Privacy Policy

Shakespeare App — United States

Last Updated: September 10, 2026

Effective Date: September 10, 2026

Important: This Privacy Policy explains how “Hangzhou Lingxi Exploration Technology Co., Ltd.”) (“Shakespeare,” “we,” “us,” or “our”) collects, uses, discloses, stores, and protects personal information when you use the U.S. version of the Shakespeare mobile application, connected smart jewelry, customer support, websites, and related services (collectively, the “Services”).

The Services process health and wellness information that may be considered sensitive personal information or consumer health data under U.S. law.

1. Scope

This Policy applies to the U.S. version of the Shakespeare Services. It does not apply to third-party websites, app stores, or services that operate under their own privacy policies.

The Shakespeare Services are consumer wellness and lifestyle services. We are not acting as your healthcare provider, health plan, or healthcare clearinghouse, and use of the Services does not by itself create a relationship governed by the U.S. Health Insurance Portability and Accountability Act (“HIPAA”).

2. Information We Collect

CategoryExamplesPurpose
Account and profile information Email address, account identifier, nickname, avatar, date of birth or age, gender, height, weight, language/region settings, and information made available through Apple or Google sign-in when you choose those methods. Create and secure your account, personalize the Services, and provide support.
Connected-device information Ring or device identifier, model, firmware version, battery status, Bluetooth connection status, device binding information, settings, and synchronization status. Pair, operate, synchronize, troubleshoot, and support Shakespeare smart jewelry.
Health and wellness information Depending on the device and features you use: heart rate, heart-rate variability (HRV), blood oxygen, stress-related indicators, sleep duration, sleep stages, activity, steps, distance, calories, temperature-related trends, vitality/energy/recovery-related scores, wellness reports, and related trends or inferences. Provide wellness measurements, summaries, trends, scores, reports, insights, and device functionality.
Women’s wellness information Menstrual-cycle dates and other information you enter or generate through cycle-related features, including estimates relating to cycle phases or fertile windows. Provide optional women’s wellness features and related estimates.
AI and conversation information Questions, prompts, AI conversation history, AI-generated responses, relevant profile information, and selected health or wellness data used to provide personalized AI features. Provide AI assistant functionality, personalized summaries, suggestions, reports, and related experiences.
Relationship and user content Couple or relationship-space bindings, profile content, messages, interaction records, and content you choose to share through supported relationship features. Provide pairing, relationship, sharing, and interaction features.
Technical and service information IP address, device model, operating system, App version, language, network status, server logs, crash or error information, synchronization logs, and security-related events. Operate, secure, diagnose, and improve the Services.
Customer support information Support emails, feedback, troubleshooting information, account/device details you provide, and communications with customer support. Respond to requests, investigate problems, and improve service quality.

We do not currently require Social Security numbers, government identification numbers, payment-card credentials, or precise geolocation to provide the core U.S. App experience.

3. Sources of Information

We collect information from:

  • you directly, including information you enter into the App;
  • your paired Shakespeare smart jewelry;
  • the App and our systems when you use the Services;
  • Apple or Google when you choose their account sign-in services;
  • technology providers that process data on our behalf; and
  • calculations, algorithms, or AI systems that generate wellness trends, scores, reports, or inferences from permitted data.

The current U.S. version does not integrate with Apple Health/HealthKit or Google Health Connect.

4. How We Use Personal Information

We use personal information to:

  • create, authenticate, maintain, and secure user accounts;
  • pair and operate connected smart jewelry and synchronize device data;
  • display health and wellness measurements, trends, sleep summaries, activity information, and related reports;
  • calculate vitality, energy, recovery, stress-related, or similar wellness indicators;
  • provide women’s wellness, breathing, mindfulness, sleep-aid, relationship, and other requested features;
  • provide AI-powered questions and answers, personalized summaries, suggestions, and narrative insights;
  • respond to customer service, account, product, and privacy requests;
  • diagnose bugs, connection failures, synchronization failures, crashes, security risks, or other technical problems;
  • protect the Services, users, devices, and accounts against fraud, abuse, unauthorized access, or unlawful activity;
  • comply with applicable law and lawful legal requests; and
  • create aggregated or de-identified information that is not reasonably linkable to an individual.

