BrainFlex+ Privacy Policy

Updated: 2024.7.4

Effective Date: 2024.7.4

 

Preface:

This "BrainFlex+ Privacy Policy" (hereinafter referred to as "this Policy") is signed between the user (you) and BrainFlex+ (hereinafter referred to as "we"), and is signed and effective on the date when the user obtains and uses our products and services. The establishment, performance, interpretation and dispute resolution of this Policy shall be subject to the laws of the People's Republic of China and exclude the application of all other conflict of laws. This Policy is established in Guangzhou Liwan District. If the two parties have any disputes over the content or implementation of this Policy (including but not limited to contractual or other property rights disputes), the two parties shall resolve them through friendly negotiation; if the negotiation fails, the two parties agree to submit the case to the jurisdiction and handling of the People's Court where this Policy is signed.

Important Notes:

1. We own the ownership and operation rights of all services and contents provided by the BrainFlex+ mobile application APP. We promise to pay the highest level of attention to the protection of user personal information and handle this information with the utmost caution and diligence. Before you download, install, start, browse or use this software and related services in any way, we strongly recommend that you read the following agreement carefully. By actively checking the "Agree" option or actually using this software, you will be deemed to have read, understood and accepted all the terms in this policy. Thereafter, users shall not raise any form of defense on the grounds of not reading/not agreeing to the content of this policy or similar reasons. If you disagree with any of the following, please stop visiting this website or using the services of this website immediately.

2. We especially remind users to read all the terms of this policy carefully, especially the terms that exempt or limit our liability (such terms usually contain words such as "not responsible" and "no guarantee"), the terms that restrict your rights (such terms usually contain words such as "may not", "should not", "not allowed", "prohibited", etc.), the applicable law and dispute resolution terms. These terms should be applied to the greatest extent permitted by Chinese law, and such terms are usually marked in bold.

3. If the user is under 18 years of age, he/she must read this policy in the presence of a guardian and pay special attention to “VI. Protection of Minors”.

 

This Privacy Policy helps you understand the following:

I. definition

II. How we collect and use personal information

III. How do we store, protect and manage personal information?

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

V. How do you access and manage your personal information?

VI. Protection of Minors

VII. Scope of application

VIII. Notice and Revision

I. Definition

1. “Affiliates” means companies related by common ownership or control. Control means the ability to directly or indirectly influence the management/operations of the controlled entity through ownership, voting shares, contracts, actual operating relationship or other legally recognized means.

2. “Third Party” refers to any company, natural person or other organization other than us, you, the user and our affiliates.

3. “Personal information” refers to any information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person alone or in combination with other information, but does not include anonymized information. For the personal information referred to in this policy, please refer to the types and scopes listed in the clause “How we collect and use personal information”.

4. “Sensitive personal information” refers to personal information that, once leaked or illegally used, is likely to infringe upon the personal dignity of a natural person or endanger the personal or property safety, including information such as biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts, and personal information of minors under the age of 14. Sensitive personal information referred to in this policy will be marked in bold and underlined form.

5. “De-identification” refers to the process of technically processing personal information so that it is impossible to identify or associate the subject of personal information without the help of additional information. For example, using pseudonyms, encryption, hash functions and other technical means to replace the identification of personal information.

6. “Anonymization” means processing personal information so that it cannot identify a specific individual and cannot be restored.

 

II. How we collect and use personal information

When you open or use BrainFlex+, we will process relevant information to realize the functions and services you choose to use, or to comply with the requirements of laws and regulations. In addition to the information required to realize the basic business functions and services of this software, and the information required according to laws and regulations, you can refuse us to process other information, but this may result in us being unable to provide the corresponding functions and services or unable to achieve the intended effect of using the relevant services.

(I) Personal information we directly collect and use

We will collect information that you actively provide when using the Services, as well as information generated by you in the process of using features or receiving services through automated means for the following purposes:

1. Ensure the normal operation of BrainFlex+ and services

When you use BrainFlex+ and related services, in order to ensure the normal and safe operation of the software and services , identify the abnormal status of your device, understand the product adaptability, prevent phishing website fraud and Trojan virus, find and connect to devices on the local network, and provide you with page display, browsing, and search services that better meet your needs , we will collect your unchangeable device unique identifier (such as IMEI number, AndroidID, IDFA, IDFV, ICCID, GUID, OPENUDID, SIM card IMSI information), hardware model, operating system version number, network device hardware address (MAC), IP address, Internet service provider (ISP), software version number, network access method and type, and operation log information . Please understand that this information is the basic information that we must collect to provide services and ensure the normal operation of products. If you refuse to provide the above information, you may not be able to use our products and services normally.

