Chuanshanjia Privacy Policy

Version Date :  May13, 2022

Effective Date: May13, 2022

Reminders

We understand the importance of your personal information and will adopt security measures to protect your personal information and privacy pursuant to the provisions in relevant laws and regulations. Therefore, Chuanshanjia and their service provider (Beijing Ocean Engine Co., Ltd and its affiliates; hereinafter referred to as "We" or the "Company") hereby formulate this Privacy Policy (hereinafter referred to as "this Policy/this Privacy Policy").

This Privacy Policy shall apply to the services provided by Chuanshanjia. Your access to Chuanshanjia and use of the services provided by Chuanshanjia, including but not limited to our website, SDK, API, tools and products or services constantly developed and innovated by us shall be governed by this Privacy Policy.

Before using Chuanshanjia and its related services, you must carefully read and thoroughly understand this Policy and only use the Platform and its related services once you fully understand and agree to this Policy. By using Chuanshanjia or its related services, this indicates you fully understand and agree to this Policy.

Through this Privacy Policy, we would like to explain to you that, when you use Chuanshanjia and its related services, we will collect, use, store, share, transfer (if applicable), and protect your personal information. In addition, we will tell you how we will process your personal information and the methods we provide for you to access, correct, supplement, delete, reproduce, withdraw your authorization and consent, and otherwise transfer your personal information. Please pay special attention to the important content, including clauses about your rights regarding your personal information, which have been highlighted in bold.

This Privacy Policy will help you understand:

I. How we collect and use your personal information

II. Our use of cookies and similar technologies

III. How we store your personal information

IV. Partners involved in the use of data and transfer and disclosure of personal information

V. How we protect the security of your personal information

VI. Management of personal information

VII. How we protect minors

VIII. Access to Privacy Policy and Revisions

IX. Contact

X. Miscellaneous

I. How we collect and use your personal information

During your use of the Chuanshanjia and its related services, we will collect information when it is legal, legitimate, and necessary.

(I) Personal information we directly collect and use

We will collect, through the following means, the information you voluntarily provide when you use the services and, by automated means, the information produced during your use of the functions or acceptance of the services:

1. Ensuring the normal operation of Chuanshanjia and its related services

When you access to Chuanshanjia and use its related services, we will collect your device brand, model, operating system version number, browser information, IP address, software version number, software region, software language, network type, system language, carrier information, platform operation, usage, and service logs in order to ensure your normal vistit to Chuanshanjia and use of its services. Please be aware that this information is essential information that we must collect to provide the services and ensure the normal operation of the products.

2. Register and log into Chuanshanjia and related services

(1) When you register and log into Chuanshanjia and its related services, you may create an account with your mobile number, in which case we will verify that your identity is valid by sending a verification code, or you may create an account with your email address and provide the appropriate online identification information, including your password, contact name, contact number, email address, mailing address, enterprise information, and product information. This information is collected to help you complete the registration process and cooperate with Chuanshanjia to receive services.

3. Information we collect during your use of our products or services

When you contact us, we may store your communication/call records and content, the contact information or other information you provide for the purpose of contacting you, helping you solve issues, or recording troubleshooting solutions and results.

4. Personal information we collect indirectly

For the purpose of providing you with better and more personalized services, or jointly providing you with services, or preventing Internet fraud, our affiliates and partners may share your personal information with us pursuant to the relevant laws, agreements with you, or with your consent.

5. You understand and agree to abide by the Compliance Specifications for Chuanshanjia SDK Developers (Link: https://www.csjplatform. com /terms/compliance-guide ).

6. When you use Chuanshanjia SDK service, you need to use SDK. We will obtain the personal information and permissions of the end users of your products through the SDK, the type, field, usage, and purpose of the personal information of end users obtained by the Chuanshanjia SDK has been detailed in the Compliance Specifications for Chuanshanjia SDK Developers. Chuanshanjia will not obtain sensitive personal information, nor shall you transmit sensitive personal information to Chuanshanjia:

(II) Safeguard the security of the products, services, and users using the products and services

We may record network log information as well as the frequency of use, corrupted data, total installations, usage conditions, performance data, and other information about the software and relevant services in order to help us better understand the operation of Chuanshanjia and its related services. This will allow us to ensure the security and provision of the service.

(III) Other purposes

We may conduct research, statistical analysis, and prediction using the information you provide or we collect after such information is de-identified. This allows us to improve and enhance the services of Chuanshanjia and provide our users with products or technical service support for making marketing decisions.

We will first obtain your consent before using the information for any other purpose not contained herein or use the information collected for a particular purpose for any other purpose.

We may also collect other information about you as reasonably necessary for the provision of services and the improvement of service quality, including information you provide when contacting our customer service team, completed questionnaires you send to us when participating in a survey, and information we collect when you interact with the affiliates and partners of Chuanshanjia.

At the same time, we may judge the risks to your account by understanding some of your Internet habits and your commonly-used software. We may record some URLs which we think are risky in order to improve your security when using Chuanshanjia services and to more accurately prevent fraud from phishing websites and Trojans.

(IV) Processing personal information without consent in accordance with the law

Please understand that, in accordance with the law, we will process without your authorization and consent your personal information if:

(1) Such information is necessary for entering into or performing the contract as required by you;

(2) Where it is necessary for performing a statutory responsibility or statutory obligation, such as legal duties or obligations directly related to national security, national defense security, criminal investigation, prosecution, trial and judgment execution, etc.;

(3) Where it is necessary for responding to a public health emergency, or for protecting the life, health or property safety of the natural person in the case of an emergency;

(4) Where the personal information is processed within a reasonable scope to carry out any news reporting, supervision by public opinions or any other activity for public interest purposes;

(5)Where the personal information, which has already been disclosed by you or otherwise legally disclosed (such as news reports, government information disclosure and other channels of legal disclosure of personal information), is processed within a reasonable scope;

1. Any other circumstance as provided by law or administrative regulations.

Special Instructions: If the information cannot be used individually or in combination with other information to identify a person, it is not personal information. When your information can be used individually or in combination with other information to identify you or we use data that cannot be connected with any particular person in combination with your personal information, this information will be subject to processing and protection as your personal information in accordance with this Privacy Policy during such combined use.

II. Our Use of cookies and similar technologies

Cookies and similar technologies are commonly used on the Internet. When you use Chuanshanjia and related services, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device in order to collect and identify information when you access and use this product. We promise that we will not use the cookies for any purpose other than those set out herein. We primarily use cookies and similar technologies in order to realize the following functions or services:

(I) Ensure the secure and efficient operation of products and services

We may set cookies or anonymous identifiers that certify and safeguard security, allowing us to confirm that you have securely logged into the services or whether you have experienced embezzlement, fraud, or other illegal actions. These technologies will also help us improve the service efficiency and accelerate login and response speeds.

III. How we store your personal information

(I) Information storage locations

In accordance with the provisions in relevant laws and regulations, we will store the personal information collected and produced about you during your operations in the People's Republic of China within the People's Republic of China. Currently, we will not transfer this information outside of the People's Republic of China, but if we do so in the future, we will follow the provisions of the appropriate country or obtain your consent.

(II) Period of storage

We will retain your personal information for only as long as it is necessary to provide Chuanshanjia and its related services. If you delete your peraonal information or beyond the necessary period, we will delete or anonymize your personal information, unless: a) it needs to comply with the information retention requirements of laws and regulations; b) a reasonable extension of time is required for the purpose of financial, audit, dispute resolution or other purposes.

IV. Partners involved in the use of data and transfer and disclosure of personal information

(I) Partners involved in the use of data

1. Basic principles

Our cooperation with our partners will be in accordance with the following principles:

a) Principle of legality: Where data processing activities are involved, the principle of legality shall be observed.

b) Principle of legitimacy and minimum necessity: Data must be used for a legitimate purpose and only to the extent necessary to achieve that purpose.

c) Security Prudence: We will carefully assess the purposes for which data is used by our partners, make a comprehensive assessment of the security capabilities of those partners, and require them to comply with the cooperation agreement and data protection agreement. The application programming interfaces (APIs) through which partners access information will be strictly monitored for security to protect the data.

2. Entrusted processing

In the case of entrusted processing of personal information, we will sign relevant agreement(s) with the entrusted party in accordance with the law and agree on their respective rights and obligations to ensure that the relevant personal information is used in compliance with the relevant provisions of the law and to protect data security.

3.Joint processing

In the case of joint processing of personal information, we will sign an agreement with the partner in accordance with the law and agree on their respective rights and obligations to ensure that the use of the personal information in question complies with the relevant provisions of the law and protects data security.

4. Scope of partners

If the specific functions and scenarios involve the provision of services by our affiliates or third parties, the scope of partners includes our affiliates and third parties.

(II) Cooperative scenario

1. To share relevant functions or services with affiliates

When you are using Chuanshanjia and its affiliates' products, we will share your de-identified personal information with these affiliates in order to ensure consistency in the services you receive between our products and those of our affiliates, and to facilitate uniform management of your information.

2.De-identified or anonymized information shared with advertisement partners

We may share with the partners who entrust us with promotion and ad delivery (hereinafter referred to as ”Ad partners”) the user portraits and tags and the de-identified or anonymized information that cannot be used to identify an individual so as to improve the effective reach of advertisements without allowing the identification of individuals. This information will help us analyse, measure and optimise the effectiveness of our advertising and related services, and increase the effective reach of our advertising.

a) Advertisment push and placement: Ad partners who push/promote and place ads or provide related services may need to use de-identified or anonymised device, network and channel information and tagging information; ad partners who work with advertisers on ad push/promotion, placement/analysis services may need to use the aforementioned information in order to place, optimise and improve the effective reach of their ads.

b) Statistical analysis of advertising: Ad partners who provide statistical analysis of advertising may need to use information about your device, network, ad clicks, views, displays and ad conversion data to analyse, measure and optimise the effectiveness of advertising and related services.

c) Use of information by Ad partners: Ad partners may combine the above information with other data they have legally obtained in order to optimise the effectiveness of their advertising, and we will require that their use of information is lawful, appropriate and necessary to protect users from infringement of their legal rights.

d) Information left in the advertisements: The contact information, address and other relevant information that you actively fill in and submit in the advertisements may be collected and used by the advertisers or the partners entrusted by them.

3. Implementing security and statistical analysis

3.1 Safeguarding the security of use: We attach great importance to the security of our products and services. In order to safeguard the legitimate and legal rights of end-users who use the Chuanshanjia services from unlawful infringement, our partners may use the necessary device, account and log information.

3.2 Analysis of products: In order to analyse the stability of the products and services of Chuanshanjia, our partners who provide analysis services may need information on the use of services (crashes, flashback records), device identification information, and the overall installation and use of applications.

3.3 Academic scientific research: In order to improve the scientific research capability in related fields and promote the level of scientific and technological development, we may use de-identified or anonymised data with partner research institutes, universities and other institutions under the premise of ensuring data security and proper purpose.

(III) Change in Operator

We may engage in mergers, acquisitions, and asset transfers in line with the continuous development of our businesses, and your personal information may therefore be transferred. Prior to the aforesaid changes, we will continue to protect or require the new holder of the personal information to continue to protect your personal information in accordance with relevant laws and regulations, as well as security standards that are not inferior to those required herein. If the successor changes the original purpose or method of processing, we will require the successor to obtain your authorisation again.

(IV) Cease of operations

If we stop operations, we will promptly cease collecting your personal information, notify you of the ceasing of operations by individual notification or an announcement, and delete or anonymize your personal information held by us.

(V) Disclosure

We will not voluntarily disclose information that you have not disclosed yourself, except in accordance with national laws and regulations or with your consent.

(VI) Processing personal information without consent in accordance with the law

Please understand that, in accordance with the law, we will process without your authorization and consent your personal information if:

(1) Such information is necessary for entering into or performing the contract as required by you;

(2) Where it is necessary for performing a statutory responsibility or statutory obligation, such as legal duties or obligations directly related to national security, national defense security, criminal investigation, prosecution, trial and judgment execution, etc.;

(3) Where it is necessary for responding to a public health emergency, or for protecting the life, health or property safety of the natural person in the case of an emergency;

(4) Where the personal information is processed within a reasonable scope to carry out any news reporting, supervision by public opinions or any other activity for public interest purposes;

(5)Where the personal information, which has already been disclosed by you or otherwise legally disclosed (such as news reports, government information disclosure and other channels of legal disclosure of personal information), is processed within a reasonable scope;

(6)Any other circumstance as provided by law or administrative regulations.

V. How we protect the security of your personal information

(I) We attach great importance to the security of your personal information and will endeavor to take reasonable security measures, in order to ensure that our processing of personal information complies with laws, administrative regulations and other rules legally applicable and prevents unauthorized access and the disclosure, alteration or loss of Personal Information.

(II) We will use encryption technology, deidentification, anonymization, and other reasonably practicable means that are not inferior to those normally adopted by the industry to protect your personal information, and use security protection mechanisms to protect your personal information against malicious attacks.

(III) We will establish a security department, a security management system, and data security processes that are dedicated to safeguarding the security of your personal information. We will adopt strict data use and access systems to ensure that only authorized personnel may access your personal information. We will also conduct safety education and training to our staff on a regular basis, and conduct security audits on the relevant data and technologies from time to time.

(IV) We will formulate contingency plans and, in the event of a security event involving user information, immediately implement such plans to prevent the expansion of the impact and consequences of such security events. Once any personal information security event (leakage of, tampering with, or loss of personal information, etc.) occurs, we will, as required by relevant laws and regulations, promptly notify you of the following: types, reasons and possible harms of personal information subject to or likely to be leaked, tampered with or lost, remedial measures that we have taken, mitigation measures that you can take and the way to contact us. We will promptly notify you of relevant information by push notification, email, correspondence, SMS, or other means, and when it is difficult to give notification to the involved parties individually, we will adopt reasonable and effective means to publish an announcement. Meanwhile, we will also report the handling of the security event involving user information as required by the competent authorities.

