SeaBrains Privacy Policy

Effective date: 2026.9.20

This SeaBrains Privacy Policy (this “Privacy Policy”) forms an integral part of the SeaBrains User Agreement (the “User Agreement”) and is entered into between you (the “User”, “you”) and HONOURAI PTE. LTD. (“we”, “us”, “our”).

If you are a minor, you must read this Privacy Policy in the company of your guardian. You and your guardian must read it carefully, and you may use the products and services we provide only after your guardian has consented to all the terms of this Privacy Policy.

We respect our users' privacy and personal information and protect it rigorously. When you use the SeaBrains products and services we may collect and use your personal information. This Privacy Policy explains the rules that apply when we collect and use your personal information, so that your rights and interests are better protected. Our explanations and statements are set out below.

1. Definitions

Unless otherwise agreed, the terms used in this Privacy Policy have the meanings set out below. Where a term is not specifically defined here, it has the meaning given in the User Agreement.

1.1 Personal information means any information relating to an identified or identifiable natural person that is recorded electronically or otherwise, excluding information that has been anonymised. The categories of personal information that we actually collect are those described in this Privacy Policy.

1.2 Sensitive personal information means personal information that, if leaked or unlawfully used, may harm a natural person's human dignity or endanger their personal or property safety, or may lead to discriminatory treatment. It includes biometric information, financial account information and the personal information of children. The categories of sensitive personal information that we actually collect are those described in this Privacy Policy.

1.3 Device means any device that can be used to access or use the products and services, such as a computer, tablet or smartphone.

1.4 Unique device identifier means a string of characters encoded into a device by its manufacturer that can be used to identify that device uniquely.

1.5 IP address means the number assigned to every device connected to the internet, known as an Internet Protocol (IP) address.

1.6 Cookies means small files containing strings of characters that are sent to and stored on your computer, mobile device or other device when you sign in to and use a website or other online content, usually in encrypted form. Technologies similar to Cookies include web beacons, proxies and embedded scripts.

1.7 Account means the account that you successfully register in accordance with the User Agreement and applicable laws and regulations in order to use the products and services.

1.8 De-identification means the technical processing of personal information so that a specific natural person cannot be identified without the use of additional information. De-identified information remains personal information and we continue to protect it in accordance with this Privacy Policy.

1.9 Anonymisation means the technical processing of personal information so that the subject of the information can no longer be identified or associated and the processed information cannot be restored. Anonymised information is not personal information.

1.10 Linked Products means the desktop products that are accessed using the SeaBrains unified account, namely Sea Work, Sea Video, Sea Game, Sea Design and Sea Harness, together with any other desktop products that we subsequently bring within the unified account system.

2. How We Collect and Use Personal Information

We collect and use the personal information that you provide voluntarily in the course of using the services, or that arises from the needs of the products and/or services, in accordance with applicable law and on the principles of lawfulness, legitimacy and necessity. If we intend to use your personal information for a purpose not described in this Privacy Policy, or to use information collected for one specific purpose for another purpose, we will inform you promptly by reasonable means and obtain your consent again before doing so.

We collect and use two types of personal information. The first is information necessary for the core functions of the products and/or services. This information is required for the products and/or services to operate normally, and you must authorise us to collect it; if you refuse to provide it, you will not be able to use our products and/or services normally. The second is information that may be collected for additional functions. This information is not required for the core functions, and you may choose whether to authorise us to collect it; if you refuse to provide it, the additional functions may not be available or may not work as intended, but this will not affect your normal use of the core functions.

2.1 Account registration and sign-in

(a) When you register a SeaBrains Account you must follow our instructions to complete the registration process, and you must provide your email address and account password. We collect this information to identify you as a user and to keep your sign-in information. This information is required for you to register an Account and use the core functions; if you choose not to provide it, you will not be able to register or sign in.

(b) You may choose to provide a nickname and avatar, which are used to display your profile within the Linked Products. Not providing them does not affect your use of the core functions.

(c) The products and services do not currently support signing in with a third-party platform account. If this function is introduced later, we will obtain the relevant information within the scope shown on the third party's authorisation page and will inform you separately.

2.2 Identity verification

(a) To comply with applicable requirements on real identity verification, you must complete identity verification before using certain functions, including publishing content, topping up and making purchases.

(b) Identity verification involves your name, the type of identity document and the document number. This is sensitive personal information. We process it only with your separate consent, and only to identify you, to identify minor users, to meet our legal obligations and to keep your Account secure.

(c) We do not use identity verification information for any other purpose and do not provide it to any third party, except where required by law or with your separate consent.