2. Help you complete payment settlement

When you make a payment settlement in this software, we will collect your order information (such as purchased items, subscription time, payment time) and transaction status. We will obtain information on whether your payment is successful from channels such as WeChat, Alipay, and IOS system. We collect the above information to confirm your order status in order to provide you with services, protect your property safety, and handle user disputes. If you do not agree to our collection of the above information, you may not be able to purchase value-added services because you cannot complete the payment settlement.

3. Assess your mental state

In order to better evaluate your mental state, we need to collect your gaming experience, usage habits, preferences and interactions to analyze your gaming test results. However, please be aware that the evaluation results are only for entertainment purposes and are not equivalent to medical identification or certification. They have no legal effect and are for your reference only.

4. Provide you with search services

In order to analyze features and profile user populations, to help present more relevant content in tool materials and advertising content recommendations, and to reduce your time to filter through massive amounts of Internet content, we will automatically collect your search keyword information and log records (search terms you use , URL addresses of social media pages you visit, length of stay, preferences, search frequency, refresh records, release records, attention, subscriptions, collections, and sharing) through cookies, web beacons, or other means . Analyzing usage data helps us analyze operational results, maintain and improve existing services, and plan and design future services and products. We may use and adjust service content based on your personal data to better suit your personal preferences, and may provide you with customized discount information. In order to provide efficient search services, some of the aforementioned information will be temporarily stored in your local storage device, and search results and search history may be displayed to you.

5. Providing you with customer service support and dispute resolution

When you contact our customer service or use other user response functions (such as submitting in-sales or after-sales applications, complaints or suggestions on personal information protection, and other customer complaints and needs), we need you to provide necessary personal information to match and verify your user identity in order to protect the security of your account and system. We will also save your contact information (other contact information you use when contacting us or that you proactively provide to us), your communication/call records and content with us, and other necessary information related to your needs, so as to contact you or help you solve problems, or record solutions and results for related problems.

6. Provide you with information about products, operations, etc.

We may provide you with information about products, operational activities, etc. for marketing purposes through text messages or other means. If you do not wish to receive the above information, you can unsubscribe at any time according to the text message prompts or other methods we provide.

7. Help you improve your access experience

In the process of using the BrainFlex+ software and its related services, in order to ensure that you can enjoy a smooth and safe experience, we may use specific technologies to send cookies or anonymous identifiers to your device. These technologies are mainly used in the following aspects: By setting authentication-related cookies or anonymous identifiers, we can confirm whether you have logged in safely and whether there is any unauthorized access or fraud. These technologies can also help you save the steps and processes of repeatedly filling in personal information and frequent logins, improve service efficiency, and increase login and response speed. In the sharing page of the software, we may use these technologies to track browsing activities, recommend relevant content to you, and help us diagnose and solve service anomalies such as program crashes or delays, and explore ways to provide better services. At the same time, we may aggregate non-personally identifiable information collected through cookies and similar technologies and share it with advertisers and other partners, which is mainly used to analyze how users use our software and services and optimize advertising. We assure you that the use of cookies is strictly limited to the purposes described in this privacy policy and will not be used for any other purpose.

(II) When you use the BrainFlex+ function, you may obtain the following permissions of your terminal device:

1. Camera and photo permissions

When you use functions such as modifying your profile picture, uploading photos, and taking photos, we will need to obtain your device camera permissions and photo permissions, and collect the picture content information (personal information) provided by you or in the phone storage space. This permission requires your authorization. If you refuse to provide it, you will only be unable to use this function, but it will not affect your normal use of other functions of the product and/or service. You can refuse when we request authorization from you or turn off the authorization of this permission through your device.

2. Privacy tracking permissions

During your use of BrainFlex+, in order to remember your identity, analyze your use of BrainFlex+, and identify you as a user of BrainFlex+, we will need to obtain your privacy tracking permission and collect your device advertising identifier IDFA. This permission requires your authorization. If you refuse to provide it, it will not affect your normal use of other functions of the product and/or service. You can refuse when we request authorization from you or turn off the authorization of this permission through your device.

