Page 1 | General Provisions
1.1 Purpose of this Privacy Policy
This Privacy Policy aims to explain the basic principles regarding the collection, use, storage, protection, and related rights and obligations of personal information and data during the user’s use of related services. The purpose of this policy is to protect the security of users’ personal information, clarify the boundaries of data processing, and ensure that related actions comply with applicable laws, regulations, and regulatory requirements.
1.2 Scope of Application of this Privacy Policy
This Privacy Policy applies to the processing of personal information and other related data involved in the user’s access to, use of, or acceptance of related services. This Privacy Policy applies to any personal information processing that occurs, regardless of how the user accesses the service.
1.3 How Users Read, Understand, and Agree to this Privacy Policy
Before using the service, users should carefully read and fully understand all the contents of this Privacy Policy. By clicking “Confirm,” checking “Agree,” actually using the service, or engaging in other actions that can be considered as acceptance of this Privacy Policy, users are deemed to have acknowledged, understood, and agreed to be bound by this Privacy Policy.
1.4 Relationship between this Privacy Policy and Other Agreements
This Privacy Policy constitutes an important part of the related service agreement and, together with the service terms or other related agreements, applies to the use of the service. In the event of any inconsistency between this Privacy Policy and other agreements, the provision that is more conducive to the protection of personal information and the achievement of legitimate compliance purposes shall prevail.
1.5 Basic Principles for Updating and Revising the Terms
This Privacy Policy may be updated or revised in accordance with changes in laws and regulations, regulatory requirements, or business adjustments. The updated Privacy Policy shall apply to personal information processing activities that occur thereafter from the date of its publication or effectiveness. Users who continue to use the service after the terms have been updated shall be deemed to have accepted the updated terms.
Page 2 | Definitions
2.1 “Personal Information” or “Personal Data” refers to various information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding information that has been anonymized and cannot identify a specific individual.
2.2 “Sensitive Personal Information” refers to personal information that, if disclosed, illegally used, or misused, may adversely affect an individual’s personal safety, property security, or legitimate rights and interests. Whether something constitutes sensitive personal information shall be determined based on the definition and scope of applicable laws and regulations.
2.3 “User” and “Data Subject” refer to natural persons, legal persons, or other organizations that use or access the relevant services; among them, “Data Subject” specifically refers to the natural person to whom the personal information is attributed.
2.4 “Processing,” “Storage,” “Use,” and “Disclosure”
“Processing” refers to any operation performed on personal information, including but not limited to collection, recording, organizing, storing, using, transmitting, disclosing, or deleting;
“Storage” refers to preserving personal information in any form;
“Use” refers to processing personal information within the scope of a lawful purpose;
“Disclosure” refers to the act of providing personal information to a specific third party in accordance with the law.
2.5 Legal and Regulatory Terms
These refer to the laws, regulations, administrative provisions, industry standards, and regulatory requirements applicable to personal information and data protection, including but not limited to systems related to data protection, privacy, and information security.
Page 3 | Scope of Information Collection (Information We Collect)
3.1 Information Provided Actively by Users
During the use of the service, users may actively provide certain information as needed, including but not limited to identity information, business-related information, or other materials submitted by the user. The specific information type is subject to the actual service scenario.
3.2 Automatically Collected Information
During service operation, the system may automatically collect information related to service usage, such as access records, usage behavior data, or other information directly related to service operation.
3.3 Technical and Operational Information
To ensure the normal operation and security of the service, necessary technical information may be collected, including equipment information, system status information, or other data used to maintain service stability.
3.4 Statement of Non-Collection of Information (if applicable)
Unless expressly required by laws and regulations or service functions, this service will not proactively collect personal information unrelated to the service. Any information processing beyond the necessary scope is subject to legality and compliance.
3.5 Minimum Necessity Principle of Information Collection
All information collection activities follow the principles of legality, legitimacy, and necessity, and are limited to the minimum scope necessary to achieve service functions or comply with legal and regulatory requirements.
