Moment Platform Privacy Policy

Last Updated and Effective Date: April 2026

1. Policy Introduction and Scope of Application

1.1 Welcome to access and use the "Moment" project (hereinafter collectively referred to as "the Platform", "we", or "our"). Protecting your personal privacy and data security is the core commitment of our business. This "Privacy Policy" (hereinafter referred to as "this Policy") aims to explain to you in a transparent and clear manner how we lawfully collect, process, use, share, store, and protect your personal information when you visit our official website, download our mobile applications, use our digital services, or interact with us in any other way.

1.2 This Policy is written in accordance with globally recognized principles of transparency, lawfulness, and fairness in privacy protection, and is designed to comply with relevant applicable data protection laws (including but not limited to the guiding principles of CCPA/CPRA and the spirit of GDPR). When you register an account, access the Platform, or continue to use our services, it constitutes your legally binding confirmation, indicating that you have fully read, completely understood, and agreed to the data processing practices and all terms described in this Policy.

2. Scope and Categories of Information We Collect

In order to provide you with a high-quality, smooth, and highly personalized interactive experience, we may collect relevant information in the following scenarios based on legitimate business purposes. The collection of information will be strictly limited to the necessary scope for realizing service functions.

2.1 Direct Information Provided Actively by You: Includes identity information you actively provide when registering an account, completing your personal profile, filling out forms, participating in surveys, or interacting with the customer support team. This typically covers your name, pseudonym, email address, mailing address, phone number, and account access credentials (such as cryptographically hashed passwords).

2.2 Telemetry and System Network Information Automatically Collected by the Platform: When you navigate or use our service infrastructure, for the purposes of system troubleshooting, network performance optimization, and security defense, our servers automatically record certain log data and system metrics. This may include, but is not limited to: your IP (Internet Protocol) address, browser type and version, operating system information, device unique identifiers (such as MAC addresses or mobile advertising identifiers IDFA/AAID), access timestamps, page viewing sequences, clickstream data, and related communication metadata.

2.3 User-Generated Content (UGC) and Its Associated Metadata: When you voluntarily upload, publish, or share multimedia content such as text, images, audio, and video on the "Moment" platform, in addition to processing the content itself, we may also automatically read the underlying metadata attached to the files (for example, EXIF format data in image files, which may contain hardware camera models, aperture and focal length settings, shooting timestamps, and geolocation coordinates permitted by your device). The sole purpose of reading such metadata is to enable the system to automatically optimize multimedia display effects for you, conduct intelligent content categorization (such as generating memoirs based on timelines), and ensure your digital assets present the optimal resolution and format compatibility across various terminal hardware.

2.4 Information from Cookies and Similar Tracking Technologies: We use essential Cookies to ensure the operation of the website's core functions. Unless you explicitly opt out through Universal Opt-Out Mechanisms (UOOMs), we and our authorized service providers may use analytical Cookies, Web Beacons, and similar tracking technologies to analyze overall website traffic patterns, remember your system preferences, and improve overall operational efficiency. You can manage or clear these trackers through your browser's advanced settings, but rejecting all Cookies may result in some platform functions requiring authentication failing to operate properly.

3. How We Use Your Information

All our processing activities regarding the collected information are always based on Legitimate Business Purposes and the original intention of providing you with excellent digital services. Within the framework permitted by applicable laws, we primarily use the information for the following strategic and operational purposes.

3.1 Basic Service Delivery and Account Maintenance: Used to operate the core infrastructure of the Platform, process your service requests, verify user identity, complete subscription billing processing, and send you necessary administrative and technical notices regarding service status changes.

3.2 System Security Prevention and Fraud Control: To continuously monitor and prevent any potential fraudulent activities, network abuse, unauthorized access attempts, and security vulnerabilities, in order to maximize the protection of your property, intellectual property, and system data security, as well as those of the Platform and the public.

