Bei22jing Tendcloud Tianxia Technology Co. Ltd. and its affiliates (hereinafter referred toas “we/us” or“TalkingData” collectively) pay much attention to the protection of personalinformation and privacy. TalkingData understands the importance of personal information and will do its best toprotect your personal information. We are committed to maintaining your trust in us, and we will abide by theprinciples of participation, openness, and transparency. When one visits the TalkingData website or signs up for anyTalkingData product or service, we will adopt appropriate protection measures to safeguard your personal information,in accordance with leading industry standards.If you have any questions, comments, or suggestions, pleasereach out to us using one of the following contact methods: E-Mail: support@tendcloud.com Phone:400-870-1230
Important Notice:
This Privacy Policy only applies to products and servicesoffered by TalkingData. including but not limited to: the website, SDK, API, Code, tools, product documentation,etc.It does not apply to products or services offered by third parties through TalkingData or through third-party linkson the TalkingData website. For these cases, we suggest you carefully read the privacy policies of each thirdparty.This Privacy Policy is very important for TalkingData's products and services.Please carefully read it to understand how we collect, use, store, and transfer your information and/or your endusers' information. We strive to explain it in a clear,understandable, and appropriate way so that you canunderstand your rights and make your choices accordingly.Please note that visiting theTalkingData website or using any of our services means you have read, learned, and agreed to our privacy policy.This policy is valid throughout the whole process of using our website and its services, so if you do not agree withthis policy you may stop using the TalkingData website immediately and the various services describedbelow. Please ensure that you utilize the TalkingData SDK in a legal and compliantmanner, adhering to relevant laws, regulations, national standards, and regulatory requirements. The specificprocedure is as follows: 1.Please upgrade the TalkingData SDK to the latest version,and you can find the download link here: https://doc.talkingdata.com/posts/catalogue/1075. 2.Please complete the SDK integration according to the "SDK Integration Document". TalkingData SDK performspreparatory work only during the initialization phase of the application, without collecting any data. You shouldensure that you initiate the analytics capabilities of the TalkingData SDK based on reasonable business scenariosand in compliance with privacy policies, only after obtaining consent from end-users. For instructions on the latestversion's initialization configuration and analytics capabilities, please refer to the following links: Android:https://doc.talkingdata.com/posts/1025 iOS: https://doc.talkingdata.com/posts/1024 Harmony: https://doc.talkingdata.com/posts/1156This Privacy Policy will help you understand the following:1. How we collect and use your personal information 2. How we use cookies and similartechnologies 3. How we share, transfer, and publicly disclose your personal information 4. How we protect yourpersonal information 5. Your rights 6. How we handle children's personal information 7. How your personalinformation is stored or transferred internationally 8. Updates to this policy 9. How to contact us
I. How we collect and use your personal information
Personal information refers to information recorded in electronic or other forms that is capable of, either byitself or in combination with other information, to identify the identity of a specific person or that specificperson's activities.TalkingData will only collect and use your personal information or that of your end users for the purposesdescribed in this policy.Unless specifically stated, this service is only available to users in mainland China (PRC). If you arelocated outside the PRC, or if you use TalkingData's products or services for end users outside the PRC, pleasecomply with the Overseas Personal Information Protection Compliance Commitment as well. When we use data forpurposes not covered by this policy, we will ask for your consent in advance. When we use information collectedfor a specific purpose in a different way, we will also ask for your consent in advance.1. Provide you with online information servicesWhen you visit and browse our website, like mostwebsites, we will:
Use cookies to store conversations/select information from yourcomputer; Automatically collect certain information and store it in log file. This informationincludes: Internet protocol(IP) address, browser type, Internet service provider (ISP), reference/exit page, OS,date/time stamp, click-data stream, and so on. We use this information to: --Improve yourwebsite experience and service quality; --Help us manage website content more efficiently; --Analyze groupusers' on-site activities.
2. Overview of Usage of TalkingData Services When you register for TalkingData, we willrequest your personal information, including your name, company name, e-mail address, password, telephone number,andQQ number to create a new account When you contact us afterwards and continue to use our services, we may requestadditional contact information, including:
--Postal address, telephone number, duty, and position; --Your company information, such as company name andbusiness type; --Your product information, such as mobile application name, content, type, promotion channel,etc.
