more information on international data transfers, see Section 8.

6. AI Features — Explicit Consent and Special Notice

xGenie's AI-powered features — including AI Notes, AI Summaries, AI Translation, and Ask xGenie — rely on third-party large language model services. Please note the following:

  1. Explicit consent before sending data: Before any audio or text data is sent to a third-party AI provider, the app presents a standalone permission dialog that clearly describes what data will be sent and to which provider(s). Data is only transmitted after you tap "Agree & Continue." You may withdraw this consent at any time in App Settings. If you withdraw consent, AI-dependent features will become unavailable, but basic features (recording, local playback, BLE device connectivity) will continue to function.
  2. User-initiated processing only: Audio and text content is sent to AI/ASR providers solely when you take an explicit action — such as tapping "Transcribe," "Generate Notes," or typing a question in Ask xGenie. No content is processed automatically without your action.
  3. Data minimization: We send only the data necessary to fulfill your specific request. When generating AI notes, for example, we transmit the transcript text and your formatting instructions — we do not attach your personal identity information to the AI request.
  4. No model training with your content: Our agreements with third-party AI providers explicitly prohibit them from using the content you submit for model training or improvement, unless you separately provide written consent.
  5. AI-generated content is for reference only: Content generated by large language models (notes, summaries, translations, Q&A answers) may contain inaccuracies, omissions, or inappropriate results. You should independently evaluate AI-generated output. We are not liable for decisions made solely based on AI-generated content. You must not rely on AI-generated output as medical, legal, investment, or emergency advice.

7. Recording Responsibly — Your Obligation

xGenie is a tool for recording. You are solely responsible for complying with all applicable recording and wiretapping laws, including obtaining the consent of all parties where required by your jurisdiction. We provide optional in-app consent reminders as a convenience; these are not legal advice and do not transfer the legal obligation from you to xGenie. We disclaim all liability arising from your recordings.

8. International Data Transfers

Your data may be processed and stored on servers located in the United States and Singapore. Where we transfer personal data out of the EEA, the UK, or Switzerland, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum, as applicable. You may request a copy of the relevant safeguards by contacting us at the email listed in Section 17.

9. Data Retention

We retain your account data for as long as your account is active. Audio recordings, transcripts, and AI-generated notes are retained until you delete them or close your account. Upon account deletion, we delete or anonymize your personal data within 30 days, except where retention is required by law (e.g., transaction records retained for tax or audit purposes).

10. Account Deletion and Data Export

You have full control over your data. You can manage it at any time through the app:

When you delete your account:

Deleted data cannot be recovered. Please export any content you wish to keep before deletion.

11. Data Security

  1. Encryption in transit: All communication between the app and our servers, and between our servers and third-party providers, uses HTTPS/TLS encryption.
  2. Storage security: Passwords are hashed using industry-standard algorithms and never stored in plain text. Audio files and user data are stored in access-controlled cloud storage.
  3. Access control: We employ role-based, least-privilege access controls. Only authorized personnel with a need-to-know basis may access production data, and all access is logged for audit.
  4. Incident response: We maintain a data security incident response plan. In the event of a personal data breach, we will notify you and relevant supervisory authorities as required by applicable law.

No method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

12. Your Rights

Depending on your location, you may have the following rights regarding your personal data. To exercise any of these rights, contact us at support@elink-future.com. We will respond within the timeframes required by applicable law.

RightHow to Exercise
Access and rectificationView and edit your account information (nickname, profile) in App → My. For a full data access report, email us.
DeletionDelete individual recordings in the app (App → Recording details → Delete). Delete your entire account in App → My → Settings → Delete Account.
Data portabilityExport your recordings and transcripts using the share/export function in the app, or request a structured data export by email.
Withdraw consentWithdraw consent for AI data sharing in App → Settings. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.
Restrict or object to processingContact us by email. We will assess your request in accordance with applicable law.
Lodge a complaintYou have the right to lodge a complaint with your local data protection supervisory authority if you believe our processing violates applicable law.

California residents may exercise rights under the CCPA, including the right to know what personal information is collected, the right to delete, and the right to opt out of the sale of personal information (although we do not sell personal information). We will not discriminate against you for exercising your rights.

13. Automated Decision-Making

Some features of xGenie use automated systems to generate transcripts, notes, summaries, and Q&A responses. This automated processing does not produce legal effects or similarly significant effects concerning you as defined under Article 22 of the GDPR. AI-generated output is provided for your convenience and is not a substitute for human review where accuracy is material.

14. Children's Privacy

The Services are not directed to children under 13 (or under the relevant digital age of consent in your EU member state, which may be up to 16). We do not knowingly collect personal data from children. If we learn that we have inadvertently collected personal data from a child under the applicable age threshold without verifiable parental consent, we will delete it promptly. If you are a parent or guardian and believe your child has provided us with personal information, please contact us.

15. Changes to This Policy

  1. We may update this Privacy Policy from time to time. When we make material changes (such as adding new categories of third-party sharing or new types of data collection), we will notify you through a prominent in-app notice, push notification, or email.
  2. For material changes, you will be asked to re-read and consent to the updated policy before continuing to use the Services.
  3. You can view the current version of this Policy at any time in App → Settings → About → Privacy Policy.
  4. Historical versions of this Policy are archived on our servers. You may request a copy by contacting us.

16. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy, or wish to exercise your data rights, please contact us at:

We will acknowledge and respond to your request within the timeframe required by applicable law (typically within 30 days).