AI Wukong Robot Privacy Policy

Last Updated: 2026-04-28

CONTENTS

I. Introduction

II. Personal Data We Collect

III.Cookies and Similar Technologies

IV. Legal Basis and How We Use Your Personal Data

V.How We Share Your Personal Data

VI.How Your Personal Data Transfers Globally

VII. How We Store and Protect Your Personal Data

VIII. Your Data Subject Rights

IX.Children's Privacy

X. Update to this Policy

XI.Contact Us

I. Introduction

Thank you for using AI Wukong Robot (hereafter referred to as "AI Wukong Robot", "this product", or "the robot")! We respect your concerns about privacy and appreciate your trust and confidence in us. We hereby develop this Privacy Policy (referred to as "this Policy") to help you understand how we collect, use, disclose, protect, store, and transmit your personal data. It also describes your data subject rights and available choices. This Privacy applies when you use our products, services, applications, and software; when you interact with us via communication channels such as email, phone, or social media; or when you engage with us in any other context (collectively, the “Services”).

Data User: UBTECH Robotics Corp Ltd (hereinafter referred to as "UBTECH", "we", "us", or "our") is the user (or similar term under applicable laws) of any data processed in connection with this Policy.

In this Policy, "personal data" means any data that can be used to directly or indirectly identify an individual, except as otherwise specifically provided by applicable law in your region. It includes data such as name, contact details, facial pictures and IP address.

Please read carefully and fully understand this Policy herein before using or continuing to use our Services and, if necessary, make appropriate choices in accordance with the guidelines in this Policy. If you have any questions about this Policy, please contact us regarding your requests and we will respond to your query as soon as possible.

II. Personal Data We Collect

We collect personal data to provide, operate, and improve our Services. The specific data we collect depends on how you use our products and services or interact with us. In some cases, you can choose not to provide such data, but this may prevent us from providing you with corresponding products or services, or may mean that we cannot respond to or resolve any issues you have raised.

1.The data you provide to us

(1) Account and device binding data

To help you register for an AI Wukong Robot account, bind the robot to the App and ensure a secure operating environment, we may collect:

- your network identity data, including mobile phone number and verification code;

- The device SN, binding time, binding IP address, and binding mobile phone number;

To complete this binding process, you will also need to grant the App permissions to access Bluetooth, location (Under the Android system, the setting of the Google framework is that location data must be obtained first to establish a Bluetooth connection; we don't collect or upload geolocation data).

(2) Network data

When using AI Wukong Robot, you need to configure the Wi-Fi network for the robot through the App. We will collect the Wi-Fi data (SSID, Wi-Fi password) and device ID you configure. The Wi-Fi password data is only stored locally on the device and will not be uploaded to the cloud.

(3) Voice command data

The AI Wukong Robot supports voice commands. User-related voice data will be sent to the Alibaba Cloud platform for speech recognition, enabling users to control the robot's volume and actions (such as singing and dancing) via voice commands. Please note that some voice commands need to be implemented through generative AI services. If you are not authorized to use generative AI services, you may not be able to execute the relevant voice commands.

(4)Video call data

The video surveillance function allows users to view the images captured by the robot's camera in the App. The images are real-time data and will not be stored. To protect your privacy, please keep your account bound to the robot secure from unauthorized use. To enable voice calls, the microphone permission of the mobile phone needs to be invoked to obtain sound data. If the microphone permission is not provided, the real-time call function will not be available, but it will not affect the video viewing function.

(5)Intelligent voice dialogue data

When you use the intelligent Chinese conversation function or English practice of the AI Wukong Robot, we will collect your voice chat records and English conversation records, and save them as the robot's long-term or short-term memory for a certain period of time. When you ask the AI Wukong Robot weather-related questions, we will collect your location data through the IP address of WiFi to complete the local weather query. We implement the above functions by accessing Alibaba's Qwen large language model. We recommend that you do not disclose any privacy or other unauthorized data about yourself or others when using it in non-home scenarios. All data you provide to us is voluntarily provided by you and has obtained the necessary legal authorization.

Please note that AI Wukong Robot currently cannot isolate and store conversation data of different users, and we hereby remind you to take notes to exercise caution when disclosing private data when using the Intelligent voice dialogue function in multi-person scenarios to avoid the leakage of your private data.

(6) Other using data

AI Wukong Robot supports picture book companion reading and other basic functions. To implement these basic functions, we may collect schedule data, picture book records, and programming file data during your use.

