Privacy Protection Guidelines Update time: 2021-6-25 LF Apps and its affiliates (hereinafter collectively referred to as "we"), as a company specializing in comprehensive Internet data services, have always attached great importance to the protection of personal information and privacy protection in data services. We are well aware of the importance of personal information to you and will do our best to protect your personal information safe and secure. We are committed to maintaining your trust in us and abide by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choosing consent, the principle of least sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. . When you browse our website or register and log in to use any of our products and services, we will take appropriate security protection measures to protect your personal information in accordance with the industry's mature security standards. If you have any questions, comments or suggestions, please contact us through the following contact details: Email: cengjinghans@gmail.com Tel: 0751-50217829 Fax: 0751-50217829 Special Note: Our Privacy Policy only applies to the various products and services we provide, including but not limited to: APKs, SDKs, APIs, codes, tools, product documents, etc. we provide, and does not apply to the first Products and services offered by third parties through us, or to which third-party links on our website point. In this case, it is recommended that you carefully read and understand the privacy policy of the third party. This Privacy Policy is closely related to the products and services we offer. Please read the following Privacy Policy carefully to understand how we collect, use, store and transfer information from or about you and your end users. We endeavour to explain to you in a clear, understandable and appropriate manner so that after you read it, you are aware of your rights and make your choices. Please note that by visiting our website or using our services, you signify that you have read, acknowledged and agreed to this Privacy Policy. This policy is in effect throughout your use of the website and services, if you do not agree to this policy, you should immediately stop using our website and the various services detailed below. This Privacy Policy will help you understand the following: 1. How we collect and use your personal information 2. How we use cookies and similar technologies 3. How do we share, transfer and publicly disclose your personal information 4. How we protect your personal information 5. Your rights 6. How we handle children’s personal information 7. How your personal information is transferred globally 8. How to update this policy 9. How to contact us 1. How we collect and use your personal information: Personal information refers to all kinds of information recorded electronically or in other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information. We will only collect and use your or your end users' personal information for the following purposes described in this policy. Unless specifically stated overseas/international versions of websites or products, this service is only available to users in the mainland of the People's Republic of China. If you are located outside the mainland of the People's Republic of China, or the products you use our services are provided to end users outside the mainland of the People's Republic of China, it may involve the collection, storage, use, and sharing of data and personal information in other jurisdictions. Different regulatory requirements. If applicable, you should also abide by the relevant provisions of the "Overseas Personal Information Protection Compliance Commitment"; when we want to use the information for other purposes not specified in this policy, we will ask for your prior consent. When we want to use the information collected for a specific purpose for other purposes, we will ask for your consent in advance. 1. To provide you with online information services When you visit and browse our website, like most websites, we will use cookie technology to store your session/selection information on your computer; - Certain information is automatically collected and stored in log files. This information includes: Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream. We use this information to: - improve your experience using the website and the quality of service; - to help us manage the website content effectively; -Analyze the on-site activities of group users; 2. Overview of using our services 1) When you register for our services, we will ask you to provide your personal information, including name, company, email address, password and mobile phone number to create an account. When you follow up with us and continue to use our services, we may ask you to provide additional contact information, including: - contact mailing address, phone number, title and position; - your business information, such as business name and business type; - Your product information, such as the name, content, category and certain features of the mobile application; promotion channel information, etc. We use this information to: - send you a confirmation of registration; - Understand and manage accounts; - Respond to your customer service requests; - Understand your business and product needs to determine applicable products and services; - to contact you for marketing and promotional purposes and to provide you with more information about our products; - Conduct research and analysis to improve the quality of our website and services; 2) We leave an email address on the website to allow you to contact us proactively. You may provide personal information when you contact us by email, and we will use this information to respond to your questions and service requests and to improve our website and services. 