We may use this information to:
--Send you a registration confirmation; --Manage your account; --Respond to clients' servicerequirements; --Learn about your company's requirements and product interests, so as to determine the mostapplicable product and service; --Contact you for marketing and promotion purposes, and provide you with moreinformation about our products; --Research and analyze to improve the quality of our website and services.
You can contact us through the e-mail address listed on our website. You may provide personalinformation when you contact us by e-mail, and we will use this information to respond to your questions and servicerequirements as well as upgrade our website and services.3. Details for Usage of TalkingData ServicesTalkingData AnalysisServiceTalkingData provides data statistics and analysis services for mobile applications, including but notlimited to App Analysis and Ad Tracking. Your application will collect and transfer users' relevant data throughtechnical means after installing the TalkingData SDK or API into it, and our service will help analyze this data tolearn more about performance and usage of your application on different devices, platforms, or applicationdistribution channels.The specific details regarding the handling of relevant data are as follows:Android Versionï¼
Product Functionality
Types of Data
Specific Data Fields
Processing Purposes
App Analysis
Mandatory
Fundamental personal information
Unique device identifiers (OAID,ODID and Android ID), IP address
To generate de-identified unique identifiers for end-users, facilitating fundamental analysis.
Basic data concerning other aspects of applications, devices, and networks
SDK or API version, platform, timestamp, system file creation time, application identifier, applicationversion, application distribution channel, application process information, sensor information, application's NFC permission status (yes or no), device's NFC capability (yes orno), device's Bluetooth capability (yes or no), device model, terminal manufacturer, terminal device operatingsystem version, session start/stop time, language locale, mobile network/country code, time zone, hard disk,CPU, and battery usage information, network information (connectivity status of WiFi network or mobilenetwork, connected WiFi BSSID or SSID information)
To conduct coarse-grained multidimensional analysis and provide data reports categorized by region andapplication version number.
Optional
Optional personal information
MEID, IMEI, or Mac information
To enhance the precision of end-user identification and identify fraudulent traffic.
Application list
To identify, analyze, and purge fraudulent traffic.
Location information (latitude and longitude, SystemID, NetworkID, and BasestationID)
To generate more precise location distribution reports and identify fraudulent traffic.
Ad Tracking
Mandatory
Fundamental personal information
Unique device identifiers (OAID,ODID and Android ID), IP address
To generate de-identified unique identifiers for end-users, facilitating fundamental analysis.
Basic data concerning other aspects of applications, devices, and networks
SDK or API version, platform, timestamp, system file creation time, application identifier, applicationversion, application distribution channel, application process information, sensor information, application's NFC permission status (yes or no), device's NFC capability (yes orno), device's Bluetooth capability (yes or no), device model, terminal manufacturer, terminal device operatingsystem version, session start/stop time, language locale, mobile network/country code, time zone, hard disk,CPU, and battery usage information, network information (connectivity status of WiFi network or mobilenetwork, connected WiFi BSSID or SSID information)
To conduct a coarse-grained multidimensional analysis, assess the effectiveness of advertisingplacements, identify, analyze, and purge fraudulent traffic.
Optional
Optional personal information
MEID, IMEI, or Mac information
To enhance the precision of user identification and identify fraudulent traffic.
Application list
To identify, analyze, and purge fraudulent traffic.
Location information (latitude and longitude, SystemID, NetworkID, and BasestationID)
To generate more precise location distribution reports and identify fraudulent traffic.
iOS Versionï¼
Product Functionality
Types of Data
Specific Data Fields
Processing Purposes
App Analysis
Mandatory
Fundamental personal information
IP address, IDFV, and IDFA
To generate de-identified unique identifiers for end-users, facilitating fundamental analysis.
Basic data concerning other aspects of applications, devices, and networks
SDK or API version, platform, timestamp, system file creation time, application identifier, applicationversion, application distribution channel, application process information, application's IDFA authorizationstatus, device model, terminal manufacturer, terminal device operatingsystem version, session start/stop time, language locale, mobile network/country code, time zone, hard disk,CPU, and battery usage information
To conduct coarse-grained multidimensional analysis and provide data reports categorized by region andapplication version number.
