Privacy Policy

Last updated: August 17, 2026

This policy explains how ThinkAsModel Limited (思模科技有限公司), a Hong Kong company (“we”, “us”), collects, uses, and protects your personal data when you use the alayo.ai website and the Alayo app. The principle up front: we collect the minimum data needed to operate, we run no third-party analytics, and we never sell personal data.

1. What we collect

2. The Alayo app itself

Alayo is local-first: your files stay on your device unless you explicitly invoke an AI feature that needs selected content. The app requires no account. Before the first request using included Alayo AI credits, the app explains the transfer and asks for your consent.

3. How we use it

That’s it. We will not use your email for marketing beyond the above, and we will not hand it to any third party for marketing.

4. Who we share it with

Only with the providers we need to operate, and only to the minimum extent required: payment providers (Paddle / Stripe), infrastructure providers (Cloudflare), and, when you use AI, the model providers described in Section 2. BYOK requests go to your configured endpoint; included Alayo AI requests pass through our Cloudflare relay to OpenRouter and an underlying model provider. Their terms and privacy policies apply to their processing. We may disclose data where the law requires it. We never sell personal data.

5. Data retention

Presale-list emails are kept until you unsubscribe or for a reasonable period after the presale ends; order and license records are kept as required by applicable law and accounting rules. Included-AI quota ledgers and balances are kept as needed to administer credits, prevent abuse, and reconcile provider charges; IP rate-limit counters are deleted after their short operational window. Request bodies and model responses are not retained by Alayo. Data past its retention period is deleted or anonymized.

6. International transfers

Our providers (Cloudflare, Paddle, Stripe, Google Fonts, OpenRouter, and underlying model providers) operate globally, so your data may be processed outside Hong Kong. A provider you configure through BYOK may likewise process content outside Hong Kong (see Section 2). We only use providers with industry-standard security safeguards.

7. Your rights

Under the Hong Kong Personal Data (Privacy) Ordinance (PDPO), you have the right to access and correct your personal data, and you may leave the presale list at any time (we will delete the corresponding list record). You may also request deletion of other personal data to the extent applicable law allows and it does not conflict with statutory retention duties such as accounting, dispute handling, or fraud prevention. Just email [email protected] and we will act promptly.

8. Changes to this policy

We may update this policy from time to time and will revise the “Last updated” date above; material changes will be announced on the Site or by email.

9. Language and contact

This policy is provided in English and Chinese; if the versions diverge, the English version prevails. Privacy questions: [email protected].