Privacy Policy


English | 中文

Update date: December 24, 2021

Effective time: December 14, 2020

Xiniu Benben (Beijing) Technology Co., Ltd. and Xiniu Securities Co., Ltd. are related, and jointly develop and operate the "Xiniu Securities" app. Specifically, the development and maintenance of the Xiniu Securities app is in charge of Xiniu Benben (Beijing) Technology Co., Ltd., and Xiniu Securities Co., Ltd. is responsible for the operation of specific business matters within Xiniu Securities' software. The two companies promised that the content of the software is legal and compliant, does not infringe the legal rights of any third party, and does not involve any unlicensed business matters.

Thank you for your trust and support to Xiniu Benben (Beijing) Technology Co., Ltd. (hereinafter referred to as "we"/"our company"). We are well aware of the importance of personal information to you. Your trust is very important to us. We Corresponding security protection measures will be taken in accordance with the requirements of laws and regulations, and committed to protecting your personal information in a safe and controllable manner. In view of this, we have formulated this "Privacy Policy" (hereinafter referred to as "this policy/this privacy policy") to help you fully understand how we collect, use, share, store and Protect your personal information and how you can manage your personal information so that you can better make appropriate choices.

This policy is closely related to your use of our services. Before using our products and services, please read this policy carefully, and use related products and services after you have confirmed that you fully understand and agree to this policy. Once you start using our products or services, it means that you fully understand and agree to this policy, and agree that we collect, use, store, share and protect your relevant information in accordance with the provisions of this policy

If you have any questions about this policy or related matters, please contact us via fixed line 010-57287075.

Section One. How we collect and use your personal information

We will follow the principles of fairness, lawfulness and necessity, based on the following functions and services, to collect and use the personal information you voluntarily provide during the use of products (or services).

1.1 Register an account

way to register Information collected application
Mobile phone number registration Phone number Login and locate account
WeChat WeChat avatar, WeChat nickname More convenient login account, personalized display of avatar, nickname
QQ QQ avatar, QQ nickname More convenient login account, personalized display of avatar, nickname
Weibo Weibo avatar, Weibo nickname More convenient login account, personalized display of avatar, nickname

Xiniu Benben also provides a local mode without registering an account. If you choose not to register an account, you can also view market quotations, browse information, watch videos, etc., but you cannot speak in the community or conduct transactions. 1.2.1

1.2 Application function

1.2.1 Synchronize data

Once you register an account and use the account to perform operations such as deposits and transactions, in order for you to synchronize data between devices in a normal and complete manner, you need to allow us to collect:

  • Your account opening data, including but not limited to name, email, work address and other information.
  • Your capital account data, including but not limited to transaction amount, available balance, etc.
  • Your position data, including stock name, stock code, cost price and other information.
  • Your community communication data, including your speeches, replies, likes, comments, etc.
  • The above information is only used for you to synchronize data between devices, we will not read your content.

    1.2.2 Search function

    When you use the search function in Xiniu Securities, in order to facilitate your query of recent search history, we may collect information including: the keywords you query (the keywords you query will only be recorded locally on the client and will not be synchronized To the cloud).

    1.2.3 Submit feedback

    When you submit feedback in Xiniu Benben, to ensure that we can accurately understand and screen the problems you encounter, we may collect information packages Including: Log files, device model, operating system version, app version information.

    1.2.4 Withdraw/deposit funds

    When you deposit/withdraw funds to your account, according to risk control and anti-money laundering requirements, you need to provide your bank card number, bank card holder name (must be the same as the name of the opened fund account), and deposit/withdrawal The amount of funds information.

