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Chuanshanjia Privacy Policy

Version Date: August 27, 2021

Effective Date: September 3, 2021


Reminders

We understand the importance of your personal information and will adopt security measures to protect your personal information and privacy pursuant to the provisions in relevant laws and regulations. Therefore, Chuanshanjia and their service provider (Beijing Ocean Engine Co.,Ltd and its affiliates; hereinafter referred to as "We" or the "Company") hereby formulate this Privacy Policy (hereinafter referred to as "this Policy/this Privacy Policy").

Before using Chuanshanjia and its related services, you must carefully read and thoroughly understand this Policy and only use the Platform and its related services once you fully understand and agree to this Policy. By using Chuanshanjia or its related services, this indicates you fully understand and agree to this Policy.

Through this Privacy Policy, we would like to explain to you that, when you use Chuanshanjia and its related services, we will collect, use, store, share, transfer (if applicable), and protect your personal information. In addition, we will tell you how we will process your personal information and the methods we provide for you to search, access, delete, correct, withdraw your authorization and consent, and otherwise protect your personal information. Please pay special attention to the important content, including clauses about your rights regarding your personal information, which have been highlighted in bold.

This Privacy Policy will help you understand:

I. How we collect and use your personal information

II. Our use of cookies and similar technologies

III. How we store your personal information

IV. How we share, transfer, and publicly disclose your personal information

V. How we protect the security of your personal information

VI. Your rights

VII. Use by a minor

VIII. Revisions to and notifications regarding the Privacy Policy

IX. Miscellaneous

I. How we collect and use your personal information

During your use of the Chuanshanjia and its related services, we will collect information when it is legal, legitimate, and necessary. The information we collect or you provide will be used to:

1. Ensure the normal and basic operations of the products;

2. Implement various functions and services;

3. Optimize and improve the products and services;

4. Safeguard the security of the products, services, and users using the products and services;

5. Comply with relevant provisions in laws, regulations, and national standards.

(I) Personal information we directly collect and use

We will collect, through the following means, the information you voluntarily provide when you use the services and, by automated means, the information produced during your use of the functions or acceptance of the services:

1. Ensuring the normal operation of Chuanshanjia and its related services

When you use Chuanshanjia and its related services, we will collect your device model, operating system version number, IP address, WLAN access point, software version number, network access mode, type, status, network quality data, operations, usage, and operation logs in order to ensure the normal operation of the software and services. Please be aware that this information is essential information that we must collect to provide the services and ensure the normal operation of the products.

2. Register and log into Chuanshanjia and related services

(1) When you register and log into Chuanshanjia and its related services, you may create an account with your mobile number, in which case we will verify that your identity is valid by sending a verification code, or you may create an account with your email address and provide the appropriate online identification information, including your password, contact name, contact number, email address, mailing address, enterprise information, and product information. This information is collected to help you complete the registration process and cooperate with Chuanshanjia to receive services.

3. Information we collect during your use of our products or services

When you contact us, we may store your communication/call records and content, the contact information or other information you provide for the purpose of contacting you, helping you solve issues, or recording troubleshooting solutions and results.

4. Personal information we collect indirectly

For the purpose of providing you with better and more personalized services, or jointly providing you with services, or preventing Internet fraud, our affiliates and partners may share your personal information with us pursuant to the relevant laws, agreements with you, or with your consent.

5. You understand and agree to abide by the Compliance Specifications for Chuanshanjia SDK Developers (Link: https://www.pangle.cn/terms/compliance-guide ).

6. The type, field, usage, and purpose of the personal information of end users obtained by the Chuanshanjia SDK has been detailed in the Compliance Specifications for Chuanshanjia SDK Developers:

SDK name Cooperation method Personal information type and field, clipboard call Usage and purpose
Chuanshanjia SDK Ad cooperation [Required information]
(Basic information required by Chuanshanjia for ad impressions)
Device Information:
[Android] Device brand, model, software system version, and other basic information.
[iOS] Device brand, model, OS version, mobile phone system restart time, total disk space, total system memory space, number of CPUs and other basic information.
App information: developer name, app package name, version number, Application Install List and other information.
Other information: carrier information and device time zone.
[Optional information]
(You can choose whether to provide Chuanshanjia with such information to boost ad performance)
[Android] Wireless SSID name, WiFi router MAC address, device MAC address, IP address, geographic location of the device, and device identifier(Such as IMEI, AndroidID, OAID, IMSI, ICCID, GAID, MEID, the specific fields differ depending on the software and hardware versions).
[iOS] IP address, geographic location of the device, and device identifier (Such as IDFV, IDFA the specific fields differ depending on the software and hardware versions)
Only applicable to versions below iOS 3200:
[iOS] Wireless SSID name, WiFi router MAC address, and MAC address of device
Ad cooperation, ad attribution, and anti-cheating