We do not use health or wellness information to make decisions about eligibility for employment, insurance, housing, credit, education, or other similarly significant opportunities.

5. Health and Wellness Information

Health and wellness information is treated as sensitive information. Depending on applicable law, it may also qualify as “consumer health data” or “sensitive personal information.”

We process health and wellness information to provide the features you request, including device measurements, sleep and activity summaries, trend analysis, wellness scores, reports, women’s wellness features, and personalized AI-powered functions.

We do not sell consumer health data. We do not use consumer health data for cross-context behavioral advertising or to build advertising profiles based on your health condition, sleep, reproductive health, stress, or other wellness information.

We do not use health signals as biometric identifiers for the purpose of uniquely identifying you.

6. AI Features and Baidu AI Cloud Qianfan / DeepSeek

The Shakespeare App currently accesses DeepSeek model capabilities through the Baidu AI Cloud Qianfan platform for certain AI-powered features.

When you use an AI feature that requires personalized wellness context, we may transmit the following information to the Qianfan platform for processing:

  • your prompt, question, or request;
  • relevant AI conversation context;
  • selected profile information where needed for personalization; and
  • selected health and wellness data, summaries, or trends necessary to generate the requested result.

We seek to limit information sent to the AI service to what is reasonably necessary for the requested function. We do not intentionally send unrelated information when it is not needed for the AI feature.

The exact physical location at which the AI service provider processes a particular request may depend on the provider’s infrastructure and service configuration. Accordingly, AI-related data may be processed outside the United States. We do not represent that AI processing is confined exclusively to U.S. data centers.

If we replace the AI provider or materially change the categories of health information used by the AI service, we will update our disclosures and obtain additional consent where required by applicable law.

7. Device Permissions

Depending on your device, operating system, and feature choices, the App may request permissions such as:

  • Bluetooth / Nearby Devices: to discover, pair, communicate with, and synchronize smart jewelry;
  • Notifications: to provide service, device, account, firmware, or feature notifications;
  • Camera: when you choose a function requiring image capture or QR-code scanning;
  • Photos / Media: when you choose to upload or save an avatar or supported content; and
  • Network access: to communicate with our servers and provide online features.

You can manage permissions through your device settings. If you disable a required permission, the associated feature may no longer function.

8. How We Disclose Personal Information

We may disclose personal information only as reasonably necessary for the purposes described in this Policy, including to:

  • processors and service providers that provide cloud hosting, connected-device technology, AI processing, security, technical support, or related infrastructure;
  • authorized personnel who require access to operate, maintain, secure, troubleshoot, or support the Services;
  • another user at your direction when you deliberately use relationship, pairing, or sharing features;
  • professional advisers or authorities where reasonably necessary to comply with law, respond to lawful requests, protect rights or safety, investigate security incidents, or establish or defend legal claims; and
  • a successor organization in connection with a merger, acquisition, restructuring, financing, bankruptcy, or sale of all or part of the business, subject to applicable law.

9. Current Service Providers and Technology Partners

Provider / TechnologyPurposeInformation Involved
BravechipSpace / ChipletRing App SDK
Yongxin Technology
Connected-device communication and operation. Device information and device-generated measurements needed to operate supported smart jewelry, including heart rate, HRV, blood oxygen, stress-related indicators, sleep, sleep-stage data, and other supported ring measurements.
Alibaba Cloud International — Silicon Valley, United States Primary U.S. application hosting, databases, storage, backend services, and system operations. Account, profile, device, health and wellness, AI conversation history, relationship-space content, and technical/service data required to provide the Services.
Baidu AI Cloud Qianfan — DeepSeek model service Provide AI-powered responses, summaries, suggestions, wellness interpretations, and related functions. Prompts, relevant conversation context, and selected profile and health/wellness information necessary for the AI feature being used.
Apple / Google Optional account authentication and app-platform services. Authentication tokens and account information made available under the sign-in method you choose.

