Privacy Policy

Last updated: June 5, 2026

1. Introduction

Seenful (the “Service”) is operated by Haoduo (Hong Kong) Holding Limited (“we,” “us,” or “our”). This Privacy Policy explains how we collect, use, share, and protect information when you use Seenful through our website, mobile applications, and related services.

By using Seenful, you agree to the practices described in this Policy. If you do not agree, please do not use the Service.

For users in the United States — please also see Section 12 (US-Specific Privacy Rights).

For users in Hong Kong — please also see Section 13 (Hong Kong-Specific Privacy Rights).

2. Information We Collect

We collect the following categories of information:

• Photos, videos, and images you upload. When you choose to upload or import photos, videos, or other media into Seenful, we receive that content so we can process it and provide the features of the Service. This content may include metadata (e.g., timestamp, camera settings, location if your device permissions allow).
• Account information. When you join the waitlist or create an account, we collect information such as your email address, username, and (if applicable) authentication credentials.
• Device and usage data. We may collect device identifiers, operating system, app version, IP address, time zone, language, crash logs, and aggregated usage data (for example, which features you interact with) to help us operate and improve the Service.
• Communications. When you contact us (e.g., for support or feedback), we keep a record of your messages and our responses.
• Inference data. We may generate derived data about your uploaded content, such as scene labels, object detection results, or thematic tags, solely to power the AI features of the Service.

3. How We Use Your Information

We use the information we collect to:

• Provide and operate Seenful’s core features — including using AI and automated analysis (via our own systems and third-party APIs such as Google Gemini and Kling) on the photos you upload to generate videos, memories, stories, captions, highlights, themes, and other creative outputs.
• Personalize your experience — for example, by surfacing content or AI outputs that are relevant to you based on your upload history.
• Improve and develop the Service — including debugging, analytics, feature research, and model performance monitoring. We do not use your personal content to train or fine-tune any AI model (whether our own or third-party models) without your explicit consent.
• Protect security and integrity — detect or prevent fraud, abuse, violations of our Terms of Service, or unauthorized access.
• Communicate with you — send waitlist updates, product announcements, security alerts, and support messages.
• Comply with legal obligations — respond to lawful requests from public authorities, enforce our rights, or meet applicable laws (e.g., data retention, anti-abuse).

4. AI Processing of Your Content — Important Details

A core part of Seenful is the automated, AI-driven generation of video and other outputs from the photos you choose to upload. By using the Service you acknowledge and agree that:

• Your photos and related metadata may be processed by automated systems and machine-learning models (including computer-vision models, generative models, and third-party AI APIs such as Google Gemini and Kling). This processing extracts concepts, scenes, objects, and other features needed to generate the requested outputs.
• Processing may occur on your device (where feasible), on our controlled servers, and/or via vetted third-party AI providers acting under contractual data-protection commitments. We do not allow third-party providers to use your content for their own model training or any purpose other than delivering the Service to you.
• No training use. We do not use your photos, videos, or other User Content to train any machine-learning or AI model — whether our own models or third-party models. The models are used only to process your content at runtime to deliver the features of the Service. We also do not use your content for advertising profiling or any form of behavioral advertising.
• AI Outputs are best-effort. AI-generated outputs may be inaccurate, incomplete, misleading, or unsuitable for a particular purpose. They are intended for personal, non-authoritative use only. You should not rely on them as factual statements without independent verification.
• Retention of AI processing data. The photos you upload and the AI outputs generated for you are retained while your account is active and for a limited period thereafter (see Section 8). You may delete your content or your account at any time.

5. Third-Party Services & Data Sharing

We do not sell your personal information. We may share information only in the following circumstances:

• Service providers. We work with vendors who help us host infrastructure (e.g., cloud storage providers), send email, run analytics, provide customer support, and process content with AI models (e.g., Google Gemini, Kling). These providers act on our instructions and are contractually bound by confidentiality and data-protection obligations that require them to use your information only for the purposes we specify.
• Legal & safety. We may disclose information to comply with applicable law, lawful requests by public authorities (e.g., court orders, law enforcement), to enforce our Terms of Service, or to protect the rights, property, or safety of users, the public, or us.
• Business transfers. If we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to standard confidentiality obligations and with notice to you where required by law.
• With your consent. We may share information for any other purpose disclosed to you and with your explicit consent.

