Terms of Service

Last updated: June 5, 2026

1. Acceptance of Terms

These Terms of Service (“Terms”) form a binding agreement between you and Haoduo (Hong Kong) Holding Limited (“Seenful,” “we,” “us,” or “our”) governing your access to and use of the Seenful website, mobile applications, and related services (collectively, the “Service”). By accessing or using the Service, joining the waitlist, or creating an account, you agree to be bound by these Terms and our Privacy Policy. If you do not agree, do not use the Service.

2. Description of Service

Seenful is a tool that uses automated systems and third-party AI models (including but not limited to Google Gemini and Kling) to analyze photos that you choose to upload, and to generate videos, memories, stories, captions, highlights, and other creative outputs from them. Features may evolve, be added, or be removed over time. The Service is provided on an “as is” basis as further described in these Terms.

3. User Content

“User Content” means any content you upload, import, submit, or otherwise make available through the Service, including photos, videos, captions, text, and feedback.

• You retain ownership. You keep all rights you already have in your User Content.
• You are responsible. You represent and warrant that you own or have all necessary rights (including, without limitation, copyright and publicity/right of personality rights) to your User Content, and that it does not infringe, misappropriate, or violate any third-party right or any applicable law. You further warrant that any person depicted in your User Content has expressly consented to the use of their likeness, voice, or other identifying characteristics for the purpose of generating AI outputs, and that you are not using content depicting minors without parental or guardian consent.
• License to operate the Service. You grant us a worldwide, non-exclusive, royalty-free license to host, store, reproduce, modify (for technical purposes such as resizing or format conversion), process via AI/automated systems, and display your User Content solely as needed to operate, provide, secure, and improve the Service for you. This license ends when you delete your User Content or your account, except where retention is required by law or for backup purposes for a limited period.
• Prohibited content. You may not upload User Content that is unlawful, infringing, hateful, harassing, sexually exploitative of minors, deceptive, or that violates the rights of others (including privacy, publicity, or intellectual property rights).
• Deepfakes / Unauthorized likeness. You may not upload User Content that contains the likeness of another individual without that individual’s express, informed consent. You may not use the Service to create AI-generated content that falsely depicts a real person engaging in conduct they did not perform, especially if such content would be defamatory, harassing, or intended to deceive. We reserve the right to remove any such content and report illegal activity to law enforcement.

4. AI-Generated Content Disclaimer

The Service uses AI and other automated techniques (including third-party APIs such as Google Gemini and Kling) to interpret your photos and produce outputs such as videos, captions, stories, themes, and highlights (“AI Outputs”). AI Outputs are generated automatically and may be inaccurate, incomplete, misleading, or otherwise unsuitable for a particular purpose. You should not rely on AI Outputs as factual statements about people, places, or events, and you are solely responsible for how you use or share them. AI Outputs are intended for personal, non-commercial use unless we expressly say otherwise.

Because AI Outputs are generated based on your uploaded content and third-party models, we do not guarantee that they do not infringe any third party’s copyright, trademark, or right of publicity. You assume all risks associated with the creation, sharing, or republication of AI Outputs.

Hong Kong AI Guideline notice: The Government of the Hong Kong Special Administrative Region has issued the Hong Kong Generative Artificial Intelligence Technical and Application Guideline (the “HK AI Guideline”), which reminds service users that AI-generated content may contain misleading, false, or inaccurate information, and that users should exercise independent judgment when using the Service. You acknowledge that you have read and understood this risk, and agree not to rely on any AI Output as factual statement without independent verification.

5. Acceptable Use

You agree not to:

• Use the Service for any unlawful, fraudulent, or harmful purpose;
• Upload content you do not have the right to use, or content depicting others without appropriate consent;
• Attempt to reverse engineer, decompile, or otherwise extract the source code, models, or proprietary components of the Service, except as permitted by law;
• Use bots, scrapers, or other automated means to access the Service in ways that exceed reasonable use;
• Interfere with, disrupt, or compromise the security or integrity of the Service or any underlying infrastructure;
• Use the Service to generate content that violates the rights of others, including intellectual-property, privacy, or publicity rights;
• Use the Service to create sexually explicit, violent, or harassing content, or content intended to mislead others as to the authenticity of an event or statement (i.e., disinformation);
• Use AI Outputs generated by the Service in a manner that may deceive others as to the authenticity, origin, or authorship of such content, including but not limited to presenting AI-generated content as human-created without clear disclosure, unless the context of use makes the AI-generated nature of the content readily apparent to an ordinary recipient.

