Effective Date: November 13, 2025

Last Updated: November 13, 2025

Phlox Corporation (“Phlox,” “Company,” “we,” “our,” or “us”) respects users’ privacy and is committed to protecting your personal information.

This Privacy Policy applies to personal information collected through the Chappy mobile application, website, and related services (collectively, the “Service”).

This Policy does not apply to data collected in the context of Phlox employees, job applicants, or corporate partners.

Article 1 (Purpose of Processing Personal Information)

Phlox processes information provided directly or indirectly by users for the following purposes:

• Service operation and contract performance
  • Creating and managing user accounts
  • Providing AI chat and personalization features
  • Delivering and improving services, conducting research, and quality assurance
  • Processing purchases, subscriptions, and payments
  • Sending notifications, updates, or push messages related to Service operation
  • Responding to inquiries, troubleshooting, and providing customer support
  • Authenticating users to enable specific modes (e.g., Adult Mode verification)
  • Maintaining safety, preventing fraud, and enforcing Terms of Service
• Legitimate interests of Phlox and users
  • Preventing fraudulent or malicious activity
  • Protecting security and enforcing legal rights
  • Improving algorithms, accuracy, and personalization through aggregated data
• Legal compliance
  • Responding to law enforcement requests or court orders
  • Complying with data protection, tax, and consumer laws
• Consent-based processing
  • Sending promotional messages and event notifications upon user consent
  • Processing optional surveys, beta participation, or AI performance feedback

Article 2 (Information Processed by the Company)

Phlox collects and processes user information as follows:

• Information you provide directly
  • Identifiers such as name, date of birth, gender, country, and email
  • Account details (login credentials, profile settings, linked SNS accounts)
  • Images, voices, or texts submitted or generated within the Service
  • Payment and subscription details processed through App Store / Google Play
  • Feedback, inquiries, and survey responses
• Automatically collected information
  • Device info: model, OS version, app version, device ID, language, and region
  • Usage data: session logs, timestamps, interactions, feature usage
  • Cookies and analytics: tracking technologies for Service improvement and personalization
  • Purchase verification info (item ID, receipt ID, purchase timestamp)
• AI-generated data
  • Chappy processes inputs and generated outputs (messages, images, audio) using artificial intelligence to provide conversational experiences.
  • Such data may be stored temporarily to improve system performance and prevent abuse.
  • Phlox does not use private chat data for external marketing without explicit consent.

Article 3 (Information Sharing)