Phocol Privacy Policy

Effective date: 03,01, 2025

Phocol respects your privacy. Phocol's ("Phocol", "we", "our") Privacy Policy describes the personal information we collect from individuals who use the Service, how it is used and shared, and your rights and choices regarding our use of your personal information. . When you review this Privacy Policy, please remember that it applies to all of our services. This Privacy Policy forms part of the Terms of Use and governs your use of the Phocol website ("Our Site") and related services and products (collectively, our "Services").

For area-specific disclosures, please see our area-specific privacy policies.

For the purposes of this Privacy Policy, "personal information" refers to various information related to an identified or identifiable natural person recorded electronically or by other means, excluding anonymized information. Please read this Privacy Policy carefully before using our services. By using our Services, you acknowledge that you have read this Privacy Policy and agree to be bound by it. If you do not agree to any services or procedures described in this privacy policy, you may not be able to use the services we provide.

1. Personal information we collect

Personal information you provide to us

Many areas and features of our Services do not require registration and you can access them without revealing any personal information (however, we will collect your personal information whenever you voluntarily provide it to us). For example, we collect your personal information:

(1) When you register for a Phocol account, you can create an account through your mobile phone number or email, and we will verify your identity by sending a verification code; or you can register and log in through your mobile phone number, email, and password, and we will collect your Your mobile phone number or email address and password (if used) are used to provide you with registration and login services.

If you do not provide the information required for any of the above login methods, you will only be able to browse and use some functions of Phocol, and will not be able to enjoy all services; if you only need to browse and use some functions of Phocol, you do not need to register as our user and provide the above information.

(2)Phocol supports the registration and login functions by using third-party accounts (such as Apple, Google, Facebook). If you choose to log in with a third-party platform account, you need to authorize us to obtain your information on the corresponding third-party platform, including public information like your profile picture and nickname, as well as other information that you separately authorize us to access. Based on this, a Phocol account bound to the third-party account will be generated, enabling you to directly register, log in and use Phocol and its related services smoothly.

(3) When you purchase our products or services online,in this case, the third-party service provider who processes payment for us will collect your credit card, bank account or other payment account information so that we can accept, process, manage , and fulfill purchase orders and process your return and refund requests after purchase.

(4) When you submit a request or inquiry to us regarding our services, such as when you interact with customer service (in this case, we will collect detailed information about your interaction, such as the date, time and reason for contacting us , record) any chat conversations, and your phone number if you call us.

Each of the above ways of providing personal information is a "transaction or request." You can decide whether to disclose your personal information. However, we will not be able to process your transaction or request without your personal information.                

When you use our Services, we collect personal information about user activities on our Services.

For example, our services automatically collect and record:

(1) "Clickstream data" or usage data of all visitors to our services, such as IP addresses (numbers automatically assigned to users' computers and mobile devices when they surf the Internet), page requests, pages visited, content viewed, Clicks and search queries and more. This user activity information includes your activities on Phocol, such as selections, design history, and search queries. We also use cookies and web beacons to collect information about user activity on our Services.

(2) Device information about the machine you use to access or use our services, such as web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers and push notifications Token.

(3) Permission information required for business functions, including camera permissions, Bluetooth, location, and permissions to store and read files, etc. For example, when you use the device search, connection, and production functions, we will apply for your camera (camera) permission and Bluetooth permission to search and connect to Phocol printing machines. When editing graphics and text and saving production files, you need to obtain your storage/read (and album) permissions to generate materials, projects, and save them.

Personal information we receive from third parties

(1) You can also post photos, comments or comments on our pages through third-party platforms. If you do so or otherwise provide personal information to ads we host on third-party platforms, we and other users may be able to view the personal information you provide through those third-party platforms.

(2) We may receive other personal information about you from third parties such as data or marketing partners and combine it with other information we have about you.                 


We rely on various legal bases to process your personal information, including:

• Consent. You may have agreed to the use of your personal information, such as sending you electronic marketing information or using certain cookies. You can withdraw your consent at any time by contacting us as described in point 10 of this policy.

• Contract. We need your personal information to provide you with our services and respond to your inquiries.

• Law. When we need to fulfill legal duties and responsibilities or legal obligations, we may have a legal obligation to process your personal information, such as complying with tax and accounting obligations.