3. Details of using our services 1) Our analysis service We provide data statistics tools and analysis services for mobile applications. After you integrate our data SDK or API in your application, your application will collect and transmit your terminal through technical means. User-related data, which is analyzed through our services to understand the performance of your application on different terminal devices, platforms or application distribution channels, and user usage. Your end user data typically includes: SDK or API version, platform, timestamp, app identifier, app version, app distribution channel, iOS vendor identifier (IDFV), iOS advertising identifier (IDFA), Android advertiser Identifier, IP address (for geolocation only), network card (MAC) address, International Mobile Equipment Identity (IMEI), device model, terminal manufacturer, terminal device operating system version, session start/stop time, language location , mobile network/country code, time zone and network status (WiFi, etc.), hard drive, CPU and battery usage, etc. Depending on the type of your mobile application and your requirements for statistical analysis options, your end-user data may also include: user gender, age, geographic location, user-triggered specific events, device status information (such as sensor data or application listings) ), bug reports and page views, etc. In order to realize the purpose of analysis service and protect the personal information of end users, the data collected by our analysis service will be de-identified by forming its own user identifier on the end user's device, and the above data will be sent to our website in encrypted form. On the server, it is displayed by us in the form of aggregated data and analysis reports. You can check the relevant statistics and analysis results by logging in to the account on our website. In the brand advertising value analysis service, we will not collect and store device characteristic tag information or local area targeting information without the authorization and consent of the end user. We do not use packet sniffing for browser page content; we do not perform browser or device fingerprinting; we do not crawl exposed pages. Under no circumstances will our services operate or alter cookies under the domains of third parties (especially Google), nor do they assist or knowingly allow third parties to do so. 2) Industry report service We will build our database based on the data collected by the analysis service and data obtained through other legal channels, and make performance evaluation or behavior pattern analysis reports applied to publishers, industries, specific regions and markets ( Collectively, the "Industry Reports"). Industry reports will be presented in an unidentifiable aggregated form, including both self-published by us and industry reports customized according to your needs. In special cases, we will also make an evaluation result of a certain or a certain type of application based on our statistical model. The evaluation result may be derived from the data obtained from your application and thus show a certain consistency with your application. , but these assessment results are calculated based on our data model for assessment purposes, and are aggregated and anonymous. 3) Smart Data Market Service (Smart Data Market) We establish a smart data market for data demanders to realize the data and data derivatives (whether in the form of data, tools or application software) that we own or are authorized to trade by the legal rights holder. , collectively referred to as "Data Products") online transactions. We ensure that the ownership of the data products provided by ourselves is clear and abides by the relevant laws and regulations on the protection of personal information. Usually, the data products that are traded and licensed in the data market are de-identified data products. When obtaining personal information data under specific circumstances, it should obtain the explicit authorization of the relevant individual and only obtain the permission to use it within a specific scope. At the same time, we use our best efforts and reasonable care to require third-party data rights holders to ensure that data products meet the above requirements. 4) Consulting services We provide solutions, professional consulting services and consulting services such as Tengyun University. When providing these services, we may require you to provide more personal information to understand your business or product situation. Please decide whether to provide it according to the demand scenario of consulting services. 5) Our big data application service In addition to the aforementioned specific services, we will build our database based on the data collected by the analysis service and data obtained through other legal channels, and conduct big data processing through aggregation, cleaning, de-identification processing, and intelligent computing. means to form a customer group tag information database or a statistical analysis database. On the basis of our own database, we provide industry customers with various forms of big data application services, such as: a. Data marketing services, using big data capabilities to boost precise advertising and marketing, build target customer groups, and comprehensively analyze target customer groups features to improve marketing effects; b. Intelligent location service, using our powerful human-centered data and geographic information data, combined with classic models and prediction algorithms, to solve scene problems such as physical store location selection and store drainage; c. Other data services, Using our database and data processing capabilities, we will also provide a variety of data services to users in various industries, including but not limited to data model establishment services, data asset management services, etc. You should understand and be aware that with the development of the big data industry, our big data services will be updated and iterated or new service methods will be launched. In any case, we will strictly abide by national laws and regulations and big data industry standards 4. Exceptions to the authorization of personal information collection and use According to relevant laws and regulations, the collection of your personal information does not require your authorization and consent in the following situations: 1) It is directly related to national security and national defense security; 2) It is related to public security, Directly related to public health and major public interests; 3) Directly related to criminal investigation, prosecution, trial, and execution of judgments; With my consent; 5) It is necessary for academic research, and the results of academic research or description have been de-identified; 6) The collected personal information is disclosed to the public by you; 7) From Personal information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels; 8) It is necessary to perform the contract you signed; 9) It is used to maintain the security and stability of the products or services we provide Necessary for operation, such as finding and disposing of failures of products or services; 10) Other situations stipulated by laws and regulations. 