(III) Safeguard the security of the products, services, and users using the products and services

We may record network log information as well as the frequency of use, corrupted data, total installations, usage conditions, performance data, and other information about the software and relevant services in order to help us better understand the operation of Chuanshanjia and its related services. This will allow us to ensure the security and provision of the service.

(IV) Other purposes

We may conduct research, statistical analysis, and prediction using the information you provide or we collect after such information is de-identified. This allows us to improve and enhance the services of Chuanshanjia and provide our users with products or technical service support for making marketing decisions.

We will first obtain your consent before using the information for any other purpose not contained herein or use the information collected for a particular purpose for any other purpose.

We may also collect other information about you as reasonably necessary for the provision of services and the improvement of service quality, including information you provide when contacting our customer service team, completed questionnaires you send to us when participating in a survey, and information we collect when you interact with the affiliates and partners of Chuanshanjia.

At the same time, we may judge the risks to your account by understanding some of your Internet habits and your commonly-used software. We may record some URLs which we think are risky in order to improve your security when using Chuanshanjia services and to more accurately prevent fraud from phishing websites and Trojans.

(V) Personal information collected and used without consent in accordance with the law

Please understand that, in accordance with relevant laws, regulations, and applicable national standards, we will collect and use, without your authorization and consent, your personal information if:

(1) Such action is directly related to national security and national defense;

(2) Such action is directly related to public safety, public health, or major public interests;

(3) Such action is directly related to criminal investigations, prosecutions, trials, or the enforcement of judgments;

(4) Such action is intended to protect the vital interests (such as the life or property) of the personal information subject or others, but is difficult to obtain the consent of the person involved;

(5) Such information is made available to the public by you on a voluntary basis;

(6) Such information is taken from legally and publicly disclosed information, such as legal news reports, published government information, and other channels;

(7) Such information is necessary for entering into or performing the contract as required by you;

(8) Such action is necessary for maintaining the secure and stable operation of Chuanshanjia and its related services, such as discovering and solving problems in Chuanshanjia and related services;

(9) Such action is necessary for legal news reporting;

(10) Such action is necessary for the compilation of statistics or performance of academic research by institutions for academic research in the public interest, provided that the personal information is de-identified when the results of such academic research or statistical descriptions are publicized; or

(11) In other circumstances provided for in relevant laws and regulations.

You are specifically reminded that, if the information cannot be used individually or in combination with other information to identify you, it is not your personal information in the legal sense. When your information can be used individually or in combination with other information to identify you or we use data that cannot be connected with any particular personal information in combination with other personal information about you, this information will be subject to processing and protection as your personal information in accordance with this Privacy Policy during such combined use.

II. Use of cookies and similar technologies

Cookies and similar technologies are commonly used on the Internet. When you use Chuanshanjia and related services, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device in order to collect and store information when you access and use this product. We primarily use cookies and similar technologies in order to realize the following functions or services:

(I) Ensure the secure and efficient operation of products and services

We may set cookies or anonymous identifiers that certify and safeguard security, allowing us to confirm that you have securely logged into the services or whether you have experienced embezzlement, fraud, or other illegal actions. These technologies will also help us improve the service efficiency and accelerate login and response speeds.

(II) Recommend, display, and push content or accounts that may interest you

We may use cookies and similar technologies, such as beacons and proxies, to understand your preferences and usage habits and conduct consulting or data analysis so as to improve the products, services, and user experience and optimize the advertisement selection presented to you.

We promise that we will not use the cookies for any purpose other than those set out herein.

III. How we store your personal information

(I) Information storage locations

In accordance with the provisions in relevant laws and regulations, we will store the personal information collected and produced about you during your operations in the People's Republic of China within the People's Republic of China. Currently, we will not transfer this information outside of the People's Republic of China, but if we do so in the future, we will follow the provisions of the appropriate country or obtain your consent.