    1.3 Permissions requested in the app

    We need to apply for some system permissions that involve personal privacy to ensure that some functions in the app can be used normally. We will ask you for authorization when you use these functions, and we will only access your personal information after obtaining your authorization. If you do not need to use these functions, you can refuse authorization; if you have never used these functions, we will not request permission from you and will not access your personal information. The permissions we will apply for and the functions corresponding to these permissions include:

  • Permission to make calls:When users have any questions and need to communicate with the platform, click the "Customer Service Phone" button, and we will apply for this permission. After obtaining the authorization, the Xiniu Benben app will jump directly to the system dialing interface, without the user entering a phone number, you can directly press the dial button to dial the customer service number.
  • Permission to write to external storage:We will apply for this permission when users upload their ID cards by taking photos during the account opening process or modify their avatars by taking photos. After obtaining authorization, Xiniu Benben will write the photos taken to local storage.
  • Permission to read external storage:We will apply for this permission when the user uploads the ID card by selecting photos from the album during the account opening process, or modifies the avatar by selecting photos from the album.
  • Allow microphone permission:When a user opens an account, video verification is required. We will apply for this permission to facilitate users to open an account smoothly.
  • Permission to call the camera:We will apply for this permission when users upload their ID cards by taking photos or modify their avatars by taking photos during the account opening process.
  • 1.4 Third-party SDK

    We collect data based on your interaction with us and the choices you make, including your privacy settings and the products and features you use. The data we collect may include SDK/API/JS code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, iOS advertising identifier IDFA, Android advertiser identifier, network card (MAC) address, International Mobile Equipment Identity (IMEI), device model, terminal manufacturer, terminal device operating system version, session start/stop time, language location, time zone and Network status (WiFi, etc.), hard disk, CPU and battery usage. The following partners and their services are carefully selected by us, and we and our partners will jointly use various security technologies and procedures to encrypt data, and implement a complete mechanism to protect your personal information from unauthorized access. Access, use or disclosure. You can learn more about it through the partner's privacy policy.

    SDK used in Android apps

  • WeChat login:When you log in with WeChat, we will collect your WeChat profile picture and nickname
  • QQ login:When you log in with QQ, we will collect your QQ profile picture and nickname
  • Weibo login:When you log in with Weibo, we will collect your Weibo profile picture and nickname
  • Baidu SDK:In your account opening process, when you need to perform video face authentication, we will call Baidu SDK to authenticate your face information to ensure that you can open an account smoothly and smoothly.
  • Umeng SDK:When you use a third party to log in, share information in the app to friends, and receive app push services, we need to call the service of the Umeng SDK to better meet your needs.
  • Information disclosure

    Under the following circumstances, the Xiniu Benben APP will disclose your personal information in whole or in part according to your personal wishes or legal requirements:

  • Without your prior consent, we will not disclose to third parties;
  • In order to provide the products and services you request, you must share your personal information with third parties;
  • According to the relevant provisions of the law, or the requirements of the administrative or judicial institutions, disclose to a third party or the administrative or judicial institutions;
  • If you violate relevant Chinese laws, regulations, or the Xi Niu Ben Ben APP service agreement or related rules, you need to disclose to a third party;
  • If you are a qualified intellectual property complaint and have filed a complaint, you should disclose it to the respondent at the request of the respondent, so that both parties can deal with possible rights disputes;
  • 2.Provide you with the functions necessary for security

    (1) In order to improve the safety of your use of our products and/or services, protect the personal and property safety of you or other users or the public, and better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, etc. Security risks, to more accurately identify violations of laws and regulations, we may use or integrate your personal information, transaction information, device information, service log information, and information that our affiliates and partners have obtained your authorization or shared in accordance with the law. Comprehensively identify the risks of your account, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

    (2) In order to meet the basic requirements of laws and regulations and provide services, to ensure the security of your account and system operation; to analyze the collected information so that we can troubleshoot the cause when the system fails, so as to realize the development, upgrade and optimization of the product service quality. We will collect information about the services you use and how you use them and associate these information. This information includes:

    Device Information:

    We will receive and record information about the equipment you use based on the specific permissions granted by you during product installation and use. We need to record your device model, unique device identifier, operating system, IP address, resolution, mobile application download channel, current mobile application version number, and mobile application language setting information.

    Operation log information:

    When you use our products and/or services, we will automatically collect your detailed usage of our products and/or services and save them as relevant web logs. We need to collect your log information, including account status, login time, browsing history, self-selected target, trading market, transaction target information (not including transaction fund information). We will obtain the storage permission of your device to save the aforementioned log information.