(V) Although the reasonable and valid measures mentioned above have been adopted and the standards required in applicable laws and regulations have been complied with, please understand that in the Internet industry, it is impossible to always ensure the total security of information even if we try our best to enhance security measures due to technical limitations and various possible malicious techniques. However, we will endeavor to ensure the security of the personal information you provide to us to the greatest extent possible. You acknowledge and understand that the system and communication network for your access to our services may fail due to factors beyond our control. We therefore strongly suggest that you adopt active measures to protect the security of your personal information, including but not limited to using strong passwords, regularly modifying the passwords, and not disclosing your personal information including your passwords to others.

(VI) You are hereby specifically reminded that the personal information protection measures provided herein only apply to Chuanshanjia and its related services. By logging out of Chuanshanjia and its related services and browsing or using other websites, services, and content resources, we will not be able or be obligated to protect any personal information you submit to the software and websites outside of Chuanshanjia and its related services, irrespective of whether your login, browse, or use the aforesaid software and websites based on links or instructions provided on Chuanshanjia.

VI. Management of personal information

We attach great importance to the management of your personal information and do our utmost to protect your rights to access to, reproduce, correct, supplement, delete your personal information, withdraw your authorization and consent, close your account, submit complaints and reports, and other functions so that you will be able to safeguard your personal information security. We will assist you in doing so by contacting us in accordance with the contact information set forth in this Privacy Policy.

However, please understand that certain business functions and services will require your information in order to be completed and when you withdraw your consent or authorisation, we will no longer be able to provide you with the corresponding functions and services and will no longer process your personal information accordingly. However, your decision to withdraw your consent or authorisation will not affect the processing of personal information that we have previously carried out on the basis of your authorisation.

The paths we provide for the administration methods in different versions or operating systems may vary, please refer to the actual.

VII. How we protect minors

If you are a minor under the age of 18, you shall read and agree to this Privacy Policy under the guardianship and direction of your parents or guardians before using Chuanshanjia and its relevant services.

We will protect the personal information of a minor in accordance with the provisions in applicable national laws and regulations and will only collect, use, store, share, transfer, or disclose the personal information of the minor where permitted by law, with the express consent of the parents or guardians or when it is necessary to protect the minor. If we discover that the personal information of a minor has been collected without prior verifiable consent of their parents or guardians, we will try to delete such information as soon as possible.

If you are the guardian of a minor, please contact us through the contact information provided in this Privacy Policy if you have any questions about the personal information of the minor under your guardianship.

VIII. Access to Privacy Policy and Revisions

(I) To provide you with better services, Chuanshanjia and its relevant services will be subject to updates and changes from time to time. As appropriate, we will revise this Privacy Policy from time to time, with such revisions forming an integral part of this Privacy Policy. We will not diminish any of your rights under the Privacy Policy currently in effect without your express consent.

(II) After this Privacy Policy is updated, we will release the updated version on Chuanshanjia and remind you of the updated content through an announcement on the official website or any other appropriate means before the updated terms take effect so that you may immediately understand the latest version of this Privacy Policy.

IX. Contact

You may submit complaints or reports using the systems we indicate. If you believe that your personal information rights may have been violated, or if you find clues that your personal information rights have been violated (for example, if you believe that we have collected your personal information in violation of the law or by mutual agreement), you may contact us by sending an email to [union_service@bytedance.com]. We will respond to your complaint or report within 15 working days after verification.

You may also contact us by logging into the "User Feedback" page in the Chuanshanjia client or through the "Contact Us" portal on the official website. We will reply to your feedback within 15 working days after verification.

If we stop operations, we will promptly cease collecting your personal information, notify you of the ceasing of operations by individual notification or an announcement, and delete or anonymize your personal information held by us.

X. Miscellaneous

This Privacy Policy applies to the products or services on Chuanshanjia. If the products or services of Chuanshanjia have been used by the products or services of our affiliates but no separate privacy policy is set, this Privacy Policy also applies to such products or services.

It should be particularly noted that this Policy does not apply to the services provided to you by other third parties nor the products or services for which Chuanshanjia has set a separate privacy policy.

Please be aware that Chuanshanjia and its related services stated herein may vary depending on your mobile device model, system version, software app version, mobile client, etc. The final products and services shall be subject to Chuanshanjia software and its related services you use.