Privacy Policy

We collect and use different types of data from and about you including:

• Personal data that we could reasonably use to directly or indirectly identify you, such as your name, email address, wallet address, user name, social media handle or other similar social identifier, or any other identifier we may use to contact or interact with you online ("personal data").
• Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
• Non-personal details about your Website interactions or activities, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Website (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, email or otherwise. This includes information you provide when you create an account and log into such account, participate in a campaign, promotion or survey, and when you report a problem with our Website.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your device or equipment, location, browsing actions and use patterns (including, as applicable, any use of or input to any AI tools) as specified above. We collect this information by using cookies, server logs, and other similar technologies.
• User contributions. You may provide information, content (which may include images, audio, video or text) or other input (including AI Inputs) for us to process in order to provide products or services to you, or to transmit to other Website users or third parties (collectively, "User Contributions"). Please be aware that no security measures are perfect or impenetrable and you submit User Contributions at your own risk. Additionally, we cannot control the actions of any third party with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorised persons will not view your User Contributions.
• Third parties or publicly available sources. We may receive information about you if you visit other websites employing our cookies or from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators. We may also collect information that is publicly available such as public blockchain data.
• Affiliate and referral links. If you create an account using an affiliate or referral link, we will automatically record that your account was created via that link at the point of sign-up. We use this to attribute your account to the relevant affiliate and to calculate referral commissions. The referral link contains a unique identifier that is captured when you click it and matched to your account at sign-up.
• Reports and feedback. If you use the in-app or Website reporting or feedback feature (as described in Section 7.4 of the Terms of Use) to report a problem, complaint or item of feedback, we collect the free-text content of your report or feedback message, together with your Account identifier, so that we can investigate and respond to it.

We provide AI agents to assist with your tasks. Those agents use AI models to understand, analyse and respond to your inputs, which may include commands, questions, prompts, information and content that you submit or upload or to which you grant access in order to use our services such as social media or wallet and trading information (collectively, “AI Inputs”), and execute tasks on your behalf. Those AI Inputs may include personal data.

The AI agents have persistent memory which means those agents retain key information from your interactions, such as preferences, configurations or attributes that you share with or create for those agents or that can be derived from your usage patterns or interactions with those agents (“Memory Data”). That Memory Data will enable the AI agents to deliver more personalised and customised responses and to maintain context.

Outputs generated by the AI agents are produced by automated systems and may be inaccurate or incomplete. Where an output contains information about you, it may represent an inference generated by a model rather than a statement of verified fact.

Do not include sensitive or special category personal data (such as information about health, biometrics, racial or ethnic origin, political opinions, religious beliefs, sexual life or criminal records) about yourself or any other person in your AI Inputs unless it is strictly necessary. We do not request such data and do not use it for any purpose other than providing the services at your direction. If you choose to include such data in your AI Inputs, you are responsible for ensuring that you are entitled to provide it.

You are reminded that once you open an account to use the agentic AI services on the Website, you will be required to provide AI Inputs which will be processed by AI agents with persistent memory, creating Memory Data. When you create an account, you will be asked to accept the Terms of Use and this Privacy Policy, which explains how we process your personal data. Because persistent memory is a core part of the agentic AI services, we process the personal data contained in your AI Inputs and Memory Data on the basis that it is necessary for the performance of our contract with you (that is, to provide the services you have asked for), and not on the basis of your consent. This means that you cannot use the agentic AI services without this processing; if you do not wish your personal data to be processed in this way, you should not use those services. Where we rely on your consent for a separate, optional purpose (for example, marketing), we will ask for that consent separately, and you may withdraw it at any time without affecting your ability to use the core services.

The persistent memory feature is a core component of an AI agent. Once you deploy an AI agent through our platform, that agent will automatically retain Memory Data derived from your AI Inputs and interactions on a continuous basis. This feature cannot be switched off.

This means that:

• Memory Data may contain personal data, including information you provide directly and information derived from your usage patterns and interactions with your agents.
• Memory Data is retained and processed across sessions, agent runs, and platform restarts. It persists until your account is terminated and, in some cases, beyond termination, subject to the limitations described below.
• Agents may share Memory Data with other agents deployed through your account for the purposes of coordinating tasks. Please exercise caution about what personal data you include in your AI Inputs.