    (2) You can choose to authorize us to collect and use personal information scenarios

    In order to provide you with more convenient and better quality products and/or services, and strive to improve your experience, our mobile application will apply for some necessary system permissions from the device. If you reject the content in the following table, you will not be able to use the corresponding functions, but it will not affect your use of other services of Xi Niu。

    Additional services based on camera/camera You can use this function to take photos of ID cards and other documents/materials after turning on the camera/camera permissions, and you can also take photos for evaluation, sharing, and facial recognition authorized by you in specific scenarios. When you use this additional feature for face recognition, we will collect your facial features and use them strictly within the scope of your authorization. In the future, if we intend to use your facial information to provide you with other product and/or service functions , We will confirm with you again.

    Additional services based on photo access and upload of photo albums (picture library) You can use this function to upload your photos/pictures after enabling photo album permissions, so as to realize changing avatars, posting comments, sharing, uploading ID cards and other supporting materials.

    Additional services related to microphone-based voice technology You can use the microphone to implement customer service voice feedback services after turning on the microphone permission, or to communicate with the customer service. Even if you have agreed to turn on the microphone permission, we will only obtain it through the microphone when you actively click the microphone icon in the mobile app or record a video voice message。

    Additional services based on address book information Address book permissions are turned off by default. If some users need to switch the clearing service provider, they can choose to open the address book permission and perform Auth authentication.。

    Calendar-based additional services After you authorize the permission to read/write your calendar, we will read/write the date of the company action you follow in the system calendar according to your operation, so as to provide you with timely reminders Serve。

    Additional services based on fingerprint and face recognition. Our mobile application provides fingerprint or face recognition instead of transaction passwords to ensure transaction security and additional security services for fingerprint or face recognition before entering the transaction and fund account interface, so that you can get more Safe user experience。

    You understand and agree that the above additional services may require you to enable access to your camera (camera), photo album (picture library), microphone (voice), address book, calendar, fingerprint, and face recognition in your device. To achieve the collection and use of information involved in these permissions. You can view the status of the above permissions item by item in your device settings, and you can decide whether to turn on or off these permissions at any time. Please note that if you enable any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you close any permission, you cancel the authorization, and we will no longer continue to collect based on the corresponding permissions. And the use of related personal information can not provide you with the services corresponding to this authority. However, your decision to close the authority will not affect the previous collection and use of information based on your authorization

    (3) Other

    Please understand that the services we provide to you are constantly updated and developed. If you choose to use other services that are not covered in the foregoing description, and we need to collect your information based on that service, we will separately explain to you the purpose and scope of the corresponding information collection by updating this policy, pop-up windows, page prompts, etc. And use methods, and provide you with a way to choose your consent, and collect and use it after obtaining your express consent. We will use, store, provide and protect your information in accordance with this policy and the corresponding user agreement; if you choose not to provide the foregoing information, you may not be able to use a certain service or part of the service, but it will not affect your use of the service we provide other service. During this process, if you have any questions, comments or suggestions, you can contact us in time and we will answer you as soon as possible

    (4) Exceptions with consent

    According to relevant laws, regulations and national standards, in the following situations, we may collect and use your personal information in accordance with the law without your authorization and consent:

    1.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 sentence execution;

    4.In order to protect your or others' life, property and other major legal rights and interests, but cannot obtain your own consent in a timely manner;

    5.The personal information collected is disclosed to the public by yourself;

    6.Collect your personal information from legally publicly disclosed information, such as: legal news reports, government information disclosure and other channels;

    7.Necessary for signing and fulfilling the contract according to your requirements;

    8.Necessary for maintaining the safe and stable operation of the provided services, such as: discovering and handling service failures;

    9.Necessary for legal news reporting;

    10.It is necessary for academic research institutions to conduct statistical or academic research based on the public interest, and when they provide academic research or description results externally, they de-identify the personal information contained in the results;

