Version 1.0, effective December 10, 2025

The L2dViewer Privacy Policy (hereinafter referred to as "this Privacy Policy") explains the types of data we collect, including personal information (collectively referred to as "data"), how we use and disclose this data when you use the L2dViewer application and the functions and services it provides (hereinafter referred to as "this Application"), and your options for accessing or updating the data.

Data Controller: Shanghai Xumi Network Technology Co., Ltd., Address: Jiading District, Shanghai.

We act as the data controller and are responsible for complying with data protection regulations and protecting your personal information and privacy rights.

Definitions

The following definitions are used in this Privacy Policy:

Personal Information refers to various information recorded in electronic or other forms that is related to identified or identifiable natural persons, excluding information that has been anonymized.

Sensitive Personal Information refers to personal information that, if leaked or illegally used, is likely to infringe upon the dignity of natural persons or endanger the safety of their person or property, including biometric data, religious beliefs, specific identity, medical health, financial accounts, location tracking, and personal information of minors under 14 years of age.

Anonymization refers to the process by which personal information is processed in such a way that it cannot identify a specific natural person and cannot be restored.

Other terms used in this Privacy Policy have the same meaning as defined in Article 4 of the Personal Information Protection Law (such as personal information processing, personal information processor, data subject, etc.), unless otherwise defined in this definition section.

Reasons for Data Collection and Data Collected

We collect data for the following purposes:

a) Providing basic functions of the Application. When you first install or reinstall this Application, we generate and collect a randomly generated identifier for providing the basic functions and settings of this Application, such as application settings management, theme preference settings (light/dark theme), and automatically recording the model files you last loaded. Please note that we do not collect, store, or process any personal information that can be traced to a specific device or individual, such as your device identifier, real name, contact information, etc. We do not associate the randomly generated identifier with any specific device or person. The legal basis for data processing required for this Application to function is the contractual performance necessary to provide services to you.

b) Improving Application experience. We may collect anonymized data based on your use of this Application to better understand application usage patterns, feature preferences, and user experience. We use this data to improve the stability, performance, and user experience of the Application. The collection of data based on your application usage is anonymized, with the legal basis being our legitimate interests in improving products and services.

c) Model file processing. When you use this Application to load Live2D model files, the Application processes these files locally to enable playback functionality. These model files are stored locally on your device, and we do not upload, collect, or store the model files you choose.

The categories of data processing involved include:

  • Automatically generated random identifiers (for application functions only)
  • Application usage data and settings preferences (local storage)
  • Theme selection preferences (light/dark theme)
  • Recently loaded model file records (local storage)

Children's Protection

This Application is not designed for children under 16 years of age and does not provide services to them. If we discover that a child under 16 has directly submitted information to us, we will strive to delete such information from our systems.

Your Privacy Choices and Rights

Your privacy choices. Your privacy choices regarding personal information are determined by applicable laws, as described below:

Mobile device notifications. We may send notifications through the Application. You can choose to opt out of receiving these push notifications by changing the settings on your mobile device.

Please note that you must opt out separately on each browser and device.

Transparency

To protect your privacy, before using your personal information, we will inform you of the categories of personal information we collect and the purposes of use. We will also inform you of the data management options you may have. For this purpose, we use this Privacy Policy and the User Agreement within this Application.

If you wish to obtain more detailed information on this topic, please feel free to contact us.

Information Sharing

Personal information collected under this Privacy Policy may be shared. We may also share your personal information with third parties as required by law (especially tax authorities or other government agencies exercising statutory powers), or if sharing is necessary to achieve the purposes defined above (especially with government agencies or parties harmed by violations of applicable laws).

To comply with the requirements of the California Consumer Privacy Act (CCPA), we hereby notify you that we will not a) retain, use, sell, or disclose any personal information for any purpose other than providing the Application; b) retain, use, sell, or disclose such personal information outside the direct relationship between you and us; c) use personal information in any manner other than as described in this Privacy Policy.

Security

We take measures to ensure that your information is processed securely and in accordance with this Privacy Policy. This Application was designed with security and privacy in mind to protect your personal information. Unfortunately, no system is 100% secure, and we cannot ensure or guarantee the security of any information you provide to us. To the maximum extent permitted by applicable law, we are not responsible for unauthorized access, acquisition, use, disclosure, or loss of personal information.

