Welcome to Tencent CodeBuddy Enterprise!
This Privacy Policy explains the when, how, and why when it comes to the processing of your personal information in connection with the website for (the “Website”, https://www.codebuddy.ai) and enterprise version of the CodeBuddy application (“CodeBuddy Application”) (together, “CodeBuddy” or the “Service”) and sets out your choices and rights in relation to that information.
For the purposes of data protection laws, the data controller of your personal information in relation to the Service is the entity you have contracted with as set out in the table below (“we” or “us”).
|
European Economic Area | Tencent Cloud Europe B.V., a Dutch registered company located at Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands |
Republic of Korea | Tencent Korea Yuhan Hoesa, a Korean registered company located at 152, Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea |
Rest of the world | Tencent Cloud International Pte. Ltd., a Singapore registered company located at 10 Anson Road, #21-07, International Plaza, Singapore 079903 |
As CodeBuddy is an agentic AI product that does not fall within any standard Tencent Cloud product category, this Privacy Policy is a standalone, product-specific notice and operates in addition to (and, in respect of CodeBuddy, prevails over) the Tencent Cloud International umbrella privacy policy (which also applies). In the event of any conflict between this Privacy Policy and the Tencent Cloud International umbrella privacy policy, this Privacy Policy shall prevail. For the purposes of this Privacy Policy:
“Enterprise Customer” means the organization that has purchased the Service for non-personal use by Enterprise Users; i.e. the administrator account holder.
“Enterprise User” or “you” means an individual who belongs to or is affiliated with the Enterprise Customer and is using the Service pursuant to the Enterprise Customer’s Tencent Codebuddy Enterprise Service Agreement.
“TCI billing system” and “TCI payment system” mean the billing and payment systems operated within the Tencent group to support the Tencent Cloud International platform.
“Skill” means a packaged capability module (typically combining instructions, API schemas, and sometimes data) that instructs the Service on how to perform a specific workflow.
Please note that this Privacy Policy only applies to the Service. This Privacy Policy does not apply:
(1) where we act as a data processor and process personal data on behalf of the Enterprise Customer. In those cases, the Enterprise Customer is the data controller, and you can review its policies for more information about how it processes your personal data; and
(2) where you use CodeBuddy’s individual version. Please see our separate Privacy Policy here for more information. If you use any other products or services, please refer to the privacy policy for that particular product or service.
What is CodeBuddy?
CodeBuddy is an agentic AI software that provides its users with a seamless development experience across plugins, IDEs and CLIs, empowering developers design, develop and launch their products and services.
CodeBuddy has two modes:
1.1 Code Mode supports software development tasks such as generating and reviewing code, fixing bugs, refactoring, and analyzing existing codebases. To use Code Mode, you will generally need to select a local project directory. In Code Mode, CodeBuddy may access, analyze, and modify files in that directory as needed to complete your requests ; and
1.2 Work Mode supports general tasks such as creating documents and presentations, analyzing data, conducting research, and drafting emails and reports. Users can issue natural-language instructions to drive AI agents that autonomously plan and execute multi-step complex tasks, delivering ready-to-use work outputs including documents, spreadsheets, presentations, charts, and more.
We use various third-party large language models (“LLM”) to support the Service and you may select the specific category of LLM that you would like to use based on their capability, e.g. general purpose, fast thinking, complex tasks etc. The Service allows you to submit text, files, audio, commands, scheduled tasks, and any other documents or instructions (“Inputs”) via the Service or to integrate your chosen instant messaging channel (“Messaging Platforms”). These Inputs are processed by an LLM, whether as provided through the Service or through Bring Your Own Key (i.e. LLMs you choose to connect through your own API key) (“BYOK”), for inference, with the AI-generated responses and actions delivered back to you (“Outputs”).
You can also install Skills, model context protocol (“MCP”) connectors (e.g. GitHub), and extensions available through CodeBuddy or from other resources you select to integrate or connect external apps and tools of your choice with the Service.