(II) Period of storage

We will retain your personal information for only as long as it is necessary to provide Chuanshanjia and its related services. Beyond the necessary period, we will delete or anonymize your personal information, unless it needs to be retained due to relevant laws and regulations.

IV. How we share, transfer, and publicly disclose your personal information

(I) Sharing and transfer of personal information

We will not share your personal information with or transfer it to third parties without your own prior authorization and consent. We only share or transfer personal information that has been de-identified, and the third parties with whom such information is shared cannot use this information to re-identify the natural person it pertains to.

1. Personal information we may share

(1) Information shared with affiliates to realize appropriate functions or services

When you use "Chuanshanjia services" and the products of its affiliates, we will share de-identified personal information about you with these affiliates to safeguard the consistency of the services you receive among the products we and our affiliates provide and to facilitate the uniform management of your information.

(2) De-identified or anonymized information shared with advertisement partners

We may share the information you upload with the partners who entrust us with promotion and ad delivery, provided, however, we do not share information that can be used to identify a user, such as names and ID card numbers. We will only share with these partners the user portraits and tags and the de-identified or anonymized information that cannot be used to identify an individual so as to improve the effective reach of advertisements without allowing the identification of individuals.

(3) Information shared with the business partners to achieve a particular function

When the software service providers, smart device providers or system service providers provide you with services in joint efforts with us, for example, when you need to use the geographical location function, we may collect your location information and relevant device information, such as your device model, operating system version number, International Mobile Equipment Identity (IMEI), and Media Access Control Address (MAC), and provide the same to the aforesaid providers upon de-identification to achieve this function.

2. Prudent assessment of and responsibility constraints on third party subjects whom we share personal information with

(1) Upon your consent, we will only share with third parties the information necessary for achieving the stated purposes. If a third party needs to use the personal information beyond the aforesaid scope of authorization when necessary for its businesses, such party must obtain your further consent.

(2) The third parties with whom we share your personal information will enter into a non-disclosure agreement with us. Concurrently, we will assess the data security capabilities and environments of the third parties, and require such third parties to process such information with confidentiality and security measures that are not inferior to those required herein.

3. Transfer of personal information upon acquisition, merger, or reorganization

We may engage in mergers, acquisitions, and asset transfers in line with the continuous development of our businesses, and your personal information may therefore be transferred. Prior to the aforesaid changes, we will continue to protect or require the new holder of the personal information to continue to protect your personal information in accordance with relevant laws and regulations, as well as security standards that are not inferior to those required herein. Otherwise, we will require such successor to obtain your authorization and consent again.

(II) Public disclosure of personal information

We will not publicly disclose your information, except as required by national laws and regulations or upon your consent. The personal information we publicly disclose about you will be subject to industry-standard security protection measures, for example: When we issue an announcement concerning the penalties imposed on an account that commits violations and/or engages in fraudulent conduct, we will only disclose the necessary information.

(III) Personal information shared, transferred, and publicly disclosed without the need for consent in accordance with the law

Please understand that in accordance with the laws, regulations and national standards, we will share, transfer, and publicly disclose, without your authorization and consent, your personal information if:

(1) Such action is directly related to national security and national defense;

(2) Such action is directly related to public safety, public health, or major public interests;

(3) Such action is directly related to criminal investigations, prosecutions, trials, or the enforcement of judgments;

(4) Such action is intended to protect the vital interests (such as the life or property) of yourself or others, but is difficult to obtain the consent of the person involved;

(5) Such information is made available to the public by you on a voluntary basis;

(6) Such information is taken from legally and publicly disclosed information, such as legal news reports, published government information, and other channels.

V. How we protect the security of your personal information

(I) We attach great importance to the security of your personal information and will endeavor to take reasonable security measures, including technical and administrative measures, to protect your personal information from improper use, unauthorized access, public disclosure, use, modification, damage, loss, or leakage.

(II) We will use encryption technology, anonymization, and other reasonably practicable means that are not inferior to those adopted by industry peers to protect your personal information, and use security protection mechanisms to protect your personal information against malicious attacks.

(III) We will establish a security department, a security management system, and data security processes that are dedicated to safeguarding the security of your personal information. We will adopt strict data use and access systems to ensure that only authorized personnel may access your personal information and we will conduct security audits on the relevant data and technologies from time to time.

