Effective Date: September 27, 2025
Governing Laws: Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable federal, provincial, and territorial privacy legislation.
Customer Support Contact: Email: sogunhyahe23er32@zohomail.com
1. Agreement Preamble
1.1 This Agreement aims to clearly define the rules by which Sogun (hereinafter referred to as "the Platform") collects, uses, stores, and protects users' personal information. It is designed to safeguard users' privacy rights and comply with Canadian privacy protection laws, as well as principles for the responsible use of generative Artificial Intelligence (AI).
1.2 By registering, logging in, or using the services provided by the Platform, you indicate that you have read, understood, and agree to all terms of this Agreement. If you do not agree, you must immediately cease using the Platform.
2. Key Definitions
2.1 Personal Information: Refers to information or data about an identifiable individual, including but not limited to name, contact details, account information, interview records, video call content, posted content, etc., consistent with the definition of "personal information" under PIPEDA.
2.2 Local Storage: Refers to the storage method where user personal information is stored solely on the user's own device (e.g., smartphone, tablet) locally and is not transmitted to the Platform's external servers.
2.3 Generative AI Functionality: Refers to the Platform's AI-powered interview simulation feature, which uses algorithms to generate interview questions, feedback, and other content as an intelligent service.
2.4 Anonymized/De-identified Data: Data that has been processed to remove or alter personal identifiers so that the remaining information cannot reasonably be used to identify an individual, either on its own or in combination with other information.
3. Collection of Personal Information
3.1 Scope of Collection
3.1.1 Account Registration Information: Information you actively provide, such as name, email address, phone number, and professional details, used for account creation and identity verification.
3.1.2 Function Usage Data:
* AI Interview Simulation: Your audio/video recordings, text responses, and interaction logs, used to generate personalized questions and feedback.
* Video Calls: Call content (stored only if you initiate local recording) and technical data like call duration.
* Content Sharing: Text, images, videos you publish, along with interaction records (likes, comments).
* Device Information: Device model, operating system version, local storage permission status, used to ensure feature compatibility and security.
3.1.3 Other Information: Information you voluntarily provide to customer support, such as inquiries or feedback.
3.2 Methods of Collection
3.2.1 Active Provision: Information you directly input (e.g., during registration, posting content, submitting feedback).
3.2.2 Automatic Collection during Use: Information collected automatically during the use of specific features (e.g., AI interview recording, call technical data), always contingent upon obtaining your explicit prior authorization (e.g., via device permissions).
3.2.3 No Scraping: The Platform does not scrape or collect publicly accessible personal information for AI training or any other purpose.
4. Use of Personal Information
4.1 Purposes of Use
4.1.1 Core Service Delivery: To manage your account, operate the AI interview simulation, support video call functionality, display shared content, and provide the core services you request.
4.1.2 Service Optimization: To analyze aggregated, anonymized, and de-identified data (which cannot be linked back to you) to understand usage patterns, improve service stability, performance, and user experience.
4.1.3 Compliance and Security: To identify, prevent, and address fraudulent, unauthorized, or illegal activities, security risks, and to comply with applicable laws, regulations, or legal processes.
4.1.4 Communication: To respond to your inquiries, complaints, and provide necessary service-related notices (non-marketing communications).
4.2 Rules for Use
4.2.1 Purpose Limitation: We adhere strictly to the principle of purpose limitation. Personal information is used only for the purposes specified in this Agreement. Any use beyond these original purposes will require your separate, explicit consent.
4.2.2 AI-Generated Content: Outputs from the AI interview simulation (questions, feedback) are generated based solely on your inputs and generic models. They do not incorporate or reveal other users' personal information. AI-generated content will be clearly identified as such.
4.2.3 Protection of Vulnerable Groups: If the Platform detects usage by a minor, it may limit the professional scenarios available within the AI interview simulation and provide enhanced prompts regarding parental guidance to mitigate potential risks.
5. Storage and Protection of Personal Information
5.1 Storage Method and Retention Period
5.1.1 Local Storage: All personal information is stored locally on your device. The Platform's servers do not store any user personal information.
