Effective Date: [2026-06-02] 

Last Updated: [2026-06-02]

This Privacy Policy explains how Axiox Media Technology Limited (“U37”, “we”, “us”, or “our”) collects, uses, discloses, and protects your personal data when you access or use the U37 platform, website, applications, and related services (collectively, the “Services”).

By using the Services, you consent to the collection and processing of your personal data as described in this Privacy Policy.

1. Who We Are

U37 is operated by Axiox Media Technology Limited, a company incorporated in Hong Kong. We are the data user responsible for your personal data under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”).

This Privacy Policy applies to all current features of the Services and will apply to future features we may introduce, including but not limited to AI-assisted tools, creator monetization programs, and additional marketplace functionalities.

2. Information We Collect

We collect personal data in the following ways:

a. Information You Provide Directly

• Account information (username, email address, password, profile details)
• User Content you upload or create, including text, images, JSON scene files, descriptions, and any other materials submitted through the Services
• Communications you send to us (support requests, feedback, reports)
• Information provided when participating in creator or monetization programs (when available), such as payment details and tax information

b. Information Collected Automatically

• Device and usage information (IP address, browser type, operating system, device identifiers, referring URLs, pages viewed, and interaction data)
• Log data and analytics
• Cookies and similar tracking technologies (see Section 6)

c. Information from Third Parties

• Information from service providers, payment processors, or analytics partners
• Publicly available information or information you authorize us to receive from third parties

d. Future Features We may collect additional categories of personal data as we introduce new features (for example, AI-generated content inputs, voice data, or enhanced creator analytics). We will update this Privacy Policy or provide specific notices where appropriate.

3. How We Use Your Personal Data

We use your personal data for the following purposes:

• To provide, operate, maintain, and improve the Services
• To enable social features, content sharing, and community interactions
• To operate the marketplace and process transactions (when monetization features are available)
• To provide and improve AI-assisted features and tools (when introduced)
• To personalize your experience and recommend content
• To ensure platform safety, prevent fraud, enforce our Terms of Service, and moderate content
• To communicate with you about the Services, updates, and support
• To comply with legal obligations and respond to lawful requests
• For analytics, research, and business development
• Any other purpose disclosed to you at the time of collection or with your consent

We process personal data only for purposes that are lawful and directly related to our functions and activities, in accordance with the PDPO.

4. Legal Bases for Processing

We rely on the following bases under the PDPO and applicable laws:

• Your consent (where required, e.g., for direct marketing or certain AI features)
• Performance of a contract with you
• Our legitimate interests (e.g., improving the Services, safety, and platform operation), provided these do not override your rights and interests
• Compliance with legal obligations

5. How We Share Your Personal Data

We may share your personal data with:

• Service Providers: Companies that provide hosting, analytics, payment processing, customer support, or other services on our behalf (they are contractually required to protect your data).
• Other Users: User Content you upload (including JSON files and profile information you make public) may be visible to other users according to your settings and platform rules.
• Legal and Safety Reasons: When required by law, to protect rights and safety, or in connection with legal proceedings.
• Business Transfers: In connection with a merger, acquisition, or sale of assets.
• With Your Consent: When you explicitly agree to sharing.

We do not sell your personal data for monetary gain.

6. Cookies and Similar Technologies

We use cookies and similar technologies to operate the Services, remember preferences, analyze usage, and improve performance. You can manage cookie preferences through your browser settings. Some features may not function properly if cookies are disabled.

7. Data Retention

We retain your personal data for as long as necessary to provide the Services, fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

When you delete your account, we will delete or anonymize your personal data within a reasonable time, except where we are required to retain it (for example, for legal, safety, or accounting reasons) or where User Content remains on the platform due to licenses granted under our Terms of Service.

8. Your Rights

Under the PDPO, you have the right to:

• Request access to your personal data we hold
• Request correction of inaccurate or incomplete data
• Withdraw consent (where processing is based on consent)
• Object to certain processing in some circumstances

To exercise these rights, please contact us using the details below. We may require verification of your identity before responding. We will respond within the timeframes required by law.

Please note that some rights may be limited (for example, we may retain certain data for legal or safety reasons, and deleted content may still exist in backups or due to licensing rights granted to U37).

9. International Data Transfers

Your personal data may be transferred to and processed in countries outside Hong Kong (for example, by our service providers). We take appropriate steps to ensure that such transfers comply with the PDPO and that your data receives an adequate level of protection.

10. Security

We implement reasonable technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission or storage is completely secure. You are responsible for keeping your account credentials confidential.

11. Children’s Privacy

The Services are not directed to children under 18. We do not knowingly collect personal data from children under 18. If you believe we have collected such data, please contact us so we can take appropriate action.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, new features, or legal requirements. We will post the updated version on the platform with a new “Last Updated” date. Your continued use of the Services after changes take effect constitutes acceptance of the revised Policy.