    11.Other circumstances stipulated by laws and regulations。

    Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information, the data recipient cannot re-identify specific individuals and cannot be restored, or we may conduct de-identification research on the collected information , Statistical analysis and prediction, used to improve our content and layout, provide product or service support for business decisions, and improve our products and services (including the use of anonymous data for machine learning or model algorithm training), then such processing The use of data does not need to notify you separately and obtain your consent。

    (5)Rules for the use of personal information

    1.We will use the collected personal information in order to realize the functions of our products and/or services in accordance with the provisions of this privacy policy。

    2.For all personal information you provide when you use our products and/or services, unless you refuse our collection through the system settings, it will be deemed to continue to authorize and agree to our use during your use of our products and/or services

    3.We will make statistics on the usage of our products and/or services, and may share these statistics with the public or third parties to show the overall usage trends of our products and/or services. But these statistics do not contain any identifying information about you。

    4.In order to meet your individual needs, maintain and improve the quality of our products and/or services, we will use the following information in compliance with legal requirements and in accordance with your specific authorization:

    We may use your device information, operation log information, account information and transaction information to perform comprehensive statistics and analysis on your preferences, habits, account status and other information to form a user portrait, which is used to recommend or show you Interested product and/or service information, or display personalized third-party promotion information to you through the system. Including push notifications on the App page to provide you with smart recommendations; through SMS, APP 、E-mails, etc. to send you promotional information or display commercial advertisements; return visits by phone, provide you with services such as information consultation, or invite you to participate in customer research related to services, products, or functions。

    For example: We will show or recommend highly relevant community and information services, information flow or advertising/promotion information results to you, display community articles that you may be interested in, recent APP activities, etc.。

    Another example: We will use your registration and account opening information, including registration time, account type, and work unit related information, according to the contact information you have provided (including but not limited to: mobile phone number, email address, etc.) through SMS, phone calls, etc. Send you business notifications, conduct user experience research, provide guidance and marketing promotion information, etc.。

    Section two、How we use cookies and similar technologies

    (1)Cookie

    A cookie is a small text file created by a website server and saved on the user's browser. When a user visits the website server, the website can access the cookie information. In addition to being generally used to confirm user identity, cookies can also be used to store user information and track user visits。

    In addition to using cookies to confirm the user’s identity and login status, we will not collect and track any user’s information and behavior through it。

    You can manage and delete cookies according to your preferences, and most browsers have a feature that allows you to disable or delete cookies in the system. It should be noted that blocking cookies may cause some functions of our website or system to not work effectively or be unavailable, which may affect your experience。

    (2) Cookie similar technology

    In addition to cookies, we will also use other similar technologies such as Authorization or "Web Beacon" on the website. Authorization is the HTTP protocol header transmitted between the Internet browser and the Internet server, which can replace Cookies. It can be calculated by using the network Beacon. Users who browse the web or visit certain cookies. We will use Authorization to record your identity and collect information about your web browsing activities through the network Beacon, such as: Internet Protocol (IP) address, browser type, Internet service provider (ISP), visited pages, operating system, date /Time stamp and click data stream, etc., so that we can understand and improve our products or services more deeply.

    Section three、How we share, transfer, and publicly disclose your personal information

    (1) shared

    We promise to keep your information strictly confidential and will not share your personal information with companies, organizations and individuals other than Laoxiniu, except in the following cases:

    1.Sharing with your consent: After obtaining your explicit consent, we will share your personal information with other parties。

    2.Sharing under statutory circumstances: We may share your personal information with external parties in accordance with laws and regulations, litigation dispute resolution needs, or requirements of administrative or judicial authorities in accordance with the law. For example: our various regulatory agencies, autonomous associations or authorized organizations (including but not limited to various exchanges and government agencies) for the purpose of supervision and inspection, may require us to provide your account information and transaction information in order to confirm us Whether the corresponding legal obligations have been fulfilled.

    3.Certain products or services may be provided by third parties or jointly provided by us and third parties. Therefore, we need to submit your identity information, contact information, Only after professional information, asset information, investment information and order information can we provide the products or services you need.