5. Indirect acquisition of personal information and authorization and consent of end-user data You are very clear that for the purpose of using our data statistics and analysis, you need us to collect, store, and process personal information from end users of your application. Therefore, you must promise: 1) You have obtained the necessary authorization, consent and permission from the end user to allow the use of our services for the purpose required; 2) You have obtained sufficient and necessary authorization, consent and permission from the end user to allow us to process the collected data anonymously and aggregately; 3) You have complied with and will continue to comply with applicable laws, regulations and regulatory requirements, including but not limited to formulating and publishing relevant policies on personal information protection and privacy protection; 4) You have disclosed and explained to end users, allowing us to de-identify and aggregate the collected data, and then build our database to provide data services, but you should also provide end users with An easy-to-use opt-in mechanism that explains how and when a user can exercise an option, and how and when that option can be modified or withdrawn after the option has been exercised, giving users the option to consent or not to the collection and use of their data for commercial purposes. De-identified data of personal information. If your breach of the above commitments causes your end users to assert any form of claim or claim against us, or causes us to be involved in legal or administrative proceedings, you will be responsible for a full settlement and indemnify us for any form of damages we may suffer as a result. loss. List of third-party SDKs for Android OS: Name: Umeng+SDK Service type: Please fill in the collection of personal information according to the functions provided by the SDK. Type of personal information: Device information (IMEI/Mac/android ID/IDFA/OPENUDID/GUID/SIM card IMSI/geolocation information) Privacy Policy Link: https://www.umeng.com/page/policy 2. How we use cookies and similar technologies 1. Cookies To ensure the normal operation of the website, we will store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, websites can store data such as your preferences or the goods or services you have selected. The above cookie technology is limited to the scope of web browser cookies, and we do not use Flash cookie technology for data storage. We will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences. See AboutCookies.org for details. You can clear all cookies saved on your computer, and most web browsers have a cookie-blocking feature. However, if you do this, you will need to personally change your user settings each time you visit our website. For more information on how to change your browser settings, visit each browser's feature options. In addition to cookies, the emails we send you may contain click-through URLs that link to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences and improve customer service. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time. 2. Do Not Track (Do Not Track) Many web browsers are equipped with a Do Not Track function, which can issue a Do Not Track request to a website. Currently, no major Internet standards organization has established policies governing how websites should respond to such requests. But if your browser has Do Not Track enabled, then all of our sites will respect your choice. 3. How do we share, transfer and publicly disclose your personal information 1. Sharing We will not share your personal information with any other companies, organizations and individuals, except in the following cases: 1) After obtaining your explicit consent, we will share your personal information with other parties. 2) We may share your personal information externally in accordance with laws and regulations or the mandatory requirements of government authorities. 3) Sharing with our affiliates: Your personal information may be shared with our affiliates. We will only share necessary personal information and subject to the purposes stated in this Privacy Policy. If the affiliated company wants to change the purpose of processing personal information, it will ask for your authorization again. Our affiliates include: Suzhou Tengyun Tianxia Data Technology Co., Ltd. 4) Sharing with advertisers, advertising alliances or other operators (collectively referred to as "business partners"): We will cooperate with such authorized partners in various forms to share The processed and processed de-identified data in our database is used for commercial purposes, such as using the data to optimize advertising delivery and improve marketing effectiveness. We do not share personally identifiable information (meaning personally identifiable information, such as name or email address, by which an individual can be contacted or identified) with our business partners unless we have permission from you and the end user . We provide these partners with information about the reach and effectiveness of their ads without providing personally identifiable information, or we aggregate this information so that it does not identify individuals. For example, we may only tell advertisers how effective their ads are, or how many people viewed their ads or installed apps after seeing them, or to partner with them only after they agree to abide by our advertising guidelines. Partners provide non-personally identifiable demographic information (eg, "25-year-old male in Beijing who likes software development") to help them understand their audience or customers. Such information alone or in combination with other information cannot identify you and/or your end users personally, and is not your and/or your end user's personal information in the legal sense. For companies, organizations and individuals with whom we share personal information after obtaining the authorization and consent of the subject of personal information, we will sign strict confidentiality agreements with them, requiring them to follow our instructions, this Privacy Policy and any other relevant confidentiality and security measures to process personal information. 2. Transfer We will not transfer your personal information to any company, organization or individual, except in the following cases: 1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer you to other parties 2) When it comes to merger, acquisition or bankruptcy liquidation, if it involves the transfer of personal information, we will require new companies and organizations that hold your personal information to continue to be bound by this privacy policy, otherwise we will require The company or organization seeks your authorization and consent again. 3. Public disclosure We will only publicly disclose your personal information under the following circumstances: 1) After obtaining your explicit consent; 2) Disclosure based on law: We may publicly disclose your personal information when required by law, legal process, litigation or government authorities. 