Page 1 | Privacy Policy Overview & Scope
This Privacy Policy (hereinafter referred to as “this Policy”) aims to explain how the platform collects, uses, stores, and protects users’ personal information and related data during their access to, browsing of, or use of related services. This Policy helps users understand the basic principles and boundaries of responsibility followed by the platform in information processing.
This Policy is legally binding between the platform and users. Users should carefully read and understand the entire contents of this Policy before using the platform’s services. This Policy constitutes an important part of the relationship between users and the platform regarding the processing of personal information.
This Policy applies to all individuals or legally established organizations that access, browse of, or use the platform’s services. Regardless of whether a user has completed registration, as long as they actually use any function or service provided by the platform, they are deemed to be subject to this Policy.
This Policy only applies to the platform’s processing of user information during the provision of its own services and does not apply to any third-party services accessed by users through the platform or other information processing activities outside the platform. The platform assumes no responsibility for information processing activities independently conducted by third parties.
By continuing to access, browse of, or use the platform’s services, users are deemed to have fully understood and agreed to the entire contents of this Policy. If a user does not agree to any part of this policy, they should immediately cease using the relevant services.
Page 2 | Definitions & Interpretation For ease of understanding and application, the following terms used in this policy shall have the following meanings unless the context clearly states otherwise:
“Personal Information” or “Personal Data” means information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding information that has been anonymized and cannot identify a specific individual.
“Processing” means any operation performed on personal information, including but not limited to collection, recording, storage, use, disclosure, transmission, organization, deletion, or other similar acts.
“User” means any individual or legally established organization that accesses, browses, or uses the platform services.
“Platform” or “Services” refers to the collective term for the related systems, functions, information, or other digital services provided by the platform to users.
“Third Party” means any individual, organization, or entity other than the platform and users.
The headings in this policy are for convenience only and do not affect the interpretation of the terms. Unless otherwise stated, the singular form also includes the plural meaning, and vice versa. This policy should be interpreted in accordance with the principles of reasonableness, comprehensiveness, and consistency with its purpose. In case of discrepancies in interpretation between clauses, the context should be considered.
Page 3 | Types and Sources of Information Collection
Information We Collect
The platform may collect information voluntarily provided by users during the provision of services. This information typically includes materials or content voluntarily submitted by users while using the service, limited to the actual needs of the service functions.
During users’ use of the platform’s services, the platform may automatically collect information related to service operation and use, such as device information, usage behavior records, or system logs. This type of information is primarily used to support the normal operation and security management of the service.
The platform may also collect necessary technical and usage-related information for analyzing service performance, optimizing the user experience, and preventing potential risks. This information is usually processed in an aggregated or technical manner.
The platform adheres to the principles of legality, legitimacy, and necessity in information collection, and only collects information in accordance with laws and regulations and the purpose of the service.
The platform generally does not proactively collect sensitive personal information. If it is necessary to involve relevant information in specific circumstances, the platform will process it in accordance with applicable laws and regulations and within a reasonable scope.
Page 4 | Purpose and Method of Information Use
How We Use Information
The platform uses collected user information only in accordance with laws and regulations and this Privacy Policy. The purpose of information use is primarily to support the normal operation, maintenance, and improvement of the platform’s services, and will not exceed the reasonable scope necessary to achieve the service’s functions.
The platform may use relevant information to provide and maintain services, including for identification, functional support, system operation assurance, and basic maintenance of user experience. Such use is limited to what is necessary to achieve the service itself and will not be used for purposes unrelated to the service.
To continuously improve service quality and functional performance, the platform may analyze or statistically process information within a reasonable scope to optimize product design, improve service stability, and enhance the overall user experience. Such processing is usually carried out in a technical or aggregative manner.
The platform may also use necessary information to fulfill compliance obligations, protect platform and user security, prevent risks, or respond to potential violations. Such use aims to maintain the legality, stability, and security of the service.
The platform adheres to the principle of minimum necessity for information use, using user information only to the extent necessary to achieve a specific purpose, and taking reasonable measures to avoid improper or excessive use. The platform will not use user information for purposes unrelated to this Privacy Policy.
Page 5 | Information Sharing & Disclosure
The platform will not disclose users’ personal information to any third party in principle, unless expressly required by this Privacy Policy or applicable laws and regulations.
The platform may share user information when it is legal and necessary: as required to provide or support services, when service providers cooperating with the platform are performing their duties, or to comply with laws, regulations, or regulatory requirements.
