Privacy Policy

Effective Date: November 30, 2025

Welcome to MakeTunes operated by Spark Fly Technology Limited (hereinafter referred to as “we,” “us,” or “MakeTunes”). This Privacy Policy applies to the MakeTunes website and related services (collectively, the “Services”). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, process, disclose, and safeguard your personal data when you use the Services, and how you can exercise your rights regarding the protection of your personal data. By using the Services, you consent to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please refrain from accessing or using any of our Services. This Privacy Policy is incorporated into and forms part of our Terms of Service. Unless otherwise defined herein, terms used in this Privacy Policy have the same meanings as defined in our Terms of Service. MakeTunes hosts a diverse community of users across different age groups. However, for users in the United States, MakeTunes is not directed to children under the age of 13. If we become aware that we have collected personal data from a child under 13, we will delete such personal data and terminate the child’s account. If you believe that we have collected personal data from a child under 13, please contact us using the methods provided under the section “How to Contact Us” below. For users in other jurisdictions, to protect the privacy and personal data of minors, we will obtain parental or legal guardian consent where required by applicable local law before processing the personal data of minors. Please note that we limit the types and scope of personal data collected from minors wherever possible and restrict the features available to them.

1. Types and Purposes of Personal Data We Collect

The scope of personal data we collect depends on the features of the Services you use and the manner in which you use them. The following summarizes the types of personal data we collect and the purposes for which they are used:

A. Personal Data You Provide Directly to Us

Registration and Login: Users may register and log in to their accounts via third-party platform accounts (e.g., Google, Facebook, etc.) (see Section 1.C below for details).

• Voice Data: When using AI music (vocal) or other audio creation features, we may process voice data extracted from recordings, audio files, or other similar content you upload, select, or generate through the Services. Such data is processed using AI models to generate audio outputs that replicate or simulate the unique auditory characteristics in the data you provide. The resulting AI-generated music output may contain distinctive voice features from the data you submitted and may be accessible, shared, or used by others. By providing or uploading voice data, you confirm that you have obtained all necessary rights, licenses, and authorizations to use and share this data for the stated purposes, and that such processing does not infringe any third-party rights, including but not limited to intellectual property or privacy rights.
• User-Generated Content (UGC) Creation and Sharing: When you publish any user-generated content (“UGC”), such as uploading audio references and creating AI music or other audio works within MakeTunes, we may collect the content you submit, posting time, location data, recordings, or distinctive voice samples depending on the features you use. Only when you choose to publish such content will we provide voice data, generated output, or other UGC to other users for listening, sharing, or other uses explicitly permitted by the Services. You have the right to manage or revoke this authorization under applicable law at any time; however, such revocation does not affect other users’ prior use of the content or any UGC derived from it before the revocation takes effect.
• Contact Information: We may use contact information you provide (e.g., email address) to conduct user surveys or send you information about products and services that may interest you. If you are not interested, you may opt out by responding accordingly.

B. Personal Data Provided or Generated During Your Use of MakeTunes

• Content Browsing: Any user can view publicly available UGC on MakeTunes without registering or logging in. Whether browsing as a logged-in user or as a guest, we may collect your browsing history to facilitate recordkeeping and further exploration of previously viewed content.
• Input Data: When using music or audio creation features, depending on how you interact with the Services, we may collect textual input data and/or voice data extracted from audio references, recordings, videos, or other similar content you upload, select, or generate. This data is processed according to your instructions to generate corresponding music or audio outputs. Additionally, we may process input data for security purposes, such as automatically screening for illegal content involving pornography, violence, fraud, infringement, or scams.
• Payments and Transactions: When using our top-up or payment features (via Apple Pay, Google Pay, Stripe, etc.) and initiating a payment request, we collect information such as your user ID, country/region, payment currency, payment amount, payment time, payment method, and order number to facilitate payment and transaction processes through APIs provided by third-party payment service providers.
• Enhancing User Experience: To improve your experience, we may automatically collect information such as language, clicks and interactions, program progress (including login status, interaction information/status), application tokens, operating system, network information (e.g., IP address), device data (e.g., IMEI and other device identifiers), country/region, device model, screen resolution, geolocation, and anonymous user identifiers, which may be analyzed to optimize Services.
• Stability and Security Maintenance: To maintain the stability and security of MakeTunes and your account, we automatically collect data related to service operation and your online activities, including login status, clicks and interactions, device data (e.g., IMEI and other device identifiers), operating system data, and network information (e.g., IP address). While using our website, we may also collect information about your access and use of the Services (“Usage Data”), which includes: (1) Log Data: Automatically generated data sent by your browser when accessing the website, such as IP address, browser type and settings, request date and time, interaction with the website, unique device identifiers, and other diagnostic data. (2) Cookies: Cookies and similar tracking technologies allow MakeTunes to access or store information about you, your settings, or your device, primarily to ensure the intended functionality of MakeTunes. Cookies generally do not contain personally identifiable information but help provide a more personalized user experience. Refusing cookies may limit your access to certain features. For example, first-party cookies save your login information to facilitate subsequent access and are essential for the proper functioning of MakeTunes.