Important:
We are not responsible for the processing of your personal information by third parties. Please review their data processing policies and other related documentation for more information. Any link to a third-party site or service does not mean our endorsement or approval of such site or service. For more information, please refer to Section 8 (Third-Party Websites and Links). Warning:
When providing input to CodeBuddy, please do not disclose any of your personal information or those belonging to others. Any personal information you include in your Inputs may be processed by third party providers of LLMs, Skills, MCP Connectors and integrated apps/tools etc. and reproduced in Outputs.
Enterprise Customers will be able to review and manage your usage of the Service through an administrative console.
If you do not agree with the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service.
By using the Service, you are acknowledging how we process your personal information as described in this Privacy Policy and, to the extent performance of a contract or legitimate interest cannot be relied upon in your jurisdiction to process the personal information, you consent to the processing of your personal information as described in this Privacy Policy.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found in Section 7 (Contact) below. 1. Children
Children must not use the Service for any purpose. By children, we mean users under the age of 18 years old or in the case of a region where the minimum age for processing personal information is higher, such different age. We do not seek nor knowingly collect personal information from children under 18 for any purpose. If you believe that we have personal information of anyone under the legal minimum age, or if you are the parent or guardian of the user and wish to notify us that a user is under the legal minimum age, please contact us as set out in Section 7 (Contact) below.
2. How We Process Your Personal Information
This section provides more detail on the types of personal information we collect from you, and why.
It also identifies the legal basis under which we process your data to the extent required by the data protection laws in your jurisdiction. To the extent the laws in your jurisdiction do not recognize the legal basis of performance of a contract or legitimate interest, the legal basis is consent.
|
Website |
|
|
Information you provide to us (either directly or through a third party) |
|
|
Login and account information, and security credential information: Information such as your enterprise account and email address, login credentials, enterprise identity binding via Tencent OneID, username and nickname, third-party login identifiers (if you choose to link a third-party login with the Service), avatar, user IDs | We use this information to create, authenticate, and manage your account for the Website and operate and provide the Website to you. | Necessary to perform our contract with you to provide the Website. |
Information generated as part of the Website |
|
|
System and device information: IP address, user IDs, system and device data and other similar information. | We use this information to create, authenticate, and manage your account for the Website and operate and provide the Website to you. | Necessary to perform our contract with you to provide the Website. |
CodeBuddy Application |
|
|
Information you provide to us (either directly or through a third party) |
|
|
Login and account information, and security credential information: Information such as your enterprise account and email address, login credentials, enterprise identity binding via Tencent OneID, username and nickname, third-party login identifiers (if you choose to link a third-party login with the Service), avatar, IP address, user IDs, system and device data and other similar information. | We use this information to create, authenticate, and manage your account for the Service and operate and provide the Service to you. | Necessary to perform our contract with you to provide the Service. |
Inputs and Outputs: User prompts, input content in any manner and form (such as code, repository information, text, voice, or any uploaded files and shared content) and instructions provided in your chat, coding and agentic sessions and related content (i.e. Inputs), the conversation and dialogue records with the Service, responses and actions generated based on your Inputs (i.e. Outputs), etc. If you choose to integrate third-party applications via a MCP Connector, or upload any files and information, including personal information, as part of your Inputs, we will collect this information, and this information may be reproduced in Outputs. | We use your information for troubleshooting and to detect and resolve any bugs. We use your Inputs and Outputs to conduct R&D and improve the Service. Please note that by default, we do not use your Inputs or Outputs for model training purposes. If you previously chose to turn it on, you may also turn it off at any time by following the steps below: How to Turn Off AI Model Training 1. Click your profile icon at the top right of the screen and click “IDE Settings”. 2. Click the “General” tab. 3. Scroll to “Experience Optimization Program” and turn the toggle off. After you turn off this setting, we will not use your subsequent Inputs or Outputs to train our AI models. If you opt in to AI model training, where possible, we may pseudonymise, aggregate and/or anonymise your personal information before using Inputs and Outputs for AI model training. Please note that we will also not use your Inputs and Outputs for AI model training if you choose to use your own AI model via API keys integration with the Service. | It is in our legitimate interests to troubleshoot errors and improve our services. We use your Inputs and Outputs for model training with your consent. |