We encrypt data in transit and at rest where technically feasible. External network resources are protected by SSL encryption.

We review personal information usage processes before implementing them. This is to minimize data usage and ensure that you, as the data owner, understand the processing procedures. When the reason for data storage expires, we delete your personal information from our servers or anonymize it for further use.

Information Storage Location

Application servers or services storing information containing personal information are located in the jurisdiction where you are located (depending on the region where the Application is released). We may process or transfer some of your personal information to servers outside your jurisdiction in accordance with applicable laws. Any such transfer will be conducted in accordance with applicable data protection laws and this Privacy Policy, and will be based on relevant legal bases.

Third-Party Links

This Application may contain links to other websites/applications, and other websites/applications may reference or link to our Application. These third-party services are not under our control. We encourage users to read the privacy policies of each website and application before interacting with them. We do not endorse, screen, or approve the privacy practices or content of such other websites or applications, and are not responsible for them. Providing personal information to third-party websites or applications is at your own risk.

Data Retention, Withdrawal of Consent, Data Access and Your Rights

Generally, we retain your personal information for the period necessary to collect data for the stated purposes. We may also retain your information if required to comply with legal obligations and/or to defend against breaches of any terms of use and/or privacy policies. We may also retain copies of your information in application logs, access logs, and/or backups made for security and support purposes. These backups are not accessed as separately segregated information.

Where applicable, you are responsible for ensuring the accuracy of personal information you provide to us. We expect you to check the personal information you provide to us and, if any discrepancies occur, update your personal information or report such discrepancies to us.

To the extent permitted by applicable law, you have the right to:

  • Right of access. You have the right to obtain confirmation from us as to whether we are processing your personal information, and if so, to request access to your personal information. Information on personal information processing includes processing purposes, relevant personal information categories, and recipients to whom the information has been or will be disclosed, or categories of recipients. However, this is not an absolute right, and the interests of other individuals may limit your right of access. In addition, you have the right to obtain copies of the personal information being processed. For additional copies requested, we may charge a reasonable fee based on administrative costs.
  • Right to rectification. You have the right to request that we rectify inaccurate personal information. Depending on the processing purposes, you have the right to complete incomplete personal information by providing supplementary statements.
  • Right to erasure (right to be forgotten). In certain circumstances, you have the right to request that we delete your personal information.
  • Right to restrict processing. In certain circumstances, you have the right to request that we restrict processing of your personal information. In such cases, the relevant personal information will be marked and can only be processed by us for certain purposes.
  • Right to data portability. In certain circumstances, you have the right to receive personal information that you have provided to us in a structured, commonly used, and machine-readable format, and have the right to transmit such personal information to another entity.
  • Right to object. In certain circumstances, you have the right to object to our processing of your personal information at any time based on reasons related to your particular situation, and we may be required to stop processing your personal information.

Where applicable, you may contact us at support@ailive2d.com.

You may also contact us to obtain up-to-date information about your personal information processing and information about any personal information recipients.

Changes to This Privacy Policy

This Privacy Policy is effective as of the effective date stated above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will publish any changes to this Privacy Policy in the Application. If we make any changes to this Privacy Policy that would have a significant impact on the practices regarding personal information previously collected, we will endeavor to provide you with prior notice of such changes by highlighting the changes when you subsequently use the Application.

Contact Us

If you have any questions or concerns, or believe that this Privacy Policy has been violated in any way, please contact us immediately at support@ailive2d.com.

Third-Party Services

This Application may use the following third-party services to provide and improve functionality:

  • System frameworks and services: This Application may use frameworks and services provided by your device's operating system to provide basic functionality. The use of these services is governed by the privacy policies of the respective operating systems.

  • Local storage: Your application settings, theme preferences, and model history are stored locally on your device, and we do not upload this information to our servers.

Legal Basis Statement

According to applicable data protection laws, the legal bases for our processing of personal information include:

  • Contract performance: Providing basic functions of the Application
  • Legitimate interests: Improving Application experience and service quality
  • Your consent: Authorized use of specific features

You have the right to withdraw your consent at any time, but this will not affect the legality of processing based on consent before withdrawal.