Optional
Network information
WiFi network or mobile network connection status, connected WiFi BSSID or SSID information
To obtain network connection status to determine network type and approximate regional scope.
Location information
Latitude and longitude
To generate more precise location distribution reports and identify fraudulent traffic.
Ad Tracking
Mandatory
Fundamental personal information
IP address, IDFV, and IDFA
To generate de-identified unique identifiers for end-users, facilitating fundamental analysis.
Basic data concerning other aspects of applications, devices, and networks
SDK or API version, platform, timestamp, system file creation time, application identifier, applicationversion, application distribution channel, application process information, application's IDFA authorizationstatus, device model, terminal manufacturer, terminal device operatingsystem version, session start/stop time, language locale, mobile network/country code, time zone, hard disk,CPU, and battery usage information
To conduct a coarse-grained multidimensional analysis, assess the effectiveness of advertisingplacements, identify, analyze, and purge fraudulent traffic.
Optional
Network information
WiFi network or mobile network connection status, connected WiFi BSSID or SSID information
To obtain network connection status to determine network type and approximate regional scope, and identify, analyze, and purge fraudulent traffic.
Location information
Latitude and longitude
To generate more precise location distribution reports and identify fraudulent traffic.
Harmony Versionï¼
Product Functionality
Types of Data
Specific Data Fields
Processing Purposes
App Analysis
Mandatory
Fundamental personal information
Unique device identifiers (OAID,ODID,AAID), IP address
To generate de-identified unique identifiers for end-users, facilitating fundamental analysis.
Basic data concerning other aspects of applications, devices, and networks
SDK or API version, platform, timestamp, system file creation time, application identifier, applicationversion, application distribution channel, application process information, device model, terminal manufacturer, terminal device operatingsystem version, session start/stop time, language locale, mobile network/country code, time zone, hard disk,CPU, and battery usage information
To conduct coarse-grained multidimensional analysis and provide data reports categorized by region andapplication version number.
Optional
Location information
Latitude and longitude
To generate more precise location distribution reports and identify fraudulent traffic.
Ad Tracking
Mandatory
Fundamental personal information
Unique device identifiers (OAID,ODID,AAID), IP address
To generate de-identified unique identifiers for end-users, facilitating fundamental analysis.
Basic data concerning other aspects of applications, devices, and networks
SDK or API version, platform, timestamp, system file creation time, application identifier, applicationversion, application distribution channel, application process information, device model, terminal manufacturer, terminal device operatingsystem version, session start/stop time, language locale, mobile network/country code, time zone, hard disk,CPU, and battery usage information
To conduct a coarse-grained multidimensional analysis, assess the effectiveness of advertisingplacements, identify, analyze, and purge fraudulent traffic.
Optional
Location information
Latitude and longitude
To generate more precise location distribution reports and identify fraudulent traffic.
