Privacy Policy

Date of Issue: 12/20/2019

Effective Date: 12/20/2019

Preface

Welcome to use the Operating System (the "Product") and related services (Collectively, the "Product and Services") developed by Xi’an Ousiqi Software Co., Ltd. ("us" or the "Company"). The Privacy Policy (the "Policy") represents our commitment to protecting your privacy, and we will strictly comply with and implement the Policy. We hope our efforts can reassure you and let you feel safe when using our Product and Services.

The Policy will help you understand:

I How we collect and use your personal information

II How we store your personal information

III How we share, transfer and disclose your personal information

IV The privacy policy involved in our provision of advertising services

V How we protect your personal information

VI Your right to manage your personal information

VII Protection of minors' personal information

VIII Application scope of the Policy

IX Change and modification of the Policy

X How to contact us

XI Updates to this Policy

Please read and comprehend the Policy carefully before using our Product and Services, and do not use our Product or Services until you fully understand and agree to the Policy. Your use of our Product and Services means you fully understand and agree to the Policy, and allow us to collect, use, store and share your personal information according to the Policy. If you have any question, advice or suggestion about the Policy, please contact us by the contact information provided in the Policy.

I How we collect and use your personal information

You may need to provide your personal information when you use our Product or Services. You don't have to provide your personal information to us. However, in some cases, your refusal to provide personal information will make us unable to provide Product or Services to you, or unable to respond to or solve your problem.

We will only collect and use your personal information for purposes described herein, which are as follows:

(1) The information that we will collect in your process of using our Product or Services:

1 Information related to your mobile phone terminal: we collect IMEI (International Mobile Equipment Identity), IMSI (International Mobile Subscriber Identity), MAC (Media Access Control) address, sequence number, equipment name and equipment identification code to provide basic equipment and system usage services;

2 Information arising from your use of our Services: we collect mobile phone numbers and SMS numbers from you so as to provide quality call rejection services;

3 Your location information (only used for certain services/features): we collect location information only for providing certain services (Such as weather services, map navigation services, geographical positioning of photos, anti-theft services, emergency call, calendar and time zone change, and personalized advertising). We will not make the collected location information related to your account and identity information, record your movement, or use the information above for any purpose other than providing related Services. Meanwhile, you can disable the location service in the mobile phone settings (search “location information” and click to close the related service). We will stop providing location-based services if we are disallowed from collecting your location information.

4 Log information arising from your use of our Services: we collect the information about your use of certain features or websites (such as error logs and active user feedbacks), so as to update and upgrade our Services;

5 We may identify your facial information through a camera system when some of our Product or Services are unlocked through facial recognition. All the data generated therefrom will be encrypted, and only be saved in your mobile phone or other terminal device (the "Device") for identity authentication and unlocking the Device. Such data will never be transmitted or stored outside of your Device.

6 If you upload Contact list, SMS, call log, application installation list, calendar and schedule information, photos and videos information data onto cloud, and you have enabled cloud backup services, we will have to store the backup data and the record that your use of the cloud platform.

7 When you use a third-party account to login, we may need to collect your account information (such as nickname, head portrait and account number) from such third party so as to provide services to you. We will acquire your explicit prior approval if our processing of your personal information goes beyond the scope of the authorization that you have granted to the third party.

(2) Non-personally identifiable information

Subject to applicable laws and regulations, we may anonymize, summarize, desensitize and encrypt your personal information so as to generate statistics or user profile (such user profile cannot be used to identify any individual, hereinafter referred to as "Non-Personally Identifiable Information"), in a bid to improve our Services provided to you.

(3) Personal information that can be collected without your approval:

Without your prior approval, we will not use the information collected hereunder for any purpose undescribed herein or purpose different from what such information is originally intended for. However, subject to applicable laws and regulations, we may collect your personal information without your authorization or approval in any of the following cases:

1 Collecting information related to national defense or national security;

2 Collecting information related to public security, public health or material public interests;

3 Collecting information related to criminal investigation, prosecution, trial and enforcement of judgements;

4 We need to collect information for the purpose of protecting lives, properties and other major legitimate interests of personal information subjects or other individuals, which will be difficult to obtain your approval;

5 Collecting information that is already disclosed to public by yourself;

6 Collecting information from legal and open sources, such as legal media report, government information channels;

7 Collecting information required to sign contracts upon your request;

8 Collecting information required to ensure the safe and stable operation of the Product or Services, such as detecting and/or removing any failures in our Product or Services;

9 Collecting information required by legal media report;

10 Personal information is collected by academic institutions to conduct statistical or academic research projects that can enhance public interests, and the personal information contained in results of such research projects is de-identified when being disclosed for academic research or for describing such results;

11 Other situations required by applicable laws and regulations.

II How we store your personal information

The information collected and generated in People's Republic of China (PRC) is stored within PRC.