2.3 Use of the products and services

(a) Device and operation information, including device model, operating system version, unique device identifier, sign-in IP address, device IP address, software version, process status and crash records. We collect this information to verify account information, keep the Account secure and diagnose and resolve faults. We may use your IP address to identify the region from which the device connects to the internet, for the purposes of certain activities and to meet necessary compliance requirements.

(b) Log information, including sign-in logs, top-up logs, conversion logs, consumption logs, order logs and other logs generated while you use the products and services. We collect this information for operational statistics and analysis, to handle customer complaints and to improve the service experience, and so that you can review your history in the client.

(c) Local file access on your device. In order to install and store files, read saved data and files (including necessary processes and caches, and reading, writing, downloading, saving and modifying images or files), the desktop client needs to access the corresponding directories on your device. If you refuse this authorisation, the relevant functions may not work normally.

(d) Content relating to intelligent features. When you use the artificial intelligence features of a Linked Product, we may collect and process the inputs that you voluntarily provide (such as text, images, video and other instructions and materials), in order to generate and return results to you, to review unlawful and harmful information, and to add labels to AI-generated content. If we need to use the relevant content for model training or optimisation, we will inform you separately in a prominent manner and obtain your separate consent.

2.4 Top-up and purchases

(a) When you use the top-up function we collect your top-up records, order number, balance and token movement records and the payment result returned by the payment channel, in order to complete top-ups, conversions and purchases, to provide order enquiries and to support dispute resolution if a transaction is disputed.

(b) Top-up and consumption records are sensitive personal information. We collect this information as it is necessary to provide the top-up and purchase functions; if you refuse to provide it you will not be able to complete the relevant transaction.

(c) The payment step is carried out by a licensed third-party payment institution. We do not collect or store sensitive payment instrument information such as your bank card number or payment account password; that information is processed by the payment institution under its own privacy policy.

2.5 Customer service

When you make a complaint, raise an appeal, make an enquiry or apply to close your Account, we may need you first to provide your account information and to match it against personal information you have previously provided, in order to verify your identity and to keep your Account and the system secure. To contact you and help resolve the issue we may also need your name, email address and other contact details. In addition we collect the records of your communications with us (including text, images, audio, video and call records) and other information necessary and relevant to your request. This information is sensitive personal information. We collect it to investigate the facts and help resolve your issue; if you refuse to provide it we may be unable to respond to your complaint, appeal or enquiry.

In order to understand user needs better and improve our services, our customer service staff may contact you by email or other means to ask about your use of the products or to conduct a follow-up. If you do not wish to receive such contact, please contact us in the manner set out in Clause 9 and we will stop contacting you by those means.

2.6 Notices and communications

We may notify you of changes relating to the products or services, including updates to the agreements, changes to functions and changes to service rules. We may also send you service updates and information about activities. Where we send you commercial information by email, telephone, SMS or other electronic means, we will provide a clear and convenient way to decline or unsubscribe; once you opt out we will stop sending it immediately.

2.7 Cookies and similar technologies

In order to improve the services we may use Cookies and similar technologies to store and, at certain times, track user-related data. This use is limited to estimating traffic volumes, analysing user preferences and similar commercial, market analysis or academic purposes. Cookies and similar technologies may be used by third parties; for example, advertising services may require identifiable data and materials as evaluation metrics and data. Such materials are used for analysis only, to evaluate and improve the effectiveness of advertising and other promotional activities for our products or services. You can manage or clear Cookies through your browser or client settings; refusing Cookies may prevent some functions from working normally.

2.8 Circumstances in which consent is not required

Under applicable law we may collect and use your personal information without your authorisation in the following circumstances:

(a) where necessary to perform our obligations under laws and regulations;

(b) where directly related to national security or national defence;

(d) where directly related to criminal investigation, prosecution, trial or the enforcement of judgments;

(e) where necessary to protect the life, health, property or other significant lawful rights and interests of you or another individual, and it is difficult to obtain that person's consent;

(f) where the personal information was made public by you, or where the information has otherwise been lawfully made public and is processed within a reasonable scope in accordance with law;

(g) where the personal information is collected from lawfully disclosed sources, such as lawful news reporting or government information disclosure;

(h) where necessary to enter into or perform a contract with you at your request;

(i) where necessary to maintain the secure and stable operation of the products or services, for example to detect and deal with faults;

(j) where necessary for lawful news reporting;

(k) where necessary for statistical or academic research in the public interest, provided that the results are de-identified when the results of the research are provided externally;

(l) other circumstances provided for by laws and regulations.

