Privacy Policy

Last updated: November 6, 2026 · Jurisdiction: Hong Kong

This Privacy Policy explains how Bleu Pearl Limited collects, uses, stores, and protects your personal information when you use Dream Actively. Please read it carefully. By using the platform, you agree to the practices described here.

1. Who we are

Dream Actively is a project of Bleu Pearl Limited, a company incorporated in Hong Kong ("we", "us", "our"). We are the data controller responsible for the personal information collected through this platform.

For privacy-related questions or requests concerning the legal entity, contact us at info@bleu-pearl.com. For questions related to the pilot, contact us at support@dreamactively.ai.

2. Information we collect

We collect the following categories of personal information:

Account and registration information. Your full name, email address, country of residence, age, gender, device type (iOS or Android), and language preference, provided when you create an account or register for the pilot.

Consent records. The consents you gave at registration, together with their timestamp: acceptance of these terms and the Privacy Policy, optional consent for communications, and optional consent for the use of testimonial and image.

Practice progress data. Your active day, completed days, timestamps for first play, last activity, and level completions. This data is used solely to operate the structured progression system.

Reflection and Bleu Pearl conversation content. Text you voluntarily submit via the post-practice reflection prompt, and messages you exchange with Bleu Pearl, our in-app AI Reflective Witness. This content is processed and stored as described in Section 5.

Payment information. Payments are processed entirely by third-party payment providers described in Section 6. We do not receive, store, or have access to your full card number, CVV, or bank details. We receive only confirmation of transaction status and a reference identifier.

Usage and technical data. Standard server logs including device type, browser type, operating system, and session timestamps. This data is used for platform stability, debugging, and security monitoring only.

Advertising identifiers and app measurement data. Our mobile apps use the Meta SDK to measure app installations and app activation/session events associated with our advertising campaigns. Depending on your platform permissions and device settings, Meta may receive your device’s advertising identifier, such as IDFA on iOS or Google Advertising ID on Android, SDK-generated identifiers, and technical information such as IP address, app and operating-system version, device characteristics and event timestamps.

We do not currently send purchase, trial, entitlement or practice-progress events to Meta. We do not send your account email, Bleu Pearl conversations or practice reflection content to Meta. Purchases and access entitlements are handled separately through the app stores, RevenueCat and our own services. See Section 6A.

3. How we use your information

We use your personal information:

To create and manage your account.
To operate the structured day-by-day practice progression.
To process purchases and manage access entitlements.
To generate contextual AI responses within the reflection and Bleu Pearl features.
To send essential account and service communications.
To respond to support enquiries.
To maintain the security and stability of the platform.
To measure the effectiveness of our advertising campaigns, including whether an advertisement led to an app installation or activation.

We do not use reflection content or Bleu Pearl conversations for advertising. We do not send marketing communications unless you have opted in.

On iOS, our Meta measurement integration starts only after you authorize tracking through Apple’s App Tracking Transparency permission prompt. Android advertising-identifier availability depends on your device settings and applicable platform restrictions.

4. No sale of personal data and advertising measurement

We do not sell, rent, or trade your personal information. Your data is not shared with data brokers.

We share limited device identifiers, app-event signals and technical information with Meta to measure and improve our advertising campaigns.

Meta’s processing of this information is subject to its applicable terms and Privacy Policy. This may involve matching information received from our app with information Meta holds from its own services or other sources for advertising measurement and other purposes described in those terms and notices.

We do not share Bleu Pearl conversations or practice reflection content with Meta.

5. Reflection content and conversations with Bleu Pearl

The post-practice reflection feature allows you to submit written reflections after completing a guided practice. Bleu Pearl is an in-app AI Reflective Witness that generates contextual responses to what you share.

This content is transmitted securely over encrypted connections and processed by a third-party AI model to generate a response. It is stored on our servers, associated with your account, and retained until you request account deletion.

The following applies to this content:

It is not used to build advertising profiles of you.
It is not shared with third parties for commercial purposes.
It is not used to train AI models without your explicit permission.
The AI model provider processes the content only to generate a response and is not permitted to retain or use the content for their own purposes.

Participation in the reflection feature is entirely voluntary. Skipping it has no effect on your practice progression.

6. Third-party services

We work with a small number of trusted third-party providers to operate the platform. Each provider is engaged under appropriate data processing terms.

Payment processing. Purchases made through the mobile application are processed by Apple through the App Store on iOS, and by Google through Google Play on Android. Each acts as the merchant of record for those transactions. Purchases made through the web are processed by Stripe. In all cases we receive only transaction confirmation and a reference identifier. Your payment data is governed by the privacy terms of the respective provider.

Meta — advertising measurement. Our iOS and Android apps include the Meta SDK for App Events. We use it to measure app installations and app activation/session events in connection with our advertising campaigns. Meta receives the limited information described in Section 6A. Its processing is governed by the applicable Meta terms and privacy notices.

RevenueCat — purchases and access management. We use RevenueCat to help process and validate in-app purchases and manage purchase-related access. RevenueCat receives purchase information and an app user identifier used to associate purchases with the appropriate account. Payment processing is handled by Apple or Google. This purchase-processing integration is separate from Meta advertising measurement.