    4.We will access third-party SDKs to provide you with related services. These third-party services are operated by related parties and are subject to the third party's own terms of service and information protection statement (not this "Privacy Policy"). Regarding the specific types of device permissions that the third-party SDK calls, and how to collect and use your personal information, it is recommended that you refer to the relevant service agreement and privacy policy of the third-party SDK. If you want to know more about the third-party SDK that we have connected, please read the third-party SDK description.

    5.In accordance with the requirements of laws and regulations, in order to effectively identify your identity, we will provide your name, date of birth, gender, identification number information and bank card number related information to the third-party identity verification provider we cooperate with during the account opening process. We can identify you as a legal and valid customer, complete the account opening and provide follow-up services for you.

    6.Sharing with our affiliated companies: Your personal information may be shared with Xiniu's affiliated companies. We will only share necessary personal information and are bound by the purpose 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。

    7.Sharing with authorized partners: Only to achieve the purpose stated in this policy, some of our services will be provided by authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. For example, when you participate in the reward activities we provide, we must share your personal information with our partners in order to arrange for rewards, or arrange for partners to provide services. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purpose.

    8.When you have questions that we need to answer, complain to us, complain to others, or be complained by others, in order to protect the legitimate rights and interests of you and others, we may save your name, contact information, and complaint in the customer service system provided by a third-party supplier And the relevant content of the communication, and may be provided to consumer rights protection departments and supervisory authorities to resolve complaints and disputes in a timely manner, unless it is expressly prohibited by laws and regulations.

    9.Exchange information with other companies and organizations in order to comply with the law, to implement or apply the terms of use of our services and other agreements, or to prevent fraud and other illegal activities and reduce credit risks。

    10.Other agreements between you and us regarding information sharing。

    If you need to share your information with a third party in order to provide you with services, we will evaluate the legality, legitimacy, and necessity of the third party's collection of information. We will require third parties to take protective measures for your information and strictly abide by relevant laws, regulations and regulatory requirements. In addition, we will obtain your consent in the form of confirmation agreements, copy confirmation in specific scenarios, and pop-up prompts in accordance with the requirements of laws, regulations and national standards, or confirm that a third party has obtained your consent.

    (2) transfer

    We will not transfer your personal information to any company, organization or individual, except in the following cases:

    1.Obtain your explicit consent in advance;

    2.According to laws and regulations or mandatory administrative or judicial requirements;

    3.When it comes to asset transfer, acquisition, merger, reorganization or bankruptcy liquidation, if it involves the transfer of personal information, we will inform you of the relevant situation and require new companies and organizations that hold your personal information to continue to be bound by this policy. If the purpose of using personal information is changed, we will require the company or organization to regain your explicit consent。

    (3) Public disclosure

    Except for desensitizing the display of the winner's mobile phone number or user nickname when announcing the list of certain prize-winning activities, in principle, we will not disclose your information publicly. If public disclosure is really necessary, we will inform you of the purpose of public disclosure, the type of information disclosed, and the sensitive information that may be involved, and we will obtain your explicit consent。

    (4) According to relevant laws, regulations and policy standards, in the following situations, we may share, transfer, and publicly disclose your personal information in accordance with the law without your consent:

    1.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 sentence execution;

    4.In order to protect your or other individuals’ life, property, and other major legal rights, but it is difficult to obtain your own consent;

    5.Your personal information disclosed to the public;

    6.Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure, etc.。

    Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot be restored, there is no need to share, transfer, and publicly disclose the data after such processing. We will notify you separately and get your consent。

    Section four、How we protect your personal information

    (1) We have adopted reasonable and feasible security protection measures that comply with industry standards to protect your information and prevent unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information. We adopt physical, technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure and modification, including but not limited to transmission layer data encryption, firewall and encrypted storage, physical access control, and information access authorization control. We have set up security procedures to protect your information from unauthorized access. For example: You and all of our network communications, we ensure that encryption technology (SSL) is used for encryption protection. We use high-strength encryption measures to encrypt and store your personal information on our servers. We will use trusted protection mechanisms to prevent malicious attacks on personal information; we deploy strict data access control and multi-identity authentication technologies to protect personal information and prevent data from being accessed and used in violation of regulations. When using personal information, such as personal information display and personal information association calculations, we will use a variety of data desensitization technologies including content replacement and SHA256 to enhance the security of personal information in use. We use automatic code security checks and data access log analysis technologies to strengthen personal information security audits.

