We fully respect your privacy and are committed to protecting it through our compliance with this Privacy and applicable laws and regulations. This Policy is meant to help you understand our practices related to the collection, use, storage, and disclosure of information we collect from or about you when you interact with us, your rights regarding the information provided to us, and how we safeguard your rights.

It is important to note that this Policy does not apply to any products, services, websites, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies. We encourage you to read and review the privacy statements of each Third-Party Service that you may choose to use.

 

1.Important Definitions

 

Personal Information: Personal Information means any information that relates to a living individual directly or indirectly and can be used to identify a living individual, in particular by reference to an identifier, location, or factors specific to the physical, physiological, genetic, economic, cultural or social identity.

 

Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

 

Cookies: Cookies are small pieces of data stored on a user's device.

Data Controller: Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Policy, we are a Data Controller of your data.

Data Subject: Data Subject is any living individual who is the subject of Personal Data.

 

2.Information Collection and Use

In order to provide services and ensure the necessary conditions for security , we collect the corresponding categories of personal data under the circumstances that depend on the services you use and the requirements of applicable laws .

 

2.1 Data you provide directly to us

Account information : When you register and log in for the first time, in order to identify your identity and provide services normally, we will collect the nickname provided by you.

2.2 Data we collect automatically

Account information : When you register for the first time and log in, in order to identify your identity and provide services normally, we will automatically collect your registration area, registration language, registration time, and registration device id.

Device information: According to the device model and permissions granted during the installation and use of this product service, we will automatically collect the current device id, idfa (iOS), gaid (Android), current language, current region, current ip, Current time zone, phone system & system version, phone model.

Log information: When you use this product, we will automatically collect the log information you use for the service, including the current network type, operation log, and service log information.

Other information: we will collect your files and docs, ueser interaction, approx location to provide you a better service.

In order to fix the logic bugs and provide a more stable, faster and more compatible app, we need to collect crash logs, performance diagnostics.

2.3 The data we collect from our partners

We also use third-party partners to supplement information about you.

3.How We Store and Protect Your Information

Your information collected by us will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected Personal Information in countries or regions outside the country where our business is located.

We generally retain your personal data as long as we need to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. While you can close your account by yourself, we may also close your account if you failed to use your account in 180 consecutive days or to comply with this Policy, our Service related rules or applicable laws and regulations. In case of such account closure, we will delete or de-identification your relevant information.

The security of your Personal Information is important to us and we implement security safeguards designed to protect your Personal Information and regularly monitor our systems for possible vulnerabilities and attack We are constantly working to improve on these safeguards to keep your personal data secure.

However, we need to remind you that that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

 

4.How We Share, Transfer and Disclose Your Personal Information

When sharing, transferring, and disclosing your Personal Information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your Personal Information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your Personal Information in the following situations:

4.1 How we share your Personal Information

WE DO NOT SELL ANY PERSONAL INFORMATION TO THIRD PARTIES. We will share your personal data with our affiliates to provide and develop our Services.

We may share the necessary Personal Information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. For example, in order to enable you to share information to third party platforms, use location service and other kinds of services and features, we may embed third party SDK or other similar applications of authorized partners in our App.

In order to provide evaluation, analysis or other business services, we may also share your non-Personal Information with third parties.

4.2 How we transfer your Personal Information

We will not transfer your information to any other parties, except in the following circumstances:

(1)Obtain your explicit consent.

(2)If we are involved in a merger, acquisition or sale of all or part of its assets, which may affect your Personal Information, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your Personal Information, and any choices you may have about your Personal Information.

(3)In the case that has been explained in this Policy or notified you by other means.

4.3 How we disclose your Personal Information

We may need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services; or (5) exercise or protect the rights and safety of us, our users, personnel or others. We attempt to notify users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

Additionally, we may share your Personal Information with:

(1)Our attorneys, lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.

(2)Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group.

(3)Other third parties, for example, the disclosure of specific information with your authorization.

5.How Your Personal Information is Transferred Across Borders

For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your Personal Information to our servers stipulated in section III of this Policy for storage or processing, we may also transfer your Personal Information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions.

In the circumstance that we transfer Personal Information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.

6.How We Handle the Personal Information of Children

Our Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children.

If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with Personal Information in violation of applicable law, we will delete any Personal Information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

7.Your data protection rights

We would like to make sure that you are fully aware of all of your data protection rights. As a data subject, you have a variety of rights regarding the use and control of your user information.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. However, if you choose to delete the information, some features that require such information may no longer be available. M

The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information. You can withdraw your consent previously granted to us for a specific purpose by deleting information, turning off device features, and requesting to withdraw consent, including the collection, use and/or disclosure of your Personal Information that we manage or control. If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of our product and Service. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent. We will respond to all requests within 15 days after verifying the identity.

According to the applicable laws of some jurisdictions, you may have other data subject’s rights. Please refer to Jurisdiction Specific Supplemental Terms at the end of this Policy

Please understand that for security reasons, we may ask you for additional information to confirm your identity and that we are providing access to information about the correct person before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.

8.Cookies and similar technologies

Cookies are small text files that are stored on your mobile device by us to ensure that this software’s normal operation and your convenient access to it. Cookies usually contain identifiers, site names, and some numbers and characters. Our website, information services may use Cookies and other similar technologies such as Pixel Tags and Web Beacons. We generally treat information collected by Cookies and similar technologies as non-Personal Information as they do not contain any of your personally identifiable information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Information by the laws of the countries concerned, we will also follow the laws of the countries concerned.

We and our partners may use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. You can manage or delete Cookies according to your preferences.

9.Third-Party Service Providers and Services

You may receive links to third-party websites or content and services provided by third parties other than us during your use of our app and its Service, and some third parties’ products or services can be accessed in the form of SDKs and others in order to provide you with some functions and features in us, such as to provide you with third party logins, notifications and user analysis.

You can choose whether to visit or accept the third-party websites, products, and services at your sole discretion. Our Privacy Policy does not apply to products and services provided by any third party. Since we are not able to substantially control a third party, we are not responsible for the third party’s collection and processing of your Personal Information.

10.Supplement and Update of the Policy

We reserve the right to update or modify this Policy from time to time in order to reflect the changes in our business, technology and applicable law and practice. In case of any modification of this Policy, we will notify you by announcements in the App or our website to let you know about the changes we made. Although this Privacy Policy may be modified, your rights under this Policy will not be diminished without your explicit consent. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Privacy Policy.