3. Notification permissions

After you enable notification permission, we can provide you with information reminders so that you can learn about the dynamics of our products and access our products more quickly. This permission requires your authorization. If you refuse to provide it, you will only be unable to enjoy this function, but it will not affect your normal use of other functions of the product and/or service. You can refuse when we request authorization from you or turn off the authorization of this permission through your device.

 

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

Please understand that in the following circumstances, in accordance with laws, regulations and relevant national standards, we do not need to obtain your authorization or consent to collect and use your personal information:

1. Related to our fulfillment of obligations stipulated by laws and regulations;

2. Directly related to national security and national defense security;

3. Directly related to public safety, public health, and major public interests;

4. Directly related to criminal investigation, prosecution, trial and execution of judgment;

5. For the purpose of protecting the life, property and other major legitimate rights and interests of the subject of personal information or other individuals, but it is difficult to obtain the consent of the individual;

6. The personal information collected about you is disclosed to the public by you on your own initiative;

7. Your personal information is collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;

8. Necessary to enter into or perform a contract at your request;

9. Necessary for maintaining the safe and stable operation of the software and related services, such as discovering and handling failures in the software and related services;

10. Necessary for legitimate news reporting;

11. When academic research institutions conduct statistical or academic research based on public interests and provide the results of academic research or descriptions to the public, they shall de-identify the personal information contained in the results;

12. Other circumstances prescribed by laws and regulations.

 

III. How do we store, protect and manage personal information?

1. We attach great importance to the security of your personal information and will strive to take reasonable security measures (including technical and management aspects) to protect your personal information and prevent the personal information you provide from being improperly used or accessed, disclosed, used, modified, damaged, lost or leaked without authorization. We will use encryption technology and anonymization processing that are no less than those of our peers in the industry to protect your personal information, and use security protection mechanisms to prevent your personal information from malicious attacks. We will establish a special management system, process and organization to ensure information security.

2. We are committed to taking all possible measures to protect the personal information you provide to maintain its security. However, you are aware and understand that due to the limitations of current technology and risk prevention measures, even if we have implemented the highest standard of security measures, the absolute security of information cannot be guaranteed 100%. The system and communication network you use to access our services may have problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of your personal information.

3. We will formulate emergency response plans and immediately activate them when a user information security incident occurs, and strive to prevent the impact and consequences of such security incidents from expanding. Once a user information security incident (leakage, loss) occurs, we will promptly inform you of the relevant possibilities, risks and remedial measures in accordance with the requirements of laws and regulations. We will promptly inform you of the relevant circumstances of the incident in the form of push notifications, emails, letters, and text messages. When it is difficult to inform you one by one, we will take reasonable and effective measures to issue announcements. At the same time, we will also report the handling of user information security incidents in accordance with the requirements of relevant regulatory authorities.

4. In accordance with the provisions of laws and regulations, we will store your personal information collected and generated during domestic operations within the territory of the People's Republic of China. Since we provide products or services to users through resources and servers around the world, if you are not located in China, your personal information may be transferred to overseas jurisdictions of the country/region where you use the products or services, or be accessed from these jurisdictions. At the same time, your jurisdiction may have different data protection laws, or even no relevant laws. In such cases, we will ensure that your personal information is sufficiently protected in the territory of the People's Republic of China. For example, we will request your consent to the cross-border transfer of personal information, or implement security measures such as data anonymization before cross-border data transfer.

5. We will only retain your personal information for the period necessary for the purpose of providing this product and service. After the necessary period, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations. If we terminate the service or operation, we will promptly stop the collection of your personal information, and will comply with relevant laws and regulations to notify you in advance, and delete or anonymize your personal information after the period necessary for the purposes described in this policy, the time limit required by laws, regulations and regulatory requirements, or after the termination of the service or operation, unless otherwise provided by laws, regulations or regulatory authorities.

6. We hereby remind you that the personal information protection measures provided in this privacy policy only apply to this software and related services. Once you leave this software and related services and browse or use other websites, services and content resources, we have no ability and obligation to protect any personal information you submit to software and websites other than this software and related services.

 

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

(I) Sharing and transfer of personal information

1. We promise not to share or transfer your personal information with any third party unless we have obtained your explicit authorization in advance, or the shared information has been de-identified to ensure that any third party cannot re-identify the natural person behind the information.