    (2) We have an industry-leading data security management system with data as the core and around the data life cycle, which improves the security of the entire system in multiple dimensions from organizational construction, system design, personnel management, product technology, etc., to protect your personal information. For example, we have established a data classification and grading system, data security management specifications, and security development specifications to regulate the storage and use of personal information. We require all employees to sign a confidentiality agreement. We will hold security and privacy protection training courses, and strengthen employees' awareness of the importance of protecting personal information through assessment, review, and adding data protection to the daily assessment of employees, and strictly follow the protection requirements. To strengthen safety certification and services, we have passed ISO27001 certification.

    (3) If you are an EU user, in addition to providing systematic personal data protection measures in accordance with GDPR terms, our Security Department-Personal Information Protection Officer will be responsible for your data protection as a data protection officer (DPO).。

    (4) We will take all reasonable and feasible measures to try our best to avoid collecting irrelevant personal information. We will only retain your personal information for the period required to achieve the purpose stated in the policy, unless it is necessary to extend the retention period or is permitted by law. After exceeding the necessary period, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations. When our products or services stop operating, we will notify you in the form of push notifications, announcements, etc.。

    (5) Please be aware and understand that the Internet is not an absolutely secure environment. We strongly recommend that you use our products and services in a secure way and with complex and reliable passwords to help us ensure the security of your account. If you find that your personal information is leaked, especially your account or password, please contact us immediately according to the contact information provided in this policy so that we can take corresponding measures.

    (6) In the unfortunate event of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions that you can independently prevent and reduce risks, Remedies for you, etc. We will inform you about the incident by email, letter, telephone, push notification, etc. When it is difficult to inform each user one by one, we will adopt a reasonable and effective way to publish an announcement. At the same time, we will also report the handling of information security incidents in accordance with the requirements of the regulatory authorities.

    Section five、How we store your personal information

    (1) The personal information we collect and generate within the territory of the People's Republic of China will be stored in the territory of the People's Republic of China, and this information will be kept strictly confidential in accordance with the law. If some services involve cross-border business and we need to transfer relevant personal information collected in China to overseas institutions, we will implement it in accordance with laws, regulations and relevant regulatory authorities, and explain to you the purpose of personal information going abroad and the types of personal information involved. Obtain your consent, and through effective measures such as signing an agreement and on-site verification, require foreign institutions to keep your personal information confidential。

    (2) We will retain your personal information for the period necessary to achieve the purpose described in this privacy policy, unless laws, regulations, rules or regulatory documents require or allow storage of this information for a longer period of time, such as the following situations:

    1.To comply with applicable laws and regulations and other relevant regulations;

    2.To comply with court judgments, rulings or other legal procedures;

    3.To comply with the requirements of relevant government agencies or statutory authorized organizations。

    4. After the retention period is exceeded, we will delete your personal information or anonymize it in accordance with the requirements of applicable laws。

    (3) If we terminate the service or operation, we will notify you at least 30 days in advance, and delete or anonymize your personal information after terminating the service or operation。

    Section six、More rights or information of individuals covered by GDPR

    If your personal information is established in the European Economic Area ("EEA"), for personal information protected by the "General Data Protection Regulation" ("GDPR"), you have a series of Legal rights related to personal information. Such rights include:

    (1) Obtain information about the processing of your personal information and access your personal information retained by our company. Please note that under certain circumstances, we have the right to refuse access to requests for copies of personal information (especially information specially protected by laws and regulations)。

    (2) If your personal information is inaccurate or incomplete, you can ask us to correct it, but if we need you to provide a copy of a valid identity document to prove the authenticity of your identity information, please cooperate in providing it。