Please understand that the functions and services we provide are continuously updated and developed. If a function or service collects your information and is not described above, we will inform you separately through page prompts, interaction flows, website notices or other means of the content, scope and purpose of the collection, and will obtain your consent.

3. How We Share, Transfer and Publicly Disclose Your Personal Information

3.1 Sharing

We attach importance to protecting your personal information, which is an important basis for, and component of, the products and/or services we provide to you. We collect and use your personal information only within the purposes and scope described in this Privacy Policy, or as required by applicable law, and we keep it strictly confidential. As a general rule we do not share your personal information with any company, organisation or individual, except in the following circumstances:

(a) where we have your express authorisation or separate consent in advance;

(b) where sharing is required by applicable laws and regulations, legal process, a government order or a judicial decision;

(c) where it is necessary to provide your personal information to a third party, within the scope required or permitted by law, to protect the interests, property or safety of us, our users or the public from harm;

(d) sharing between Linked Products. To enable unified account sign-in and cross-product enquiry of Balance and orders, your account information and your Balance and order information may be shared among the Linked Products we operate. We share only the personal information necessary for those functions, and that sharing is subject to the purposes stated in this Privacy Policy. Where a Linked Product needs to change the purpose of processing, it will seek your authorisation and consent again;

(e) sharing with service providers. To provide you with more complete and higher quality products and services, some of our services are provided by authorised partners (including payment services, cloud services and customer services). We may share certain of your personal information with those partners. We share only for lawful, legitimate, necessary, specific and clearly defined purposes, and only the personal information necessary to provide the service. We require our partners to process your personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures. Our partners are not entitled to use the shared personal information for any other purpose. If you refuse to allow our partners to collect the personal information necessary to provide a service, you may not be able to use that third-party service.

Our partners collect and process information in accordance with their own privacy policies or related statements, which do not apply in place of this Privacy Policy. To protect your information as far as possible, we recommend that you review the privacy policy of any third-party service before using it. If you become aware of a risk in a third-party service, we recommend that you stop using it immediately and contact us promptly.

A list of the third parties with which we share information is published at 【Third-Party Sharing List Location】, setting out the name of each third party, the categories of personal information shared, the purpose of sharing and the manner of sharing. We will update the list promptly when it changes.

3.2 Transfer

We will not transfer your personal information to any company, organisation or individual, except in the following circumstances:

(a) transfer with your express consent;

(b) where transfer is required by applicable laws and regulations, legal process, or a mandatory administrative or judicial requirement;

(c) in connection with a merger, demerger, acquisition, transfer of assets, insolvency or similar transaction. Where personal information is transferred, we will inform you of the name and contact details of the recipient and require the company or organisation that holds your personal information to continue to be bound by this Privacy Policy; otherwise we will require it to seek your authorisation and consent again.

3.3 Public disclosure

We publicly disclose your personal information only in the following circumstances:

(a) with your express consent;

(b) disclosure required by law: where required by law, legal process, litigation or a mandatory requirement of a government authority.

3.4 Circumstances in which prior consent is not required

Under applicable law and national standards we may share, transfer or publicly disclose personal information without obtaining your prior authorisation in the following circumstances:

(a) where necessary to perform our obligations under laws and regulations;

(b) where directly related to national security or national defence;

(d) where directly related to criminal investigation, prosecution, trial or the enforcement of judgments;

(e) where necessary to protect the life, health, property or other significant lawful rights and interests of the subject of the personal information or another individual, and it is difficult to obtain that person's consent;

(f) where the personal information was made public by the subject;

(g) where the personal information is collected from lawfully disclosed sources, such as lawful news reporting or government information disclosure.

3.5 De-identified and anonymised data

Where we de-identify personal information, that information remains personal information and we continue to protect it in accordance with this Privacy Policy. Where personal information has been anonymised and the recipient is unable to restore or re-identify the subject, the sharing, transfer or public disclosure of that information is not treated as the sharing, transfer or public disclosure of personal information, and we may store and process that data without further notice to you or your consent.

4. How We Store and Protect Your Personal Information

4.1 Storage

(a) Place of storage. In accordance with applicable law, we store the personal information we collect in the location of the platform. Where it is necessary to transfer your personal information outside the jurisdiction in which it was collected, we will do so only after completing the transfer mechanism required by applicable law (such as a security assessment, the conclusion and filing of standard contractual clauses, or personal information protection certification), and after informing you separately in a prominent manner of the purpose of the transfer, the name and contact details of the recipient, the categories of personal information involved and how you may exercise your rights, and obtaining your separate consent.