2. According to the law, sharing and transferring de-identified personal information, and ensuring that the recipient of the personal information cannot restore and re-identify or associate the subject of the personal information, does not constitute external sharing, transfer or public disclosure of personal information, and the preservation and processing of such personal information will not require additional notification to you and your consent. In order to achieve programmatic advertising display, we may share de-identified or anonymized information with advertising partners to help them improve the accuracy and effective reach of advertising without identifying your personal identity.

3. With your consent, we will only share information with third parties for specific purposes when necessary, and ensure that these third parties sign confidentiality agreements with us and commit to taking confidentiality and security measures no less stringent than those required by this Privacy Policy to handle your personal information. If a third party does need to use personal information beyond the scope of authorization, they will need to obtain your consent again.

4. As our business continues to develop, we may merge, acquire, or transfer assets, and your personal information may be transferred as a result. When the aforementioned changes occur, we will continue to protect or require the successor of your personal information to continue to protect your personal information in accordance with laws and regulations and security standards no less stringent than those required by this Privacy Policy, otherwise we will require the successor to obtain your authorization and consent again.

5. To ensure the realization of relevant functions and the safe and stable operation of applications, we may access software development kits (SDKs) provided by third parties to achieve relevant purposes. Before that, we will conduct strict security monitoring to protect data security. Please note that the third-party SDK may cause certain changes in data processing types due to version upgrades, policy adjustments, etc. Please refer to its official instructions.

The above third-party social media or other services are operated by the relevant third parties. Your use of such third-party social media services or other services (including any information you provide to such third parties) is subject to the third party’s own terms of service and information protection statement (not this policy), and you need to read their terms carefully. This policy only applies to personal information collected by us and does not apply to any services provided by any third party or the third party’s information use rules. If you find that these third-party social media or other services have risks, it is recommended that you terminate the relevant operations to protect your legal rights and interests and contact us in a timely manner.

(II) Public Disclosure of Personal Information

We will not disclose your information publicly unless necessary information is required to be disclosed when announcing penalties for illegal accounts or fraudulent behavior, or in compliance with national laws and regulations or with your consent. When we disclose your personal information publicly, we will adopt security protection measures that meet industry standards.

(III) Personal information that is exempted from obtaining consent for provision or disclosure in accordance with the law

Please understand that in the following circumstances, in accordance with laws, regulations and national standards, we do not need to obtain your authorization or consent to provide or disclose your personal information to our partners or third parties:

1. necessary for the conclusion and performance of a contract to which you are a party, or for the implementation of human resources management in accordance with labor rules and regulations formulated in accordance with the law and collective contracts signed in accordance with the law;

2. Necessary for the performance of statutory duties or obligations;

3. Directly related to national security and national defense security;

4. It is necessary to respond to public health emergencies or to protect the life, health and property safety of natural persons in emergency situations;

5. Directly related to criminal investigation, prosecution, trial and execution of judgment;

6. Carry out news reporting, public opinion supervision and other activities for the public interest and process personal information within a reasonable scope;

7. Personal information that you disclose to the public on your own initiative;

8. Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure, etc.

9. Other circumstances prescribed by laws and administrative regulations.

 

V. How do you access and manage your personal information?

We guarantee that you can exercise the following rights on your personal data. Please note that for security reasons we may ask you to verify your identity before processing your request. You can access and manage your personal information in the following ways:

1. Visit Privacy Policy

You can view the full content of this Privacy Policy when you install the software for the first time, or go to [Personal Center] - [Settings] - [Privacy Policy].

2. Change or revoke sensitive permission settings

You can disable the permissions for taking photos and recording videos, reading and writing photos and files on the device, and resident notifications in the device's operating system, change the scope of consent, or withdraw your authorization. After you withdraw your authorization, we will no longer collect information related to these permissions.

3. Query your personal information

You can check your subscription status on the [Settings] page.

4. Deleting your personal information

If information such as your order records needs to be deleted, you can contact customer service or email us to request us to delete your relevant information. We will arrange to process it within 15 working days after receiving your request.

After you or we assist you in deleting the relevant information, we may not be able to immediately delete the corresponding information from the backup system due to applicable laws and security technologies. We will safely store your personal information and isolate it for further processing until the backup can be cleared or made anonymous. If the retention period prescribed by laws and administrative regulations has not expired, or it is technically difficult to delete personal information, we will stop processing except for storage and taking necessary security protection measures.