If we may transmit domestically-collected personal information to overseas institutions in the process of providing cross-border services, such transmission shall comply with all applicable laws, administrative rules and related regulatory requirements. We ensure your personal information is well protected via measures such as anonymization, encryption, among others.

We only store your personal information within the period necessary for fulfilling purposes described herein and/or the period required by law.

If we stop to operate our Product or Services, we will immediately stop all activities of collecting your personal information, inform you of such stop on a case by case basis or via a public notice, and delete or anonymize all the stored personal information.

III How we share, transfer and disclose your personal information

(1) Share

We will not share your personal information with any company, organization or individual except:

1 We may share your personal information with others after obtaining your explicit approval;

2 We may share your personal information to comply with applicable laws and regulations, to settle a lawsuit or dispute, or to fulfill requirements set forth by administrative or judiciary authorities;

3 Subject to applicable laws and regulations, we may share your personal information to protect the interests or properties, or ensure the safety of yours, ours, our affiliates or partners, other users, or the public benefit.

4 We may disclose your personal information to our affiliates who provide services to you or us, but such disclosure shall be on need-to-know basis, and our affiliates receiving your personal information agree to be bound by the Policy. Our affiliates will never change the purposes of your personal information without your authorization and approval.

5 Unless explicitly authorized or permitted by yourself, we will never share your personal information with any third-party advertisers, program developers, open platform or other partners. However, we may provide them with summarized and anonymized information or other information that is not personally identifiable. For instance, we may tell program developers how many people have installed their programs.

6 We may share your personal information with our suppliers, service vendors, advisors or agents only for the purpose of the Policy, so as to improve our customer services and user experiences. Such suppliers, service vendors, advisors or agents may be providing technological infrastructure to us, analyzing the ways our services are used, measuring the efficiency in advertising and services, providing customer services or payment services, conducting academic researches and investigations, or acting as legal, financial and technological advisors. For instance, we may invite registered users to join lucky draw activities from time to time. If you win a prize in the lucky draw activities, we may send your personal information to related logistics service providers so that they can send the prize to you.

7 We will enter into stringent data protection agreement with companies, organizations and individuals that we share your personal information with. Such agreement will oblige the recipient of your personal information to process your information pursuant to our requirements, the Policy and other applicable confidentiality and security rules.

(2) Transfer

We do not transfer your personal information to any other company, organization or individual except:

During the development of our business, we and our affiliates may undergo merger, acquisition, asset transfer or other similar transactions that involve transfer of your personal information, where we will require the company, organization and individuals receiving your personal information to be bound by the Policy or regain your authorization and approval for use of your personal information.

Information transfer is made with your explicit approval, which means we will transfer your personal information to another party with your explicit approval.

(3) Disclosure

We only disclose your personal information to public when:

1 We have obtained your explicit approval;

2 We are required to do so by applicable laws, legal proceedings, litigation process or competent government authorities;

3 We are required to do so by applicable laws and regulations in other cases.

IV The privacy policy involved in our provision of advertising services

(1) Personalized advertising services

Subject to applicable laws and regulations, we may use your location information that is collected in the process of using core and other features, or collected through our partnership with a third party, in a bid to assess advertising-related statistics. Based on the assessment results, we may present to you the advertisements that can best fit your need and interest you. Such practices aim to bring the best experiences, the most important information and the most relevant advertisement to you. We are committed to delivering the best experiences. We will share your personal information only on a need-to-know basis and only for appropriate, legitimate, necessary, specific and clear purposes. We will not use your location information for any purpose other than personalized advertising.

Meanwhile, we know that some users may not want to receive advertisement that is pushed based on their interests or browsing history. If you disapprove of our personalized advertising services, you can disable the location service in the mobile phone settings (search “location information” and click to close the related service). If you decline to provide location information, you will only be unable to receive location-based advertising services, and your use of other features of the Product will not be impacted.