    (3) In some cases you can ask us to delete your personal information. Please note that under certain circumstances (such as for public interest, public health or scientific and historical research purposes), even if you ask us to delete your personal information, we have the right to keep it。

    (4) In some cases, we object to the processing of your personal information and request us to restrict the processing of your personal information. Similarly, in some cases, even if you object or request us to restrict the processing of your personal information, we have the right to refuse your request. If there are other legitimate legal reasons, we also have the right to continue using or processing without your permission。

    In accordance with GDPR terms, in addition to providing systematic personal data protection measures, we will also set up a data protection officer (DPO) to be fully responsible for your data protection work。

    We will evaluate all requests and complaints we receive and provide you with a prompt response. We may require you to provide a copy of a valid identity document so that we can fulfill our security obligations and prevent unauthorized data disclosure. If your request for access to data is clearly unfounded or an extraordinary request。

    For personal information protected by GDPR, we may transfer your personal information to areas outside the EEA for specific permitted purposes. We will ensure that any such international transmissions will be properly protected in accordance with GDPR or other relevant laws。

    Section seven、How do you manage your personal information

    In accordance with relevant Chinese laws, regulations and standards, as well as the common practices of other countries and regions, we guarantee that you exercise the following rights with respect to your personal information

    (1) Access your personal information

    1.You have the right to access your personal information, except for exceptions provided by laws and regulations;

    2.You can log in to our mobile application homepage to enter "My" page, click "Settings" in the upper right corner to enter "Account Management" and "Security Settings" to access and change the bound mobile phone and email information, manage the binding and unbinding of social accounts; "-"Personal Homepage"-"Edit" to modify personal information, including avatar, nickname, profile; "My"-"Settings"-"Security Settings" to modify the login password and transaction password, etc.

    3.You can enter the "Personal Center" page by logging in to our website homepage to modify your personal information, including mobile phone number, email address, login password, etc.;

    4.You can log in to our PC homepage and click "Settings" to enter the "Personal Settings" page to modify your personal information, including nickname, profile, mobile phone number, email address, login password, etc.;

    5.You can view your transaction history on our website and mobile app;

    6.If you cannot access the above information, you can get in touch with customer service, we will respond to your access request within 15 working days;

    7.If you are an EU user, according to GDPR terms, you have the right to request us to retrieve your personal data and transfer it to another data controller。

    (2) Correct your personal information

    You can correct or supplement your personal information by the methods listed in "Access to Your Personal Information"。

    If you are unable to manage this personal information through the above methods, you can contact our customer service at any time. We will respond to your access request within 15 working days。

    (3) Delete your personal information

    In the following situations, you can request us to delete personal information:

    1.If our handling of your personal information violates the law;

    2.If we collect and use your personal information without your explicit consent;

    3.If our handling of personal information seriously violates the agreed terms with you;

    4.If you no longer use our products or services, or you have voluntarily cancelled your account;

    5.If we no longer provide you with products or services;

    6.If you are an EU user, you have the right to request us to delete your personal data in accordance with the GDPR。

    If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us and require them to delete them in a timely manner, unless laws and regulations provide otherwise, or these entities obtain your independent authorization. When you delete information from our service, we may not delete the corresponding information in the backup system immediately, but we will delete the information when the backup is updated.

    (4) Protect your personal information

    You can protect your personal information by using complex passwords and not revealing your login password or account information to anyone. Once you leak your account number and password, it may have unfavorable consequences for you. If you find that your account number and password have been or will be leaked for any reason, please contact our customer service immediately so that we can take corresponding measures. However, until we become aware of this situation and take action within a reasonable time, we are not responsible for it.