• Public interest. We may also process your personal information when necessary to respond to public health emergencies or protect the life, health or property safety of individuals in emergency situations.                                              

2. Our use of personal information

The Personal Information We Collect.The information we collect directly from you includes:
a. IP address and MAC identifier (when you use our online services)
b. Feedback records when you encounter issues within the app (when you experience software crashes, we log the cause of the crash and work on fixing the functionality)
c. Your device information, such as device model, system version, and other hardware details (when you encounter software crashes, we optimize the functionality based on your device model)
d. Your Bluetooth address, used for connecting to printers and transferring print data
e. Your camera, photo album, and file information, used for taking pictures or selecting images from your album for printing

We use personal information for the following purposes:
(1) Provide, maintain, enhance and improve our products and services.
(2) Improve the pages and content of our services.
(3) Manage and maintain the operation of our services.
(4) Communicate with our users and members.
(5) Manage and manage transactions and relationships with our users and members. For example, if you:
  • Provide us with personal information in connection with a transaction or request, and we will use your personal information to process, manage, manage and communicate with you such transaction or request.
  • After registering as our user, we will use your personal information to set up, manage, provide services and communicate with you about your account.
  • Purchase products from us and we will use your personal information to process and fulfill your order, communicate with you about that order, and provide you with member care.
  • Submit a request or inquiry to us and we will use your personal information to respond to your request or inquiry.
  • Provide us with your email address or mailing address, which we may use to send you notices of a transactional, administrative or relationship nature or as required by law, such as notices of material changes to this Privacy Policy or the terms of your use of our Services, Notifications of security breaches affecting your personal information stored by or for us, etc.
(6) For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or of interest to you.
(7) Personalize your experience with our services, such as presenting customized content.
(8) De-identify, anonymize and/or aggregate personal information collected through our services and use it for our business purposes.
(9) Detect and prevent fraud and respond to possible trust and security issues.
(10) For compliance purposes, including to enforce our Terms of Use or other legal rights, or as required by applicable laws and regulations or as required by any judicial process or government agency.
(11) For other purposes for which we provide specific notice when collecting personal information.

Pseudonymization

For the information we collect from you, we will promptly apply pseudonymization techniques. Without disclosing your personal information, we have the right to analyze, mine, and utilize the pseudonymized user data. We also have the right to conduct statistical analysis on the usage of Phocol printing products and share this information with potential third parties.

3. Disclosure to third parties other than Phocol

Based on technical needs, Phocol APP needs to integrate third-party software development toolkits (SDK). The information collected or shared by the integrated third-party SDK is as follows:

SDK Name: GoogleSignIn
Third Party Name: Google LLC
Usage Scenario: Allows users to authenticate via their Google accounts
Information Collected: Google account name, email address, Google profile picture, OAuth authorization token, etc.
Privacy Policy: https://policies.google.com/privacy

SDK Name: AndroidSupportLibraryFragment
Third Party Name: Google Inc.
Usage Scenario: Constructs the basic framework of the project and determines main progress status
SDK Package Name: androidx.fragment, android.support.v4
Information Collected: Running process info, SD card data, Android ID
Privacy Policy: https://developer.android.com/topic/libraries/support-library/packages?hl=zh-cn

SDK Name: OkHttp
SDK Package Name: OkHttp Network Request SDK (okhttp3.internal.connection)
Provider: Square (Block, Inc.)
Purpose: Used for fundamental network service functionality
Information Collected: IP address
Privacy Policy: https://square.github.io/okhttp/

SDK Name: Android AppCompat Library
Third Party Name: Google LLC
SDK Package Names:
androidx.core, androidx.appcompat.app, androidx.appcompat.graphics, androidx.appcompat.text, androidx.appcompat.view, androidx.appcompat.widget, androidx.viewbinding, androidx.viewpager.widget, androidx.versionedparcelable, androidx.lifecycle, androidx.coordinatorlayout, androidx.drawerlayout.widget, androidx.asynclayoutinflater, androidx.lifecycle.viewmodel, androidx.interpolator.view, com.google.android.material, androidx.constraintlayout.widget, androidx.startup, androidx.databinding.library, androidx.activity, androidx.vectordrawable, androidx.lifecycle.livedata.core, androidx.coordinatorlayout.widget, androidx.fragment.app, androidx.vectordrawable.animated, androidx.viewpager2, androidx.documentfile, androidx.legacy.coreutils, androidx.viewpager2.widget, androidx.media, androidx.exifinterface, androidx.room, androidx.transition, androidx.legacy.widget, androidx.loader, androidx.savedstate, androidx.customview, androidx.annotation, androidx.cardview.widget
Information Collected: Device version, SDK version, SD card data, Android ID, Android version, app installation list, device sensor - accelerometer
Information Type: Device information, device identifiers
Purpose: Assists in background development, provides compatibility across different device versions
Usage Scenario: Builds the basic framework of the project and provides UI support for the app
Privacy Policy: https://policies.google.com/?hl=zh