Feedback information: If you choose to provide feedback and suggestions for improvement, or ratings on an Output, we will collect information that you provide as part of your feedback, including feedback content, screenshots and user environment information. | We use this information to resolve any issues you may face, debug and repair any problems, and to improve the Service. | It is in our legitimate interests to diagnose errors that you raised to us and to further improve and develop the Service. |
Marketing information: Email address and contact preferences. | If you choose to receive marketing communications, we will use your contact information to provide you with marketing information and recommendations in relation to Tencent Cloud’s products and services. | We use this information with your consent. |
Information generated as part of the Service |
|
|
Diagnostic and usage data: Device information (such as device identifiers, types, models, operating system information, MAC address, device fingerprint, etc.), log information (such as crash, error logs, etc.), usage behavior data and other diagnostic information relating to your use of the Service. | We use this information: to monitor the performance and quality of the Service; to detect and identify errors and bugs; for troubleshooting; to improve and optimize the Service. | It is in our legitimate interests to maintain the functioning of our Service, diagnose errors and to improve the Service. |
Configuration information: End user configuration information: We process information about your configurations for the Service, such as model selection preferences, authorization for third-party account bindings, device binding configurations, Skills, Messaging Platforms configurations and MCP Connector configurations, task automation settings and general settings and other similar data. This data is stored locally on your device and is not processed on our servers. Enterprise-level administration configuration information: Enterprise-defined policies and settings, such as for models, Skills, instructions, quotas, and networks | We use this information to maintain your configuration settings of the Service and to provide you with the Service. | Necessary to perform our contract with you to provide the Service. |
Compliance records: Consent and withdrawal records, data deletion and export request records, logs, and any other personal information required to be retained or disclosed pursuant to applicable laws, regulations, courts, tribunals or other governmental bodies or otherwise requested by courts, tribunals or other governmental bodies. | We use this information to comply with applicable legal obligations, respond to regulatory requests, and fulfill data subject rights. | We process this information to fulfill our legal obligations or in our legitimate interest. |
Cookies
We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.
You have the option to permit installation of such Cookies or subsequently disable them. You may accept all Cookies, or instruct the web browser to provide notice at the time of installation of Cookies, or refuse to accept all Cookies by adjusting the relevant function in the web browser of your computer. However, in the event of your refusal to install Cookies, we may be prevented from providing some of its services available to you.
For more information about the Cookies we use, please see our Cookies Policy. 3. How We Store and Share Your Personal Information
We have a global platform and may transfer your personal information outside the location in which you are based for the purposes described in the Privacy Policy. Except for Login and account information, and security credential information which is stored in Hong Kong, your personal information will be stored in servers in Singapore. We also have global support, engineering, and other teams who support the Service, including from the People’s Republic of China (“PRC”), who may access your personal information for the purposes specified in this Privacy Policy.
To provide the Service, the personal information we collect from you will be transferred to, remotely accessed, locally stored, and/or otherwise processed outside of the jurisdiction in which you are based for the purposes described in this Privacy Policy, including in the aforementioned jurisdictions. When we do so, we will take steps to ensure that your personal information is protected and we implement safeguards where required. Safeguards include standard contractual clauses, adequacy decisions where available, data processing agreements with all third-party data processors, and other contractual safeguards.
We will share your personal information with third parties (who may be based in jurisdictions outside of the jurisdiction in which you are based) in the following situations:
Third parties that provide services in support of the Service, including providers of services that process personal information identified in this policy. For example, we will transfer your personal information to:
third-party AI LLM providers that support the Service by processing your Inputs and providing you with Outputs;
Messaging Platforms that relay messages between you and the Service, if you choose to interact with the Service through a Messaging Platform;
third-party payment processors that process payment instruction data for payment of the Service; and
third-party service providers for Skills and MCP Connectors that process personal information in order to provide Skills and MCP Connectors that you have installed or configured on the Service.