3.3 Service Improvement, Technical Research and Development, and Algorithm Iterative Optimization: To drive the Platform's technological innovation and provide a smarter user experience, we may subject the collected raw data to strict De-identification or irreversible Anonymization. We reserve the right to use these aggregated, non-personally identifiable derived data for internal academic research, statistical analysis, product A/B testing, and for training, calibrating, and optimizing our automated processing systems (including core recommendation algorithms and large machine learning models). During this R&D process, the intellectual property and ownership of any technical improvements, derived algorithm formulas, and machine learning models resulting from the aforementioned processing shall absolutely and exclusively belong to the Platform.

3.4 Customized Experience and Personalized Content Delivery: To comprehensively analyze your historical usage preferences, interaction patterns, and characteristic metrics, in order to recommend more relevant functional modules and community content to you, and to optimize your exclusive user interface (UI/UX).

3.5 Legal Compliance and Fulfillment of Defense Obligations: Used to fulfill statutory disclosure obligations under applicable laws, government regulations, judicial subpoenas, or mandatory government investigation requests, or to defend the legal rights and interests of the Platform in potential legal proceedings.

4. Strategic Sharing of Information and Affiliate Disclosure

We abide by business ethics and will never "sell" your personal information to unaffiliated third parties in exchange for direct monetary compensation. We strictly and lawfully share your specific information only within the narrowest scope necessary to achieve the purposes described in Article 3 of this Policy.

4.1 Core Service Providers and Technical Processors: To maintain the high availability of the Platform, we must share necessary encrypted information with authorized "Service Providers" who assist us in operating critical infrastructure. This includes top-tier cloud storage vendors, global Content Delivery Network (CDN) operators, payment gateway processors, and third-party customer support platforms. These providers are subject to extremely strict Data Processing Agreements, are only permitted to access data when performing specific support functions on our behalf, and are strictly prohibited from using the data for any independent commercial purposes.

4.2 Corporate Transactions, Mergers and Acquisitions, and Asset Restructuring: In the event that the Platform or its parent company is involved in a merger, acquisition, due diligence, bankruptcy restructuring, or the sale of substantially all of its assets, your personal information, as a core component of the company's business assets, will be legally transferred to the potential buyer or successor entity. We will make reasonable commercial efforts to ensure that the new data controller continues to substantially comply with the commitments of this Privacy Policy.

4.3 Third-Party Links and Uncontrollable Ecological Services: The interface of this Platform may contain external links pointing to third-party websites, plugins, or integrated applications (such as third-party social media login APIs) not actually controlled by this Platform. When you click on such external links or interact with third-party services, all collection, retention, and use of relevant information will be entirely governed by the third party's own privacy policy. The Platform assumes no direct, indirect, or joint legal liability for the data privacy practices, security breaches, or non-compliant processing actions of any third-party entities.

4.4 Mandatory Cooperation with Law Enforcement and Disclosure for Rights Protection: If we believe in Good Faith that it is genuinely necessary to comply with orders, subpoenas, or other mandatory judicial procedures of a court of competent jurisdiction, or to cooperate with lawful criminal or national security investigations by law enforcement agencies, we reserve the right to disclose any of your information in accordance with the law. Furthermore, to enforce our Terms of Service, protect the intellectual property of the Platform, or prevent imminent harm to the public, we also reserve the right to proactively disclose necessary information.

5. Your Statutory Rights and Autonomous Information Management

We fully respect your control over your own data. Depending on your actual jurisdiction of residence and applicable local data protection laws, you may be entitled to exercise some or all of the following privacy rights.

5.1 Right to Data Access and Correction: You can access, view, update, and correct some of the core identity information you previously provided at any time through your personal account Dashboard to ensure its accuracy.

5.2 Right to Request Data Deletion (Right to be Forgotten): You have the right to request us to erase part or all of your personal information under certain applicable circumstances. However, please note that this right is not absolute. To fulfill statutory obligations such as Anti-Money Laundering (AML), cooperate with pending dispute resolutions, enforce our Platform agreements, or for compliance audit needs related to system security, we may continue to retain certain tamper-proof data records within a reasonable statutory retention period where explicitly permitted or mandated by law.

