Effective Date: July 15, 2026
Last Updated: July 15, 2026
  1. Introduction
This Privacy Policy (the “Policy”) describes how LINK RIVER LIMITED, a company incorporated under the laws of Hong Kong, business registration number 76600135, with its registered office at Flat A, 8/F, Kingswell Commercial Tower, 171 Lockhart Road, Wan Chai, Hong Kong (“Link River Limited”, “we”, “our”, or “us”), collects, uses, stores, and shares information when you use Kisei AI (the “Service”).
Kisei AI is an artificial intelligence-powered assistant that operates through the Telegram messaging platform and integrates with third-party services to enhance productivity, including Google Workspace services such as Gmail, Google Calendar, Google Drive, and Google Sheets.
This Policy applies to all users of the Service. By using the Service, you acknowledge that you have read and understood this Policy.
If you do not agree with this Policy, you must not use the Service.
  1. Information We Collect
2.1. Account Data
When you access the Service, we collect a unique identifier and display name from the messaging platform through which you use the Service. We do not collect your phone number, legal name, or government-issued identifiers unless you explicitly provide them.
2.2. Content You Provide
We process messages, files, voice recordings, and other content that you submit to the Service in order to generate responses and perform actions requested by you.
2.3. Contextual Memory
To provide consistent interactions across sessions, the Service stores structured contextual data (“Memory”) obtained through your interactions with it. Memory consists of facts, preferences, and references that you explicitly or implicitly ask the Service to remember.
2.4. Information from Connected Third-Party Services
When you connect a third-party service to the Service (for example, Google Workspace, Notion, or another service), the Service accesses data from that third-party service only to the extent necessary to perform actions requested by you. The specific data accessed from Google services is described in Section 4.
2.5. Technical Data
We automatically collect technical data necessary for the operation of the Service, including timestamps, error logs, and metadata about the nature of your use of the Service. This data is not linked to the content of your messages.
  1. How We Use Information
We use the information we collect for the following purposes:
To provide, maintain, and operate the Service.
To process your requests and perform actions initiated by you in connected third-party services.
To preserve context between your sessions through the “Memory” feature.
To improve the reliability, security, and performance of the Service.
To detect, prevent, and address technical issues, abuse, or violations of our Terms of Use.
To comply with applicable legal requirements.
We do not use your information for advertising purposes. We do not sell your information to third parties.
  1. Google User Data
This section describes how the Service accesses, uses, stores, and shares data obtained through Google APIs. This section is provided for the purpose of complying with the Google API Services User Data Policy.
4.1. Limited Use Disclosure
Kisei AI’s use and transfer to any other application of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
In particular, we comply with the following restrictions:
We use Google user data only to provide or improve user-facing features of the Service.
We do not use Google user data for advertising.
We do not transfer Google user data to third parties except where necessary to provide or improve user-facing features of the Service, comply with applicable law, or in connection with a merger, acquisition, or sale of assets with notice to users.
We do not allow humans to read Google user data unless we have obtained your explicit consent for specific messages, where necessary for security purposes (for example, to investigate abuse), to comply with applicable law, or for internal operations where the data has been aggregated and anonymized.
We do not use Google user data to develop, improve, or train generalized or non-personalized artificial intelligence and/or machine learning models.
4.2. Google Services We Access
The Service requests permission to access the following Google services through OAuth 2.0:
Service — Scope — Purpose:
Gmail — gmail.modify — Reading, searching, and organizing emails, as well as modifying their labels when you instruct the Service to manage your inbox.
Service — Scope — Purpose:
Gmail — gmail.send — Sending emails on your behalf only after you have reviewed and confirmed the draft.
Service — Scope — Purpose:
Gmail — gmail.compose — Creating and saving email drafts in your Gmail account.
Service — Scope — Purpose:
Google Calendar — calendar — Creating, viewing, modifying, and deleting events when you instruct the Service to manage your schedule.
Service — Scope — Purpose:
Google Drive — drive.file — Accessing files that you explicitly open with the Service or create through it.
Service — Scope — Purpose:
Google Sheets — spreadsheets — Reading and modifying spreadsheets that you have explicitly authorized the Service to access.
Service — Scope — Purpose:
Basic Profile Data — userinfo.email, userinfo.profile, openid — Identifying your account and displaying your email address in the Service interface.
4.3. How Google User Data Is Processed
Google user data is processed only upon your explicit request. The Service does not perform background or automated processing of your Gmail, Google Calendar, Google Drive, or Google Sheets data outside actions initiated by you.
Email content accessed through Gmail is processed in working memory only for as long as necessary to generate a response and is not stored persistently, except for Memory items that you explicitly ask the Service to remember.
Outgoing emails are presented to you as drafts for review and confirmation before sending. The Service does not send emails on your behalf without your explicit confirmation.
4.4. Revoking Access
You may revoke the Service’s access to your Google account at any time by visiting the Google Account permissions page at https://myaccount.google.com/permissions and removing access for Kisei AI.
