Privacy Policy for TuTuTalk

Effective date: May 19, 2026 · Last updated: May 19, 2026

This Privacy Policy explains how TuTuTalk ("TuTuTalk", "we", "us", or "our") collects, uses, shares, and protects information when you use the TuTuTalk mobile application (the "App") available on Google Play and the Apple App Store in the United States and Canada.

By using TuTuTalk, you agree to this Policy. If you do not agree, please do not use the App.

1. Who we are

TuTuTalk is the developer and operator of the App and is the data controller responsible for the personal information described below.

Contact for privacy questions: edward_wa@163.com

2. Summary (at a glance)

TuTuTalk lets you create AI-generated avatars from selfies and have real-time audio/video sessions with those avatars.
To do that, we process your photos and microphone audio.
We do not sell your personal information, and we do not use your selfies or voice to train third-party AI foundation models.
Some processing happens on third-party infrastructure (Google Firebase / Google Cloud, LiveKit, and our AI avatar generation provider). These providers act as our service providers / processors.
You can delete your content and request deletion of your data at any time by emailing the address above.

3. Information we collect

3.1 Information you provide

Photos / selfies you capture with the camera or choose from your photo library and upload to TuTuTalk to generate an avatar.
Microphone audio captured during a live avatar session.
Generated avatar media (images and videos) produced from your inputs.
Any messages, prompts, or other content you submit in the App.
Correspondence you send to our support email.

3.2 What we do not collect

We do not collect your name, email address, phone number, or precise location unless you voluntarily provide it (for example, when contacting support).
We do not access your contacts, calendar, SMS, or files outside of the photos you select.
We do not use advertising identifiers or run third-party advertising or analytics SDKs that track you across other apps.

4. How we use information

Purpose	Categories used	Legal basis (where applicable)
Generate avatars from your selfies	Photos, generated media	Performance of the service you requested
Run real-time audio/video avatar sessions	Microphone audio, network metadata	Performance of the service you requested
Operate, secure, and debug the App	Device, network, usage, crash logs	Our legitimate interest in a working, secure App
Respond to support requests	Information you include in your message	Performance of the service / our legitimate interest
Comply with law and enforce our terms	As needed	Legal obligation / legitimate interest

We do not: sell your personal information, "share" it for cross-context behavioral advertising (as defined under U.S. state privacy laws), or use your photos or voice to train third-party AI foundation models.

5. Permissions we request

Permission	Why	Required?
Camera	To capture a selfie and (optionally) provide live video in a session.	Optional — you can pick an image from your library instead.
Photo library	To let you choose a selfie to upload.	Optional — you can use the camera instead.
Microphone	To capture your voice during a live avatar session.	Required for voice sessions.
Network / Internet	To communicate with our backend and the real-time-communication service.	Required.
Bluetooth (Android, legacy)	To route audio through Bluetooth headsets on older Android versions.	Optional.

You can revoke any permission at any time in your device's system settings; some features will stop working without the corresponding permission.

6. How and where data is processed

TuTuTalk uses the following service providers ("processors") to operate the App. They process your information only on our instructions and only for the purposes described in this Policy.

Provider	Role	What they process
Google Firebase / Google Cloud (Cloud Storage, Cloud Functions)	Backend, storage, server-side recording bucket	Uploaded selfies, generated avatar preview videos. Privacy.
LiveKit, Inc.	Real-time audio/video transport	Microphone audio, connection/IP metadata during a live session. Privacy.
AI avatar generation provider (e.g., LemonSlice)	Generates avatar media from your selfie and prompt	The selfie you upload and the prompt parameters needed to generate the output. Inputs are used to produce your output and are not used by us to train third-party foundation models.

TuTuTalk and its processors operate servers primarily in the United States. We rely on industry-standard contractual safeguards with our processors.

7. Data retention

Uploaded selfies and generated avatars: retained while your account / device session is active so you can re-use them in the App. You can delete them in-App or by contacting us. We will delete them within 30 days of your verified deletion request, except where we need to retain a copy for legal reasons (e.g., fraud investigation).
Live session audio/video: streamed in real time. We do not retain a copy of a live session unless server-side recording is enabled for that session; if recorded, the recording is stored in our Google Cloud Storage bucket and is deleted on the same schedule as your other content.
Logs and crash data: retained for up to 90 days for debugging and security.

8. Security

We use commercially reasonable safeguards to protect your information, including TLS encryption in transit, access controls on our backend, and storage on reputable cloud providers. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. Children's privacy (COPPA / mixed audience)

TuTuTalk is a mixed-audience app under Google Play's Families policy. We do not direct the App primarily to children, and we do not knowingly collect personal information from children under 13 without verifiable parental consent.

We do not use third-party advertising SDKs or behavioral advertising in the App.
We do not use children's selfies, voice, or video to train third-party AI foundation models.
Children under 13 should not provide personal information, upload selfies, or use the microphone in the App without a parent or guardian's permission.
If you are a parent or guardian and believe that your child under 13 has provided personal information to us, please contact edward_wa@163.com. We will delete the information promptly and terminate the child's session.

For more about COPPA, see the U.S. Federal Trade Commission's Children's Privacy resources.

10. Your rights

10.1 United States

Depending on the U.S. state you live in (for example California, Colorado, Connecticut, Utah, Virginia, Texas, Oregon), you may have the right to:

Know what personal information we have about you;
Request access to or a copy of that information;
Request correction or deletion;
Opt out of "sale" or "sharing" for cross-context behavioral advertising — we do neither;
Not receive discriminatory treatment for exercising your rights.

To exercise any of these rights, email edward_wa@163.com. We will verify your request (typically by replying from the address you contacted us from and asking you to confirm details of your use) and respond within the timeframes required by law (generally 45 days).

10.2 Canada (PIPEDA)

If you reside in Canada, you have the right under the Personal Information Protection and Electronic Documents Act (PIPEDA), and any applicable provincial law (such as Quebec's Law 25), to access and correct your personal information, to withdraw consent, and to lodge a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.

11. How to delete your data

You can request deletion of your uploaded selfies, generated avatars, and session data at any time:

In-App: delete individual items where the option is available, or uninstall the App to stop further data collection from your device.
By email: send a deletion request to edward_wa@163.com from the device/account you used in the App. We will action verified requests within 30 days.

12. Third-party links and content

The App may contain links to third-party websites or services. We are not responsible for their privacy practices. Review their policies before providing them information.

13. Changes to this Policy

We may update this Policy from time to time. When we do, we will update the "Last updated" date above and, if the changes are material, we will provide a more prominent notice in the App. Your continued use of the App after the new Policy takes effect constitutes your acceptance of the updated Policy.

14. Contact

For any questions, requests, or complaints about this Policy or our handling of your information, please contact:

TuTuTalk
Email: edward_wa@163.com