5. Complaints

If you believe that your personal information rights may be infringed, or discover clues of infringement of your personal information rights, you can contact us through Article 8 of this Privacy Policy. After verification, we will respond to your complaint and report within 15 working days.

6. Accessing, Correcting and Obtaining a Copy of Your Personal Information

You have the right to access, correct and obtain a copy of your personal information. You can contact us through the contact information listed in this policy. If technically feasible, if the data interface has been matched, we can also directly transfer a copy of your personal information to the third party you specify at your request.

7. Protection of Personal Information of Deceased Users

After the death of a user (natural person only), his/her immediate family members may, for their own legal and legitimate interests, exercise the rights to review, copy, correct, and delete the relevant personal information of the deceased user through the contact information disclosed in this policy, unless the deceased user had made other arrangements during his/her lifetime.

Please understand and confirm that in order to fully protect the personal information rights and interests of deceased users, the close relatives of deceased users who apply to exercise the rights under this article need to submit the deceased user's identity document, death certificate, identity document of the applicant, and documents proving the relationship between the applicant and the deceased user in accordance with our specified process or customer service prompts , and provide the type and purpose of the rights applied for.

8. Respond to your above requests

For security reasons, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. We will respond within 15 working days. If you are not satisfied, you can also find our customer service staff to file a complaint.

In principle, we do not charge you for reasonable requests, but we will charge a certain cost for repeated requests that exceed reasonable limits. We may reject requests that are unreasonably repeated, require too many technical means (for example, require the development of new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are extremely impractical (for example, involving information stored on backup tapes).

In the following circumstances, we will be unable to respond to your request in accordance with laws and regulations:

(1) Related to the personal information controller’s performance of obligations prescribed by laws and regulations;

(2) Those related to national security or national defense security;

(3) Related to public safety, public health, and major public interests;

(4) Related to criminal investigation, prosecution and trial;

(5) There is sufficient evidence that you have subjective malice or abuse of rights;

(6) For the purpose of protecting the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the consent of the individual;

(7) responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

(8) Involving trade secrets.

 

VI. Subscription Service Agreement

1. Subscription Plan

Some of the advanced services and content provided by this software require payment (hereinafter referred to as "subscription services"), but we will provide a free trial period. Once the fees are paid in full, you will receive the subscription services during the subscription period.

2. Automatic Renewal

Subscriptions will automatically renew unless you cancel before the end of the current subscription period. You authorize us to charge your payment method at the beginning of each subscription period. This may include Apple Pay and any other payment methods we offer you from time to time. You agree to abide by any terms of service or other legal agreements, whether with Apple or other third parties, that govern your use of payment methods.

3. Cancellation of Subscription

If you decide you no longer want to use our services, you can cancel your subscription before it expires. Before canceling, make sure you understand the policies and possible fees in advance. Please note that you will be automatically charged unless you cancel your subscription 24 hours before the end of the free trial period or the current subscription period. Subscriptions can be managed by you through the in-app settings or App Store. Please note that deleting the app from your device will not cancel your subscription. Cancellation of subscription will take effect at the end of the current subscription period, and users can continue to use premium services during the current subscription period.

4. Automatic renewal management

You can manage your auto-renewal plan in your account settings in the app, subscription management in the App Store, or subscription management in your Apple ID. Please make appropriate adjustments before your subscription expires.

5. Refund Policy

Except as expressly provided by laws and regulations, we will not provide refunds after the subscription is completed. Any paid services purchased by users and items/functions that have been redeemed cannot be returned for any reason (i.e., returned for other virtual props/items or legal currency) or exchanged for other services or items. If we agree to a refund, the user should compensate for the fees incurred by using payment channels such as credit cards and mobile phones when paying, and we have the right to deduct them directly from the fees returned to the user. If you subscribe in an illegal manner, or use a subscription method not specified by us, or use loopholes in different channels to make malicious refunds, we do not guarantee that the subscription will be completed smoothly or correctly. If your rights and interests are damaged as a result, the company will not make any compensation or compensation. The company also reserves the right to terminate your account qualifications at any time, recover the amount paid for illegal subscriptions, and stop providing various services.

In the absence of contrary evidence, the subscription behavior of underage users is deemed to have been consented by their legal guardians, and we are not obligated to provide a refund.

6. Data Deletion

If the subscription service expires and the user decides not to renew, the service enjoyed by the user will be closed at the same time, and we will delete such data on the cloud server. Please make sure to back up your data in time. We do not assume any responsibility if the user data is damaged, lost, or destroyed as a result.