6. Cross-Border Data Transfers

The Service is operated globally. Your information, including photos and AI outputs, may be transferred to and processed in countries other than your country of residence, including the United States and Hong Kong. Data protection laws in those countries may differ from those in your jurisdiction.

For users in Hong Kong: When we transfer personal data outside Hong Kong, we take steps to ensure that your data is protected by appropriate safeguards, such as model contractual clauses or ensuring the recipient jurisdiction provides substantially similar protection to that under the Personal Data (Privacy) Ordinance (Cap. 486). You may contact us for more information about these safeguards.

For users in the European Economic Area (EEA) or the UK: We rely on Standard Contractual Clauses (SCCs) approved by the European Commission to ensure adequate protection for data transferred outside the EEA/UK.

7. Cookies and Similar Technologies

We use essential cookies and similar technologies to operate the Service (e.g., for authentication and security). We do not use non-essential cookies or tracking technologies for advertising or analytics purposes without your prior consent where required by law. You can manage your cookie preferences through your browser settings; however, disabling essential cookies may affect the functionality of the Service.

8. Data Storage & Retention

We store your information on infrastructure operated by us or by our service providers. Retention periods are as follows:

• Uploaded photos/videos and related metadata: Retained while your account is active and for a limited period of up to 30 days after account deletion or your request to delete content, to allow for recovery and to comply with backup requirements. After that period, the content is permanently deleted from our active systems.
• AI outputs (generated videos, stories, captions, etc.): Retained as long as your account is active. You may delete individual AI outputs at any time. After account deletion, AI outputs are retained for up to 30 days as part of backup recovery, then deleted.
• Account information (email, username, etc.): Retained as long as your account is active. After account deletion, we retain minimal account data (e.g., hashed email for fraud prevention) for up to one year to comply with legal obligations and enforce our Terms.
• Usage and crash logs: Retained for up to 12 months for debugging and analytics purposes.
• Communication records: Retained for 2 years from the date of last contact, unless a longer retention is required by law.

We retain personal information for as long as needed to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. You can request deletion at any time as described in Section 9.

9. Your Rights & Choices

Depending on where you live, you may have the following rights regarding your personal information:

To exercise any of these rights, email us at hi@seenful.ai. We will respond within the timeframes required by applicable law (generally 30 days). We may need to verify your identity before processing your request.

For users in California, Virginia, Colorado, Connecticut, and other US states with comprehensive privacy laws, please see Section 12 for additional rights and how to appeal a denial.

10. Children’s Privacy (COPPA and international laws)

Seenful is not intended for children under the age of 13 (or the equivalent minimum age in your jurisdiction).

United States: In compliance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without verified parental consent, we will delete that information as soon as reasonably practicable. If you believe a child under 13 has provided us with personal information, please contact us at hi@seenful.ai.

Hong Kong: Under the Personal Data (Privacy) Ordinance, we require parental or guardian consent for any child under the age of 13. We do not knowingly collect personal data from children without such consent.

Other jurisdictions: Where local law sets a higher age threshold (e.g., 16 in certain EU countries), we comply with that threshold.

If you are between 13 and 18 years of age, you represent that you have obtained verifiable parental or legal guardian consent to use the Service.

11. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect your information, including:

• Encryption in transit (TLS 1.2+ for all data transmitted to/from our Service).
• Encryption at rest for stored photos and AI outputs.
• Access controls restricting employee and contractor access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing.

No method of transmission or storage is 100% secure. If we become aware of a data breach affecting your personal information, we will notify you and relevant authorities as required by applicable law (e.g., within 72 hours under GDPR, or as required under Hong Kong’s PCPD guidance).

12. US-Specific Privacy Rights (CCPA/CPRA and other state laws)

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or other US state with a comprehensive privacy law, you have additional rights.

12.1 Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information from users (as defined under the CCPA):

12.2 Business Purposes for Collection

We collect and use your personal information for the business purposes described in Section 3 (providing the Service, security, analytics, legal compliance).

12.3 Your Rights Under US State Laws

You have the right to:

• Know what personal information we collect, use, disclose, and sell.
• Delete personal information we hold about you (subject to exceptions).
• Opt-out of the “sale” or “sharing” of your personal information for cross-context behavioral advertising. We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
• Correct inaccurate personal information.
• Limit the use and disclosure of sensitive personal information (we do not collect sensitive personal information as defined under the CCPA, such as SSN, precise geolocation, or biometrics for identification).
• Non-discrimination — we will not discriminate against you for exercising any of your privacy rights.

