Privacy Policy.

Effective Date: June 15, 2025

1. Introduction

Welcome to eyeOS ("we," "our," or "us"). We are committed to protecting your privacy and ensuring you have a positive experience when using our services.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our wearable device, companion application, website, and related services (collectively, the "Service"). This policy is compliant with the General Data Protection Regulation (GDPR), the Personal Information Protection Law of the People's Republic of China (PIPL), and other applicable privacy laws.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. If you do not agree with the terms of this Privacy Policy, please do not access the Service.

2. Information We Collect

2.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Create an account
• Use our spatial perception, voice guidance, and environmental understanding features
• Contact our support team
• Make payments through our platform

This information may include:

• Account Information: Name, email address, password, and profile information
• Visual & Spatial Data: Camera captures, depth sensor readings, and LiDAR data processed on-device for real-time environmental understanding
• Audio Recordings: Voice recordings to enable voice-guided navigation, audio feedback, and transcript quality improvements through on-device processing
• Conversation Data: Transcripts, summaries, and analysis of voice interactions with the device
• Agent Interaction Data: Logs and context from AI agent coordination via the A2A protocol
• Payment Information: Payment method details (processed by our payment processors)
• Location Data: Geolocation data (if permitted by you), including precise GPS coordinates used for pedestrian navigation assistance
• Background Location Data: If you grant permission, we may collect your device's precise location even when the companion app is closed. This is used to provide continuous spatial navigation assistance and tag interactions with location context.
• Usage Data: Information about how you use our Service

2.2 Automatically Collected Information

We may automatically collect certain information when you use our Service, including:

• Device Information: Device type, operating system, unique device identifiers, firmware version
• Sensor Data: Anonymized performance metrics from on-device AI agents
• Log Data: IP address, browser type, pages visited, time spent on pages
• Cookies and Similar Technologies: Information collected through cookies and similar tracking technologies on our website

3. How We Use Your Information

We use your information for various purposes, including to:

• No training without permission. We do not use your recordings, visual data, transcripts, or other content to train AI models without your explicit permission.
• Provide, maintain, and improve our Service—including real-time spatial perception, pedestrian signal detection, and obstacle avoidance
• Process and complete transactions
• Send you technical notices and support messages
• Respond to your comments and questions
• Coordinate on-device AI agents through the A2A protocol for environmental understanding
• Develop new products and services
• Monitor usage patterns and analyze trends
• Protect against, identify, and prevent fraud and other illegal activity
• Tag interactions with location data to help users recall spatial context
• Provide optional functionality such as audio playback and transcript improvement using on-device post-processing

4. Legal Basis for Processing (GDPR & PIPL)

Under the GDPR and China's PIPL, we process your personal data based on the following legal grounds:

• Performance of a Contract: Processing necessary to provide you with our Service
• Legitimate Interests: Processing that serves our legitimate business interests
• Consent: Processing based on your explicit consent
• Legal Obligation: Processing necessary to comply with our legal obligations under Chinese and international law

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

On-device processing is our default. Visual and spatial data from the camera and LiDAR sensors is processed entirely on-device by our Lightnet 7B model and AI agent pipeline. This data does not leave your device unless you explicitly opt in to cloud features.

Audio may be processed on-device to enable real-time voice guidance. To support certain optional functionality (such as audio playback and transcript-quality improvement), we may store conversation audio in encrypted form with your consent.

You can request deletion of your data at any time through our Service: jydu_seven@outlook.com

When you delete a conversation, we delete the transcript and associated data tied to that conversation, including any stored audio associated with it.

6. Data Sharing and Third-Party Services

6.1 Third-Party Service Providers

We may share your information with third-party service providers to help us operate, provide, improve, and promote our Service. These third parties have access to your information only to perform specific tasks on our behalf and are obligated not to disclose or use it for any other purpose.

6.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency), in compliance with applicable Chinese law and international regulations.

6.3 Where & How Your Data Is Stored

Storage	What's Kept	Security
On-Device	Visual/spatial data, AI agent processing, real-time perception pipeline	Hardware-encrypted local storage; data never leaves device by default
Cloud (opt-in)	Transcripts, summaries, metadata, files you upload	AES-256 encryption at rest, TLS in transit, access restricted by service account
Cloud Storage	Conversation audio (where supported), voice-profile samples	Private bucket, signed-URL access, encrypted at rest & in transit

Local caches on the companion app hold recent transcripts for offline viewing; they follow your OS sandbox and are deleted when you uninstall the app.

6.4 Third-Party Processors

Service	Purpose	Data They Receive
On-device AI	Spatial perception, object detection, pedestrian signal recognition	None — processed locally via Lightnet 7B and A2A agent pipeline
Cloud LLM (opt-in)	Extended AI reasoning for complex queries	Text prompts only (no raw visual/audio data)

We select vendors with strong published security commitments. They process data solely to provide their service to us. Our core perception pipeline runs entirely on-device with zero cloud dependency.

7. Your Rights and Choices

Under the GDPR, PIPL, and other applicable laws, you have certain rights regarding your personal information:

• Access: You can request a copy of the personal data we hold about you
• Rectification: You can request correction of inaccurate or incomplete information
• Deletion: You can request that we delete your personal information
• Restriction: You can request restriction of processing of your personal information
• Portability: You can request your data in a structured, machine-readable format
• Withdrawal of Consent: You can withdraw consent where processing is based on consent

To exercise these rights, please contact us at jydu_seven@outlook.com.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

eyeOS is designed with a privacy-first, on-device architecture. Our 10+ AI agents process spatial data locally through the A2A protocol, ensuring that sensitive visual and environmental data never needs to leave your device for core functionality.

9. International Data Transfers

eyeOS is based in Shanghai, China. Your information may be transferred to—and maintained on—servers located in the People's Republic of China. If you are located outside China and choose to provide information to us, please note that we transfer the information to China and process it there.

We comply with applicable laws to ensure that your information is appropriately protected when transferred internationally, including the use of Standard Contractual Clauses approved by the European Commission and compliance with China's cross-border data transfer regulations under the PIPL.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Effective Date" at the top of this Privacy Policy. We encourage you to review this Privacy Policy periodically.

We may not be able to notify users individually of all changes. We publish updates on this page and may also announce material updates through our official channels.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: jydu_seven@outlook.com

Location: Shanghai, People's Republic of China

12. Your Consent

By using our Service, you consent to our Privacy Policy.

— End of Privacy Policy —