The current U.S. version of the Shakespeare App does not currently use the Umeng analytics SDK. If we later introduce Umeng or another analytics SDK, we will complete the required technical and privacy review and update this Policy before using it to collect additional personal information where required.

10. Sale, Sharing, Advertising and Profiling

We do not sell personal information or consumer health data for monetary consideration.

We do not currently use health and wellness information for cross-context behavioral advertising, targeted advertising based on activity across unrelated businesses, or advertising profiles based on your health condition, sleep, reproductive health, stress, or similar wellness information.

The current U.S. App does not contain third-party advertising and does not currently use Umeng for U.S. App analytics.

If these practices change, we will update this Policy and provide any notice, opt-out, consent, or authorization mechanism required by applicable law before the new practice begins.

11. Data Storage and International Processing

Our primary U.S. application environment and databases are hosted using Alibaba Cloud International in the Silicon Valley region of the United States.

However, some processing or access may occur outside the United States. For example:

  • selected information sent to Baidu AI Cloud Qianfan for DeepSeek-powered AI features may be processed outside the United States depending on the provider’s infrastructure and service configuration; and
  • authorized personnel located outside the United States, including in China, may remotely access U.S.-hosted systems when reasonably necessary for service operation, technical support, troubleshooting, security, maintenance, or incident response.

We limit operational access based on job responsibilities and business need and use access controls, confidentiality requirements, and security measures designed to protect personal information.

12. Retention and Account Deletion

We retain personal information for as long as reasonably necessary to provide the Services, maintain service and account security, resolve disputes, comply with applicable law, and support legitimate operational needs consistent with this Policy.

When account deletion is completed, we delete health and wellness information associated with the account and delete or de-identify other account-associated personal information that is no longer required for lawful security, fraud-prevention, dispute, or legal purposes.

Information stored in backups may remain temporarily until the relevant backup is overwritten or deleted. Where applicable consumer-health-data law requires a specific deletion deadline, we follow that deadline. For example, where Washington law applies, deletion from archived or backup systems may be delayed only for the period allowed by that law.

13. Security and Health-Data Breach Response

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including access controls, encryption in transit, need-to-know access restrictions, logging, monitoring, and confidentiality obligations.

No system can guarantee absolute security. If a security incident occurs, we will investigate and provide notices to affected individuals, regulators, or other parties when required by applicable U.S. law, including the Federal Trade Commission’s Health Breach Notification Rule where applicable.

14. Your U.S. Privacy Rights

Depending on the state where you live and the law that applies to us, you may have rights to:

  • confirm whether we process your personal information;
  • access personal information we maintain about you;
  • correct inaccurate personal information;
  • delete personal information;
  • obtain a portable copy of certain information;
  • withdraw consent to certain processing;
  • opt out of certain sale, sharing, targeted advertising, or profiling practices where applicable;
  • limit certain uses of sensitive personal information where applicable;
  • appeal certain denials of privacy requests where state law provides an appeal right; and
  • exercise applicable rights without unlawful discrimination.

To exercise a privacy right, use available in-App account or privacy controls or email support@shakespearelife.com.

We may take reasonable steps to verify your identity before completing a request. We will respond within the timeframe required by applicable law.

15. California Privacy Notice

This section supplements the rest of this Policy for California residents to the extent the California Consumer Privacy Act, as amended (“CCPA”), applies to us.

The categories of personal information we may collect are described in Section 2 and may include identifiers, account/profile information, internet or electronic-network activity, user content, inferences, and personal information collected and analyzed concerning health. Health information may constitute sensitive personal information under California law.

We collect and use these categories for the purposes described in Section 4 and disclose them to the categories of recipients described in Sections 8 and 9.

We do not currently sell personal information or share personal information for cross-context behavioral advertising. We do not use sensitive health information to infer characteristics for unrelated advertising purposes.

Where the CCPA applies, California residents may have rights to know/access, delete, correct, opt out of sale or sharing, limit certain uses of sensitive personal information, and receive non-discriminatory treatment for exercising applicable rights.