If you do not wish your personal data to be processed in this manner, you should not use the Website.

While you have a right to request deletion of your personal data (as described in the "Your Rights" section of this Policy), the technical nature of persistent memory means that complete erasure of all Memory Data cannot be guaranteed in all cases. Specifically:

• Certain Memory Data may be stored in compressed, encoded, or vector-embedded form within third-party large language model or infrastructure environments that are not fully within our control or accessible to us for the purposes of targeted deletion.
• We do not currently provide an in-app tool to view or selectively delete individual items of Memory Data. If, in the course of a conversation, you instruct an AI agent to "forget" or disregard specific information, that instruction operates only within that conversation or agent session and does not constitute a verified deletion of the underlying data from our (or any third-party provider’s) storage systems. To have your Memory Data deleted, you may close your Account as described below. Before doing so, you may export your Memory Data as part of your Agent Materials, as described in the section headed “Your Agent and Agent Exports”.
• Where Memory Data has been incorporated into model inference outputs, infrastructure environments or execution logs held by third-party LLM providers, we may be technically unable to procure its deletion from those providers' systems, but we will use our reasonable endeavours to procure the pseudonymization or anonymization of such data that cannot be deleted from third-party systems.

When you request an export, we will provide your Agent Materials to you in a structured, commonly used and machine-readable format. Please be aware that:

• your Agent Materials may contain personal data about you and, where other people have interacted with your AI agents, about those other people. We may exclude or redact information from an export where necessary to protect the rights of others or to comply with applicable law;
• once you download or transfer your Agent Materials, we no longer control them. Any platform, application or service into which you import them will process that data under its own terms and privacy policy, and you are responsible for your use of the exported data, including any personal data of other people that it contains; and
• the limitations described in the section headed “Important Notice Regarding Persistent Memory and Data Deletion” also apply to exports, as certain Memory Data held within third-party large language model or infrastructure environments may not be retrievable.

If we close your account other than at your request, we will keep your Agent Materials available for at least 30 days so that you can request an export, unless we are prevented from doing so by law, sanctions or an order of a court or competent authority.

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalised service when you browse our Website. It also allows us to improve our Website by enabling us to improve your user experience on the Website.

We use the following categories of cookies and similar technologies: (i) strictly necessary cookies, which are required for the Website to function; (ii) functional cookies, which remember your preferences; (iii) analytics cookies, which help us understand how the Website is used; and (iv) affiliate and referral cookies, as described below.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, your user experience may be affected and certain features may not work correctly. We will not set non-essential cookies (including analytics and affiliate-tracking cookies) unless and until you have given your consent, which you can give, manage or withdraw at any time through our cookie banner or cookie settings. Strictly necessary cookies, which are required to operate the Website, do not require consent.

Our Website pages may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or to compile other similar statistics such as recording Website content popularity or verifying system and server integrity.

On our Website, we use cookies and URL parameters to track whether you have accessed our Website via an affiliate or referral link. These tracking technologies capture a referral identifier at the point of click and associate it with your account upon sign-up. Affiliate tracking cookies on the Website remain active for a period of 30 days from the date of the referral click. Where you access the Services through the App, attribution of your account to a referral or affiliate link is performed without the use of any cookies or cross-app tracking SDK; no App Tracking Transparency prompt is displayed within the App.

Where you access the Services through our mobile application, we may also collect: device information (such as device model, operating system and version, and application version); device and other mobile identifiers; application usage, diagnostic and crash data, which we collect using analytics tools including Firebase Analytics and PostHog; and, with your permission, data from device features you choose to enable (such as notifications, camera, photos or files). You control application permissions through your device settings and can withdraw them at any time. The application does not send push notifications from our servers and we do not hold any push notification tokens. It does provide local, on-device reminder notifications (which you can turn on or off at any time using the notifications setting within the application or your device settings); these local reminders do not involve any data being collected by, or transmitted to, us. Cognition and subscriptions are purchased through our Website rather than in the application, and payment data is handled by our payment processors as described in this notice. You can request deletion of your account and the associated personal data at any time by submitting a deletion request through your Account settings on our Website. Upon submission, your account will enter a 30-day period during which you may cancel the request by logging in; if you do not do so, your account will be permanently deleted at the end of that 30-day period and you will no longer be able to sign in to it. This mechanism is described in more detail in the section headed "Account Deletion" of the Terms of Use. Where we are required to retain certain personal data (for example for security, fraud prevention, tax or regulatory compliance) we will retain only that data, and only for the periods described in the section headed “Retention period”. The App Store providers also make their own privacy information available (for example, Apple’s “App Privacy” details and Google Play’s “Data safety” section).