In cases involving third-party participation in service provision, the platform will only provide necessary information to the relevant third parties to a reasonable extent and require them to process such information in accordance with applicable laws and regulations and corresponding compliance obligations.
If laws, administrative regulations, judicial procedures, or regulatory agencies require the platform to disclose relevant information, the platform may disclose such information if it complies with legal requirements.
In any process of information sharing, disclosure, or transfer, the platform adheres to the principles of legality, legitimacy, and necessity, and takes reasonable measures to protect the security and integrity of user information.
Page 6 | Data Storage, Protection, and Security Measures
The platform stores user information reasonably, in compliance with legal and regulatory requirements. The storage period is commensurate with the purpose of providing services, fulfilling legal obligations, or risk management needs.
The platform adopts reasonable technical and management measures to protect user information from unauthorized access, disclosure, alteration, or misuse. These measures aim to reduce information security risks and maintain data integrity.
The platform continuously evaluates and improves information security measures; however, users understand and acknowledge that no technical or management means can completely eliminate all potential risks, and information security is relative.
In the event of a data breach or other information security incident, the platform will take reasonable measures in accordance with applicable laws and regulations and internal procedures to minimize any potential adverse effects.
Users understand that information security depends on the joint efforts of the platform and users. Users should also take reasonable measures to protect their own information security and avoid information risks caused by their own actions.
Page 7 | Data Retention and Deletion Mechanism
The platform retains user information only for the period necessary to achieve the purposes described in this Privacy Policy. The retention period for information will be determined based on the nature of the service, the purpose of use, and the requirements of applicable laws and regulations.
The retention period for user information is directly related to its collection and use purpose. When the relevant purpose has been achieved, cannot be achieved, or is no longer necessary, the platform will delete or anonymize the relevant information in a manner permitted by law.
Subject to compliance with laws and regulations, the platform will take reasonable measures to ensure that information no longer needed will not be retained or used. Anonymized information will no longer be used to identify specific users.
Users may request the deletion of their personal information in accordance with legal provisions and the platform’s reasonable procedures. The platform will evaluate and process relevant requests based on the content of the request and applicable laws and regulations.
In specific circumstances, such as to fulfill legal obligations, resolve disputes, enforce agreements, or meet compliance and security requirements, the platform may retain some information in accordance with the law. Even if a user requests deletion, the relevant information may continue to be retained to the extent necessary.
Page 8 | User Rights & Choices
Users have the right to know how the platform processes their personal information, including the type of information collected, the purpose of use, and the related processing methods. The platform will provide users with relevant explanations in a reasonable manner.
Subject to compliance with laws and regulations, users have the right to access, correct, or update the personal information they provide to the platform to ensure the accuracy and completeness of the information.
Under applicable law, users may request the deletion of their personal information or restriction of the platform’s processing of related information under certain circumstances. The platform will process such requests within a legal and reasonable scope.
If information processing is based on user consent, the user has the right to withdraw their consent at any time. Withdrawal of consent does not affect the legality of processing based on consent prior to withdrawal.
Users understand and acknowledge that the exercise of user rights may be reasonably restricted due to legal obligations, public interests, the platform’s legitimate rights and interests, or technical limitations.
Page 9 | Third-Party Services and External Platforms
Third-Party Services In providing services, the platform may include services, content, or external links provided by third parties. Such third-party services or links exist solely for the convenience of users.
The privacy policies and information processing practices of third-party services are the independent responsibility of the respective third parties and are not bound by this privacy policy. The platform is not responsible for the information processing practices of third parties.
Users should review and understand the privacy policies and terms of use of the relevant third parties when using third-party services or accessing external platforms. The platform is not responsible for any relationships or disputes between users and third parties.
Users acknowledge that they bear all risks arising from the use of third-party services or content, and the platform is not responsible for any losses or consequences arising therefrom.
Page 10 | Privacy Policy Updates & Applicable Law
Policy Updates & Governing Principles
The platform reserves the right to update or modify this Privacy Policy based on changes in laws and regulations, business adjustments, or other reasonable reasons. The updated Privacy Policy will take effect after being published in an appropriate manner.
Continue access to or use of the platform’s services after an update to this Privacy Policy constitutes acceptance of the updated policy. If users do not agree to the updates, they should cease using the relevant services.
If any provision of this Privacy Policy is deemed invalid or unenforceable, that provision shall be adjusted to the extent necessary, while the remaining provisions shall remain in full force and effect.
The formulation, interpretation, and enforcement of this Privacy Policy shall comply with the general principles of applicable law regarding the protection of personal information and the right to privacy.