    When you log in to our website or mobile application, especially when you log in on a public device, you should click "My"-"Settings"-"Logout" to log out immediately after the session is over。

    We are not responsible for the loss of your personal information being accessed by a third party due to your failure to protect the privacy of your personal information. If you find any unauthorized use of your account or other security breaches, you must notify us immediately. Your assistance will help us better protect your personal information。

    (5) Change the scope of your authorization or withdraw your authorization

    You can change the scope of your authorization to continue to collect personal information or withdraw your authorization by deleting information, turning off device functions, etc. You can also withdraw all our authorization to continue to collect your personal information by canceling your account。

    Please understand that each business function requires some basic personal information to be completed. After you withdraw your consent or authorization, we cannot continue to provide you with services corresponding to the withdrawal of your consent or authorization, and will no longer process your corresponding personal information . However, your decision to withdraw your consent or authorization will not affect the previous processing of personal information based on your authorization.

    (6) Independent management and control of marketing information and targeted push

    Our application provides you with news bulletins, hot posts, reminders and notifications of related content, so that you can get the latest information about the content you are concerned about in a timely manner。

    If you do not want to use our information push service, you can click "Settings"-"Notification Management" on the "My" page to turn off APP push, SMS email notification, WeChat service account notification and other information push services。

    If you don’t want to receive our promotional text messages or call back visits, you can also unsubscribe through the corresponding unsubscribe function in the message, or express your refusal in the call back visits。

    (7) Log out of your account

    You can apply for cancellation of your account in the following ways:

    1. You can directly apply to cancel your account on the "My" page and click "Settings"-"Account Management"-"Account Cancellation";

    2. Contact our customer service for help and assist you in applying to cancel your account。

    After you actively cancel your account, we will stop providing you with products or services, delete your personal information in accordance with the requirements of applicable laws, or make it anonymized。

    (8) Respond to your above request

    To ensure safety, 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 reply within 15 working days. If you are not satisfied, you can also initiate a complaint through our customer service. For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we may refuse or charge a certain cost depending on the circumstances. Especially for information that is not directly related to your identity, unreasonably repeated information, or requires too many technical means (for example, the need to develop a new system or fundamentally change the current practice), bring risks to the legitimate rights and interests of others, or are irrelevant We have the right to refuse the actual request.

    In the following situations, we will have the right to reject your request in accordance with the requirements of laws and regulations:

    1. Related to national security and national defense security;

    2. Related to public safety, public health, and major public interests;

    3. Related to criminal investigation, prosecution, trial and execution of judgments, etc.;

    4. There is sufficient evidence that the subject of personal information has subjective malice or abuse of 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 trade secrets。

    Section eight、How do we protect the information of minors

    (1) We attach great importance to the protection of personal information of minors. If you are a minor under the age of 18, you should obtain the written consent of your parent or guardian before using our products and/or services. We protect the personal information of minors in accordance with relevant national laws and regulations. If you are a minor, according to the requirements of relevant laws and regulations, we may refuse to open certain services to you;

    (2) In the case of collecting personal information of minors with the consent of their parents or guardians, we will only use or disclose this information when permitted by laws and regulations, the parents or guardians have expressly agreed, or are necessary to protect the minors;

    Section nine、How to update this policy

    In order to provide you with better services, our business will change from time to time, and our privacy policy may be updated and adjusted from time to time。

    Without your explicit consent, we will not restrict your rights in accordance with this policy. We will display the latest version of the privacy policy on a dedicated page (such as "My→Settings→Privacy Policy" in the mobile application). For major changes, we will also provide more noticeable notifications (including we will notify you through publicity and even provide you with pop-up prompts).

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

    (1) Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

    (2) Major changes in our control rights, such as changes in information controllers caused by mergers and acquisitions, etc.;

    (3) Changes in the main objects of personal information sharing, transfer or public disclosure;

    (4) Your right to participate in the processing of personal information and how to exercise it has undergone major changes;

    (5) Changes in our responsible department, contact information and complaint channels for handling personal information security;

    (6) When the personal information security impact assessment report shows that there is a high risk。

    Our product integrates Youmeng+SDK, Youmeng+SDK needs to collect your device Mac address, unique device identification code (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI Information) in order to provide statistical analysis services, and calibrate the accuracy of report data through geographic location, and provide basic anti-cheating capabilities。