5.3 Withdrawal of Consent and Marketing Communication Unsubscription: You can refuse to receive subsequent promotional or marketing communications by clicking the "Unsubscribe" link at the bottom of non-transactional emails we send, or by adjusting the push notification settings within the app. However, we still retain the absolute right to send you critical administrative notices directly related to the Platform services themselves (such as account security alerts, billing receipts, or policy change notices), and such notices are not affected by unsubscription requests.

6. Data Security Defense and Maximum Liability Limitation Statement

6.1 Industry Standard Security Measures: We attach great importance to the security of your information. The Platform has deployed and continuously maintains physical, technical, and administrative defense-in-depth measures compliant with modern information security industry standards (such as implementing Transport Layer Security (TLS) encryption, AES-256 encryption for data at rest, strict internal access controls, and regular vulnerability penetration testing) to best protect your personal information from unauthorized access, malicious theft, accidental loss, or illegal alteration.

6.2 Liability Cap and Disclaimer Defense System: Please fully understand and agree that, given the openness of the underlying internet architecture, the continuous evolution of hacking technologies, and unforeseen system vulnerabilities, no data transmission, network communication, or electronic storage system can guarantee you one hundred percent absolute security. To the maximum extent permitted by applicable law, for any data breach, service interruption, or data tampering caused by events beyond our reasonable direct control (including but not limited to Advanced Persistent Threat (APT) attacks, zero-day exploit vulnerabilities, third-party telecommunication infrastructure failures, global network paralysis, or force majeure events), the Platform and all its affiliates, executives, employees, or agents shall not assume any form of indirect, punitive, incidental, or consequential damages liability (including but not limited to any form of lost profits, damaged business reputation, loss of business opportunities, or huge costs of redundant data recovery). Regardless of any direct liability we assume under any circumstances, the Platform's total cumulative maximum liability to you for a data security incident shall absolutely not exceed the total direct service fees you actually paid to us for using the Platform's services within the twelve (12) months prior to filing the claim; if you have not paid any fees, the Platform's maximum liability disclaimer cap is fixed at one hundred (100) US dollars.

7. Unilateral Modification Rights and Dynamic Evolution of this Privacy Policy

7.1 To continuously adapt to the evolution of the Platform's business model, major adjustments to the technical architecture, and continuous updates of laws and regulations across global jurisdictions, we reserve the absolute right to freely revise, update, or supplement the terms of this "Privacy Policy" at any time based on our unilateral reasonable business judgment.

7.2 When material changes occur to the terms of this Policy, we will publish the latest version by modifying the "Last Updated and Effective Date" at the top of this page. For significant revisions that may substantially affect your core rights, we may provide commercially reasonable disclosure and notification by posting a banner announcement or a pop-up window in a prominent position on the Platform, or by sending a system notification to your registered email address.

7.3 Implied Confirmation of Consent: After any policy modification or term change formally takes effect, if you fail to take action to cancel your account and continue to access the official website or use any services or applications of the "Moment" Platform, it legally constitutes your irrevocable implied confirmation. This indicates that you have fully read, completely understood, and unreservedly agreed to be legally bound by all terms of the revised and updated version of the Privacy Policy. If you completely disagree with the relevant policy updates or any additional terms, your sole and exclusive legal remedy is to immediately and permanently stop using all our services.

8. Privacy Affairs and Compliance Contact

If you have any questions about the content of this "Privacy Policy", need further clarification on our specific compliance practices regarding data processing, or need to submit an access request regarding personal information rights in accordance with the law, please contact our privacy compliance team through the following officially designated channels.

Official Compliance Email: support@metana.ai

We highly value your concerns and promise to provide an initial response to your inquiries within a reasonable statutory timeframe specified by relevant applicable laws (typically within 30 to 45 business days after receiving a verifiable request), and remain committed to protecting the privacy and security of your digital ecosystem within a compliant framework.