(7) Face recognition data

To distinguish between different users, the robot's camera processes images to classify users in an anonymized state. This enables the robot to interpret its visual input. Regarding the facial data involved:

The facial data we obtain is de-identified data and is not associated with any real identity data, unless authorized by you or other users. Facial data is associated with an identity (e.g., a nickname) only when you actively request this feature during an interaction with the robot. For instance, if you ask the robot to remember you and provide your nickname, facial feature vectors will be stored locally and linked to that name. We strictly adhere to the "minimum necessary" principle. The processing of facial data is conducted only locally on the robot, and it is only stored on the robot terminal without being uploaded to the cloud. The original facial images you have entered will be automatically deleted periodically, and we do not retain or back up any of them, only storing facial feature values in the form of vectorized encoding. You can clear this data by canceling your account.

Note for direct user and account owner: You have the obligation to use the Service reasonably and manage user data, including but not limited to: managing the on/off status of the "Intelligence Enhancement Mode" through the App; assisting other users who actively input data to exercise their rights to personal data such as the right to query and the right to delete; and other obligations related to reasonable use and data management.

(8) Customer service data

You can directly click on "Help and Feedback" - "Feedback" in the App, or contact us through the contact information at the end of this policy. When you contact us for support, feedback, or dispute resolution, we collect necessary data such as your nickname, contact details, the content of your feedback and any attachments, communication records, call logs, and any evidence you provide (e.g., images/videos/text). If your inquiry relates to a specific order, we may also use your order data and shipping address.

(9) Survey data

If you participate in our optional surveys, we collect the data you submit in your responses.

2.Data we collect from you automatically

To the extent necessary to provide you with the robot and its related services, we also collect the following personal data without your active provision to us:

(1) Device and application software data.

We collect certain data automatically when you use the Services. The related data may include mobile device model, software version data, operating system and version, mobile network data, device manufacturer, UUID.

(2) Log data

When you use our Services, we may automatically collect and log robot IDs, system version, main service version, firmware version, storage space, battery capacity, online status, activation IP address, robot wake-up log, camera activation log, usage duration statistics, etc.

3.Data from other sources

Our Services may, from time to time, contain links to and from social media platforms. If you choose to connect with us through a social media platform, we may, through the social media platform connection, collect additional data from you, such as your usernames, chat content. Similarly, the social media platforms may collect data about your interaction with our Services. We do not have any control of the collection, use and sharing of your data when using any social media platforms. You should read any associated privacy policies before using them.

4. Non-Personal data

We also collect aggregated, non-personal data that does not directly identify you, such as statistical data on user operations (e.g., clicks). This data is used to improve our services. If non-personal data is combined with personal data, it will be treated as personal data during the period of combination.

III.Cookies and Similar Technologies

To ensure the normal operation of our services and provide you with a smoother and more convenient user experience, we may sometimes place small data files on your computer, mobile communication terminal, or other devices. These data files may include Cookies, Clickstream, Web, or other local storage provided by your browser or associated applications (hereinafter collectively referred to as "Cookies"). Cookies are small data files that a website or mobile application stores on your computer, mobile communication terminal, or other devices when you visit the website.

They enable us to remember your actions and preferences (such as login name, interface language, setting preferences, etc.) over a period of time. We may collect and store relevant data about your visits to our website or mobile application through various technologies, which can identify your identity, save you the trouble of repeatedly entering registration data, or help determine the security status of your account. Therefore, whenever you return to the App or browse pages, you do not need to keep re-entering or reconfiguring user settings. You can clear the cache in the corresponding settings of your browser or APP. Please understand that some of our services can only be implemented through the use of Cookies.

IV. Legal Basis and How We Use Your Personal Data

We use your personal data only on a legal basis. According to applicable local laws, we may use your personal data for the following purposes under one of the legal bases: contractual necessity, legitimate interests, consent, compliance with applicable laws and regulations.

1. Contractual necessity

(1) To provide and maintain our services to you. For example, we use your personal data to bind your robot to the App, enable robot control and management, configure voice output, and provide real-time visual sharing.

(2) To synchronise and store the data you have uploaded or downloaded, as well as the data needed for upload and download operations.

(3) To communicate with you about the Service.

(4) To troubleshoot problems after you send error details to us.

2. Legitimate interests

Whenever we rely on legitimate interests for processing, we ensure that we consider and balance our interests against the individual’s interests before processing. We do not use your personal data on the basis of legitimate interest for activities where individuals’ interests override our interests.