6. Accounts

You are responsible for maintaining the confidentiality of any credentials you use to access the Service and for all activity that occurs under your account. You agree to provide accurate information and to keep it up to date.

Age restriction & COPPA (US): You must be at least 13 years old to use the Service. If you are located in the United States and are under 13 years of age, you may not use the Service. We do not knowingly collect personal information from children under 13. 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 and to agree to these Terms. If we learn that we have collected personal information from a child under 13 without parental consent, we will delete that information as soon as reasonably practicable. Please contact us at hi@seenful.ai if you believe we have inadvertently collected such information.

We may suspend or terminate your account or access to the Service at any time, with or without notice, if we reasonably believe you have violated these Terms, if required by law, or if continuing to provide the Service to you would create risk for us or other users. You may stop using the Service and request deletion of your account at any time by emailing hi@seenful.ai.

7. Subscriptions and Payments

The Service is currently provided free of charge. In the future, we may introduce paid plans, in-app purchases, subscriptions, or other features that require payment, including through the Apple App Store or other distribution platforms. If we do, additional terms (including pricing, billing cycle, renewal, cancellation, and refund terms) will be presented to you before you are charged, and those terms will form part of these Terms. Purchases made through the Apple App Store are also subject to Apple’s terms.

8. Intellectual Property

The Service, including its software, design, text, graphics, logos, and underlying models (excluding User Content and AI Outputs created from your User Content), is owned by Haoduo (Hong Kong) Holding Limited or its licensors and is protected by intellectual-property laws. We grant you a limited, personal, non-exclusive, non-transferable, revocable license to use the Service for your personal, non-commercial use in accordance with these Terms. All rights not expressly granted are reserved.

9. Disclaimers & Limitation of Liability

THE SERVICE IS PROVIDED “AS IS” AND “AS AVAILABLE,” WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR ACCURACY OF AI OUTPUTS. WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE.

THIRD-PARTY APIs. The Service uses third-party AI models provided by Google Gemini and Kling (and other providers). We are not responsible for the acts, omissions, data handling, or output quality of any third-party API. Any claim arising from the use of such APIs shall be brought solely against the applicable third-party provider, subject to its own terms.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL HAODUO (HONG KONG) HOLDING LIMITED OR ITS AFFILIATES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, REVENUE, DATA, OR GOODWILL, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE SERVICE. OUR TOTAL CUMULATIVE LIABILITY ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICE SHALL NOT EXCEED THE GREATER OF (A) THE AMOUNT YOU PAID US (IF ANY) IN THE TWELVE MONTHS PRECEDING THE EVENT GIVING RISE TO LIABILITY, AND (B) USD 50.

Nothing in these Terms limits or excludes liability that cannot be limited or excluded under applicable law.

10. Indemnification

You agree to defend, indemnify, and hold harmless Haoduo (Hong Kong) Holding Limited and its affiliates, directors, employees, and agents from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys’ fees) arising out of or relating to: (i) your User Content; (ii) your use of or reliance on AI Outputs; (iii) your violation of these Terms, including but not limited to your warranties regarding consent of depicted persons and age compliance; (iv) your violation of any third-party right, including publicity, privacy, copyright, or trademark rights; or (v) any claim that your AI Outputs infringe or misappropriate a third party’s likeness or other rights.

11. Copyright Infringement (DMCA Notice)

We respect the intellectual property rights of others. If you believe that any content available through the Service (including AI Outputs or User Content) infringes your copyright, please send a written notice to our designated copyright agent at:

• Designated Agent: Legal Department, Haoduo (Hong Kong) Holding Limited
• Email: copyright@seenful.ai (or hi@seenful.ai)
• Address: Rm 1903, 19/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong

Your notice must substantially comply with the requirements of the Digital Millennium Copyright Act (17 U.S.C. § 512(c)), including identification of the copyrighted work claimed to be infringed, identification of the material to be removed, and a statement under penalty of perjury. We will respond promptly and may remove or disable access to the allegedly infringing content. Repeat infringers may have their accounts terminated.

12. Changes to Terms

We may update these Terms from time to time. When we do, we will revise the “Last updated” date and, where appropriate, provide additional notice (e.g., via email or in-app notification). Your continued use of the Service after the changes take effect means you accept the updated Terms. If you do not agree to the updated Terms, you must stop using the Service.