To cater to the multidimensional analytical needs, based on the type of your mobile application and yourrequirements for statistical analysis options, your users' device data may also include: user's gender, age, triggerevent, equipment status information（such as sensor data or application list）,error reports, page views,etc.. If you use our products or services to collect more personal information from your users, you should disclosesuch information in your privacy policy and obtain authorization from users in accordance with laws andregulations.For the purpose of providing our analysis service as well as protecting the personal information ofusers, Above data collected by TalkingData analysis service will form its own user identifier on the end user deviceside for de-identification and be sent to TalkingData's servers in encrypted form through your application and displayit in a data and analysis report. You could check relevant statistics and analysis results through logging into youraccount on our website.When performing TalkingData Brand Growth service, TalkingData SDK or/and API do notcollect any impression-level data through the ad that will be used for subsequent ad targeting, TalkingData does notuse hyperlocal geo-targeting (especially with mobile ads via GPS) or browser packet-sniffing, and no activities suchas browser/device fingerprinting tracking impression-level page scraping will be conducted.Under nocircumstances will we set, or assist or knowingly permit any third party to set a cookie, or alter/delete a cookieset, on any third Party Owned and Operated domains (especially Google).eAuthService:TalkingData's eAuth service can meet a variety of verification and authentication scenarios in the APP,such as one-click login, mobile phone number verification, SMS verification code, user real-name authentication andother functions. For privacy guidelines on eAuth service, please refer to the eAuth Privacy Guidelines.Industry ReportService:We will build a TalkingData database based on data collected through our analysis service and throughother legal means. We will make an analysis report about an application's performance evaluation or behavior pattern(hereinafter referred to as an “industry report”) regarding publisher, industry, specific area, and marketinformation. Industry reports will be displayed in an unidentifiable convergent way, including those published byTalkingData itself and those customized in accordance with your requirements.In special cases, we will also useTalkingData's statistical models to make assessments of certain applications or types of applications. The results ofthese assessments may be derived from the data obtained from your application and are therefore consistent with yourapplication. However, these assessments are based on the data model we calculated for evaluation purposes and they areaggregated and anonymous.Smart Data MarketWe provide a service named Smart Data Marketboth for data service providers and demanders to enable online transactions or services of data and its derivatives(referred to as “data products,” regardless of whether they are in the form of data API, tools, orapplication software), which are produced and/or processed by TalkingData itself or authorized by a legitimate rightholder.We guarantee that the ownership of data products produced and/or processed by us is clear and compliantwith relevant laws and regulations regarding the protection of personal information. Under normal circumstances, dataproducts used in the Smart Data Market for trading and licensing are de-identified. Under some special circumstanceswhen personal information may be accessed, it is required that explicit authorization is received from the relatedperson and that use of such data is limited within a specific range. Meanwhile, we are trying our best to require thatthird party data owners guarantee that their data products meet the above requirements.ConsultingWe provide solutions, professional consulting services, and TalkingData University. In the provisionof these services, we may ask that you provide additional personal information to understand your business or product.Please decide carefully whether you feel comfortable providing this information. TalkingDatabig data application serviceIn addition to the specific services above, we will build TalkingData databasebased on the data collected by the analysis service and data obtained through other legal channels, and form acustomer group label information database or statistical analysis database by means of big data processing throughaggregation, cleaning, anonymization as well as intelligent calculation. We provide various forms of big dataapplication services on the basis of our own database for many industry customers, such as:a) Data MarketingService. Through big data capability to boost precision advertising marketing, build target customer group,comprehensively analyze the characteristics of target customer group, and improve marketing effect;b) SmartLocation Based Service. Taking full advantage of population-based data and geographic data, combined with classicmodels and predictive algorithms, to improve your location-related decision-making such as store location siteselection and foot traffic exploration of potential customers for retail.c) Other data services. We make fulluse of homomorphic encryption, data security island solutions and other technical capabilities to help demanders todiscover the deep value of data from different angles. Through comprehensive analysis of multi-terminal behaviorcharacteristics of users in private traffic, we provide a variety of data services, and create a comprehensive userdata platform, including but not limited to data model building services, data asset management services, riskassessment services, etc.You should be aware that with the development of the big data industry, our big dataservice will update and iterate or launch new service. In any case, TalkingData will strictly abide by laws andregulations as well as national standards in big data industry.4. 4.Permission related to the collection of personal informationSubject to different systemrequirements, you may also be required to obtain relevant permission to collect personal information using theTalkingData service. Android:
Name of the Permission
Purpose of Permission
INTERNET
To permit applications to establish online connectivity and transmit data.
ACCESS_NETWORK_STATE
To permit applications to check the connectivity status, and suspend data transmission in instances ofnetwork irregularities.
READ_PHONE_STATE
To generate de-identified unique identifiers for end-users.
ACCESS_WIFI_STATE
To generate de-identified unique identifiers for end-users.
WRITE_EXTERNAL_STORAGE
To store device information, and document logs.
ACCESS_FINE_LOCATION (optional)
To rectify end-user geographic distribution data, enhancing the precision of report data, and identifyfraudulent traffic.
ACCESS_COARSE_LOCATION (optional)
To identify fraudulent traffic.
GET_TASKS (optional)
To enhance the precision in evaluating end-user engagement levels.
iOS:
Name of the permission
Purpose of the permission
INTERNET
To permit applications to establish online connectivity and transmit data.