12.4 How to Exercise Your US Rights

To exercise your rights, please email hi@seenful.ai or use our web form (available in the app settings). We will respond within 45 days (or as required by your state law). For requests to delete, we may ask for verification (e.g., confirming email ownership or device ID).

Authorized agents: You may authorize someone to act on your behalf. They must provide your written permission and verify their identity with us.

Appeals: If we deny your request, you may appeal by emailing privacy@seenful.ai (a dedicated address). We will respond within 60 days explaining our reasoning.

12.5 “Shine the Light” (California Civil Code § 1798.83)

California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing without your consent. To make such a request, email hi@seenful.ai with “Shine the Light Request” in the subject line.

13. Hong Kong-Specific Privacy Rights (PDPO)

If you are a user located in Hong Kong, the following additional provisions apply, in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”).

13.1 Data User Identity

The data user (data controller) for your personal data is:

13.2 Personal Information Collection Statement (PICS)

When we collect your personal data (e.g., email address, photos), we provide this notice as required under DPP 1 of the PDPO:

• Purpose of collection: To provide and operate the AI video generation Service, improve the Service, communicate with you, and comply with legal obligations.
• Classes of transferees: Our service providers (cloud hosting, AI APIs such as Google Gemini and Kling), law enforcement if required, and any successor in a business transfer.
• Your rights: You have the right to request access to and correction of your personal data held by us (see Section 13.4).
• Consequences of not providing data: If you do not provide your email address, you may not create an account; if you do not upload photos, you cannot use the core AI generation features.

13.3 Six Data Protection Principles (DPPs) Compliance

We comply with the six DPPs as follows:

• DPP1 (Collection): We collect personal data lawfully, fairly, and for purposes directly related to our Service. Collection is not excessive.
• DPP2 (Accuracy and retention): We take steps to keep personal data accurate and do not keep it longer than necessary (see Section 8 for retention periods).
• DPP3 (Use): Personal data is used only for the purposes stated in this Policy or directly related purposes. Any new purpose requires your express consent.
• DPP4 (Security): We take reasonably practicable security measures (Section 11).
• DPP5 (Openness): This Policy is publicly available. We also provide a PICS at the time of collection.
• DPP6 (Access and correction): You may request access or correction (Section 13.4).

13.4 Access and Correction Requests (DPP 6)

To request access to or correction of your personal data held by us, please email hi@seenful.ai. We will respond within the timeframe prescribed by the PDPO (generally 40 days). We may charge a reasonable fee for access requests, as permitted by the PDPO.

13.5 Direct Marketing

We do not currently engage in direct marketing using your personal data. If we plan to use your email address for direct marketing (e.g., promotional newsletters), we will obtain your prior opt-in consent and provide a simple opt-out mechanism in every message.

13.6 Cross-Border Data Transfer (Section 33 — not yet in force)

While Section 33 of the PDPO (restriction on transferring personal data outside Hong Kong) is not yet in force, we follow the guidance of the Office of the Privacy Commissioner for Personal Data (PCPD) by adopting appropriate contractual safeguards (e.g., model clauses) when transferring your personal data to third-party AI providers located outside Hong Kong (such as Google Gemini or Kling). You may contact us for a copy of these safeguards.

13.7 AI Governance Alignment (PCPD Model Framework & DPO AI Guideline)

We align with the PCPD’s Artificial Intelligence: Model Personal Data Protection Framework (June 2024) and the Digital Policy Office’s Hong Kong Generative Artificial Intelligence Technical and Application Guideline (April 2025) by:

• Conducting risk assessments before deploying AI features.
• Maintaining human oversight over AI outputs.
• Ensuring transparency about AI processing (this Section and Section 4).
• Not using your personal data for model training without consent.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top and, where appropriate, provide additional notice (such as via email or in-product notification). Your continued use of the Service after the changes take effect means you accept the updated Policy. If we make material changes that affect your rights, we will provide at least 30 days’ advance notice by email or through the Service.

15. Contact Us

If you have questions about this Privacy Policy or our data practices, or to exercise your privacy rights, please contact us: