1.1 Personal Information

Personal information refers to various information recorded electronically or by other means related to identified or identifiable natural persons, excluding anonymized information. When you use Shanghai Hongying Intelligent's products and services or interact with us, we may collect your personal information. The specific data types collected will vary depending on the products/services you use and how you interact with us. You are not obligated to provide personal information to Shanghai Hongying Intelligent, but in certain cases, if you choose not to provide it, we may not be able to provide you with relevant products/services or address your issues. Shanghai Hongying Intelligent will only collect and use your personal information for the purposes stated in this declaration. The personal information we may collect includes:

1.2 Sensitive Personal Information

Sensitive personal information refers to personal information that, if leaked, illegally provided, or misused, may endanger personal and property safety, or easily cause damage to personal reputation, physical/mental health, or discriminatory treatment. Such information includes but is not limited to ID numbers, biometric data, bank account numbers, communication content, and health/physiological information.

1.3 Personal Information Subject

The personal information subject refers to the natural person identified by the personal information, also referred to as the end-user in this agreement.

1.4 Device

Device refers to equipment that can be used to access our services, such as desktop computers, laptops, tablets, or smartphones.

1.5 Unique Device Identifier

Unique Device Identifier (Unique ID or UUID) refers to a string of characters programmed into the device by the manufacturer that can uniquely identify the corresponding device, including IMEI/IDFA/IDFV/UUID/Android ID/OAID/IMSI. Unique device identifiers serve various purposes.

1.6 IP Address

Each internet-connected device is assigned a number called an Internet Protocol (IP) address. These numbers are typically assigned based on geographic regions. IP addresses can usually identify the location where a device connects to the internet.

1.7 WiFi

WiFi is a technology that allows electronic devices to connect to a wireless local area network (WLAN), commonly referred to as wireless networks.

1.8 HTTPS

HTTPS (Hyper Text Transfer Protocol Secure) is an HTTP channel aimed at security, essentially a secure version of HTTP.

2.1

We strictly adhere to the principles of "consistent rights and responsibilities, purpose limitation, explicit consent, data minimization, transparency, security assurance, and subject participation" when collecting and using information.

2.2

We provide App developers with third-party independent plugins that utilize non-open-source, non-resident SDK modules embedded in Apps to collect basic device information. The scope of basic device information collection is controlled by App developer authorization. When the App launches, the SDK module activates and quickly completes the collection of authorized information, then automatically terminates without background self-startup or associated startup. The entire process typically lasts only seconds, completely preventing the SDK module from directly or indirectly obtaining subsequent user behavior information.

2.3

We collect different information based on the services you select, as detailed in the table below. We only collect standalone device information that cannot identify specific individuals or reflect specific individual activities. For collected unique device identifiers, we employ technical measures to convert original immutable identifiers into modifiable states, retaining no immutable identifier information.

2.4 System Permission Requirements

To ensure end users can properly use relevant features and services, we request the following system permissions through developer applications. We will seek end user consent before requesting permissions, and end users may choose to "Allow" or "Deny" these requests. After authorization, we will enable the relevant permissions. End users may revoke authorization at any time through system settings, which may disable related features but won't affect access to other functionalities. The specific features and their corresponding permission requirements are as follows:

3.1 Sharing and Transfer of Personal Information

3.1.1 We will not share your personal information with any other company, organization, or individual, except in the following circumstances:

(1) With your prior explicit consent or authorization;

(2) When required by applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements;

(3) Sharing with authorized partners: For the purposes stated in this policy, some of our services may be provided jointly by us and authorized partners. We may share certain information with partners to provide better customer service and user experience. We will only share your personal information for lawful, legitimate, necessary, specific, and clear purposes, and only the personal information necessary to provide the services. Our partners are not authorized to use the shared personal information for purposes unrelated to the product or service. For partners with whom we share your personal information, we enter into confidentiality agreements with them. You understand and agree that we may share your personal information with the following authorized partners:

1) Sharing with affiliates to achieve specific functions or services

When you use our services and products provided by our affiliates, to ensure consistency in the services you receive across our and our affiliates' products and to facilitate unified management of your information, we may share your de-identified personal information with these affiliates.

2) We may share de-identified or anonymized information with advertising partners

We may share information you upload with partners entrusted to conduct promotions and ad placements, but we will not share information used to identify individual users.

3) Sharing with business partners to achieve specific functions

When software service providers, smart device providers, or system service providers jointly provide services with us, you authorize us to provide the information to third-party service platforms or providers so they can offer services to you based on the relevant information.

3.1.2 Prudent Assessment of Third Parties and Liability Constraints

(1) With your consent, we will only share the information necessary to achieve the purpose with third parties. If a third party requires the use of personal information beyond the aforementioned scope for business needs, the third party must seek your consent again.

(2) For third parties with whom we share your personal information, we enter into confidentiality agreements with them. At the same time, we assess their data security capabilities and environment and require these third parties to handle the information with confidentiality and security measures no less stringent than those required by this Privacy Policy.

3.1.3 Transfer of Personal Information During Acquisitions, Mergers, or Reorganizations

As our business continues to develop, we may undergo mergers, acquisitions, or asset transfers, and your personal information may be transferred as a result. In such cases, we will notify you via a pop-up window to ask whether your personal information may be transferred to the new company and will require the new holder of your information to continue to be bound by this Privacy Policy. Otherwise, we will require the company or organization to seek your authorization and consent again.

3.2 Public Disclosure of Personal Information

We will not publicly disclose your information unless required by national laws and regulations, litigation, mandatory government department requirements, or with the explicit consent of the end user.

3.3 Circumstances Where Consent Is Exempted by Law for Sharing, Transferring, or Publicly Disclosing Personal Information

Please understand that in the following circumstances, in accordance with laws, regulations, and national standards, we may share, transfer, or publicly disclose your personal information without your authorization or consent:

(1) When directly related to national security or national defense security;

(2) When directly related to public safety, public health, or significant public interests;

(3) When directly related to criminal investigation, prosecution, trial, or execution of judgments;

(4) When necessary to protect the life, property, or other significant legitimate rights and interests of you or others but difficult to obtain consent from the individual;

(5) When the personal information is disclosed to the public by you on your own;

(6) When collected from legally publicly disclosed information, such as lawful news reports or government information disclosure channels;

(7) When related to our fulfillment of obligations under laws and regulations.

4.1 Location of Information Storage

We retain your information only for the period necessary for the purposes stated in this Privacy Policy and as required by applicable laws and regulations. Information collected and generated during our operations within the territory of the People's Republic of China is stored within China.

4.2 Duration of Information Storage

We commit to storing your personal information for the minimum period required by law, ensuring compliance with legal provisions on personal information retention. Personal information exceeding the aforementioned retention period will be deleted or anonymized, unless otherwise stipulated by laws and regulations.

4.3 Methods of Information Protection

We take the security of your personal information very seriously and implement reasonable security measures (both technical and administrative) to protect it from unauthorized access, disclosure, use, modification, damage, loss, or leakage. Our protection of personal information follows these principles:

(1) Anonymization of Personal Information: After collecting your personal information, we promptly anonymize the data through technical means. You should understand that anonymized information is no longer considered personal information. Without disclosing your personal information, we reserve the right to mine, analyze, and utilize (including commercially) the anonymized user database.

(2) Security Safeguards: We employ industry-standard security measures to protect the personal information you provide from unauthorized access, disclosure, use, alteration, damage, or loss. We take all reasonably feasible steps to safeguard your personal information. For example, data exchanged between your browser and our services is protected by SSL encryption; we use encryption technologies to ensure data confidentiality; we deploy trusted protection mechanisms to prevent malicious attacks; we implement access control measures to ensure only authorized personnel can access personal information; and we conduct security and privacy training to enhance employees' awareness of the importance of protecting personal information.

(3) Timely Notification: The internet is not an absolutely secure environment, and communication methods such as email, instant messaging, and interactions with other users are not encrypted. We strongly advise against sending personal information through these channels. Please use complex passwords to help us secure your account. In the event of a breach of our physical, technical, or administrative safeguards leading to unauthorized access, disclosure, alteration, or destruction of your information, resulting in harm to your legitimate rights, we will assume corresponding legal liability. In the unfortunate event of a personal information security incident, we will promptly notify you as required by law, providing details of the incident, its potential impact, measures we have taken or will take, recommendations for self-protection and risk mitigation, and remedial actions. We will inform you via email, letter, phone, or push notification. If individual notification is impractical, we will issue a public notice in a reasonable and effective manner. Additionally, we will report the handling of the incident to regulatory authorities as required.

You can access and manage your information in the following ways.

5.1 Accessing, Correcting, and Supplementing Your Information

We strive to enable you to review, correct, or supplement the information you have provided to us. To do so, please visit our website and log in to your account. If a specific action cannot be performed through your account page, you may contact us using the methods provided in the "How to Contact Us" section of this policy, and we will assist you accordingly.

5.2 Account Deletion and Personal Information Removal

If you no longer wish to use our products, you may submit a request to delete your account. We typically respond to such requests within 15 days. For account security purposes, we will verify your identity before processing your request and may require you to provide valid identification. After account deletion, we will no longer provide services to you. If you wish to have your personal information deleted, you may also submit a request for its removal.

5.3 Obtaining a Copy of Personal Information

You have the right to request a copy of your personal information. Where technically feasible (e.g., through compatible data interfaces), we may also transmit a copy of your personal information directly to a third party you designate.

If your end users wish to obtain a copy of their personal information, they may submit a request to us. After verifying their identity, we will provide them with a copy of their personal information.

Our products, website, and services are primarily intended for adults. We do not actively collect personal information from minors. If you are under 18, please read this Privacy Policy carefully with your guardian, ensure their consent, and use our services or provide information to us only with their approval. We will collect, process, and protect your personal information in accordance with relevant laws and agreements.

If you or your guardian believe we have collected or used your personal information without authorization, please contact us using the methods provided in this Privacy Policy. Upon verification, we will promptly delete the relevant information. If we discover that we have collected personal information from a minor without verifiable parental consent, we will take steps to delete the information as soon as possible.

For personal information of children under 14, in addition to the measures outlined elsewhere in this Privacy Policy, we will implement the following safeguards:

· We strictly adhere to the requirements of the "Regulations on the Online Protection of Children's Personal Information" and other relevant laws when collecting and using children's personal information.

· We designate dedicated personnel responsible for protecting children's personal information, as required by the "Regulations on the Online Protection of Children's Personal Information."

· When you, as a guardian, choose our services for a child under your guardianship, we may need to collect the child's personal information to provide our services. By providing such information, you consent to our handling of the child's personal information in accordance with this Privacy Policy. We will collect children's personal information only with your authorization and inform you of the purpose and use. Without this information, the child will not be able to access certain services. As a guardian, you should fulfill your responsibilities to protect the child's personal information and guide them to avoid providing their personal information to us without your consent.

Children or their guardians have the right to access and correct the child's personal information and may request its correction or deletion. If you have any questions, suggestions, complaints, or reports regarding children's personal information, please contact us at any time.

To provide you with better services, our business may change from time to time, and this Privacy Policy will be adjusted accordingly. We will not reduce your rights under this Privacy Policy without your explicit consent. For any revised or updated privacy policy, we will seek your consent again. When there are changes in the purposes, methods, or scope of collecting and using personal information, we will notify you again through pop-up notifications or in-site messages.

If you have any questions, comments, or suggestions regarding this Privacy Policy, you may contact us through the following methods. We will respond within 15 days:

Company Name: [Shanghai Yunxi Information Technology Co., Ltd.]

Registered Address: [Room JT9738, Building 2, No. 4268 Zhennan Road, Jiading District, Shanghai]

Data Protection Officer Contact: [contact@aiclk.com]

If you are dissatisfied with our response or believe our personal information processing has infringed your legitimate rights, you may also seek resolution through: Reporting to the Cyberspace Administration of China (website: http://www.12377.cn, hotline: 12377), or filing a lawsuit with a competent people's court.