Privacy Policy

Last Updated: June 26, 2026

1. INTRODUCTION

This Privacy Policy describes how ULT Studio Limited ("ULT Studio," "we," "us," or "our"), doing business as NPCC.app, collects, uses, stores, and shares your personal information when you use the NPCC.app website, mobile applications, multi-system calculation engines, divination tools, gamified virtual spaces, and related services (the "Service").

We respect your data privacy and comply with the Hong Kong Personal Data (Privacy) Ordinance (PDPO), the General Data Protection Regulation (GDPR), and other applicable regional data protection laws.

Contact: privacy@ult-studio.com | ULT Studio Limited, Hong Kong

2. INFORMATION WE COLLECT

Personal Information You Explicitly Provide:

  • Account Data: Name, email address, account password, and your personal birth coordinates (date, time, and location of birth) required to calculate your unified metaphysical profiles.
  • Third-Party Birth Data (NPC Sync): Birth coordinates of third parties provided by you for the purpose of relationship analysis or chart comparison features. You warrant that you have obtained explicit consent from these individuals before inputting their data.
  • Payment Data: Credit card or bank details required for premium reports or subscriptions. All payment transactions are securely processed directly by our third-party payment gateway, Airwallex.
  • User-Generated Content & Inputs: Profile information, custom room configurations, avatar choices, and text strings manually inputted by you into the Service's wish manifestation tools within "My NPC Room."
  • Communications: Feedback, customer support tickets, or direct correspondence sent to our team.

Automatically Collected Data:

  • Device & Log Data: IP address, browser type, operating system, device identifiers, and approximate geographical location.
  • Usage Data: Pages viewed, specific divination or calculation features used, session duration, and interaction paths within the gamified environments.
  • Cookies: Technical cookies used to manage active login sessions, security protocols, language preferences, and anonymized user traffic analytics.

We do not collect sensitive data (such as race, precise health metrics, or political affiliation) beyond the metaphysical birth data explicitly required to generate your profile outputs.

3. HOW WE USE YOUR INFORMATION

We process your personal and astrological data to:

  • Generate unified metaphysical profiles, divination outputs, spatial Feng Shui analyses, and cross-system compatibility readings.
  • Render and save your gamified progress, avatar configurations, and wish manifestation text within "My NPC Room."
  • Securely process subscriptions and premium transactional purchases via Airwallex.
  • Optimize app performance, analyze usage trends, and improve our proprietary cross-referencing data layers.
  • Communicate critical product updates, legal changes, and opt-in marketing newsletters.

Legal Bases for Processing: Consent, performance of a contract (providing the service), compliance with legal obligations, and our legitimate business interests in maintaining system security and application enhancement.

4. SHARING YOUR INFORMATION

We do not sell, rent, or trade your personal or birth data to third-party marketers. We share data only with trusted service providers essential to running the app:

  • Payment Infrastructure: Airwallex (for secure transaction processing).
  • Cloud Infrastructure & Hosting: Secure enterprise cloud servers located in Hong Kong and the European Union.
  • Advanced AI APIs: Secure, enterprise-grade Large Language Model (LLM) endpoints utilized to process automated reading interpretations and contextual textual outputs (see Section 11).
  • Legal Compliance: Law enforcement or government regulatory bodies only when strictly required by a binding legal order under Hong Kong law.

5. DATA RETENTION

  • Active Accounts: Your profile data, avatar states, and historical inputs are retained as long as your account remains active.
  • Upon Deletion: If you delete your account, your personal identifying data (email, name) will be permanently erased. System backups are kept for up to twelve (12) months post-deletion for legal defense and fraud prevention compliance, after which they are fully purged or completely anonymized.

6. INTELLECTUAL PROPERTY & AI DATA PROCESSING

NPCC.app integrates proprietary traditional algorithms with state-of-the-art Third-Party Large Language Models (LLMs) and Advanced AI Processors to generate personalized reading summaries, synthesis profiles, and contextual interpretations.

  • Data Minimization: When data is sent to external AI processing endpoints, identifying personal information (such as your name or email) is stripped. Only the underlying metaphysical coordinates, structural chart values, or user-submitted manifestation text strings are processed.
  • Zero Public Training: We utilize enterprise-tier API contracts. Your specific birth coordinates, chart layouts, and manifestation inputs are never used by third-party AI vendors to train public foundation models.

7. YOUR RIGHTS & CONTROL

Depending on your geographic location, you possess comprehensive rights over your personal data under the Hong Kong PDPO or GDPR:

  • Access & Correction: You have the right to request a copy of the personal data we hold about you and correct any inaccuracies.
  • Data Erasure ("Right to be Forgotten"): You can request the total erasure of your profile and birth data via your in-app settings or by contacting privacy@ult-studio.com.
  • Data Portability: Request an export of your personal data in a clean, machine-readable format.

We will address verified requests within thirty (30) days of receipt.

8. SECURITY MEASURES

We implement rigorous security frameworks to safeguard your data, including end-to-end transport layer encryption (HTTPS/TLS), encryption of data at rest within our databases, strict internal access controls, and regular vulnerability checks. However, please be aware that no method of transmission over the internet or cloud storage environment can guarantee absolute, infallible security.

9. CHILDREN'S PRIVACY

The Service is strictly built for and directed to individuals aged 18 and older. We do not knowingly collect data from minors. If we discover that a minor under 18 has registered an account, we will immediately delete all associated data from our active databases.

10. CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy as our metaphysical engine and application scale. The date of the latest update will always be posted at the top of the page. Material adjustments will be broadcast directly via an in-app prompt or email notification.

11. CONTACT US

For any inquiries regarding data protection, right exercises, or privacy practices, please contact our Data Privacy Officer: ULT Studio Limited
9F The Siberian, 29 Des Voeux Road Central,
Hong Kong, Hong Kong
Email: privacy@ult-studio.com