Third party websites and services: You may choose to integrate the Service with various third-party websites, apps and services, including external repositories you choose to clone from open source platforms such as GitHub (e.g. through API keys, Messaging Platforms or MCP Connectors). If you choose to do so, your personal information will be shared with these third-party websites, apps and services in accordance with your instruction. Processing once transferred to such third-party websites and services shall be subject to the third party’s privacy policy.
Companies within our corporate group who process your personal information to efficiently provide the Service, including LLMs offered as part of the Service. All such group companies may only use your personal information in accordance with this Privacy Policy.
Payment and billing information is processed through the TCI payment system and TCI billing system, and identity and authentication are provided through the Tencent Unified Identity (Tencent OneID) platform. These are systems operated within the Tencent group to support the Tencent Cloud International platform.
Regulators, judicial authorities, and law enforcement agencies. There are circumstances in which we may disclose personal information about you as requested by regulators, judicial authorities, tribunals or law enforcement agencies in order to comply with legal obligations or processes or otherwise protect the rights, property, or safety of us, our users, a third party, or the public as required or permitted by law.
Third parties to ensure safety, security, or compliance with laws. We may disclose your personal information to: (a) enforce our terms and conditions; (b) detect, prevent, or otherwise address security, fraud, or technical issues; or (c) protect the rights, property, or safety of us, our users, a third party, or the public as required or permitted by law.
Professional advisors. We may disclose your personal information to auditors, law firms, or accounting firms.
A third party that acquires all or substantially all of us or our business. We may also disclose your personal information to third parties if we either sell, transfer, merge, consolidate, or reorganize any part(s) of our business.
4. The Security of Your Personal Information
We have information security and access policies regarding access to our systems and technology, and we protect personal information using appropriate technological protection measures such as encryption, hashing, role-based access controls, audit logs of data access.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted via the internet; any transmission is at your own risk.
5. Data Retention
Please note that we do not keep your data for longer than is necessary to fulfill the relevant purpose described above unless we are required or permitted to do so under law.
|
Login and account information, and security credential information System and device information | For as long as you maintain an account with us and deleted within one (1) month after the termination of your account. |
Feedback information | For as long as you maintain an account with us and deleted within one (1) month after the termination of your account. |
Diagnostic and usage data |
|
Configuration information | End user configuration information: This data is stored locally on your device and is not processed on our servers. Enterprise-level administration configuration information: This data is stored for as long as you maintain an account with us and deleted within one (1) month after the termination of your account. |
Inputs and Outputs | For up to fourteen (14) days. |
Compliance records | For so long as necessary to fulfil the applicable legal obligations. |
Marketing information | For as long as you consent to receiving marketing communications from us. |
6. Your Rights
We offer our users the following rights in respect of your personal information (which you may have a legal right to exercise depending on where you are). Some of these only apply in certain circumstances. You can exercise some of these rights directly by accessing and updating the personal information in your account. Otherwise, you can exercise those rights (including data erasure and relevant opt-outs) by contacting us using the details in Section 7 (Contact) below.
Access. You may have the right to access personal information we hold about you, how we use it, and who we share it with.
Portability. You may have the right to receive a copy of certain personal information we process about you.
Correction. You may have the right to correct personal information we hold that is inaccurate.
Erasure. You may be able to delete your account, or remove certain personal information, by logging into your Service account or requesting erasure from us.
Restriction of Processing to Storage Only. You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances).
Objection. You may have the right to object to our processing of your personal information in certain situations.
Consent Withdrawal. To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.
Automated Decision-Making: To the extent provided by applicable laws and regulations, you may have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning or similarly significantly affecting you.
You also have the right to lodge a complaint directly with us, as well as with the relevant data protection authority in the country you live or work.