(IV) Although the reasonable and valid measures mentioned above have been adopted and the standards required in applicable laws and regulations have been complied with, please understand that in the Internet industry, it is impossible to always ensure the total security of information even if we try our best to enhance security measures due to technical limitations and various possible malicious techniques. However, we will endeavor to ensure the security of the personal information you provide to us to the greatest extent possible. You acknowledge and understand that the system and communication network for your access to our services may fail due to factors beyond our control. We therefore strongly suggest that you adopt active measures to protect the security of your personal information, including but not limited to using strong passwords, regularly modifying the passwords, and not disclosing your personal information including your passwords to others.

(V) We will formulate contingency plans and, in the event of a security event involving user information, immediately implement such plans to prevent the expansion of the impact and consequences of such security events. Once any personal information security event (leakage, loss, etc.) occurs, we will, as required by relevant laws and regulations, promptly notify you of the following: basic information and possible impact of the security event, handling measures we have taken or will take, suggestions on how to prevent and lower your risks on your own, as well as the corresponding remedial measures. We will promptly notify you of relevant information by push notification, email, correspondence, SMS, or other means, and when it is difficult to give notification to the involved parties individually, we will adopt reasonable and effective means to publish an announcement. Meanwhile, we will also report the handling of the security event involving user information as required by the competent authorities.

(VI) You are hereby specifically reminded that the personal information protection measures provided herein only apply to Chuanshanjia and its related services. By logging out of Chuanshanjia and its related services and browsing or using other websites, services, and content resources, we will not be able or be obligated to protect any personal information you submit to the software and websites outside of Chuanshanjia and its related services, irrespective of whether your login, browse, or use the aforesaid software and websites based on links or instructions provided on Chuanshanjia.

VI. Management of personal information

We attach great importance to the management of your personal information and do our utmost to protect your rights to search, access, modify, and delete your personal information, close your account, submit complaints and reports, and set privacy functions so that you will be able to safeguard your privacy and security. The specific paths by which you can search, access, modify, and delete your information shall be the ones provided in the appropriate products or services in Chuanshanjia.

You may also contact us by logging into the "User Feedback" page in the Chuanshanjia client or through the "Contact Us" portal on the official website. We will promptly process and respond to your feedback.

You may submit complaints or reports using the systems we indicate. If you believe that your rights to your personal information may have been violated or you discover any evidence of such a violation (for example, if you believe that our collection of your personal information violates relevant laws and regulations or the agreements between the parties), you may contact us by sending an email to union_service@bytedance.com. Upon verification, we will provide immediate feedback with respect to your complaints.

If we stop operations, we will promptly cease collecting your personal information, notify you of the ceasing of operations by individual notification or an announcement, and delete or anonymize your personal information held by us.

VII. Use by a minor

If you are a minor under the age of 18, you shall read and agree to this Privacy Policy under the guardianship and direction of your parents or guardians before using Chuanshanjia and its relevant services.

We will protect the personal information of a minor in accordance with the provisions in applicable national laws and regulations and will only collect, use, store, share, transfer, or disclose the personal information of the minor where permitted by law, with the express consent of the parents or guardians or when it is necessary to protect the minor. If we discover that the personal information of a minor has been collected without prior verifiable consent of their parents or guardians, we will try to delete such information as soon as possible.

If you are the guardian of a minor, please contact us through the contact information provided in this Privacy Policy if you have any questions about the personal information of the minor under your guardianship.

VIII. Revisions to and notifications regarding the Privacy Policy

(I) To provide you with better services, Chuanshanjia and its relevant services will be subject to updates and changes from time to time. As appropriate, we will revise this Privacy Policy from time to time, with such revisions forming an integral part of this Privacy Policy.

(II) After this Privacy Policy is updated, we will release the updated version on Chuanshanjia and remind you of the updated content through an announcement on the official website or any other appropriate means before the updated terms take effect so that you may immediately understand the latest version of this Privacy Policy.

IX. Miscellaneous

This Privacy Policy applies to the products or services on Chuanshanjia. If the products or services of Chuanshanjia have been used by the products or services of our affiliates but no separate privacy policy is set, this Privacy Policy also applies to such products or services.

It should be particularly noted that this Policy does not apply to the services provided to you by other third parties nor the products or services for which Chuanshanjia has set a separate privacy policy.

Please be aware that Chuanshanjia and its related services stated herein may vary depending on your mobile device model, system version, software app version, mobile client, etc. The final products and services shall be subject to Chuanshanjia software and its related services you use.

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