Page 4 | Purpose & Use of Information
4.1 Necessary Uses for Providing and Maintaining the Service
The collected personal information is mainly used to provide, maintain, and support the normal operation of related services, including but not limited to service function implementation, service status confirmation, and necessary service support. The above uses are limited to the scope necessary to achieve the service itself.
4.2 Purpose of Optimizing Service Experience and Functionality
To improve service quality and user experience, relevant information may be analyzed, within legal and compliant limits, to improve service processes, optimize functional design, and enhance overall stability. The analysis results will be used in a summarized or de-identified manner.
4.3 Compliance, Risk Control, and Security Purposes
Subject to compliance with laws, regulations, and regulatory requirements, relevant information may be used for compliance review, risk control, anomaly identification, and security management to ensure the legality, stability, and security of the service.
4.4 Internal Analysis and Operational Management Purposes
Without identifying specific individuals, relevant information may be used for internal statistical analysis, operational evaluation, and business management to support continuous service optimization and reasonable operation.
4.5 Statement of Non-Use for Unauthorized Purposes
Unless otherwise stipulated by laws and regulations or with the user’s explicit consent, the collected information will not be used for purposes not expressly stated in this Privacy Policy, nor will it be processed or used beyond reasonable limits.
Page 5 | Information Sharing & Disclosure
5.1 Statement on Non-Disclosure in Principle
Users’ personal information will not be disclosed to any third party without legal basis or user consent.
5.2 Information Sharing under Legal and Compliance Circumstances
In cases where it complies with laws and regulations, regulatory requirements, or is necessary for the performance of services, some information may be shared within a reasonable scope to ensure the normal provision of services.
5.3 Necessary Sharing with Third-Party Service Providers
To achieve service functions, necessary information may be shared with third-party partners providing technical support, system maintenance, or related services. Such sharing is limited to the minimum scope necessary to achieve the service objectives and requires third parties to comply with corresponding data protection obligations.
5.4 Disclosure under Legal, Regulatory, or Judicial Requirements
Relevant information may be disclosed in accordance with the law when required by laws and regulations, regulatory agencies, or judicial authorities. Such disclosure will be strictly conducted in accordance with legal procedures.
5.5 Principle of Minimum Scope of Information Sharing
All information sharing activities adhere to the principles of necessity and minimization, ensuring that the content and scope of sharing do not exceed the minimum required to achieve the legitimate purpose.
Page 6 | Third-Party Platforms & Services
6.1 Statement on the Independence of Third-Party Platform Data Rules
The data processing rules and privacy policies of third-party platforms or external service providers are independent of this Privacy Policy, and their specific content is not controlled or formulated by this Service.
6.2 Statement Regarding User Understanding of the Applicability of Third-Party Privacy Policies
Users understand and acknowledge that when using third-party platforms or external services, the processing of their personal information will be subject to the third party’s own privacy policy and related rules.
6.3 External Technologies or Platforms May Be Involved in the Service
During the service process, technologies, systems, or platforms provided by third parties may be used to support the implementation of service functions. Such use is limited to the necessary scope.
6.4 Statement on the Boundaries of Responsibility for Third-Party Activities
This Service assumes no responsibility for controlling or guaranteeing the actions of third-party platforms or service providers within their independent operating scope. Users should understand and assess the relevant risks themselves.
6.5 Risk Warning Regarding Users’ Choice to Use Third-Party Services
Users who choose to use third-party services should bear the risks arising therefrom. This Privacy Policy does not guarantee the security, compliance, or continuity of third-party services.
Page 7 | Data Storage & Security Measures
7.1 General Principles of Data Storage
Personal information will be stored in accordance with the principles of legality, legitimacy, and necessity, and will only be stored to achieve the purposes described in this Privacy Policy or to the extent required by laws and regulations.