7. Contact
Please get in touch with us if you have any questions. You can reach us, including our data protection officer, in the first instance at:
We will endeavor to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the jurisdiction in which you live or work where you think we have infringed data protection laws.
8. Third-Party Websites and Links
The Service allows the Enterprise Customer and you to select and integrate third-party LLM providers (via BYOK), Skills, MCP connectors, IM platforms, and external repositories (e.g. on GitHub). These integrations are enabled at the Enterprise Customer's and your own selection and authorisation.
LLM providers: Conversation content is transmitted via the Service to the selected model provider for processing and is handled independently by that provider under its own privacy policy and terms.
IM platforms: Necessary identity identifiers and message content are shared with the relevant platform to enable channel access.
Skills and connectors: Users may install first-party and third-party Skills and connectors. Skills are subject to a governance framework (security review, code review/static analysis, signing and verification, vulnerability scanning, and annual review). Connectors configured by Enterprise Users and are used at the Enterprise User's own risk.
Extensions: Users may choose to add extensions that may support your code writing. Connecting to such extensions is wholly voluntary and at your own discretion and risk.
External repositories: Users may choose to clone repositories from external websites such as GitHub and edit and amend code directly on the Service, and contribute your code to such external repositories. Connecting to and cloning external repositories is wholly voluntary and at your own discretion and risk.
We are not responsible for the privacy or security practices of third parties. Our inclusion of links or integration options does not imply endorsement. Please review the applicable third-party policies and terms. To revoke any integrations, Enterprise Users can remove the provider or revoke CodeBuddy’s authorisation in the relevant third-party application, or contact us at cloudlegalnotices@tencent.com to submit a withdrawal request.
9. Changes
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.
10. Language
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.
Jurisdictional Addendum
Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you
are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction
apply to you in addition to the terms set out in our Privacy Policy above.
Australia
We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients. You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.
Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and in-Service purchases.
If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au). Brazil
Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in Section 7 (Contact). This may affect our provision of the Service to you. BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.
EEA (for jurisdictions in which the Service is provided)
For any transfers of data outside the EU/EEA, the data transfer will be under the European Commission’s standard contractual clauses for the transfer of personal data to third countries (specifically, module one (controller to controller transfer) or module two (controller to processor transfer), as relevant), unless the data transfer is to a country that has been determined by the European Commission as applicable to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Should you wish to examine a copy of the EU standard contractual clauses, you can request a copy of the mechanism by emailing: cloudlegalnotices@tencent.com. If you think we have infringed data protection laws, you also have the right to lodge a complaint with a supervisory authority.
France
Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.
You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation, or, unless otherwise provided for, in the event of the death of the designated person, the heirs will have the right to be informed of your instructions and to request their implementation from us.
When you wish to make such instructions, please contact us. Hong Kong
As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.
Indonesia
By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.
In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.
You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).
Japan
By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information). Information about the personal data information protection systems in the countries where your data is processed is available on the Personal Information Protection Commission website. You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 7 (Contact). Kingdom of Saudi Arabia
How We Store and Share Your Personal Information
Your personal data may be transferred abroad and to third parties as follows:
|
Google Inc. https://policies.google.com/privacy | United States | Log-in credentials | Log-in |
GitHub https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement | United States | Log-in credentials | Log-in |
Tencent Technology (Shenzhen) Co. Ltd | PRC | For R&D and improvement of our services, troubleshooting, security, and training services | Login and account information, and security credential information Diagnostic and usage data Feedback information Configuration information Inputs and Outputs Compliance records |
MOONSHOT AI PTE. LTD. | Singapore | To facilitate your use of Kimi as an LLM model as part of the Services | Inputs and Outputs This transfer is for troubleshooting and model training where you have opted in |
Jingsheng Hengxing Technology Pte. Ltd. | Singapore | To facilitate your use of GLM as an LLM model as part of the Services |
|
Transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.