5.1.2 User-Controlled Retention: You control the storage duration. You can delete AI interview records, call recordings, posted content, etc., at any time via the Platform's functions or device settings. Upon account deletion, any personal information stored locally on your device remains under your control for retention or deletion.
5.1.3 Anonymized Data: Anonymized and de-identified data used for service optimization may be retained indefinitely on our servers, as it is no longer considered personal information.
5.2 Security Safeguards
5.2.1 Technical Measures: Utilization of encryption technologies to protect sensitive information (like account passwords) stored locally on your device against unauthorized access.
5.2.2 Access Permissions: Access to local storage, microphone, camera, etc., is strictly controlled by your device permissions. Relevant functions cease access immediately when permissions are revoked.
5.2.3 Internal Management: Platform developers and operational personnel are subject to strict access controls and contractual confidentiality obligations. They have no technical means or authorization to access information stored locally on your device.
5.2.4 Security Testing: Regular security and adversarial testing of AI functionalities is conducted to identify and mitigate potential information leakage risks.
6. Disclosure and Transfer of Personal Information
6.1 General Non-Disclosure: We do not disclose or share your personal information with any third parties (including affiliates or partners), except in the following limited circumstances:
* With your explicit, prior written consent.
* In response to a lawful subpoena, court order, or other legal obligation, wherein we will endeavor to notify you beforehand unless legally prohibited.
* When necessary to protect the rights, property, or safety of the Platform, our users, or the public from imminent and serious harm, and where no less intrusive means are available.
6.2 No Cross-Border Transfer: Due to the local storage architecture, your personal information remains within the jurisdiction of the device you use to access the Platform. No cross-border transfer of personal information occurs.
7. Your Rights (Under PIPEDA)
In accordance with PIPEDA and related regulations, you have the following rights regarding your personal information:
7.1 Right to Access: You can view a summary of the personal information stored locally on your device through the "My Account - Personal Information" section within the Platform.
7.2 Right to Correction: You can correct inaccuracies in your account registration information or profile data directly within the Platform, or contact customer support for assistance.
7.3 Right to Deletion: You can permanently delete your AI interview records, posted content, call recordings, etc. Once deleted, this information cannot be recovered.
7.4 Right to Withdraw Consent: You can withdraw consent for the collection or use of specific information types by disabling relevant permissions (e.g., storage, microphone) in your device settings. Withdrawing consent may render certain Platform functions unusable but will not affect other services.
7.5 Right to Complain: If you believe your privacy rights have been violated, you may file a complaint via our customer support email. We commit to investigating and responding to the outcome of your complaint within 15 business days.
8. Data Breach Protocol
8.1 Local Storage Implication: Given the local storage model, there is no risk of a data breach from the Platform's servers. If personal information is compromised due to device loss, theft, unauthorized access to your device, or other reasons beyond the Platform's direct control, we may, upon request, provide technical guidance but cannot assume direct liability.
8.2 Platform-Related Security Incidents: In the unlikely event of a security incident related to a Platform vulnerability that poses a real risk of significant harm to an individual, we will immediately activate our incident response plan. This includes notifying affected individuals via the contact information provided, reporting the incident to the Office of the Privacy Commissioner of Canada (OPC) as required by law, and retaining related records for a minimum of 6 years.
9. Agreement Updates and Modifications
9.1 We will notify you of any material updates to this Agreement through prominent notices on the Platform's homepage, in-app messages, or via email. The updated terms will become effective 15 days after the notification is issued.
9.2 If you disagree with the updated terms, you must discontinue using the Platform. Continued use of the Platform after the effective date constitutes your acceptance of the revised Agreement.
10. Miscellaneous
10.1 Matters not covered in this Agreement shall be governed by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant provincial/territorial privacy laws.
10.2 Any disputes between you and the Platform regarding privacy matters shall first be attempted to be resolved through negotiation via the customer support email. If negotiation fails, you may lodge a complaint with the Office of the Privacy Commissioner of Canada or the relevant provincial/territorial privacy authority, or seek recourse in a court of competent jurisdiction.