We use your personal data to provide you with access to the Website, improve your user experience on the Website, communicate with you or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:

• Present our Website and provide you with the information, products, services, and support that you request from us.
• Fulfill the purposes for which you provided the data or that were described when it was collected.
• Notify and communicate with you about changes to our Website, products, or services.
• Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Improve our Website, products or services (including train the models that power our services, unless you have opted out using the Website), marketing, or customer relationships and experiences.
• Protect our Website and the offering of our products and services on the Website.
• Make suggestions and recommendations to you about goods or services that may interest you. Where we share data with affiliates or partners for marketing or referral purposes, we will do so only in compliance with applicable law.
• Prevent fraud, cyberattacks, illegal or unlawful activities or any abuse or misuse of our products and services on the Website.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.

We may also use non-personal data for any business purpose.

We will use your personal data for one or more of the following purposes and for the following lawful bases:

We may share the following categories of your personal data with the following categories of recipients:

We may also disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• to a buyer or other successor in the event of merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold;
• to comply with any court order, law, or legal process, including responding to any government or regulatory request; and to protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

We may share non-personal data without restriction.

Where we share your personal data with any third party — including analytics providers, advertising networks, third-party software development kits, and any parent, subsidiary or other related entity that has access to your personal data — we require that third party, by contract or other appropriate means, to provide the same or equal protection of your personal data as is set out in this notice.

We will retain your personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you (for example, for as long as you have an account with us);
• The amount, nature, purpose of collection and sensitivity of the data;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

You are also reminded that certain data which is available on the public blockchain (for example, on-chain trading data of digital assets (such as transaction time stamps, wallet addresses, etc.)) will be retained on the blockchain permanently.

We may retain anonymised or aggregated data derived from your personal data indefinitely, provided that such data cannot reasonably be used to identify you directly or indirectly.

As a guide, and subject to the criteria above and to any longer period required by applicable law, we apply the following retention periods:

– Account and profile data: for as long as your account remains open, deleted within 60 days of account closure (as described in the Terms of Use);

– AI Inputs and Memory Data: for as long as your account remains open, deleted or suppressed from active use within 60 days of account closure, subject to the limitations described in the section headed “Important Notice Regarding Persistent Memory and Data Deletion” (and, where we close your account other than at your request, not before the end of the export period described in the section headed “Your Agent and Agent Exports”);

– Payment and transaction records: for 7 years after the transaction, as required by applicable tax, accounting and anti-money laundering laws;

– KYC and identity-verification records: for the period required by applicable KYC/AML regulations, typically 7 years after the end of the customer relationship;

– Marketing preferences and related records: until you opt out or withdraw consent, plus a record of your opt-out for as long as necessary to honour it; and

– Server logs and security and diagnostic data: typically no more than 12 months.

We are based in Hong Kong. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.

In particular, we may transfer the personal data we collect to (i) our other group companies, which operate in (among others) Australia; and (ii) any other country in which we engage our service providers or in which our business partners operate, to the extent that those service providers or business partners are involved in the offering of our products and services on the Website. We use appropriate safeguards for such data transfers, including the European Commission’s model contracts and standard contractual clauses, unless the data transfer is to a country that has been determined by the European Commission or other relevant authority, as applicable, to provide an adequate level of protection for personal data.

We rely on appropriate transfer safeguards for these transfers rather than on your consent. Depending on the destination, these safeguards include the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s standard contractual clauses, the European Commission’s standard contractual clauses, or a finding of adequacy by the relevant authority. You may contact us for more information about the safeguards we use and, where relevant, to obtain a copy.

You acknowledge that when your AI Inputs are transmitted to third-party large language model providers for processing, those providers may process the data in jurisdictions where their infrastructure is located. This is necessary to provide the Services, as we do not operate our own large language model. To reduce the risks to you, where available, we use API configurations that restrict or disable the use of your AI Inputs for the provider's own model training purposes (for example, by using enterprise or zero-data-retention API tiers).