16. Consumer Health Data Privacy Notice

This section supplements the rest of this Policy and is intended to provide disclosures concerning “consumer health data” under applicable U.S. state laws, including the Washington My Health My Data Act and Nevada consumer health data law.

16.1 Categories of Consumer Health Data We Collect

Depending on the Services you use, consumer health data may include heart rate, HRV, blood oxygen, stress-related indicators, sleep and sleep stages, activity information, steps, distance, calories, temperature-related trends, women’s wellness and reproductive-health-related information, vitality/energy/recovery-related scores, and health-related trends or inferences generated from these data.

16.2 Sources

We obtain consumer health data from you, your paired Shakespeare smart jewelry, the connected-device technology used to operate the product, and our own calculations, algorithms, and AI-assisted processing based on permitted data.

16.3 Purposes

We collect and use consumer health data to provide device and App functions requested by you, synchronize and display measurements, calculate trends and wellness scores, provide sleep and activity summaries, provide women’s wellness features, generate reports and insights, personalize AI features you choose to use, troubleshoot service quality, and maintain the reliability and security of the Services.

16.4 Consumer Health Data Processed by Service Providers

We may make consumer health data available to processors where reasonably necessary to provide a requested Service, including:

  • the connected-device technology provider for ring/device functionality;
  • Alibaba Cloud International for U.S. application hosting and storage; and
  • Baidu AI Cloud Qianfan when you use an AI feature that requires selected health or wellness context to generate the requested result using a DeepSeek model.

We do not currently provide consumer health data to Umeng because the U.S. App does not currently use the Umeng analytics SDK.

16.5 Other Sharing

We may disclose consumer health data to another user when you deliberately choose to share it through a supported relationship feature. We may also disclose information where required by law or when reasonably necessary to protect rights, safety, security, or the Services.

16.6 Sale of Consumer Health Data

We do not sell consumer health data. If we ever propose to sell consumer health data, we will provide the separate authorization required by applicable law before doing so.

16.7 Your Consumer Health Data Rights

Where applicable law provides these rights, you may request confirmation of whether we collect, share, or sell consumer health data concerning you; access the data; obtain information about recipients; withdraw consent to future collection or sharing; and request deletion.

Submit a request through available in-App controls or email support@shakespearelife.com.

If a request is denied and applicable law provides an appeal right, you may appeal by replying to our decision or emailing the address above with the subject line “Consumer Health Data Appeal.”

16.8 Deletion

When applicable law requires us to honor a consumer health data deletion request, we will delete covered consumer health data from our records and instruct applicable processors or recipients to honor the request as required by law. Where Washington law applies, deletion from archived or backup systems may be delayed only within the period permitted by that law.

16.9 Material Changes

If we seek to collect, use, or disclose materially different categories of consumer health data, use health data for materially different purposes, or involve new recipients in a way that requires additional notice or consent, we will provide the required disclosures and obtain affirmative consent before the new processing begins where required by applicable law.

17. Children and Teens

The current U.S. Services are intended for users age 18 and older as a Shakespeare product policy.

We do not knowingly collect personal information from children under 13, and the Services are not directed to children under 13. We also do not intend to maintain U.S. accounts for users under 18 under our current product policy.

If we learn that we have collected personal information from a person who is not eligible to use the Services under this policy, we will take appropriate steps to delete the information and/or disable the account, subject to applicable law.

18. Changes to This Privacy Policy

We may update this Policy to reflect changes in the Services, providers, technology, security practices, or law. If a change materially affects how personal information or consumer health data is processed, we will provide appropriate notice and obtain additional consent where required.

The “Last Updated” date at the top identifies the current version.

19. Contact Us

Company: Hangzhou Lingxi Exploration Technology Co., Ltd.

Address: Room 37976, 3rd Floor, No. 1040 Yueming Road, Changhe Subdistrict, Binjiang District, Hangzhou, Zhejiang Province, China

Customer Support and Privacy Requests: support@shakespearelife.com