C. Personal Data Provided by Third Parties

Third-Party Login: For convenience, you may choose to register and log in via third-party platform accounts (e.g., Google, Facebook, etc.). In such cases, we may collect information such as your nickname, avatar, email address associated with the third-party account, open platform ID, date of birth/age, gender, and location information. By logging in through a third-party account, you consent to the third party providing such personal data to us. If you provide personal data of any other data subjects, you must inform them of this Privacy Policy. You confirm that, before providing such data, you have obtained their consent or fulfilled any other legal requirements applicable for processing personal data without consent. By submitting such information, you represent that you are authorized to provide it and that we are permitted to process the personal data for the purposes described in this Privacy Policy. Generally, we use your personal data solely for the purposes described in this Privacy Policy or as disclosed at the time of collection. Where permitted by applicable law, we may also process personal data for other purposes not inconsistent with the disclosed purposes. In such cases, we will notify you separately to ensure transparency.

2. How We Handle Children’s Personal Data

• For users in the United States: MakeTunes is not intended for children under the age of 13. If we become aware that we have collected personal data from a child under 13, we will delete such personal data and terminate the associated account. If you believe we may have collected personal data from a child under 13, please contact us using the method provided in the “How to Contact Us” section below.
• For users in other regions: To protect the privacy and personal data of minors, we will obtain consent from a parent or legal guardian before processing a minor’s personal data, where required by the local laws of your country or region. We will seek to limit the types and scope of personal data collected from minors and restrict the features minors may access. If we discover that we have collected personal data from a minor below the applicable age threshold in your country or region without parental or guardian consent, we will promptly delete such personal data.

We recognize that we have special obligations when collecting and processing personal data of minors. We strongly encourage parents and guardians to educate their children not to disclose or provide any personal data while using our Services without prior permission.

3. How We Share and Delegate the Processing of Your Personal Data

To provide you with higher-quality services, we may engage third parties (such as service providers assisting us in delivering MakeTunes-related services) to process your personal data on our behalf. We enter into strict confidentiality agreements with such third parties, requiring them to handle personal data in accordance with our instructions, this Privacy Policy, and applicable laws and regulations, implementing appropriate confidentiality and security measures.

We may share your personal data with third parties under the following circumstances:

• To provide you with a better user experience, we may share your personal data with our partners—for example, sharing your Google user identifier to facilitate login via third-party platform accounts.
• We may provide information and content to service providers that support our business, such as cloud service providers, payment service providers, and analytics service providers, to ensure that MakeTunes remains a secure and satisfactory platform. We may also provide information to service providers assisting in our platform marketing. For example, we may use Google Analytics to collect and share information regarding your use of the Services (such as frequency of visits, actions taken during visits, and login locations) to carry out marketing campaigns and provide tailored services to users in specific regions.
• We may share your information with advertisers and third-party companies to display personalized advertising, if applicable.
• We may share your information with other members, subsidiaries, or affiliates of our corporate group to provide, improve, and optimize MakeTunes services, prevent unlawful use, and support users.
• To detect, prevent, or address security or fraud issues during transactions and payments, we may provide your registration information (e.g., email address or social media token used to log in), your chosen country/region, and your last login IP address to the relevant third-party payment service providers.
• If user-generated content or other information on the platform is used in advertising and marketing campaigns to promote the platform, any personal data contained therein may be disclosed to recipients of such advertising or marketing content.
• In the event of any transfer, merger, acquisition, reorganization, or liquidation involving personal data, we will require the new company or organization processing your personal data to continue handling it in accordance with this Privacy Policy. If the new company or organization needs to use your personal data for purposes not specified in this Privacy Policy, they will obtain your consent unless otherwise required by applicable laws and regulations.
• We may disclose information to relevant law enforcement authorities, regulators, government agencies, courts, or other third parties if we believe such disclosure is necessary to: (1) comply with applicable laws and regulations; (2) exercise, establish, or defend our legal rights; or (3) protect the vital interests of you or any other person.