(2) Privacy policy of third-party advertising service provider

Advertising services provided by a third party shall be subject to the privacy policies released by such third party ("Third-Party Privacy Policies"). If you have any problem regarding any Third-Party Privacy Policy, you may communicate with us at the contact email address provided herein.

V How we protect your personal information

We have adopted safety measures that are commonly used in the industry to protect your personal information and prevent related data from any unauthorized access, disclosure, use, change, damage or loss. We will take all reasonable and feasible measures to protect your personal information.

1 We encrypt personally identifiable information in the process of transmitting and storing so as to ensure its confidentiality. We use MD5 algorithm to anonymize and encrypt the International Mobile Equipment Identity (IMEI) of your mobile phone, and only collect and upload the anonymized and encrypted identities.

2 If our applications use WebView technology, we may verify URL for all file protocols that are used in WebView, and restrict access to sensitive data and SDCard data of such applications, so as to avoid any unpermitted use or steal of private files or sensitive information of our product, and thereby prevent leakage of any of your personal information.

3 We put in place an access control mechanism in the service side, and apply principle of least privilege to employees who may have access to your personal information. In addition, the list of such employees and their access record are examined regularly.

4 We will store users' personal information in server operating system with reinforced security. We also audit and monitor accounts in server operation. If any external announcement reveals any security issue in any server operating system, we will upgrade the system security at our earliest opportunity so as to ensure security of all our server systems and applications.

5 We will regularly train our employees to learn more about laws and regulations applicable to personal information protection, and thereby strengthen their awareness of protecting user's privacy.

6 If any of our physical, technological or administrative security measures is disrupted, we may use contingency plans to keep the security incident under control, and report such incident to competent government authorities according to applicable laws and regulations. In addition, we may timely inform you of such security incident, its impact and the measures we have taken and will take via push notification, public notice or any other reasonable and effective manners.

VI Your right to manage your personal information

You may revoke your consent to the collection or use of your personal information by disabling the location service in system setting. You can also enable or disable certain feature or authorization through authority management.

Some basic personal information is necessary in order to provide the services requested by you. Therefore, please bear in mind that revoking your consent or authorization can make us unable to provide services that require such consent or authorization, and we do not process related personal information without such consent or authorization. Nevertheless, your revoking of such consent or authorization shall not impact the prior processing of personal information that is already authorized by you.

VII Protection of minors' personal information

Minors must be accompanied by their guardians during the use of our Product and Services, and the guardians shall read the Policy in such minors' best interest. Minor users shall seek guidance and approval of their guardians before submitting personal information. If you are a guardian of a minor user, and you have any question about personal information of such minor user, you may get in touch with us at the contacts specified in Article 10 of the Policy.

VIII Application scope of the Policy

(1) The Policy is not applicable to third-party products or services contained in our Product. Providers of such third-party products or services (the "Third-Party Providers") may collect your information when you use such products or services. Therefore, we remind you to read the privacy policies of the Third-Party Providers.

(2) The Policy is not applicable to the data collection of external websites after you click certain hyperlinks.

IX Change and modification of the Policy

Our privacy policy may change. We do not restrict your rights under the Policy without your explicit approval.

We will notify you of any major changes in the Policy in a highly noticeable way (for instance, when you re-login or when a software is revised or upgraded, we may show a popup).

The aforementioned major changes described in the Policy include, without limitation:

◆ Any major change in our service mode, including the purpose of processing personal information, the types of processed personal information and the ways of using personal information, among others.

◆ Any major change in our control, such as owner change caused by merger & acquisition or restructuring;

◆ Any change in the persons or entities that we share personal information with, or transfer or disclose personal information to;

◆ Any major change in your rights regarding personal information processing and ways to exercise such rights;

◆ Any change in our department responsible for safeguarding personal information, our contact information or complaint channels; or

◆ High risks specified in personal information risk assessment reports.

X How to contact us

If you have any question, advice, suggestion or complaint regarding the Policy or the processing of your personal information, you may send an email to [supportab@126.com].

Normally, we will reply to you within 15 workdays.

Our Registered Address is: 17th Floor, East Tower, Singapore Teng Fei Ke Hui City, 88 Tiangu 7th Road, Yanta District, Xi’an, Shaanxi Province.

XI Updates to this Policy primarily includes:

1 Detailing the types of collected information, such as information that is generated in the process of using our Product or Services, or provided by you;

2 Updating the circumstances where information is used.

3 Updating the contents of personalized advertisements that are pushed.

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