(1) To improve the Services and develop new features.

(2) To carry out audits, data analysis, and research.

(3) For safety, security, fraud and abuse measures.

3. Your consent

When we process your data based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on such consent before it is withdrawn.

(1) To participate in surveys and research: We may conduct online surveys from time to time to better understand your opinions and suggestions on the services we provide.

(2) To update the Services or marketing: If you have consented, we may use your personal data to send you updates about our products, services, and promotional activities.

(3) To provide us with sensitive personal data: If you choose to provide us with personal data that may be considered “special” or “sensitive” in certain jurisdictions, you’re consenting to our processing of that data in accordance with this Policy.

4. Compliance with applicable laws and regulations

(1) To comply with applicable local laws/regulations.

(2) To complying with legitimate governmental requirements, such as assisting law enforcement.

(3) To gather and to provide data required by or relating to audits, inquiries or investigations by regulatory bodies;

(4) Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under safety law or rules issued by our professional regulator.

V.How We Share Your Personal Data

We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable laws and regulations. We do not allow our third-party partners to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with contractual obligations which ensure adequate protection.

1. Sharing with your consent or at your request

With your explicit consent or at your request, we will share your personal data within the scope of your consent or request with specific third parties designated by you.

2. Sharing with affiliates

In order to provide you with richer features and services, or to carry out our obligations and enforce our rights under our contract or this Policy, your personal data may be shared with affiliated companies of UBTECH. This includes such affiliates that process your personal data, necessary for providing our products or services to you.

3. Sharing with third-party service providers

We may disclose personal data to our service providers for the performance of certain features or to provide you with better service and a better user experience. The categories of service providers to whom we entrust personal data include service providers for:

a.Delivery of physical products;

b.Data hosting and storage;

c.Intelligent voice interaction (ASR、TTS、LLM);

d.Picture book reading function;

e.Video call function;

f.Troubleshoot application problems;

g.Security and service delivery;

h.Customer support and customer management;

i.Other service providers (where applicable).

This policy does not apply to products or services provided by a third party. Depending on the service you use, it may incorporate third parties’ products or services, such as intelligent voice services, etc. Some of these will be provided in the form of links to third-partes's websites, and some will be accessed in the form of SDKs, APIs, etc. Your personal data may also be collected by these third parties when you use these products or services. For this reason, we strongly suggest that you take the time to read the third party’s privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal data which they collect from you. This Policy does not apply to other sites linked to our services.

4. Sharing with authorities

Where necessary, we will disclose the relevant personal data to:

a.Public bodies or other organizations having regulatory authorities in case of specific requirements made in accordance with the applicable law;

b.Courts and tribunals, in case of specific requirements made in accordance with the applicable law;

c.Law enforcement agencies, in case of specific requirements made in accordance with the applicable law.

5. Others

We may share your personal data with our accountants, auditors, lawyers or other professional external advisors who serve us under professional obligations of secrecy when we ask them to provide us with professional advice or when their professional service is required by applicable law.

In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if personal data transfer is involved, we will require the new company or organization that is about to hold your personal data to continue to be bound by this Policy. Otherwise, we will require the company or organization to re-solicit your authorization and consent.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated such anonymized data with third parties.

VI.How Your Personal Data Transfers Globally

We process and back up personal data through a global operating and control infrastructure. Currently, the personal data we collect about you will be stored on servers located in Chinese Mainland. Under the Personal Data (Privacy) Ordinance of Hong Kong, China before transferring your personal data to places outside Hong Kong (including Chinese Mainland), we will ensure that we have obtained your voluntary, explicit, and written consent (unless such place has been recognized by the Hong Kong Privacy Commissioner for Personal Data of Hong Kong as having substantially similar levels of protection). Your ticking of the relevant cross-border notice option during registration and login constitutes such consent.

We may also transfer your personal data to third-party service providers and business partners. Therefore, your data may also be transmitted to other countries or jurisdictions that may not have data protection standards equivalent to those in your jurisdiction. If we need to transfer personal data outside of your jurisdiction, we will comply with applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing comprehensive security safeguards. You can find out about the safeguards in the following chapter or contacting us at ucare@ubtrobot.com.