After access is revoked, the Service will immediately lose the ability to access your Google data. Previously processed data stored in the Service’s Memory will be retained until you delete it using the Service’s data management features.
  1. How We Share Information
We do not sell your personal information. We do not share your personal information with third parties for marketing or advertising purposes.
We share information only with the following categories of recipients and only to the extent necessary for the operation of the Service:
Recipient — Data Shared — Purpose:
DeepSeek — Message content and context necessary for AI processing — Generating AI responses
Recipient — Data Shared — Purpose:
OpenAI, L.L.C. — Audio recordings and text for speech processing; message content and context necessary for AI processing — Generating AI responses and speech processing (text-to-speech, speech re-recognition, and text editing)
Recipient — Data Shared — Purpose:
Hetzner Online GmbH — All stored data (as infrastructure provider) — Hosting the Service infrastructure
Recipient — Data Shared — Purpose:
Telegram FZ-LLC — Messages transmitted through the messaging platform — Delivering messages between you and the Service
All other models used by the Service are deployed locally within our infrastructure, meaning that user data is processed on our own servers and is not transferred to third parties.
We have entered into data processing agreements with each of the subprocessors listed above where required by applicable law.
We may disclose information where required by law, a court order, or a legally binding request from a competent governmental authority.
  1. Data Storage and Security
Data is stored on servers operated by Hetzner Online GmbH and located in the Federal Republic of Germany.
We implement appropriate technical and organizational measures to protect your information, including:
Encryption of data stored in storage systems.
Encryption of data in transit using TLS 1.3.
Access controls limiting employee access to user data according to the need-to-know principle.
Two-factor authentication for employees with administrative access.
Regular security audits and vulnerability assessments.
No system is completely secure. In the event of a data breach affecting your personal information, we will notify you in accordance with applicable law, including where required by the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.
  1. Data Retention
Data Category — Retention Period:
Message Content — For the duration of your use of the Service
Data Category — Retention Period:
Contextual Memory (user-managed) — Until deleted by you or your account is closed
Data Category — Retention Period:
OAuth Tokens for Connected Services — Until you revoke access or your account is closed
Data Category — Retention Period:
Google User Data Obtained via APIs — Not retained after completion of your request unless you save it to Memory
Data Category — Retention Period:
Technical Logs Without Content — 90 days
Data Category — Retention Period:
Content Logs for Debugging — 30 days
Data Category — Retention Period:
Backups After Account Deletion — 30 days
After the applicable retention period expires, the data is deleted or anonymized.
  1. Your Rights
Under applicable law, you have the following rights regarding your personal information:
Right of Access: You may request a copy of the personal information we hold about you.
Right to Rectification: You may request that inaccurate or incomplete information be corrected.
Right to Erasure: You may request deletion of your personal information, subject to certain exceptions.
Right to Restriction of Processing: You may request that the processing of your information be restricted.
Right to Data Portability: You may request a copy of your information in a structured, commonly used, and machine-readable format.
Right to Object: You may object to processing carried out on the basis of our legitimate interests.
Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time.
Right to Lodge a Complaint: You may lodge a complaint with a data protection authority, including the Office of the Privacy Commissioner for Personal Data, Hong Kong (pcpd.org.hk).
To exercise any of these rights, contact us at privacy@kisei.ai. We will respond to your request within 30 days.
  1. International Data Transfers
Personal information processed by us may be transferred to, stored, and processed in jurisdictions outside your country of residence.
When transferring personal information across borders, we implement appropriate safeguards, including contractual protections, to ensure an adequate level of protection for your personal information.
  1. Children’s Privacy
The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under the age of 18. If we become aware that we have collected personal information from a child under the age of 18, we will promptly delete such information.
  1. Changes to This Policy
We may update this Policy from time to time. When we make material changes, we will notify you through the Service and update the “Last Updated” date at the beginning of this Policy. Your continued use of the Service after such changes constitutes acceptance of the updated Policy.
  1. Telegram Platform
The Service operates on the Telegram platform. This Policy applies in addition to the Telegram Bot Platform Terms of Service for Developers and the Telegram Privacy Policy. In the event of a conflict between this Policy and those Telegram documents, the Telegram documents shall prevail.
The Service is an independent product operated by us and is not operated, endorsed, or affiliated with Telegram Messenger Inc. We are solely responsible for the processing of your personal data within the Service.
When you interact with the Service through Telegram, Telegram may provide us with certain account data as described in the Telegram Privacy Policy, including your Telegram user ID, username, and profile information. Any data you share with the Service is governed by this Policy, while data processed by Telegram itself remains governed by the Telegram Privacy Policy.
  1. Contact Us
If you have any questions about this Policy or our data practices, please contact us:
LINK RIVER LIMITED
Flat A, 8/F, Kingswell Commercial Tower, 171 Lockhart Road, Wan Chai, Hong Kong
Email: privacy@kisei.ai
Website: https://kisei.org

Privacy Policy