3) In an emergency, reasonably determined to protect the legitimate rights and interests and safety of us, our agents, customers, end users or others. 4) We file lawsuits or arbitrations against users in order to safeguard the legitimate rights and interests of ourselves or other users; 4. How we protect your personal information 1. The data confidentiality measures we take do not have any method of transmission on the Internet, or the method of electronic storage is 100% secure. Although we have made reasonable efforts, it may still be stolen, illegally possessed or abused to you and you. users who bring personal, property and reputation losses. You understand the above risks and voluntarily assume them. We will use industry-accepted and reasonable standards to protect the security and confidentiality of the information we store. Including but not limited to: firewalls and data backup measures; data center access restrictions; encryption of identifying information of mobile terminals, etc. We have established a sound data security management system, including classifying user information, encrypting storage, dividing data access rights, and specifying internal data management systems and operating procedures. There are strict process requirements for data acquisition, use, and destruction to avoid User privacy data is used illegally. We will take all reasonably practicable steps to ensure that irrelevant personal information is not collected. We will only retain your personal information for as long as is necessary to achieve the purposes described in this policy, unless an extension of the retention period is required or permitted by law. We have also established a training mechanism to regularly hold security and privacy protection training to improve employees' awareness of personal information protection. We will review, update and publish our security risk and personal information security impact assessment report from time to time. 2. Emergency response and early warning If a personal information security incident unfortunately occurs, we will promptly inform you of the basic situation and possible impact of the security incident through the in-site letter/contact information you have reserved in accordance with the requirements of laws and regulations. or the emergency response and other relevant disposal measures to be taken, remedies for you, etc. If it is difficult to inform the personal information subjects one by one, we will take a reasonable and effective way to publish announcements and take the initiative to report the handling of personal information security incidents to the relevant regulatory authorities. If you find that your personal information is leaked, please contact us immediately through the contact information agreed in this statement, so that we can take corresponding measures in a timely manner. 5. Your rights In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you exercise the following rights over your personal information: 1. To access your personal information, you can log in to your account and enter the "Account Management" page Access your personal information on your own, subject to exceptions provided by laws and regulations. We will provide you with other personal information generated during the use of our products or services as long as we do not need to invest too much. If you would like to exercise your data access rights, please send an email to [cengjinghans@gmail.com]. 2. Correcting or supplementing your personal information When you find that there is an error in the personal information we have collected about you, or when your personal information needs to be updated and supplemented, you can log in to your account and enter the "Account Management" page to correct it yourself or supplement. Correction of some special information may not be possible on your own, and you can contact us in accordance with or through this Privacy Policy or through the various contact methods posted on our website. To protect your account security, we may require you to verify your identity. 3. Deleting your personal information You can cancel your authorization to collect and use your personal information by canceling your account and setting the OPT-OUT privacy settings on our website. We will stop using and delete your personal information. Please note that we may not delete the corresponding information from the backup system immediately, but will delete the information when the backup is updated. In the following situations, you can request us to delete your personal information: 1) If our processing of personal information violates laws and regulations; 2) If we collect and use your personal information without your consent; 3) If our handling of personal information violates our agreement with you; 4) If you no longer use our products or services, or you cancel your account; 5) If we no longer provide you with products or services. If we decide to respond to your deletion request, we will also try our best to notify the third parties we share with your personal information, and require such third parties to delete your personal information in a timely manner, unless otherwise required by laws and regulations, or such third parties The third party has obtained your independent authorization. If you cannot access, update or delete such personal information through the above path, you can contact us through our customer service at any time. We will respond to your request for access within 15 days. Notwithstanding the above, we may retain certain data for a reasonable period of time, to the extent permitted by law, in order to resolve disputes, enforce user agreements, and comply with technical requirements related to safe operations. 4. Change the scope of your authorization and consent. Each business function requires some basic personal information to be completed (see "Part 1" of this policy). For the collection and use of additionally collected personal information, you can give or withdraw your authorization and consent in specific services at any time. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization. You can reject commercial advertisements through the OPT-OUT channel request to delete your personal information, unless otherwise provided by laws and regulations. 6. Obtaining copies of personal information You have the right to obtain copies of your basic personal information, personal identification information, personal health and physiological information, and personal education and work information by sending a request to our contact person. Under the premise of technical feasibility, such as data interface matching, we can also directly transmit a copy of your personal information to a third party designated by you upon your request. 