IDFV
To generate de-identified unique identifiers for end-users.
Location (optional)
To rectify end-user geographic distribution data, enhancing the precision of report data, and identifyfraudulent traffic.
WIFI (optional)
To identify fraudulent traffic.
Harmony:
Name of the Permission
Purpose of the Permission
ohos.permission.INTERNET
To permit applications to establish online connectivity and transmit data.
ohos.permission.APP_TRACKING_CONSENT（optional）
To generate de-identified unique identifiers for end-users.
ohos.permission.APPROXIMATELY_LOCATION（optional）
To rectify end-user geographic distribution data, enhancing the precision of report data, and identify fraudulent traffic.
You should understand and confirm that the collection will only take place when applying for authorizationhas been approved through the application function page where installing TalkingData Service, and obtaining theauthorized consent of the user. You should also inform your users that if they do not want their information mentionedabove to be collected, they can refuse or withdraw their consent by turning off the appropriate authorizations.5. Exceptions:Pursuant to relevant laws and regulations, it is not necessary toobtain your authorization to collect your personal information in the following cases:
Directly related to national security and national defensesafety; Directly related to public safety, public health, and major publicinterest; Directly related to criminal investigation, prosecution, trial, and enforcement ofjudgments; To protect material legal rights such as the lives and property of individuals orother individuals but fail to obtain the consent in time; For the purpose of academic researchand related outcomes, it will be de-identified; The information collected is already madepublic by yourself; The information collected is publicly and legally disclosed, such aslegitimate news reports, government information disclosure or others; To fulfill thecontract you have signed; To maintain stable operation of the products or services provided byTalkingData, such as discovering and disposing malfunction of products or services; Othercircumstances as prescribed by laws and regulations.
6. Authorization and Consent from End Users' DataYou are clearly aware that you need us tocollect,store, and process personal information from users of your application, for the purpose of carrying out ouranalysis and providing our statistics. Therefore you must undertake the following:
You have fully obtained necessary authorization, consent, and permission from end users for thepurpose of the performance of our service; You have fully obtained necessaryauthorization,consent, and permission from end users for us to process the data anonymously wecollected; You have complied and will comply with applicable laws, regulations, andrequirements, including but not limited to formulating and publishing policy relevant to protection of personalinformation and privacy. You should make the disclosure and explanation to the end user,allowingus to build TalkingData database for the purpose to provide data service on the condition that de-identification andaggregation processing has been made with respect to such data and information before transfer. You should alsoprovide end users with easy-to-use selection mechanisms, indicating how and when the user may exercise the option andhow and when the user can modify and withdraw the option, so that the user can choose to agree or disagree with thecollection and use of his/her de-identification information for business purposes.
You shall be liablefor comprehensive settlement and compensation to us for possible loss of any kind if you violate the abovecommitment and cause your end user's claim against us in any way, or if you cause us to be involved in any legal oradministrative procedure.
II. How do we use cookies and similar technologies
1. CookiesIn order to keep our website up and running, we store small data files called cookies on your computer or mobiledevice. Cookies often contain identifiers, site names, and some numbers and characters. With cookies, websites canstore data including your preferences or which goods and services you are interested in. The above cookie technologyis limited to the scope of web browser cookies, We do not use Flash Cookie technology for data storage.We will not use cookies for any purpose other than those described in this policy. You can manage or deletecookies according to your preferences. For details, see AboutCookies.org. You can clear all cookies saved on yourcomputer, and most web browsers have a cookie-blocking feature. However, if you choose to do this, you will need topersonally change your user settings each time you visit our site. In addition to cookies, the email we send you mayinclude a click URL that links to the content of our website. If you click on this link, we will track your click tohelp us understand your product or service preferences and improve customer service. If you do not want your activityto be tracked this way, you can unsubscribe from our mailing list at any time.2. Do Not Track FeatureMany web browsers have a “Do Not Track” feature that can issue “Do Not Track” requests towebsites. At present,major Internet standards organizations have not yet set up policies to specify how websitesshould respond to such requests. If your browser has “Do Not Track” enabled, all of our websites respectyour choice.
III. How do we share, transfer, and publicly disclose your personal information
1. SharingWe do not share your personal information with any other company, organization, or individual except in thefollowing cases:We may share your personal information with other parties after obtainingyour explicit consent; We may share your personal information externally in accordance withlaws and regulations, or as required by government authorities; Share with ouraffiliates:Your personal information may be shared with TalkingData affiliates. We only share the necessary personalinformation and are bound by our Privacy Policy. If an affiliate wants to use your personal information in a differentway, we will seek your explicit consent; Our affiliates include: Suzhou Tendcloud Tianxia TechnologyCo.Ltd Sharing with advertisers, ad networks, or other operators: We will cooperate with suchauthorized partners to use processed data from the TalkingData DMP platform for commercial use in various ways,such asusing data to optimize ad delivery and increase marketing effectiveness. We will not use personally identifiableinformation (including name, e-mail, or any contact information through which one can contact or identify anindividual) or provide advertising and analysis unless we receive your permission and the end user's permission. Wewill provide our partners with information about advertising coverage and effectiveness without providing personallyidentifiable information. We may aggregate this information so that it does not identify individuals. For example,only after advertisers agree to comply with our advertising guidelines may we tell them how effective their ads are,how many people saw their ads, or how many people installed applications after seeing their ads. We provide partnerswith demographic information that is not personally identifiable (e.g."25-year old male in Beijing who likes softwaredevelopment") to help them understand their audience or customers.For companies, organizations, and individualswith whom we share personal information, we will sign strict confidentiality agreements with them and ask them toprocess this information in accordance with our instructions, this privacy policy, and any other relevantconfidentiality and security measures.2. TransferWe will not transfer your personal information to any company, organization, or individual except in the followingcases:Transfer with explicit consent: We will transfer your personal information to otherparties only with your explicit consent;When it comes to mergers and acquisitions orbankruptcy, if it requires a transfer of personal information we will require the new company or organization toeither continue following this privacy policy or ask for your consent.3. Public disclosureWe will only publicly disclose your personal information in the following circumstances: After obtaining your explicit consent Legal disclosures: We may discloseyour personal information publicly, if we are subject to legal procedures, lawsuits, or mandatory requirements fromgovernment authorities In an emergency situation, we will still seek to protect the legalrights and safety of our company, our agents, our customers, end users, and others If webring forward lawsuits or arbitration in order to safeguard our legitimate rights or those of our users.
IV. How We Protect Your Personal Information
1. Measures we have taken to ensure data confidentiality:There is no method of transmission on the Internet or method of electronic storage that is 100% secure. Eventhough we have safeguarded personal information to the highest level, it is still possible for there to bestolen,illegally obtained, or misused data that brings risk to you, your property, and your reputation (or that ofyour users). You have understood the above risks and agree to continue.We will use industry-accepted and reasonable standards to protect the security and confidentiality of theinformation we store, including but not limited to: firewall and data backup measures, data center accessrestrictions, encryption of mobile device identification information.We have established a sound data security management system, including hierarchical classification, encryption andpreservation of user information, data access rights, internal data management systems and operational procedures,andstrict process requirements for data acquisition, use, and disposal.We will take all reasonable and feasible measures to ensure that no unnecessary personal information iscollected.We will only keep your personal information for the period required to achieve our purposes, as described inthis policy, unless we need to extend the retention period for reasons required by law.We have also established a safety and privacy protection training program with the goal of increasing employeeawareness. We will review, update, and disclose TalkingData security risk and impact assessment reports from time totime.2. Emergency situations and early warning:In the unfortunate event that there is a personal information security incident, we will promptly notify you ofthe basic situation and possible impact, as well as the emergency response we have undertaken or plan to take, inaccordance with relevant laws and regulations. We will also notify you of any related data disposal measures,remedialmeasures, etc. If it is too difficult or impossible to notify individuals one by one, we will adopt a reasonable andeffective method to issue an announcement. We will also take the initiative to report the security incident to therelevant authorities.If you discover that any of your personal information is leaking out, please contact us immediately usingthe contact information outlined in this privacy policy.