Backend infrastructure. The platform's database, authentication, and storage infrastructure is hosted on secure cloud servers. Account data, practice progress, conversation history and session information are stored in an encrypted database with access controls in place.

AI processing. Reflection content and conversations with Bleu Pearl are processed by a third-party AI model provider. This provider processes the content only to generate a response and is not permitted to retain or use the content for their own purposes. Information about the specific provider is available on request.

WhatsApp. Part of the pilot runs through a WhatsApp group for Dreamers. If you join, your phone number becomes visible to Bleu Pearl Limited and to the other Dreamers in the group. WhatsApp processes that information under its own terms. Joining the group is voluntary.

No third-party provider has unrestricted access to your personal data. All providers are engaged under confidentiality obligations appropriate to their role.

6A. Meta SDK and your choices

What we measure

Our current Meta integration measures:

App installations, reported when the installed app is opened and measurement starts.
App activation and session activity.

Automatic purchase-event logging is disabled. We do not currently send purchase, trial or entitlement events to Meta.

Information Meta may receive

Depending on your permissions, device settings and SDK configuration, this includes:

Advertising identifiers, such as IDFA on iOS or Google Advertising ID on Android.
SDK-generated identifiers.
Installation, activation and session signals.
Technical information such as IP address, app and SDK versions, operating-system and device characteristics, timestamps, and SDK diagnostic information where collected.

These signals may be associated with a device or matched with information Meta holds. They should not be understood as necessarily anonymous.

We do not attach your account email, practice progress, reflection content or Bleu Pearl conversations to Meta events.

iOS

Before starting Meta measurement, the app requests permission through Apple’s App Tracking Transparency prompt.

If permission has not been granted, this integration does not initialize Meta measurement or send its installation and activation events. You can review or change your tracking permission in iOS Settings. The app checks the permission again when it returns to the foreground.

Declining this permission does not prevent you from using the app’s practice or purchase features.

Android

Advertising-identifier availability is controlled by Android and your device settings. Depending on your Android version, you can reset or delete your advertising ID or adjust advertising privacy settings.

Changing the advertising ID setting does not necessarily stop all app-event or technical-data processing described in this section.

Further information and privacy requests

You can review Meta’s Privacy Policy for information about Meta’s processing and available privacy controls.

To exercise applicable privacy rights concerning Dream Actively, contact info@bleu-pearl.com, as described in Section 9.

7. Data retention

We retain your personal data for as long as your account is active or as necessary to provide the service and comply with legal obligations.

Account data is retained until you request deletion or close your account.
Practice progress data is retained for the duration of your access period and for a reasonable period thereafter.
Reflection content and conversations with Bleu Pearl are stored on our servers and retained until you request account deletion.
Payment records are retained for a minimum of 7 years in accordance with Hong Kong accounting and tax requirements.

Following account deletion, personal data is removed within 30 days, except where retention is required by law. Account deletion can be requested from within the app or by writing to info@bleu-pearl.com.

8. Security measures

We implement reasonable and appropriate technical and organisational measures to protect your personal information, including:

Encrypted data transmission (HTTPS/TLS) for all platform communications.
Encrypted storage of sensitive data at rest.
Role-based access controls limiting who can access user data internally.
Row-level security policies on the database ensuring data is accessible only by the owning user.
Authentication token management and session expiry.

No method of electronic transmission or storage is completely secure. While we take your privacy seriously and apply strong safeguards, we cannot guarantee absolute security against all threats.

9. Your rights

Subject to applicable law, you have the following rights regarding your personal data:

Right of access. You may request a copy of the personal data we hold about you.

Right of correction. You may request that inaccurate or incomplete personal data be corrected. Some corrections can be made directly within your account settings.

Right of deletion. You may request the deletion of your personal data. We will action this within 30 days, subject to any legal retention obligations.

Right to object. You may object to certain processing activities. We will assess and respond to your objection within a reasonable timeframe.

To exercise any of these rights, contact us at info@bleu-pearl.com. We will respond within 30 days.

10. Cookies

We use essential cookies on the website for session management, authentication and language preferences. We do not use advertising or tracking cookies on the website.

Advertising measurement in the mobile apps uses the Meta SDK described in Section 6A and is separate from website cookies.

11. Children's privacy

Dream Actively is not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that a minor has provided personal data, we will delete it promptly.

12. Changes to this policy

We may update this Privacy Policy from time to time. When material changes are made, we will notify you via email or a prominent notice on the platform prior to the change taking effect. Continued use of Dream Actively after updated terms are posted constitutes acceptance.

13. Governing law

This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region. Any disputes arising in connection with this policy shall be subject to the exclusive jurisdiction of the courts of Hong Kong.

If you are located in the European Economic Area or another jurisdiction with specific data protection legislation, please contact us and we will address your rights as applicable under relevant law.

Contact

Dream Actively, a project of Bleu Pearl Limited
Hong Kong
Legal entity enquiries: info@bleu-pearl.com
Pilot enquiries: support@dreamactively.ai