The large language model providers we currently use to process your AI Inputs include OpenAI (ChatGPT), Google (Gemini), xAI, Z.ai (GLM), Xiaomi (MiMo) and Nanonoble (MiniMax). If we add or materially change the large language model providers that we use, we will update the interface of the Website and use reasonable endeavours to notify you.

Notwithstanding the above, you should be aware that certain third-party large language model providers may process data in accordance with their own privacy policies, and the degree to which we can contractually restrict their processing may vary. We encourage you to review the privacy policies of the providers listed above or in our sub-processor register.

Personal data comprised in AI Inputs and Memory Data may be accessed or shared with other AI agents for the purposes of execution or coordination of tasks or through communication platforms that are open to such AI agents. Importantly, this data sharing may occur between AI agents belonging to different users of the Website, not only between AI agents within your own account. This means that your AI agents may share data (including data derived from your AI Inputs and Memory Data) with those other agents, and may receive data from them. You should treat any data you provide to an agent that operates in a multi-agent environment as potentially accessible to other agents, including agents belonging to other users, in the same way you would treat data shared in a collaborative or networked environment.

Data may be shared between AI agents, including agents belonging to other users, where this is necessary for the execution or coordination of the tasks that you ask your Agents to perform. You can control what your Agents are permitted to share through the configuration and data sharing settings available in your account, and we recommend that you apply the principle of least privilege when configuring them.

Please be aware that your personal data may be disclosed or transferred to third parties where you have chosen to use our agentic AI services with persistent memory features. You are responsible for the configuration and supervision of AI agents deployed through your account, including any data sharing settings you elect to apply or not apply. Where you intentionally share agent access or account credentials with third parties, any resulting data sharing between AI agents is outside our control and is your sole responsibility. We strongly recommend applying the principle of least privilege when configuring your AI agents (i.e., granting each agent only the access to data and tools that is strictly necessary for the tasks it is intended to perform).

We may wish to use your name and contact details (such as your email address) to send you news, offers and other marketing communications relating to our products and services and those of our group companies. We will not use your personal data for direct marketing unless you have consented to, or (where permitted by applicable law, including the Hong Kong Personal Data (Privacy) Ordinance) you have been informed of and have not objected to, such use, and we will not provide your personal data to any third party for use in that third party’s own direct marketing without your consent.

You may opt out of direct marketing at any time, free of charge, by using the unsubscribe link in any marketing message, adjusting your account settings, or contacting us at info@animocaminds.com, and we will stop using your personal data for direct marketing as soon as practicable after receiving your request.

You may send us an email at info@animocaminds.com to request access to, correct, or delete personal data that you have provided to us. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement.

You have the following rights with respect to your personal data (subject to any limitations which are expressly identified in this notice):

• Right of access to personal data provided
• Right to correct incomplete, inaccurate, or to update outdated data
• Right to information on the possibility of not providing consent and on the consequences of such denial
• Right to withdraw or revoke consent
• Right not to be subject to a decision based solely on automated processing, or profiling, which produces legal effects or negatively affects the individual
• Right to have data deleted or erased
• Right to either opt out of or object to certain processing
• Right not to be subject to discrimination
• Right to restriction of processing – this will only apply in certain circumstances
• Right to data portability – this will only apply in certain circumstances (in addition, you may export your Agent Materials at any time as described in the section headed “Your Agent and Agent Exports”)
• Right to object – this will only apply in certain circumstances
• Existence of the right to lodge a complaint with a local data protection authority

These rights apply to your personal data wherever we hold it as a controller, including personal data contained in your AI Inputs, Memory Data and outputs. We do not currently provide an in-app tool to view or selectively delete individual items of Memory Data, and instructing an AI agent to "forget" information within a conversation is not the same as erasure. Where a valid request to erase personal data would require deletion of Memory Data, we will give effect to that request by closing your Account (which deletes or suppresses your Memory Data as described in the section headed "Important Notice Regarding Persistent Memory and Data Deletion") or, where closing your Account is not necessary to address the request, through other reasonable means. We will not refuse a valid request to rectify or erase your personal data solely on the ground that doing so may affect the accuracy or performance of a model. Some personal data may be held by third-party providers or embedded within models in a form we cannot target for deletion; in those cases we will take the steps described in the section headed "Important Notice Regarding Persistent Memory and Data Deletion".