SDK Name: RxJavaFX
Third Party Name: RxJavaFX is not a third-party SDK; it is mainly used for asynchronous operations and is part of app logic. IP address collection is used for basic anti-fraud capabilities and related logs.
Purpose: Reactive request framework
Information Collected: Device information (IMEI, Android ID, SIM card serial number, phone number, IMSI), camera permission – collected by the app itself
Privacy Policy: https://docs.github.com/en/site-policy/privacy-policies/github-privacy-statement

SDK Name: Matisse
Provider: Zhihu
Usage Scenario: Allows users to select photos from local storage for recognition purposes
Information and Permissions Collected: Access to phone storage photos, read SD card content, device sensor - accelerometer
Privacy Policy: https://mvnrepository.com/artifact/com.github.Shouheng88/matisse

SDK Name: FBSDKCoreKit
Third Party Name: FACEBOOK
Usage Scenario: Provides core functionality of the Facebook SDK, including connection to Facebook APIs, user authentication, and data requests
Information Collected: Facebook account info (name, email, profile picture), social data (friend information, public profile, etc.)
Privacy Policy: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

SDK Name: FBSDKCoreKit_Basics
Third Party Name: FACEBOOK
Usage Scenario: A lightweight foundational toolkit within the Facebook SDK supporting authentication, data tracking, and lightweight analytics
Information Collected: Basic personal information (name, email, profile picture), user behavior data for tracking application functionality
Privacy Policy: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

SDK Name: FBSDKLoginKit
Third Party Name: FACEBOOK
Usage Scenario: Integrates Facebook login functionality to allow users to sign in using Facebook, obtain access tokens, and authorize the app
Information Collected: Basic user info (name, profile picture, email), authorization data (public profile, friends list, etc.)
Privacy Policy: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

SDK Name: Facebook SDK for Android
Third Party Name: FACEBOOK
Usage Scenario: Enables Android apps to support Facebook login, sharing, user information retrieval, etc.
Information Collected: Basic personal info (name, email, profile picture, friend list), social data (public profile, friend info, etc.)
Privacy Policy: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

SDK Name: Sensors Analytics SDK
Third Party Name: Sensors Data Co., Ltd. (Beijing)
Purpose: For basic data collection and modeling to support business decision-making and analytics
Information Collected: Device identifiers (Android ID, IDFA, IDFV, OAID, UUID, etc.), location data (GPS), sensor info (screen orientation), unique app ID, hardware info (model, resolution, manufacturer, product name), OS info (name, version, language), app info (time zone, app ID, name, version), network info (network type, carrier name, IP address).
Note: Information collected may vary depending on the device and system (Android/iOS/HarmonyOS)
Privacy Policy: https://manual.sensorsdata.cn/sa/latest/zh_cn/sdk-22255999.html

SDK Name: Zoho Mobilisten
Third Party Name: Zoho Corporation
Purpose: Allows users to select photos from device storage for image recognition and supports device information retrieval to enhance interaction experience
Information Collected: Device information, location data, user-provided personal information, chat history with customer service
Privacy Policy: https://github.com/zoho

SDK Name: MMKV
Third Party Name: Tencent
Purpose: High-performance local key-value storage for caching user settings, login status, tokens, etc.
Information Collected: Local storage access
Privacy Policy: https://github.com/Tencent/MMKV

SDK Name: Okio
Third Party Name: Square, Inc.
Purpose: A low-level, high-efficiency I/O library used for file reading/writing, network data handling, caching, etc. Often used by libraries like OkHttp and Coil
Information Collected: None – Okio processes only local I/O, does not handle network requests or collect user data
Privacy Policy: https://square.github.io/okio/

SDK Name: image-cropper
Third Party Name: CanHub (originally by ArthurHub)
SDK Package Name: Typically com.canhub.cropper
Purpose: Implements image cropping functionality within the app, allowing users to edit and upload photos
Information Collected: None – the SDK only performs local image cropping and does not collect or upload user data
Permissions Required: None directly; however, the app typically needs to request photo and camera access permissions (e.g., storage read, camera)
Sharing Method: Processes image cropping locally without communicating with external servers
Privacy Policy: https://github.com/CanHub/Android-Image-Cropper