Your Rights
You have the right to be informed about our processing of your personal information, which we satisfy by providing this Privacy Policy to you. You also have the following rights as further described in Section 6 (Your Rights): the right to access, correction, erasure, restriction and to withdraw consent. Unless otherwise stipulated by law in Saudi Arabia, you will not be required to pay any fees in return for exercising these rights. We will respond to your request within 30 days of receiving it. Where you wish to make such requests, please contact us as set out in Section 7 (Contact). You also have a right to lodge a complaint with the Saudi Data and Artificial Intelligence Authority by contacting them directly. Their website is accessible at: www.sdaia.gov.sa
Data Destruction
Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.
Macau
You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau data subject, you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.
Malaysia
If you wish to use the Service you will be required to provide your personal data. If you do not wish to supply your personal data you should stop using the Service.
Rights of Data Subjects
Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.
When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.
Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.
Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Service to you.
To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information:
Our data protection officer, responsible for the management and safety of your personal information
Telephone: +603-22872388
Morocco
We collect information for purposes strictly necessary for the proper use of the Service. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Service.
Kindly note:
the identity of the Data Controller is set out at the beginning of this Privacy Policy New Zealand
We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.
You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to request the correction of any of your personal information we hold that is inaccurate.
If you are under the age of 16, you must not use the Service.
If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.
Singapore
You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.
To the extent provided by Singapore data privacy laws, you may withdraw consent you previously provided to us for certain processing activities by contacting us at cloudlegalnotices@tencent.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.
Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 7 (Contact). South Korea
Collection and Use of Personal Information
We collect your personal information for the purposes described in this Privacy Policy. Personal information that we collect from Republic of Korea is stored in and processed on our server located in Singapore.
(for consent): we use this information pursuant with your consent, pursuant to Article 15(1)(1) of the PIPA.
(for complying with legal obligations): we use this information where necessary to comply with a legal obligation pursuant to Article 15(1)(2) of the PIPA.
(for contractual necessity): we use this information where necessary to perform our contract with you to provide our Services, pursuant to Article 15(1)(4) of PIPA.
Delegation of Personal Information
For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:
|
Google | Login via Google account |
GitHub | Login via GitHub account |
Tencent Technology (Shenzhen) Co. Ltd | For R&D and improvement of our services; troubleshooting and security; and training our model with your consent |
MOONSHOT AI PTE. LTD. | To facilitate your use of Kimi as an LLM model as part of the Services This transfer is for troubleshooting and model training where you have opted in |
Jingsheng Hengxing Technology Pte. Ltd. | To facilitate your use of GLM as an LLM model as part of the Services This transfer is for troubleshooting and model training where you have opted in |
Overseas Transfer of Personal Information
We transfer personal information to third parties overseas as follows:
|
PIPA Articles 28-8 (1)(1), 17(1)(1) (Consent of Data Subject) | Google Inc. https://policies.google.com/privacy | United States | Transmitted if user logs in using Google ID | Log-in credentials | Log-in | |
| GitHub https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement | United States | Transmitted if user logs in using GitHub | Log-in credentials | Log-in | In accordance with GitHub’s privacy policy |
PIPA Art. 28-8(1)(3) Delegation and Retention for Contract Performance | Tencent Technology (Shenzhen) Co. Ltd | PRC | Transferred via information and communications network at the time of service use | Login and account information, and security credential information Diagnostic and usage data Feedback information Configuration information Inputs and Outputs Compliance records | For R&D and improvement of our services, troubleshooting, security, and training services | |
| MOONSHOT AI PTE. LTD. | Singapore | Transferred via information and communications network at the time of service use | Inputs and Outputs This transfer is for troubleshooting and model training where you have opted in | To facilitate your use of Kimi as an LLM model as part of the Services | |
| Jingsheng Hengxing Technology Pte. Ltd. | Singapore | Transferred via information and communications network at the time of service use |
| To facilitate your use of GLM as an LLM model as part of the Services | |
You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.