V. Your Rights:
In accordance with China's relevant laws, regulations, and standards, as well as common practices in othercountries and regions, we guarantee that you exercise the following rights with regard to your personal information:1. Access your personal information:You can access your personal information by logging into your account and going to the “AccountManagement” page,with the exception of any exceptions provided by laws and regulations. We will provide you withother personal information that arises from your use of our products or services to the best of our ability. If youwant to access your data, please send an email to: [support@tendcloud.com]2. Correction/SupplementationWhen you find that there is any mistake in your personal information that we collect or that there should be anupdate to your personal information, you can log into the “Account Management” page and correct or update ityourself. If there is special information that cannot be processed by yourself, you may contact us through variousmethods posted either in this privacy policy or on other TalkingData web pages. To protect your account, we may askyou to finish verification.3. DeletionIf you choose to close your account or click “opt-out” on the TalkingData website, it would be deemedthat you choose to withdraw your authorization. We would stop collecting your personal information and delete yourpersonal information. Please understand that we may not delete your personal information immediately from the backupsystem,but we will delete your personal information when the backup is updated. You can request for TalkingData todelete your personal information in the following cases: If we use your personalinformation ina way that violates laws, regulations, or this agreement If we collect and use yourpersonal information without your consent If we deal with personal information in violation ofyour agreement If you no longer use our products or services, or if you cancel youraccount If we no longer provide you with products or servicesIf we decide to respond to your request for deletion, we will also, as soon as possible, notify the third partywith which we have shared your information to delete your personal information, unless this party has acquired yourauthorization or other contrary legal provisions. If you are unable to access, update, or delete your personalinformation, you may contact us through TalkingData Customer Service at any time. We will respond to your requestwithin 15 working days.Notwithstanding the above provisions, we may keep certain data for a reasonable period of time within thelimit allowed by law for dispute settlement, users' agreement performance and compliance with technical requirementsrelated to safe operation.4. Changing the scope of your authorized consentEach business function requires some basic personal information to be completed (see Part 1 of this policy). Forthe collection and use of additional collected personal information, you may give or withdraw your consent at anytime. When you withdraw your consent, we will no longer process the corresponding personal information. However, yourdecision to withdraw your consent will not affect the processing of personal information from your previousauthorization. You can cancel by rejecting commercial advertisements through the “Opt-Out” channel:http://www.talkingdata.com/optout.jsp?languagetype=zh_cn5. Cancel the accountYou can cancel your previously registered account at any time. You can do it yourself by doing thefollowing:【support@tendcloud.com】. After cancellation of the account, we will stop providing products orservices for you. We will delete your personal information in accordance with your requirements, unless otherwiseprovided by laws and regulations.6. Obtain a copy of your personal informationYou have the right to obtain a copy of your basic personal information, personally identifiableinformation,personal health information, and personal education or work information by sending a request toTalkingData. We can also directly send a copy of your personal information to a designated third party according toyour requirements where technological feasibility allows, such as through data interface matching.7. Automatic decision-making information systemBased on the personal information that is legally collected, automatic decision-making (such as commercialinformation push) is implemented through tagging or profile processing through non-manual automatic decision-makingtechniques, such as information systems and algorithms. The above behaviors make your personal informationunidentifiable, and cannot be considered as sharing, transferring, or disclosing any of your personal information toany third party. If these decisions significantly affect your legal rights, you have the right to ask us for anexplanation and we will provide appropriate remedies to the situation. If you do not wish to participate in thistype of targeted advertising, please cancel through the following Opt-Out channel:http://www.talkingdata.com/optout.jsp?languagetype=en_us8. Responding to your requestFor security, you may need to provide a written request or prove your identity in some other way. We may ask youto verify your identity before processing your request. We will respond within 15 working days. If you are notsatisfied, you can read Part 9 about how to file a complaint.For your request, we do not charge fees out of principle. However, we will charge a certain amount for requeststhat are repeated many times or in excess of reasonable limits. We may reject requests that are duplicative, requireexcessive technical assistance (for example, developing new systems or fundamentally changing current practices),poserisks to the rights of others, or are very impractical (for example, involving backup of information stored on tapes).In the following cases, we will not be able to respond to your request, as required by laws and regulations, if itrelates to the following: Directly related to national security and national defensesecurity Directly related to public safety, public health, and the publicinterest Directly related to a criminal investigation, prosecution, trial, or execution ofjudgment If there is sufficient evidence that you have abused your rights Ifresponding to your request may result in serious damage to your rights, those of other individuals, and those oforganizations Involving or related to trade secrets
VI. How we handle children's personal information
We have made it clear that we do not accept minors as registered users. We will not knowingly collect and usechildren's data.If your application is designed and developed for children, make sure that you take the necessarytechnical measures and precautions to ensure that the end user's registration and use of the application isperformed by the child's guardian. In addition, you must establish a full user agreement and privacy policy. Forcollecting children's personal information through parental consent, we will only use such information if permittedby law and if there is explicit parental or guardian consent.Although local laws and customs may have different definitions for children, we consider anyone below the age of14 to be a child.If we find ourselves inadvertently collecting personal information from children without first obtaining parentalconsent, we will try to delete the data as soon as possible.