Where we make a decision about you that is based solely on automated processing and that produces legal effects concerning you or similarly significantly affects you, we will provide meaningful information about the logic involved and the significance and likely consequences of the processing, and you have the right to obtain human intervention on our part, to express your point of view and to contest the decision. Most outputs generated by your Agents are carried out on your instruction and are not decisions made by us about you.

If you are a resident of California or another U.S. state with a comprehensive consumer privacy law, the following additional information applies. The categories of personal information that we collect, and the purposes for which we use them, are described above and include: identifiers (such as name, email address, username and wallet address); commercial information (such as Cognition purchases and transaction history); internet or other electronic network activity information (such as usage data and information collected via cookies); audio, visual or similar information and user content (such as AI Inputs and User Contributions); and inferences (such as Memory Data). We disclose these categories to the recipients described above for the purposes described above.

We do not sell personal information for money. Depending on how applicable state law defines “sale” or “sharing”, our use of analytics, advertising or affiliate cookies may constitute a sale, sharing or targeted advertising; you can opt out at any time through our cookie settings and, where applicable, we honour recognised opt-out preference signals such as the Global Privacy Control. U.S. residents may exercise the rights of access, correction, deletion and portability, and the right to opt out of sale, sharing or targeted advertising, by contacting us at info@animocaminds.com or through the mechanisms described in this notice. We will not discriminate against you for exercising any of these rights, and an authorised agent may submit a request on your behalf where applicable law permits.

In the event that any of your questions or requests cannot be resolved, you may reach out to the Hong Kong Office of the Privacy Commissioner for Personal Data, the UK Information Commissioner’s Office or your local regulatory authority for personal data.

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorised access, use, alteration, or disclosure.

Encryption and similar measures reduce the risk to your personal data but do not render it anonymous; encrypted personal data remains personal data.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password or any other sensitive personal data (such as social security numbers, health or banking information) with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. Nothing in this notice excludes or limits our responsibility to implement appropriate technical and organisational measures to protect your personal data as required by applicable data protection law, or any liability that cannot be excluded or limited under that law.

We maintain procedures to detect, investigate and record personal data breaches. Where a breach is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority (such as the UK Information Commissioner’s Office or the Hong Kong Office of the Privacy Commissioner for Personal Data) without undue delay and, where required, within 72 hours of becoming aware of it. Where a breach is likely to result in a high risk to your rights and freedoms, we will also notify you without undue delay, using the email address registered to your account, and tell you what steps you can take to protect yourself.

We do not direct our Website to minors and we do not knowingly collect personal data from children under 18 years of age or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at info@animocaminds.com.

This section applies to individuals who do not hold an Account but whose personal data we process in connection with the Services -- for example, if you send an email to, or are copied on an email exchange with, one of our Agents, or if you participate in a Telegram or other messaging group in which an Agent operates. We process the content of your message and associated information such as your email address or messaging handle in order to enable the Agent to respond to and act on your communication, to operate and improve the Services, and to maintain the security and integrity of the Services, as described elsewhere in this notice. If you do not hold an Account and wish to object to this processing or to request deletion of your personal data, you may contact us at info@animocaminds.com; we will consider your request in accordance with applicable data protection law and the section headed "Your Rights" above. Records of your interactions with an Agent may also form part of that Agent’s Agent Materials and may be included in an export requested by the Agent’s owner, subject to any exclusion or redaction we apply to protect your rights.

Since the agentic AI services on the Website are launched as a beta product, data handling practices such as data retention periods and third party processing may change. We will post any changes we may make to our privacy notice on this page and indicate on the Website home page that we updated this privacy notice. If the changes materially alter how we use or treat your personal data we will notify you by email to the primary email address specified in your account. Please check back frequently to see any updates or changes to our privacy notice.

Please address questions, comments, and requests regarding this privacy notice and our privacy practices to info@animocaminds.com.

Compliance Officer
Animoca Minds Limited
28/F, Landmark South, 39 Yip Kan Street, Wong Chuk Hang, Hong Kong
info@animocaminds.com