Data Destruction
Personal information is retained in accordance with the data retention periods as detailed in section “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.
The personal information detailed in section “Data Retention” are required to be retained pursuant to the following laws:
Act on the Consumer Protection in Electronic Commerce, Etc. | Article 6 of the Act on the Consumer Protection in Electronic Commerce | In an electronic commerce or a mail-order sale: Records regarding labelling and advertising (6 months) Records regarding execution or withdrawal of a contract (5 years) Records regarding the payment of a price and the supply of goods and services (5 years) Records regarding customer services or dispute resolution (3 years) |
Protection of Communications Secrets Act | Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act | Log records, IP address (3 months) The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months) |
Your Rights
You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, or objecting to or requesting an explanation on an automated decision concerning your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act (“PIPA”). You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a suspension of the personal information processing at any time.
Additional Use and Provision of Personal Information
In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Pursuant to Articles 15(3) and 17(4) of the PIPA, we consider the following factors set forth in Article 14-2 of the Enforcement Decree of the PIPA when using or providing to a third party additional personal information without your consent:
whether the additional use/provision is related to the initial purpose of the collection;
whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;
whether the additional use/provision unfairly infringe on the interests of the data subject; and
whether the necessary security measures such as pseudonymization or encryption were taken.
Based on the standard explained above, we have considered the following factors for additional use/provision of personal information.
the additional use/provision is related to the initial purpose of the collection because (…)
the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing because (…)
the additional use/provision does not unfairly infringe on the interests of the data subject because (…); and
we have taken necessary security measures such as (…).
Measures to Ensure Safety of Personal Information
We implement the following measures to ensure safety of your personal information:
1. Managerial measures: establishment and implementation of internal management plan, operation of dedicated organization, regular employee training
2. Technical measures: management of access rights to the personal information processing system, installation of an access control system, encryption of personal information, and installation and renewal of security programs
3. Physical measures: access control of computer rooms, data storage rooms, etc.
Domestic Privacy Representative
Pursuant to the Article 32-5 of Network Act and Article 31-2 of the amended PIPA, the information regarding the domestic agent is as follows:
Name: Tencent Korea Yuhan Hoesa (Representative: Li Yan)
Address: 152, Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea
Telephone: +82-2-2185-0926
Contact
To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.
Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0926
Remedies for Infringement of Rights and Interests
In order to seek remedies for personal information infringement, you may file an application for dispute resolution or consultation with the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency's Personal Information Infringement Reporting Center, etc. In addition, you may contact the following institutions for other reports and consultations on personal information infringement:
1. Personal Information Dispute Mediation Committee: (no area code required) 1833-6972 (www.kopico.go.kr) 2. Personal Information Infringement Report Center: (no area code required) 118 (privacy.kisa.or.kr) 3. Supreme Prosecutors’ Office: (no area code required) 1301 (www.spo.go.kr) Thailand
You acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the Service.
You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at cloudlegalnotices@tencent.com. We will give you notice by email of any changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.
Türkiye
You have legal rights, which are set forth in Article 11 of the Turkish Law on Personal Data Protection Law (“DPL”), in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):
learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data and whether they have been used accordingly;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.
In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:
|
Google Inc. https://policies.google.com/privacy | United States | Log-in credentials | Log-in |
GitHub https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement | United States | Log-in credentials | Log-in |
Tencent Technology (Shenzhen) Co. Ltd | PRC | For R&D and improvement of our services, troubleshooting, security, and training services | Login and account information, and security credential information Diagnostic and usage data Feedback information Configuration information Inputs and Outputs Compliance records |
MOONSHOT AI PTE. LTD. | Singapore | To facilitate your use of Kimi as an LLM model as part of the Services | Inputs and Outputs This transfer is for troubleshooting and model training where you have opted in |
Jingsheng Hengxing Technology Pte. Ltd. | Singapore | To facilitate your use of GLM as an LLM model as part of the Services |
|
Vietnam
By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.
Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.
You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.