 

VII. Protection of Minors

1. If you are a minor under the age of 18, you should read and agree to this Privacy Policy under the supervision and guidance of your guardian before using the BrainFlex+ software and related services.

2. In the case of collecting personal information of minors when using our products or services with the consent of their guardians, we will only use, share, transfer or disclose this information when permitted by laws and regulations, with the explicit consent of the guardians or when it is necessary to protect minors.

3. If your guardian does not agree with your use of our services or provision of personal information to us in accordance with this Policy, please immediately terminate your use of our services and notify us in a timely manner.

4. If you are a parent or guardian, please contact us in a timely manner if you have any questions about the use of our products / services or user information provided to us by the minors under your guardianship. We may need to collect personal information of the minors under your guardianship from you for the purpose of performing relevant services for you. If it is necessary to collect personal information of minors from you in specific services, we will obtain your authorization and consent in advance and inform you of the purpose and use of the collection. If you do not provide the above information, you will not be able to enjoy the relevant services we provide. As a guardian, you should properly perform your guardianship duties and protect the personal information security of minors. If the minor himself needs to register or use our products and/or services, you should correctly guide and supervise him.

 

VIII. Scope of application

It should be noted that this Privacy Policy applies only to information collected through this software or emails, texts or other electronic communications sent by this software. This policy does not apply to information collected offline, information collected by other software or websites (including other companies or organizations that provide advertising services in our services, jump links to third-party entities, etc.), or information collected by any third party. These third parties will provide you with services based on their own privacy policies. For your convenience, we have provided the corresponding URLs in this policy and encourage you to read these policies before providing them with information.

The software and related services described in this Privacy Policy may vary depending on the model of your mobile phone, system version, software application version, etc. The final products and services are subject to the BrainFlex+ software and related services you use.

Supplemental notice for California residents

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below.

Category

Detail

Source

Identifiers

such as your name as it appears on your social media profile, open ID / user ID, IP address, phone number, mailing address, email address, and nickname

directly from you and your device and from social media platforms (if sign up via a social media account)

Internet or other electronic network activity data

such as your data regarding your use of the Service, including level, score, date and other device data as described in the main policy

directly from you and your device

Commercial data about any transactions within the Service

such as what products were purchased and how much they cost

directly from you and your device and the Google Play or Apple iOS store

Other data described in subdivision (e) of Section 1798.80.

 

directly from you in the context of being our consumer

In the past 12 months, we have not sold Personal Data of California residents within the meaning of “sold” in the CCPA. 

 

Rights under the CCPA 

If you are a California resident, you have the right to:

•Request we disclose to you free of charge the following data covering the 12 months preceding your request:

l  the categories of personal data about you that we collected;

l  the categories of sources from which the personal data was collected;

l  the purpose for collecting personal data about you;

l  the categories of third parties to whom we disclosed personal data about you and the categories of personal data that was disclosed (if applicable) and the purpose for disclosing the personal data about you; and other specific pieces of personal data we collected about you;

•Request we delete personal data we collected from you, unless CCPA recognizes an exception; and

•Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.   

 

We aim to fulfil all verified requests within 45 days pursuant to the CCPA.  If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay. 

 

IX. Notices and Revisions

1. The copyright of this Privacy Policy belongs to us. We have the right to interpret and modify it within the scope permitted by law. Our Privacy Policy may be changed from time to time according to business adjustments, changes in laws, regulations or policies. Without your explicit consent, we will not reduce the rights you should enjoy under this policy. We will publish any changes to this policy on a dedicated page. For major changes, we will notify you through pop-ups, push notifications, etc. in the product or service.

If you do not agree to the revised Privacy Policy, you have the right and should immediately stop using our products and/or services. If you continue to use our products and/or services, you will be deemed to have accepted the changes we have made to the relevant terms of this policy.

Major changes referred to in this policy include but are not limited to:

(1) The purpose of our processing of personal information, the type of personal information we process, the way we use personal information, etc. have changed;

(2) Your rights to participate in the processing of personal information and the way in which you exercise them have changed;

(3) When the personal information security impact assessment report indicates the existence of risks.

2. If you have other complaints, suggestions, personal information of minors or questions about this policy, you can contact us through our online customer service or email guangzhoutongzhuo@outlook.com. We will review the issues as soon as possible and respond within 15 working days after verifying your user identity.