When a third party acts as a data controller in processing your personal data, please refer directly to their official websites or other platforms for their privacy policies to understand their data processing practices.

4. How We Protect Your Personal Data

We implement appropriate technical and organizational measures to protect the personal data we collect and process about you. These measures are designed to provide a level of security commensurate with the risks associated with the processing of your personal data. For example, we use at-rest encryption to protect all user data, including database files and backups, with secure key management; transport encryption via Transport Layer Security protocol (TLS 1.2) to secure data flows from user devices to servers and between servers over public networks; and code review mechanisms to ensure the effective implementation of these technical measures. Additionally, we regularly test our applications and systems for vulnerabilities and security issues and apply access controls such as access tokens and multi-factor authentication to ensure the security of information.

Please note that no method of transmission or storage over the Internet can be guaranteed to be completely secure. If you believe your personal data has been compromised, please contact us using the information provided in Section 14 so that we can take appropriate measures.

In the event of any accident, force majeure, or other incidents resulting in the disclosure of your personal data, we will make every effort to contain the situation and promptly inform you of the cause of the disclosure, the security measures we have implemented, steps you may take, and any other relevant information. For any security incident involving personal data, we will report the incident to the competent authorities in accordance with applicable laws and regulations, investigate the matter promptly, and take emergency measures as necessary.

5. How We Store Your Personal Data

A. Cross-Border Transfer

To support our global operations and security management needs, your personal data may be transferred to and processed in multiple jurisdictions where our affiliated entities are located, which may differ from your jurisdiction of residence. In such cases, we will implement necessary and appropriate safeguards to ensure the security of your personal data during transfer, and require that the recipients of your personal data provide a level of protection and security consistent with this Privacy Policy and applicable laws and regulations.

B. Retention Period

Unless otherwise required by applicable laws and regulations, we will retain your personal data only as long as necessary for legitimate business purposes, such as providing services to you and complying with legal, tax, and financial obligations. Once your personal data is no longer needed or the statutory retention period under applicable laws and regulations has expired, we will delete or anonymize your personal data.

6. Your Rights

We take the protection of your personal data seriously. If you wish to access, correct, or delete your personal data, submit a complaint, withdraw consent, or exercise other rights provided under applicable laws and regulations, please contact us using the methods provided below. You have the right to access the personal data we have collected about you. We will implement appropriate measures to ensure that your personal data is accurate and up to date. In the event we discontinue the service or cease operations, we will provide at least thirty (30) days’ notice and, after termination, delete or anonymize your personal data.

If we process your personal data based on your consent, you may withdraw that consent at any time. Please note that withdrawing consent will not affect the lawfulness of any processing performed prior to the withdrawal, nor will it affect our processing of personal data on other legal grounds.

If you wish to exercise other statutory rights under applicable laws and regulations (for example, requesting that we transfer your personal data to a designated third party, restrict our processing of your personal data, or object to processing based on legitimate interests under applicable conditions), you may contact us using the methods provided under “How to Contact Us” below.

To protect your information, we may need to verify your identity before responding to your request, such as by requesting documentation related to your identity. We will respond to your requests to exercise your data subject rights in accordance with applicable laws and regulations.

7. Special Notice for California Residents

If you are a resident of California, this section provides specific notices applicable to you. For California residents, the term “personal data” is equivalent to “personal information,” referring to information that identifies, relates to, describes, or is reasonably capable of being associated, directly or indirectly, with a particular consumer or household.