SDK Name: Google Pay API 
Third Party Name: Google LLC 
SDK Package Name: 
- Android: com.google.android.gms.wallet 
- Web: https://pay.google.com/gp/p/js/pay.js 
Purpose: Enables users to make payments using their Google account and stored cards. 
Information Collected: Device information, Payment token, Transaction details (e.g., total amount, currency). 
Permissions Required: INTERNET, ACCESS_NETWORK_STATE (No sensitive runtime permissions required) 
Sharing Method: Google Pay securely shares encrypted payment tokens with the merchant or PSP (e.g., Stripe, Adyen) 
Privacy Policy: https://policies.google.com/privacy 

You agree and acknowledge that we will share or otherwise disclose the personal information we collect from or about you as described below or as otherwise disclosed at the time of collection.
(1) Disclosure to affiliated companies. We may share any personal information we receive with our affiliates for our business operations as described in this Privacy Policy.
(2) Disclosure to service providers. We may disclose your personal information to external vendors, service providers and contractors who require access to such personal information to perform their services (including, but not limited to, transaction/payment processing, order fulfillment, surveys). To provide administration and prize fulfillment, data research and analysis, data collection and processing, data storage, data security, hosting and technical support for our services and marketing and advertising support to us (hereinafter collectively referred to as "Service Providers"). For example, from time to time we may hire a marketing firm to conduct online surveys. At the same time, we guarantee that third parties will not retain data longer than necessary to provide these services or use it for any other purpose.
(3) Disclosure to other users. Please note that any personal information you post in any public, community, or interactive areas of our Services (such as chat rooms, bulletin boards, message boards, and discussion groups) will be accessed, collected, and used by others, and may Result in unsolicited or unwanted messages or contact from others. Therefore, please use caution when providing personal information in any public, community or interactive areas of our Services.
(4) Disclosure required by law and similar circumstances. We may access, store and disclose your personal information to others if required to do so by law or if we believe in good faith that it is reasonably necessary to:
  • Comply with legal process (including court orders or subpoenas);
  • Cooperate with law enforcement;
  • Enforce this Privacy Policy and/or our Terms of Service;
  • Respond to emergencies;
  • Protect the rights, property or safety of Phocol, one or more of our users and members, and/or the public.
(5) Disclosure in merger, sale or other asset transfer. In addition, we may disclose your personal information to service providers, consultants, potential transaction partners or other third parties involved in the consideration, negotiation or otherwise of a corporate transaction in which we (or parts of our business) are involved. Following such disclosure, the acquiring entity's privacy policy may govern the further use of your personal information.
(6) Disclosure with consent. With your permission, we may also disclose personal information from or about you or your device.

4. Your choice

(1) Information access. If you wish to review, update or correct personal information you have previously provided to us (such as name, address, phone number or payment information), you may send your request to us by email: support@phocolprinter.com and we will try our best to do so. Your request will be processed as soon as possible after receipt. Additionally, if you have an active account on our Services, you may log in to your account to review, update and correct your account information. For other personal information, we will provide you with access, except in the following circumstances: We may refuse to process requests that are frivolous/vexatious, endanger the privacy of others, are extremely impractical, or where access is not required by law.
(2) Opt out of email marketing. You can unsubscribe from marketing emails from us by sending us your request by emailing support@phocolprinter.com. or use any opt-out methods provided in marketing emails (such as an "unsubscribe" link). However, please note that unsubscribing will not stop our email communications related to your transactions or requests, whether of a transactional, administrative or relationship nature, or as required by law, such as notifications of material changes to this Privacy Policy and/or our Terms of use of the service.
(3) Cancel account/delete information. If you wish to cancel your account on our Services and delete personal information you have previously provided to us, you may do so by
  • Log in to your Phocol account and select "Log out"
  • Send your written request to us via email to: support@phocolprinter.com. Doing so via our Phocol account settings is systemic, while doing so via email may require authentication and will be processed as soon as possible upon receipt.

Notwithstanding the foregoing, we retain your personal information if required to do so by law or to comply with legal process (including a court order or subpoena), legitimate law enforcement needs, or for legitimate business purposes.