VII. How We Store and Protect Your Personal Data

1. Retention time

We will keep your personal data only as long as is necessary for the purposes set out in this Policy and to fulfil our legal obligations. We will destroy or anonymize your personal data when we have reasonably determined that:

(1) The purpose for which personal data was collected is no longer being served by the retention of such personal data;

(2) Retention is no longer necessary for any legal or business purposes; and

(3) No other legitimate interests warrant further retention of such personal data.

In each case, there are also occasions where we may need to keep your data for longer in accordance with this Policy, our legal obligations or where it is necessary for legal claims. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

After you have terminated your use of our Service, we will store your personal data in an aggregated and anonymised format.

2. Protection of your personal data

We use appropriate technical means and organizational measures to safeguard the personal data we collect about you. The measures we take provide you with security that matches the risk of processing your personal data. The specific measures we take include Secure Sockets Layer (SSL) encryption to ensure that your data is securely transferred from your browser to our network system.

Your personal data will be stored on a secure server and protected in a controlled facility. We classify your data by importance and sensitivity and ensure the highest level of security for your personal data. We guarantee that employees and third-party service providers who provide products and services to you by accessing the data have strict contractual confidentiality obligations, and if they fail to fulfill these obligations, they will be subject to disciplinary actions or termination of cooperation. Similarly, we have dedicated access control measures for cloud-based data storage. In summary, we regularly review our data collection, storage and processing practices, including physical security measures, to prevent any unauthorized access or use of your personal data.

We will take all practicable measures to protect your personal data. However, you should be aware that the use of the Internet is not always secure, therefore we cannot guarantee the security or integrity of any personal data when transmitted in both directions over the Internet. At the same time, your assistance will help us protect the privacy of your personal data.

a.You can protect your personal data by not disclosing your robot control password or WIFI data to anyone (unless duly authorized by you). Whenever you use the AI Wukong Robot App or other UBTECH products, especially when downloading and connecting our products by someone else's device or public Internet terminal, please be sure to clear the relevant data after use.

b.UBTECH is not liable for any security loophole in the event of any third party's access to your personal data due to your failure to maintain the privacy of your personal data. Notwithstanding the foregoing, you must notify us immediately in the event of unauthorized use of your account by any other user on the Internet or any other security loophole.

We will promptly notify the relevant regulatory authorities about the disclosure of personal data, and in some special circumstances, notify the data owner of relevant data slope events to meet relevant applicable laws, including data protection regulations in your location.

VIII. Your Data Subject Rights

1. Rights you have over your personal data

You have the right to request access to, correction of, erasure of any personal data we hold about you, or to obtain a copy of your personal data (collectively referred to as a "Request"):

(1) Right of Access and Inquiry
You have the right to access and inquire about your personal data, except as otherwise provided by law. If you wish to exercise your right of access, you may do so through the following methods:
- Access/Inquiry of avatar, nickname, and bound mobile phone number: Enter AI Wukong Robot → “My” → click on the avatar to access account data;
- Other personal data generated during your use of our products or services, such as device SN data: Contact us directly via the contact details provided below this Privacy Policy to submit your inquiry.

(2) Right of Correction
You have the right to request correction of your personal data. You may contact us via the contact details in Section 9 of this Policy, and we will assist you in completing the correction.

(3) Right of Erasure / Deletion
If any of the following situations occur, you may submit a request for erasure of your personal data via the contact details in Section 9 of this Policy. We will verify your identity and the request and take measures to erase the data as soon as practicable:

- Our handling of personal data violates applicable laws;

- We collected or used your personal data without obtaining your consent;

- Our handling of personal data breaches our agreement with you;

- You no longer use our products or services, or you have closed your account;

- We cease services and operations.

We will evaluate your erasure request and, if it meets relevant requirements, take appropriate steps (including technical measures) to comply. If we decide to fulfill your request, we will also notify our partners or third parties who obtained your personal data from us, requesting timely erasure, unless otherwise required by law or such partners have obtained your separate authorization.

After you or we assist in erasing relevant data, due to applicable legal and technical constraints, we may not be able to immediately delete the data from backup systems. We will securely store your personal data and isolate it from further processing until the backup can be cleared or anonymized.

(4) Withdrawal of Consent
You may withdraw your consent for the collection, use, and/or disclosure of your personal data held or controlled by us by submitting a request. Where we share, transfer, or publicly disclose your personal data externally, we will provide you with notice of the option to withdraw consent.

Please note that each business function requires certain basic personal data to operate. After you withdraw consent or authorization, we will no longer be able to provide you with the services corresponding to the withdrawn consent, nor continue collecting or processing the relevant personal data. However, your withdrawal will not affect processing previously carried out based on your authorization.