(b) Storage period. We retain your personal information for the shortest period necessary to fulfil the purposes for which it was collected, and in any event for the period required by applicable law. For example, where you use the registration and top-up functions we need your email address and top-up records, and we retain them while you use those functions so that we can provide them normally and keep your Account and transactions secure. We may also retain relevant information for the minimum periods prescribed by law, such as network logs for at least six months and top-up and consumption records for at least 180 days.

4.2 Protection

(a) The security of your personal information is vital to us. We comply strictly with applicable law and take reasonable and practicable measures that are recognised in the industry to protect your personal information, to prevent unauthorised access, disclosure, use or modification, and to avoid damage to or loss of information.

(b) When we ask users to provide information relating to their personal identity, we disclose this Privacy Policy to them in advance in a clear and readily visible manner and take the necessary measures to protect their information.

(c) Except as expressly provided in this Privacy Policy or as required by applicable law, we will not provide, disclose or share with any third party the name, identity document number, contact details or other personal identity information contained in your registration data.

(d) We adopt technical and organisational measures including encryption, access control, permission management and security auditing, and we carry out grading, filing and assessment in accordance with applicable cybersecurity requirements.

4.3 Personal information protection officer and compliance audits

To safeguard the security of user accounts, we reserve the right to verify that the identity information provided during registration is authentic and valid, and to adopt appropriate technical and administrative measures to ensure the security and integrity of user accounts. Users are obligated to properly safeguard their accounts and passwords, and to use them correctly and securely. If either party fails to fulfill such obligations, resulting in the loss or theft of an account or password, and thereby causing damage to the civil rights of the affected user or any other person, that party shall bear the corresponding legal liabilities.

5. Your Rights in Relation to Your Personal Information

We understand your concerns about your personal information and we do our utmost to ensure that you can access, copy, rectify, supplement, delete and transfer your personal information, withdraw your consent and close your Account, so that you are fully able to protect your privacy and security. Your rights are as follows.

5.1 Right to access your personal information

You may access the personal information you have provided to us in accordance with the instructions or settings we provide, including:

(a) Account information: you can sign in to your profile page at any time to access your profile information within the products, including avatar, nickname and email address;

(b) Transaction information: you can check your top-up records, conversion records and consumption records on the order enquiry page;

(c) if you encounter operational difficulties, or need to obtain other personal information that you cannot access yourself, please contact us in the manner set out in Clause 9.

5.2 Right to rectify and supplement your personal information

If you find that the personal information you have provided to us is inaccurate, incomplete or out of date, you may contact us in the manner set out in Clause 9 and submit a request for rectification or supplementation.

(a) For some of your personal information, such as your avatar and nickname, we provide settings on the relevant function pages where you can make the correction or amendment directly;

(b) where you encounter difficulties in exercising the above rights, or where we are unable to provide an online self-service correction, you may contact us in the manner set out in Clause 9 and ask us to rectify or amend your data. After verifying your identity, and provided that the correction or amendment does not affect the objectivity and accuracy of the information, we may rectify or amend inaccurate or incomplete information, unless applicable law provides otherwise.

5.3 Right to delete your personal information

(a) For some of your personal information, you may contact us in the manner set out in Clause 9 and submit a deletion request. Once a deletion request is approved we will delete or anonymise that information, unless applicable law provides otherwise.

(b) You may ask us directly to delete your personal information in the following circumstances, unless the information has been anonymised or applicable law provides otherwise:

① our processing of the personal information breaches applicable law;

② we collected or used your personal information without your consent;

③ our processing of the personal information breaches our agreement with you;

④ you have closed your Account;

⑤ we have ceased the services or our operations;

⑥ you have withdrawn your consent and we have no other lawful basis for processing.

5.4 Right to withdraw your consent

As described above, some functions of the products and services require authorisation to use device permissions. You may withdraw (or stop) that authorisation at any time after granting it. You may also withdraw your consent to this Privacy Policy through the relevant function page within the products, or permanently withdraw all consent for us to continue collecting your personal information by closing your Account. You should understand that once you withdraw your consent we can no longer provide the specific function or service to which the withdrawal relates. However, your withdrawal does not affect the processing of personal information carried out previously on the basis of your consent.

5.5 Right to close your Account

You may contact us in the manner set out in Clause 9 to apply to close your Account. After you close your Account you will no longer be able to sign in to or use the products and services with that Account; unconsumed Balance in the Account will be dealt with in accordance with the User Agreement and the rules published on the top-up page; and the content, information, data and records under that Account will be deleted or anonymised (unless applicable law or a regulator requires otherwise). Once an Account is closed it cannot be restored.