(4) Privacy Rights in Specific Regions. For more disclosures on the privacy rights of residents in these regions or countries, please refer to our Specific Region Privacy Statement.

Appendix: Privacy Statement for Residents of the European Economic Area (EEA) and the United Kingdom

1. Legal Basis for Processing Personal Information in Europe
If you are located in the EEA or the UK, we process your personal information only when we have a valid "legal basis," including:
a. Consent. You consent to the use of your personal information, such as the use of cookies.
b. Contractual Necessity. We need your personal information to provide our services to you, such as responding to your inquiries.
c. Compliance with Legal Obligations. We are legally obligated to use your personal information, such as complying with tax and accounting obligations.
d. Legitimate Interests. We or third parties have a legitimate interest in using your personal information. Specifically, we have a legitimate interest in using your personal information for product development and internal analysis purposes, as well as to otherwise improve the security, safeguarding, and performance of our services. We will rely on our or third parties' legitimate interests to process your personal information only when these interests are not overridden by your rights and interests.

2. Residents of the EEA and the UK - Your Legal Rights
If you are located in the EEA or the UK, you have the following rights:
● The right to request a copy of your personal information we hold
● The right to request the update/correction of your personal information we hold
● The right to request the deletion of your personal information we hold
● The right to request us to restrict the processing of your personal information we hold
● The right to object to our processing of your personal information based on our legitimate interests
● The right to object to direct marketing processing 
● The right to request the transfer of your personal information to yourself or another provider
● You have the right to withdraw any consent you have previously provided us regarding the processing of your personal information at any time, free of charge. We will continue to apply your preferences, which will not affect the legality of the processing before you withdrew your consent.

If you wish to exercise any of the above rights, please contact us using the details in point 10 below. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that each right has exceptions and limitations, and while any changes you make will be reflected in the active user database immediately or within a reasonable time, we may retain information for backup, archiving, fraud and abuse prevention, analysis, legal obligation fulfillment, or when we reasonably believe we have a legitimate reason to do so.

You also have the right to file a complaint with regulatory authorities, including those in your country of residence, place of work, or where the incident occurred. However, we hope to have the opportunity to address your concerns before you contact the regulatory authorities. Please contact us before escalating your complaint.

5. Data retention

We prioritize protecting your personal information and using it in a manner consistent with legal requirements and member expectations. Your personal information is retained to better provide you with services. When determining the specific retention period (3 years and above), we take into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, and mandatory retention periods imposed by law and statute of limitations.

6. Safety

Phocol understands the importance of protecting the security and integrity of the personal information shared with us and will do its best to protect your personal information. It is also important for you to protect your password and computer from unauthorized access. We strongly recommend that you keep your account login information in a safe place and do not disclose it to anyone. Also, please remember to log out of your account and close your browser window when you are done visiting. This is to ensure that others cannot access your account, especially if you share your computer with others or use your computer in a public place such as a library or internet caf.

You should be reminded that no data transmission or data storage over the Internet is 100% secure. Therefore, while Phocol will strive to protect your personal information, Phocol cannot guarantee the absolute security of such personal information.

7. Use of cookies and similar tracking technologies

We or our third-party partners may use your information through cookies and similar tracking technologies and store such information as log information. The purpose is to provide you with a better user experience and service, and for the following purposes:
(1) Remember who you are. To help us identify you as our registered user, or to save your preferences or other information you have provided to us.
(2) Analyze your use of our services. For example, we may use cookies and similar tracking technologies to understand what activities you use our services for, or which services are most popular with you.
While we use cookies and similar tracking technologies for the above purposes, we may provide the non-personally identifiable information collected through the use of cookies and similar tracking technologies to other partners after statistical processing to analyze how users use our Serve.
Our products and services may use cookies and similar tracking technologies placed by other partners. Non-personally identifiable information about you may be collected for the purpose of analyzing how you use such products or services. The use of these third-party cookies and similar tracking technologies to collect and use such information is not subject to this Privacy Policy, but is subject to the privacy policies of the relevant third parties. We are not responsible for the use of such cookies and similar tracking technologies.
You can refuse or manage cookies through your browser settings. However, please note that if you disable the use of cookies and similar tracking technologies, you may not be able to enjoy the best service experience, and some products or services may not work properly.