You may withdraw consent to this Privacy Policy by navigating to: AI Wukong Robot → “My” → “About” → “Privacy Policy” → “Withdraw Authorization”. Please note that withdrawal of consent may result in legal consequences, including potential loss of access to certain features and services of AI Wukong Robot.

(5) Account Closure
You may directly apply to close your account within our app.

Close Personal Account: Your personal account is linked to your mobile phone number. You may close your personal account by following these steps: AI Wukong Robot → “My” → Top-left profile picture → “Close Account”.

As closing your account may result in the deletion of all data associated with it, please proceed with caution. To protect your legitimate rights and interests or those of others, we will assess whether to support your account closure request based on your usage of AI Wukong Robot. After account closure, we will cease collecting, using, or disclosing related personal data and will delete your personal data, unless otherwise required by law.

(6) Obtaining a Copy of Your Personal Data
You have the right to obtain a copy of your personal data. If you need a copy of your personal data collected by us, you may contact us via the contact details in Section 9 of this Policy. Our customer service staff will verify your identity and, after confirming you are the data subject, will provide a copy of your personal data via email. Subject to compliance with relevant laws and technical feasibility, we will provide the copy upon your request.

2. Responding to Your Request
If you cannot complete the above request via the specified methods, or if you believe AI Wukong Robot has violated any laws, regulations, or this Policy, you may contact us via the contact details in Section 11 of this Policy. To protect the security of your personal data, you must submit a written request through our designated channel and provide sufficient data for us to verify your identity, ensuring the requester is you or a legally authorized person. We will respond to your request within 40 days after receiving your feedback and verifying your identity.

We will generally not charge fees for reasonable requests, but for repeated or excessive requests, we may charge a cost-based fee on a case-by-case basis. We reserve the right to refuse requests that are frivolous, vexatious, repetitive, infringe others’ legitimate rights, are unrealistic, require disproportionate technical effort, are not required under local law, involve publicly available data, or are subject to confidentiality obligations. We may also refuse requests for erasure or access if such requests would prevent us from lawfully using data for legitimate anti-fraud or security purposes.

IX.Minor's Privacy

Although local laws and customs may define minors differently, we consider any individual under the age of 18 as a minor. If you are a minor under the age of 18, you shall obtain the consent of your legal guardian prior to using our services. Should your guardian disagree with this Policy, you must immediately cease using our products and services and refrain from providing any personal data. We will protect the personal data of minors in accordance with applicable laws and regulations.

We attach great importance to the protection of children's personal data. Without the consent of the child's legal guardian, we shall not unlawfully collect, use, transfer, or disclose the personal data of children. In accordance with relevant laws and regulations, if you are a child under the age of 14, we have also developed the "AI Wukong Robot Children's Privacy Statement" specifically for you. Before registering for or using our services, you should carefully read this Statement, Terms of Use, Privacy Policy and obtain prior written consent from your parent or legal guardian.

We do not intentionally require children under that age to provide more data than is necessary to provide the product. If you are a guardian of a child and have any questions about the personal data of the child you are guarding, please contact us according to Chapter 11 "Contact Us". If we find that we have collected personal data from children without verifiable parental or guardian consent where this is required, we will try to delete the relevant data as soon as possible.

X. Update to this Policy

We may update this Policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this Policy, we will revise the “Last Updated” date at the top of this Policy. We recommend that you check this page from time to time to inform yourself of any changes.

If there are any material changes to this Policy, we will notify you as required by applicable law.

XI.Contact Us

If you have questions or concerns about this Policy or practices of personal data protection, please contact us via:

Our Data Protection Officer Email: ucare@ubtrobot.com

Phone number: +86-400-6666-700 (Monday to Friday, 9:00 - 18:30 GMT+8)

Mailing address : 22nd Floor, Building C1, Nanshan Zhiyuan, No. 1001 Xueyuan Avenue, Nanshan District, Shenzhen, China.

We will reply to you within 30 days (or within the time limit stipulated by your local laws) . If you are not satisfied with our response, especially if our personal data processing has damaged your legal rights, you can also file a complaint or report to the data protection supervisory authority.

Note: Due to differences in local laws and languages, the local versions of this Policy may differ from this version. In case of any conflicts, the English versions shall prevail.(to the extent permitted by applicable laws and regulations)