VII. How your personal information is stored or transferred internationally
1.Storage LocationIn principle, personal information collected and generated within the People's Republic of China will be storedwithin the territory of the People's Republic of China.During the process of providing services, we may transfer the data obtained from you or your product end users toan affiliated entity or other third party outside your jurisdiction, and such transfer will be handled to the extentpermitted by applicable laws and regulations and provide adequate protection of your personal information inaccordance with this policy.If you or your product end user is located beyond the jurisdiction of the PRC, or when you and your productterminal user is in the jurisdiction of the PRC while we need to transfer it to the place outside the jurisdiction ofthe PRC, you shall consent or obtain consent from the end user for this international transfer.We highly advise you to consult local professionals to ensure that this transfer complies with local dataprotection requirements. Especially, when the international transfer involves the European Union or the United States,please pay attention to the legal regulations for data protection and protection of personal information in theseplaces.2.Storage TimeWe retain your and your users' personal information solely for the purposes outlined in this privacy policy andfor the minimum storage time mandated by legal regulations. Following the expiration of the stipulated storage period,we commit to deleting or anonymizing the personal information in accordance with the requirements of applicable lawsand regulations. However, if specific legal provisions or your and your end-users' explicit consent necessitateotherwise, we may extend the storage duration of the personal information.
VIII. Policy Updates
We have the right to adjust the privacy policy at any time in accordance with change of service, adjustment ofapplicable laws and policies, as well as other factors. We will not diminish your rights guaranteed under this PrivacyPolicy without your explicit consent. Any update to this privacy policy will be published on this webpage marked withthe updated time.Therefore,please check the privacy policy regularly so that you are always in compliance. Ifyou do not agree with this privacy policy, please terminate visiting and using our service.If there are material changes to this Privacy Policy, such as changes in the content of your personalinformation,changes in the controller of your personal information, changes in the sharing/transfer/disclosure ofpersonal information, or changes in your rights related to the protection of personal information, we will notify youin amore significant way, such as through a pop-up or letter.Material changes to this policy include, but are not limited to: If there have beenmajor changes in our service model, such as in the purpose of processing personal information, the types of personalinformation handled, how we use personal information, etc. If we have undergone major changes inownership and organizational structure, such as business adjustment, bankruptcy, mergers, or other suchchanges If there have been changes in personal information sharing, transfer, or publicdisclosure If there has been a major change in your rights to participate in the processing ofpersonal information and in the way it is used If there are changes in the responsibledepartment, contacts, or complaints channel, with regard to how we handle personal informationsecurity If the personal information security impact assessment report indicates that there ishigh riskThis policy is an important part of the TalkingData Terms of Service.
IX. How to contact us
If you have any question, advice, or complaint related to our privacy policy, please contactsupport@tendcloud.com. We have set up a Personal Information Protection Department. You can contact us here:【td_legal@tendcloud.com】. In general, we will reply within 15 working daysIf you are unsatisfied with our response, especially if you believe that our personal information processingpractices are in any way detrimental to your legitimate rights and interests, you can also make complaints or reportsto the relevant telecommunications, public security, and commercial regulatory authorities.You may also submitthe dispute to the Beijing Arbitration Commission for arbitration in Beijing in accordance with its rules at thattime.