8. Third-party websites and third-party applications

Our services may
(1) Contains links to third-party websites;
(2) Includes applications developed and hosted by third parties that are not owned or controlled by Phocol or affiliated with Phocol. Phocol is not responsible for the privacy practices of such third-party websites or applications. Once you enter such third-party website or join such third-party application, this Privacy Policy will no longer apply, and any personal information collected on or about you on such third-party website will be subject to the privacy policy of that third-party website jurisdiction. Your access to such third-party websites and applications is entirely at your own risk. We recommend that you read the privacy policies of third-party websites and applications before disclosing any personal information on those websites and applications.

9. Children’s privacy

Our Services are not designed or intended for use by children under the age of 4, and we do not knowingly collect, maintain or use personal information from children under the age of 4. Children under 4 years of age are not allowed to register on our Services. If you become aware that personal information provided to us by a child violates this Privacy Policy, you may alert us at: support@phocolprinter.com

10. Contact Us

If you have any questions, complaints, or reports, you can contact us through the following methods, and we will respond to your request within 15 days.
Zhuhai Quyin Technology Co., Ltd.
Registered Address: Room 103-029, Floor 1, Building 1, No. 18 Futian Road, Xiangzhou District, Zhuhai City (Centralized Office Area)
Email:support@phocolprinter.com(The email subject should include 【Phocol Personal Information Processing Inquiry】)

11. How we store your personal information

1. The personal information we collect and generate in our operations in the People's Republic of China is, in principle, stored in the People's Republic of China, and your personal information is stored in accordance with the storage period stipulated in the laws and regulations of the People's Republic of China, departmental rules and regulations, and so on.

1.The storage period is for the duration of your use of Phocol or until you send Phocol a request to delete your personal information, and we will delete your personal information in a timely manner when you request the deletion of the stored information or decide to stop using Phocol and cancel your account. We will also retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless there is a mandatory retention requirement by law. For example, the Law of the People's Republic of China on Electronic Commerce requires that information on goods and services and transaction information be retained for a period of not less than three years from the date of completion of the transaction, and that logs of user behavior in connection with the Services be anonymized. The criteria for determining the foregoing period include:

1.to fulfill the purpose of transactions related to you, to maintain corresponding transaction and business records, and to respond to your possible inquiries or complaints;

2.to ensure the security and quality of the services provided to you by the Platform;

3.whether you agree to a longer retention period;

4.whether there is any other special agreement on the retention period.

2.After your personal information exceeds the retention period, the Company will delete or anonymize your personal information in accordance with the requirements of applicable laws (if you are a minor, we will handle your personal information in accordance with the requirements of relevant laws and regulations after your personal information exceeds the retention period). If we are unable to delete your personal information in accordance with the relevant requirements due to special circumstances, we will explain this part of the matter to you.

 

VII. How we protect your personal information

1. We take the security of your personal information very seriously. We strive to protect your personal information by taking all reasonable physical, electronic, and managerial security measures and use our best reasonable efforts to protect your personal information from disclosure, destruction, or loss, including but not limited to SSL, encrypted storage of information, and access control in data centers. We also take strict management of employees or outsourced personnel who may have access to your personal information, including but not limited to adopting measures such as controlling access rights to information, signing confidentiality agreements with personnel who have access to personal information, and monitoring the operation of such personnel.

2. Despite the agreement in paragraph 1 above, please understand that due to the existence of a variety of unpredictable or existing technology can not be defended against malicious means, even if we have tried to take the necessary protection measures, your information may still be leaked, destroyed or lost. If you find that your account number or password has been or will be leaked for any reason, you should contact us immediately so that we can take timely measures to prevent or minimize your losses. 3.

3. In the unfortunate event of personal information security incident, we will activate the contingency plan to prevent the security incident from expanding, and will promptly inform you in accordance with the requirements of laws and regulations of the following: the basic situation of the security incident and its possible impact, the measures we have taken or will take to deal with the incident, the suggestions you can independently prevent and reduce the risk, and remedial measures for you. We will promptly inform you of the situation related to the incident by email, letter, phone call or push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take reasonable and effective ways to publish announcements. At the same time, we will also take the initiative to report the disposition of personal information security incidents in accordance with the requirements of the regulatory authorities.

4. If we undergo a merger or separation of enterprises, your information will continue to be protected by the surviving enterprise subject at that time, and we will notify you by way of announcement, SMS or other written methods; if our products or services cease operation, we will stop collecting your information in time and notify you by way of announcement, SMS, etc., and we will delete or conceal your information at that time. We will delete or conceal your information at that time.