7.2 Data Security Management and Technical Protection Measures
Reasonable management systems and technical means will be adopted to protect the security of personal information, including but not limited to access control, permission management, and security review measures, to reduce the risk of data misuse, leakage, or damage.
7.3 Reasonable Measures to Prevent Unauthorized Access
Through reasonable internal management and technical arrangements, unauthorized access, use, or disclosure of personal information will be restricted, ensuring that processing is carried out only by personnel with appropriate permissions to the extent necessary.
7.4 General Explanation of Data Retention Period
Personal information will be retained for the shortest time necessary to achieve the purpose of collection, or as otherwise stipulated by laws and regulations. Information exceeding the retention period will be deleted or anonymized in accordance with the law.
7.5 Basic Principles for Handling Data Security Incidents
In the event of or potential data security incidents, reasonable measures will be taken in accordance with the law to mitigate adverse effects, and corresponding notification obligations will be fulfilled in accordance with laws and regulations. Page 8 | User Rights
8.1 Right to Know
Users have the right to know how their personal information is collected, used, and processed, and have the right to be aware of the relevant content regarding personal information protection in this Privacy Policy.
8.2 Right to Access, Correction, and Update
Subject to compliance with laws and regulations, users have the right to request access to their personal information and to correct or update inaccurate or incomplete information.
8.3 Right to Deletion or Restriction of Processing
Subject to applicable law, users have the right to request the deletion of their personal information or restriction of further processing of their personal information.
8.4 Explanation of Withdrawal of Consent
If personal information processing is based on user consent, users have the right to withdraw such consent, subject to compliance with laws and regulations. Withdrawal of consent does not affect processing actions already taken based on legal grounds prior to withdrawal.
8.5 Reasonable Restrictions on the Exercise of Rights
Under circumstances stipulated by laws and regulations, users’ exercise of the above rights may be subject to reasonable restrictions, such as for fulfilling legal obligations, maintaining public interests, or protecting the legitimate rights and interests of others.
Page 9 | Cross-Border Data Processing
9.1 General Explanation of Cross-Border Data Processing
In the course of providing services or fulfilling related obligations, personal information may be processed or stored between different countries or regions.
9.2 Principle of Compliance with Applicable Data Protection Laws
Cross-border data processing will comply with applicable data protection laws, regulations, and regulatory requirements, and necessary measures will be taken to ensure the security and compliance of personal information.
9.3 Notice Regarding Differences Between Jurisdictions
Different jurisdictions may have different data protection laws and regulatory requirements. Users understand and acknowledge that such differences may affect the processing of personal information.
9.4 Security and Compliance of Data Transmission
When conducting cross-border data transmission, reasonable security measures will be taken to ensure that the data transmission process complies with the requirements of relevant laws and regulations.
9.5 Confirmation of User Understanding and Consent
During the use of the service, users understand and agree that their personal information may be processed cross-border in accordance with the above principles.
Page 10 | Amendments & Legal Application
10.1 Update and Effectiveness Mechanism of this Privacy Policy
This Privacy Policy may be updated in accordance with laws, regulations, regulatory requirements, or business adjustments. The updated policy shall apply to personal information processing activities occurring thereafter from the date of its publication or effectiveness.
10.2 Continued Use Constitutes Acceptance of Updated Policy
Users who continue to use the relevant services after the Privacy Policy has been updated shall be deemed to have accepted the updated Privacy Policy.
10.3 Explanation of Applicable Law and Regulatory Principles
The establishment, interpretation, and enforcement of this Privacy Policy shall comply with applicable laws, regulations, and relevant regulatory principles.
10.4 Independence and Severability of Terms
Each clause of this Privacy Policy is independent. If any clause is deemed invalid or unenforceable, it shall not affect the validity of the remaining clauses.
10.5 Final Interpretation of this Privacy Policy
To the extent permitted by law, the right to interpret this Privacy Policy is reserved.