13. US-Specific Terms

If you are a user located in the United States, the following additional terms apply:

• Governing Law for US Users: Your relationship with us is governed by the laws of the State of California, without regard to its conflict-of-laws principles. The Federal Arbitration Act and federal law also apply. This choice of law does not deprive you of any mandatory protections under the laws of your state of residence.
• Consumer Rights: Nothing in these Terms limits any non-waivable rights you have as a consumer under applicable US federal or state law, including the right to pursue claims in small claims court.
• COPPA & State Privacy: We comply with the Children’s Online Privacy Protection Act (COPPA) as described in Section 6. For California residents, we provide additional privacy disclosures in our Privacy Policy consistent with the California Consumer Privacy Act (CCPA).
• Liability Cap — US Users: The limitation of liability in Section 9 applies to the fullest extent permitted by law, but does not waive any rights you may have under state consumer protection laws that cannot be waived by contract.

14. Hong Kong-Specific Terms

If you are a user located in the Hong Kong Special Administrative Region, or if you are otherwise accessing the Service from Hong Kong, the following additional terms apply. These terms are intended to reflect the regulatory expectations set forth by the Government of the Hong Kong Special Administrative Region, including the Digital Policy Office (DPO) and the Office of the Privacy Commissioner for Personal Data (PCPD).

14.1 No Dedicated AI Law — Existing Framework Applies

There is currently no standalone, comprehensive AI ordinance in force in Hong Kong. However, AI governance in Hong Kong is shaped by a combination of existing laws (in particular the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”)) and various guidance instruments, including the DPO’s Ethical Artificial Intelligence Framework (last updated December 2025) and the DPO’s Hong Kong Generative Artificial Intelligence Technical and Application Guideline (April 2025) (the “HK AI Guideline”), as well as the PCPD’s Artificial Intelligence: Model Personal Data Protection Framework (June 2024). As a service provider whose business covers Hong Kong, we are required to comply with Hong Kong’s relevant laws, and if our business involves alleged violations, law enforcement agencies may investigate and take follow-up action in accordance with the law.

14.2 Personal Data Protection — PDPO Six Data Protection Principles

When the Service processes any personal data (as defined under the PDPO) of users located in Hong Kong, we act as a “data user” (as defined under Section 2 of the PDPO) and are subject to the six Data Protection Principles (“DPPs”) set out in Schedule 1 to the PDPO.

• DPP 1 (Purpose and manner of collection): We collect personal data only for lawful purposes directly related to our functions or activities. The data collected is necessary for, but not excessive in relation to, such purposes. We collect personal data in a lawful and fair manner, and we provide a Personal Information Collection Statement (PICS) at the time of collection, specifying the purposes of collection and the classes of persons to whom the data may be transferred.
• DPP 2 (Accuracy and duration of retention): We take all practicable steps to ensure that personal data under our control is accurate and up to date, and is not kept longer than is necessary for the fulfilment of the purposes for which it is used. Personal data used for AI processing is retained in accordance with our Privacy Policy and deleted after the purpose is fulfilled or as required by law.
• DPP 3 (Use of personal data): Personal data collected from you is used only for the purposes stated in our Privacy Policy (operating, providing, securing, and improving the Service). Any use of your personal data for a new purpose (i.e., a purpose other than the original purpose of collection or a directly related purpose) will require your express and voluntary consent.
• DPP 4 (Security of personal data): We take all reasonably practicable steps to protect personal data under our control against unauthorized or accidental access, processing, erasure, loss, or use. Security measures include access control, data encryption, penetration testing, and, where appropriate, anonymization of personal data.
• DPP 5 (Openness): We maintain open policies and practices regarding the types of personal data we hold, how we use it, and the main purposes for which it is held. Our Privacy Policy is publicly available and contains all relevant information.
• DPP 6 (Access and correction): You have the right to request access to and correction of your personal data held by us. Such requests should be directed to hi@seenful.ai. We will respond to your request within the time periods prescribed under the PDPO.

14.3 AI Governance — Alignment with PCPD Model Framework

We have adopted internal AI governance measures in alignment with the PCPD’s Artificial Intelligence: Model Personal Data Protection Framework. These measures include:

• AI strategy and governance: We have established an internal AI governance framework covering the procurement, implementation, and ongoing operation of AI systems that involve personal data.
• Risk assessment and human oversight: Before deploying AI features that process personal data, we conduct risk assessments and maintain appropriate human oversight over AI outputs, particularly for high-risk use cases.
• AI model development and system management: We implement security measures to protect personal data processed by AI systems, including access controls and data minimization practices.
• Stakeholder communication and engagement: We maintain transparent communication with users regarding the use of AI in the Service, including through this Section and our Privacy Policy.