• California Shine the Light Law: California residents may request a list of all third parties to whom we have disclosed your personal data for marketing purposes. You may submit such a request once per calendar year. In your request, please verify that you are a California resident and provide your current California address to receive our response. Requests can be made using the contact methods provided under “How to Contact Us” below. Please allow up to thirty (30) days for a response.
• California Minors: If you are under 18 years old and a California resident, and cannot delete information you have submitted to MakeTunes that is publicly accessible, you may contact MakeTunes via the methods under “How to Contact Us” to request deletion of such information. When submitting a deletion request, you must clearly specify the information you wish to delete and provide specific details (e.g., the URL of each page containing the information) to help us locate it. MakeTunes is not required to delete any information in the following circumstances: (i) federal or state law requires us or a third party to retain it; (ii) the information was not provided by you; (iii) the information has been anonymized such that you cannot be identified from it; (iv) you failed to follow our instructions to delete or request deletion of the information; or (v) you received compensation or other consideration for providing the information. Deleting your information from the service does not mean it will be completely or fully removed from our systems or those of our service providers. Additionally, materials you have published may be reposted or shared by other users or third parties. MakeTunes fulfills its obligations under California law as long as the information is anonymized or made inaccessible to other users and the public.
• Do Not Sell My Personal Data: Where applicable, the California Consumer Privacy Act (“CCPA”) gives you the right to opt out of the “sale” of your personal data. We generally do not directly sell your personal data in the traditional sense (i.e., in exchange for money or other valuable consideration). However, like many social and entertainment mobile applications, we use services that enable interest-based advertising and may share personal data with business partners for such purposes. Under the CCPA, providing personal data to these companies (such as online identifiers or browsing activity) may be considered a “sale.” If you wish to opt out of the “sale” of your personal data, please contact us using the methods under “How to Contact Us” below. Please note that certain transfers of personal data may not be considered a “sale” under the CCPA, and specific exemptions may apply (e.g., sharing aggregated demographic and interest data). Your choice will not affect other data sharing practices described in this Privacy Policy. Whether you opt out or not, you may still see some advertisements.
• Do Not Track: Currently, there is no global, consistent standard or definition for how to respond to, process, or communicate “Do Not Track” signals. Therefore, our services may not respond to “Do Not Track” requests sent by browsers. Additionally, while using our services, we and third parties may use tracking technologies to collect personal data regarding your online activities for various purposes, including delivering advertisements and personalized content. If you wish to opt out of third-party collection of your online activity and device data, various tools and mechanisms are available to all users. For example, your mobile device settings may provide features to limit the use of advertising identifiers for interest-based advertising purposes. Please note that opting out of tracking and interest-based advertising using these tools does not mean you will not see ads while using MakeTunes, nor does it prevent you from receiving interest-based advertisements from third parties. However, under the relevant network and platform policies and choice mechanisms, you will no longer participate in interest-based advertising activities conducted via those networks and platforms.
• Additional Information: Exercising any rights under the CCPA does not subject you to discriminatory treatment. To the extent permitted by law, we may charge a reasonable fee to respond to your request.

8. How We Update This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in laws, technology, or business practices. When we make updates, we will take appropriate measures to notify you based on the significance of the changes. You can determine the effective date of this Privacy Policy by reviewing the “Effective Date” displayed at the top of the policy. Your continued use of any features of MakeTunes constitutes your acknowledgment that you have read, understood, and agreed to the updated Privacy Policy.

9. How to Contact Us

If you have any questions or concerns about this Privacy Policy or our handling of your personal data—particularly if you believe that our processing of your personal data has infringed upon your legal rights—please contact us at [email protected]. We will promptly review your inquiry and respond in a timely manner in accordance with applicable laws and regulations.

10. Governing Law and Dispute Resolution

This Privacy Policy is governed by the laws of Hong Kong, without regard to its conflict-of-law principles. Any dispute arising out of or relating to this Privacy Policy (including any question regarding its existence, validity, or termination) shall be submitted to the Hong Kong International Arbitration Centre (“HKIAC”) for arbitration in accordance with the HKIAC Administered Arbitration Rules in force at the time of the arbitration, which are hereby incorporated by reference. The seat of arbitration shall be Singapore.