7. Constraining the automatic decision-making of the information system Based on the authorized and legally collected personal information, we use information systems, algorithms and other non-manual automatic decision-making technologies to achieve labeling or image processing, so as to make automatic decision-making decisions (such as commercial information push), This behavior constitutes data de-identification and no personal information about you is shared, transferred or disclosed to any third party. If these decisions significantly affect your legal rights, you have the right to ask us to explain and we will provide appropriate remedies. If you do not wish to participate in such targeted advertising information push, please cancel through the following OPT-OUT channels. 8. In response to your above request, you may need to provide a written request to ensure your safety, or to prove your identity in other ways. We may ask you to verify your identity before processing your request. We will respond within thirty days. If you are not satisfied, you can also file a complaint through Section IX. For your reasonable requests, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. For those that are unnecessarily repetitive, require excessive technical means (eg, need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (eg, involve backing up information stored on tapes). requests, we may refuse them. In the following cases, according to the requirements of laws and regulations, we will not be able to respond to your request: 1) It is directly related to national security and national defense security; 2) Directly related to public safety, public health and major public interests; 3) Directly related to criminal investigation, prosecution, trial and execution of judgments; 4) There is sufficient evidence to show that you have subjective malice or abuse your rights; 5) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations. 6) Involving commercial secrets. VI. HOW WE PROCESS CHILDREN'S PERSONAL INFORMATION We have made it clear in the service premise that minors are not accepted to register as our users. We do not knowingly collect and use children's data. If your application is designed and developed for children, please ensure that you take the necessary technical measures to ensure that the registration and use of the application by the end user is carried out by the guardian of the child. At the same time, you have formulated a sufficient user agreement and privacy policy to fulfill the obligation of notification. For the collection of children's personal information with parental consent, we will only use it when permitted by law, expressly consented by parents or guardians, or necessary to protect children. or publicly disclose this information. Although local laws and customs define children differently, we consider anyone under the age of 14 to be a child. If we discover that we have collected personal information from a child without first obtaining verifiable parental consent, we will try to delete the relevant data as soon as possible. 7. How your personal information is transferred globally In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. In the course of providing services, we may transfer data collected from you or the end users of your products to our affiliated entities or other third parties outside your jurisdiction, and such transfers will be governed by laws and regulations within the scope of your permission and in accordance with this policy to process and provide adequate protection to your personal information. If you or the end user of your product is located outside the jurisdiction of the People's Republic of China, or when you or the end user of your product is located in the jurisdiction of the People's Republic of China, but we need to transfer outside the jurisdiction of the People's Republic of China , you shall agree to or obtain the consent of the end user regarding this international transfer. We strongly recommend that you consult local professionals to ensure that this transfer in or out complies with local data protection requirements. In particular, when the international transfer involves the European Union or the United States, please pay attention to the legality of personal information and data protection regulations in these countries and regions. 8. How to update this policy We reserve the right to adjust the Privacy Policy at any time in light of changes to the Services, adjustments to applicable laws and policies, and other factors that may be affected. We will not reduce your rights under this Privacy Policy without your express consent. Any updates to this Privacy Policy will be posted on this web page in a time-marked manner, so please feel free to review and understand the Privacy Policy you should abide by. If you do not agree to accept this Privacy Policy, please stop accessing and using our services. For major changes to this Privacy Policy, we will notify you in a more prominent way (such as a pop-up prompt on the first-level page or an internal letter on the site). The major changes referred to in this policy include but are not limited to: 1. Significant changes to our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.; 2. We have undergone major changes in ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.; 3. The main objects of personal information sharing, transfer or public disclosure have changed; 4. Significant changes in your rights to participate in the processing of personal information and the manner in which it is exercised; 5. When there are changes to the responsible department, contact information and complaint channels that we are responsible for handling personal information security; 6. When the personal information security impact assessment report indicates that there is a high risk. This Policy is an integral part of our Terms of Service. 9. How to contact us If you have any questions, suggestions or complaints about our privacy policy, please contact [cengjinghans@gmail.com]. We have set up a dedicated personal information protection department (or personal information protection specialist), you can contact them through the following methods: [cengjinghans@gmail.com] Under normal circumstances, we will reply within 30 days. If you are not satisfied with our reply, especially if you think that our personal information processing has harmed your legitimate rights and interests, you can also file a complaint or report to the regulatory authorities such as Internet, telecommunications, public security and industry and commerce, or you have the right to report The dispute is submitted to the Hangzhou Arbitration Commission for an arbitration award in Hangzhou in accordance with its then-effective arbitration rules.