5.6 Right to obtain a copy of your personal information and to request transfer

You have the right to contact us in the manner set out in Clause 9 to obtain a copy of your personal information. Where the conditions prescribed by applicable law are met, you may also request that we transfer your personal information to a personal information processor designated by you, and we will provide a means of transfer.

5.7 Right to an explanation of our processing rules

You have the right to ask us to explain this Privacy Policy and our rules for processing your personal information. You may contact us in the manner set out in Clause 9.

5.8 Responding to your requests

For security reasons we may ask you to submit your request in writing or to verify your identity in another way. We will process your request after verifying your identity and will respond within 15 business days from receipt of the email. We do not generally charge for reasonable requests; where a request is repetitive or exceeds reasonable limits we may charge a reasonable cost.

6. Protection of Minors

6.1 We attach great importance to the information security and protection of minors. We encourage parents and other guardians (each, a “guardian”) to guide minors in using our services. If you are a minor, please tell your guardian to read this Privacy Policy with you, and seek their consent and guidance before using the products and services or submitting personal information.

6.2 Where we collect a minor's personal information with a guardian's consent, we use or publicly disclose that information only where permitted by law, expressly agreed by the guardian, or necessary to protect the minor.

6.3 The personal information of a child below the minimum age specified by applicable law (for example, under 14 where the law of the People's Republic of China applies) is sensitive personal information. Where we process such information we obtain the consent of the child's parent or other guardian and apply dedicated personal information processing rules.

6.4 We conduct, ourselves or through a professional institution, an annual compliance audit of our processing of minors' personal information.

6.5 If you are the legal guardian of a minor, please monitor whether the minor uses the products and services after obtaining your consent. If a guardian expressly refuses to allow us to provide the services to a minor in the manner described above, we will promptly delete the personal information of that minor that we have collected, stored or used, in accordance with applicable law, and will stop providing services to that minor.

7. Suspension and Termination of Services

7.1 If a user publishes unlawful information, seriously offends public morals or engages in any other conduct prohibited by law, we are entitled to terminate the provision of services to that user immediately.

7.2 If a user engages in improper conduct while using the services, we are entitled to terminate the provision of services to that user.

7.3 After the services are suspended or terminated, we will delete or anonymise your personal information in accordance with Clause 4 once the statutory or agreed storage period expires.

8. Updates to and Access to this Privacy Policy

8.1 To provide you with better services, we will update the terms of this Privacy Policy in line with product updates and applicable legal requirements, and those updates form part of this Privacy Policy. We will not reduce the rights you enjoy under this Privacy Policy without your express consent. If an update materially reduces your rights under this Privacy Policy or constitutes a material change, we will notify you by prominent notice, by sending you a notification or by other means, and will obtain your consent again as required by applicable law.

8.2 Material changes include, but are not limited to:

(a) a material change in our service model, such as a change in the purpose of processing personal information, the categories of personal information processed, or the way in which personal information is used;

(b) a material change in our ownership structure or organisational structure, such as a change of owner resulting from business reorganisation, insolvency or merger;

(d) a material change in your rights in relation to the processing of personal information, or in the way those rights are exercised;

(e) a change in the contact details of the personnel responsible for the security of personal information processing or in the complaints channel;

(f) a personal information security impact assessment indicating a high level of risk.

8.3 You may access the content of this Privacy Policy through the relevant function pages of the products and through our official website. If you have any questions about that access, please contact us in the manner set out in Clause 9.

8.4 We retain previous versions of this Privacy Policy. You may ask to review the previous versions.

9. Contact Us

9.1 If you have any questions about the content of this Privacy Policy, or about any matter relating to the protection of personal information that you encounter when using our services, or if you wish to make an enquiry or complaint, you may contact us by any of the following means:

a) You may submit feedback via the relevant feature pages within the product, or contact us at [customer@seabrains.ai];

b) You may also send an email to [legal@seabrains.ai]

9.2 After receiving your comments and suggestions and verifying your identity, we will respond within 15 business days from receipt of the email. In special or complex cases our response time may be extended accordingly. You also understand and are aware that we may be unable to respond to your request in the following circumstances:

(a) where it relates to national security or national defence;

(b) where it relates to public security, public health or significant public interest;

(d) where there is sufficient evidence that you are acting in bad faith or abusing your rights;

(e) where responding to your request would seriously harm the lawful rights and interests of you or another individual or organisation;

(f) where it involves trade secrets;

(g) other circumstances provided for by laws and regulations.

9.3 If you are not satisfied with our response, or consider that our processing of personal information has harmed your lawful rights and interests, you may also complain to the competent authority responsible for personal information protection, or bring proceedings before a court with jurisdiction.