14.4 Generative AI — Compliance with HK AI Guideline

In accordance with the HK AI Guideline issued by the DPO, we, as a service provider, have established a responsible generative AI service framework that includes the following:

• Content governance: We take reasonable measures to ensure that our Service systems do not generate illegal, non-compliant, or otherwise inappropriate content. We reserve the right to review, filter, or remove any AI Outputs or User Content that violate these Terms or applicable laws.
• Traceability and auditability: We maintain appropriate logs and records to enable traceability and auditability of AI-generated content, to the extent commercially reasonable.
• Transparency: AI Outputs generated by the Service are identified as AI-generated where technically feasible and as required by applicable guidelines.
• Fact-checking and verification: We encourage you, as a service user, to exercise independent judgment when reviewing AI Outputs, as they may be inaccurate, incomplete, misleading, or unsuitable for a particular purpose. The HK AI Guideline reminds service users that AI-generated content may contain misleading, false, or inaccurate information, and that users should exercise independent judgment when using the Service. You agree not to rely on AI Outputs as factual statements without independent verification.

14.5 User Obligations under Hong Kong Framework

As a service user located in Hong Kong, you acknowledge and agree that:

• When you share or disseminate AI Outputs created through the Service, you should clearly indicate whether generative AI has been involved in the content creation process, unless the context makes the AI-generated nature of the content readily apparent to an ordinary recipient.
• You will proactively verify the accuracy, reliability, and suitability of AI Outputs before using or sharing them, and you understand that AI Outputs may carry risks such as model bias, hallucinations, or data leakage that must be properly managed.
• You will choose AI services with robust privacy policies, and exercise caution when sharing personal or sensitive data through the Service.

14.6 Cross-Border Data Transfer

While Section 33 of the PDPO (which restricts cross-border transfer of personal data) is not yet in force, the PCPD has issued guidance encouraging data users to adopt recommended practices, including the use of model contractual clauses, to protect personal data transferred outside Hong Kong.

When you use the Service, your User Content (including any personal data contained therein) may be processed by our third-party AI service providers (including but not limited to Google Gemini and Kling). We will take reasonable steps to ensure that any transfer of personal data outside Hong Kong is protected by appropriate contractual or other measures, including using model contractual clauses or ensuring that the recipient jurisdiction provides a level of protection substantially similar to that under the PDPO, to the extent reasonably practicable.

14.7 Hong Kong Governing Law and Jurisdiction (Non-US Users)

For users located outside the United States, these Terms and any dispute arising out of or relating to them or the Service are governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region, without regard to its conflict-of-laws principles. Subject to applicable mandatory consumer-protection laws, the courts of Hong Kong have exclusive jurisdiction over any dispute. This Section 14.7 supersedes and replaces any prior governing law provisions to the contrary for such users.

15. Dispute Resolution — Binding Arbitration & Class Action Waiver (for US Users)

This Section applies only to users located in the United States. If you reside outside the United States, the governing law and dispute provisions set forth in Section 14.7 (Hong Kong Governing Law and Jurisdiction) shall apply.

• Agreement to Arbitrate: You and Seenful agree that any dispute, claim, or controversy arising out of or relating to these Terms or the Service (including its enforceability) shall be resolved exclusively by binding individual arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, and not in any court. The arbitration shall take place in San Francisco, California, or by videoconference if you choose.
• Exceptions: Either party may bring an individual action in small claims court (if within that court’s jurisdiction) or seek injunctive relief in a court of competent jurisdiction to prevent actual or threatened infringement, misappropriation, or violation of intellectual property or confidential information.
• Class Action Waiver: YOU AND SEENFUL AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, REPRESENTATIVE, OR PRIVATE ATTORNEY GENERAL PROCEEDING. The arbitrator may not consolidate more than one person’s claims and may not preside over any form of representative or class proceeding.
• Opt-Out: You may opt out of this arbitration and class action waiver by sending a written notice to hi@seenful.ai within 30 days of first accepting these Terms. The notice must include your name, address, and account email, and a clear statement that you opt out of the arbitration agreement. If you opt out, you may pursue claims in court subject to the governing law provisions.

16. Governing Law (Non-US Users) — Cross Reference

For users located outside the United States, the governing law and dispute resolution provisions set forth in Section 14.7 (Hong Kong Governing Law and Jurisdiction (Non-US Users)) shall apply. In the event of any conflict between this Section 16 and Section 14.7, Section 14.7 shall control for users outside the United States.

17. Contact

If you have questions about these Terms, please contact us: