ZWPhone Privacy Policy

Welcome to using the services provided by ZWPhone Cloud Phone! BETTENS (referring to HONG KONG BETTENS TECHNOLOGY CO.,LIMITED in this Privacy Policy, hereinafter also referred to as "we" or "the Company") places great importance on your privacy protection and user information protection. This Privacy Policy applies to your access and use of various services provided by ZWPhone through any means. When you use the services provided by the ZWPhone Cloud Phone platform (hereinafter referred to as the "ZWPhone Cloud Phone"), in addition to providing services to you in accordance with the provisions of the "ZWPhone Cloud Phone Platform User License Agreement," we will also follow the principles of legality, legitimacy, and necessity in accordance with the "ZWPhone Cloud Phone User Privacy Policy" (hereinafter referred to as "this Privacy Policy"), openly disclosing the collection and use of your user information.

If you or your guardian disagree with any content of this Privacy Policy, you should immediately stop using the ZWPhone Cloud Phone products or services. When you use any service provided by ZWPhone Cloud Phone, it indicates that you agree to our collection, use, storage, and protection of your relevant information in accordance with this Privacy Policy.

You can achieve various services for cloud phone use and operation through ZWPhone (hereinafter collectively referred to as "ZWPhone"). We will only process the user information necessary for your use of ZWPhone.

This Privacy Policy applies to your access and use of our products and services through the ZWPhone web version, desktop version, mobile version (including but not limited to Apps), or other methods.

This Privacy Policy aims to help you understand what user information we collect, why we collect this user information, what we do with this user information, and how we protect this user information. We will collect and use your user information in accordance with the privacy policy, but will not adopt a mandatory bundling method to collect all your user information solely because you authorize and agree to this Privacy Policy. We will strictly comply with legal requirements and seek your separate consent in specific circumstances. This Privacy Policy stipulates how we process your information in different scenarios, but we will only process your information to achieve the relevant functions and services when you enable the relevant functions or use the relevant services. If you do not enable the relevant functions or use the relevant services, we will not process your corresponding information. In addition to this Privacy Policy, we may also inform you of the rules for processing your user information through product pages, pop-up prompts, information pushes, and other methods. The user information processing for specific business functions shall be subject to specific rules, which have the same effect as this Privacy Policy.

Unless otherwise provided by laws and administrative regulations, regarding how we process your user information, you have the right to be informed and decide, and the right to restrict or refuse us or other parties from processing your user information; at the same time, you have the right to request us to explain the user information processing rules we provide to you. Please carefully read and understand this Privacy Policy before using ZWPhone and various services, so that you can make appropriate choices.

This Privacy Policy will help you understand the following:

1. Information We Collect and the Corresponding Purposes of Use

We will follow the principles of legality, legitimacy, and necessity to collect and use your user information. Specifically, we collect and process your user information to provide you with the corresponding business functions. In the corresponding functions, if the user information you provide belongs to others, please ensure that you have obtained authorization from the relevant subject. We reserve the right to verify the legitimate source of such user information at any time.

You need to provide us with user information to enable us to achieve the basic business functions of ZWPhone. The information necessary for achieving basic business functions is necessary user information. If you refuse to provide this necessary user information, we will be unable to provide you with the basic business functions and corresponding services. Beyond the basic business functions, you may choose to provide us with some user information to enable us to achieve the extended business functions of ZWPhone. We will inform you of the purposes of use and process this user information based on your authorization and consent or for purposes necessary to achieve the extended business functions you select. Your refusal to provide such extended business function information will not affect your use of our basic business functions, but if you refuse to provide the user information necessary for extended business functions, we will be unable to provide you with the extended business functions.

For your convenience, we list the business functions provided, processing purposes, and required user information as follows:

User information refers to various information recorded electronically or otherwise that can identify a specific natural person's identity alone or in combination with other information or reflect a specific natural person's activity status. User information of children under 14 years old (inclusive) belongs to sensitive user information. When you use ZWPhone, you need to provide or allow us to collect necessary information to provide you with services, including:

1. Information you actively provide to us

1. To help you become our user, the registration information you fill in, including your phone number, is used for registering and logging into the ZWPhone Cloud Phone account to use ZWPhone Cloud Phone products and services, and for our customer service and after-sales to provide you with consulting services, as well as to ensure the security of your account. If you only need to browse or learn about ZWPhone Cloud Phone, you do not need to register as our user or provide the above information;
2. When you contact us, we may save your communication or call records and content or the contact information you leave to help you solve problems or record the processing solutions and results of related issues.
3. Please note that when you use the cloud gaming function of ZWPhone Cloud Phone to try third-party operated mobile games online, you may need to register or log in to your game account, and the third-party mobile game operator may collect and use your relevant information to enable you to use the services it provides. Please rest assured that ZWPhone Cloud Phone will not collect or use any of your game account information or other information you provide to the third-party mobile game operator. For how third-party mobile game operators collect and use your user information, please refer to the relevant service agreements and privacy policies of the third-party mobile game operators.
4. You can log in to ZWPhone Cloud Phone using a third-party account (such as WeChat or QQ). At this time, you will authorize ZWPhone Cloud Phone to read the public information registered in your third-party account (such as nickname and avatar).

2. How we collect and use your user information during your use of the service:

We may collect information about your use of this service, including the following:

1. Registration and login account

   To facilitate our provision of continuous and stable services to you and ensure the security of your use of this service, you can create a ZWPhone universal account via mobile phone number, and you can complete your account information. When registering or logging into the ZWPhone universal account, you need to provide us with your mobile phone number. You can choose to set an account name, avatar, and login password.

   You can also log in to ZWPhone using a third-party account (such as WeChat, Baidu, or QQ). At this time, you will authorize ZWPhone to obtain the public information registered in that third-party account (including your nickname, avatar, and other information you authorize).

2. Real-name authentication

   To meet mandatory legal requirements, for purposes necessary to provide products or services, or based on your need for enhanced account protection levels, when you use certain services of ZWPhone or have further needs, you need to provide your real name and ID number to complete real-name authentication for the account. To verify the accuracy and completeness of the information you provide or to ensure account security, we may compare and verify the real-name information you provide to Huabang Internet Technology Co., Ltd. with your corresponding information saved by institutions or government agencies authorized by laws and regulations.

3. Ensuring service and operational security

   To improve the security of your use of our services, protect you, other users, or the public from harm to personal and property safety, better prevent risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, etc., and more accurately identify situations violating laws, regulations, or ZWPhone platform-related agreement rules, with your authorization, we will collect or use your registration information, device information (including device attribute information of the terminal device you use to install and run ZWPhone, such as hardware model, operating system version and system status, device configuration, International Mobile Equipment Identity IMEI, International Mobile Subscriber Identity IMSI, network device hardware address MAC, Advertising Identifier IDFA, Vendor Identifier IDFV, Mobile Equipment Identifier MEID, Anonymous Device Identifier OAID, Integrated Circuit Card Identifier ICCID, Android ID, hardware serial number, and other device identifiers), device connection information (such as browser type, telecommunications operator, language used, WIFI information, BSSID information), device status information, network logs, and the list of installed applications, overall operation of applications, and overall installation and usage of applications, to comprehensively assess your account and transaction risks, and detect and prevent security incidents.

4. Optimizing service experience and resolving issues in the service

   When you use ZWPhone, to ensure your normal use of ZWPhone Cloud Phone services, more accurately locate and resolve issues you encounter while using ZWPhone Cloud Phone services, and improve and optimize the service experience of ZWPhone Cloud Phone, we will collect device information. For information collected from your various devices, we may associate them to provide you with consistent services on these devices. To facilitate your more effective selection and upload of needed APPs to your cloud phone when using ZWPhone Cloud Phone services, we will obtain the application list information on your device when you upload files to the cloud phone. At the same time, to better optimize the APPs that need to be synchronously installed in your cloud phone, we will collect information on the uninstallation and installation of applications on your device to enhance your user experience.

5. Recording requests you send

   Like most Internet services, our servers will automatically record the requests you send when accessing ZWPhone Cloud Phone, including your IP address, browser type, hardware device information, operating system version, network operator information, date, time, and duration of your access to the service. Please note that this is basic information we need to collect to ensure the normal operation of the software and services.

6. Enhancing cloud gaming experience functions

   To facilitate smoother game trials and enhance your game trial experience, we need to obtain your device location information to allocate service resources nearby based on your device location. When you enable the device location function and authorize ZWPhone Cloud Phone to access your location information, we will use various technologies for positioning, including IP address, GPS, and other sensors that can provide relevant information (such as information on nearby devices, Wi-Fi access points, and base stations). You can stop our collection of your geographic location information at any time by revoking system authorization for ZWPhone to access your location information. Afterward, you may be unable to use the relevant services or functions based on location information or achieve the intended effects of the relevant services based on location information, but it will not affect your normal use of other business functions of ZWPhone Cloud Phone.

7. When you share information or receive shared information, we will read codes, links, and other content in the clipboard to achieve content jumps and sharing.
8. To ensure you receive ZWPhone activity information, promotional news, etc., at the first time, we will use your phone number, device information, and obtained ZWPhone product information to provide you with unified pushes of product or service and activity information.
9. When you use image upload, avatar modification, or voice conversation functions, we will request camera, photo, and recording permissions from your device system. If you refuse to authorize, you will be unable to use the corresponding functions, but it will not affect your normal use of other functions of ZWPhone that do not rely on the above permissions.
10. Customer service or other user response functions

    When you contact our customer service or use other user response functions (such as other user complaints and needs), we need you to provide necessary identity information to match and verify your user identity to ensure the security of your account and system. To handle your requests, manual customer service needs to query or verify your relevant information within the scope of your authorization and use it only within the necessary scope. If you refuse to provide or provide incorrect information, we may be unable to provide you with corresponding support. After verifying your user identity, we will also save your contact information (the contact method you used to contact us or other contact information you actively provided to us), your communication/call records and content with us, and other necessary information associated with your needs, to contact you or help you solve problems, or record the processing solutions and results of related issues.

11. To jointly provide this service to you or improve the quality of the service or for reasonable needs such as considering the security of products and services, we may receive your user information and other information from the ZWPhone platform, affiliated companies, partners, and other trusted third-party suppliers in accordance with laws and regulations or based on your valid authorization. We will require the user information provider to explain the source of the user information in advance and confirm the legitimacy of the user information source. At the same time, we will understand the scope of authorization and consent obtained by the user information provider for processing user information. If the user information processing activities required for business operations exceed the scope of the obtained authorization and consent, we will seek your explicit consent within a reasonable period after obtaining the user information or before processing the user information, or seek your explicit consent through the user information provider.
12. Anonymized processing of user information

    Without publicly disclosing or providing your user information externally, Huabang Internet Technology Co., Ltd. has the right to mine, analyze, and utilize the anonymized user database (including commercial use), and has the right to conduct statistics on product/service usage and share anonymized statistical information with the public/third parties.

13. Device permission invocation

    During the provision of services, to ensure your normal use of product functions, we will apply to the system for the following system device permissions on your device. Before applying, we will seek your consent, and you can choose to "allow" or "prohibit" the permission application. After your authorization, we will enable the relevant permissions. You can cancel the authorization at any time in the system, and canceling the authorization will cause you to be unable to use the relevant business functions, but will not prevent you from using other business functions.

    The invocation of system privacy permissions by various business functions is as follows:

    Device Permission	Usage Scenario or Purpose	Permission Authorization Method	Can It Be Disabled
    Obtaining geographic location information	Allocating better cloud phone server resources for users / Fine-tuned offline advertising pushes based on scenarios	Pop-up inquiry when user first uses location-related business functions	Yes
    Obtaining precise location	Allocating better cloud phone server resources for users	Pop-up inquiry when user first uses location-related business functions	Yes
    Reading phone status and identity	Providing terminal proof files to SDK to ensure normal function use	Pop-up inquiry when user first uses the corresponding function	Yes
    Camera	When users use the camera function in the cloud phone, it can invoke the user's phone camera for photos and videos	Pop-up inquiry when user first uses camera shooting	Yes
    Reading contacts	Determining if Uri is an image Uri in the local address book; if yes, reading contact avatars in the address book	Pop-up inquiry when user first uses the corresponding function	Yes
    Reading external storage card	Users can upload files from their local phone to the cloud phone, requiring reading external storage card information	Pop-up inquiry when user first uses the corresponding function	Yes
    Microphone/Recording	When users use voice functions in the cloud phone, it can invoke the user's phone microphone for recording	Pop-up inquiry when user first uses the corresponding recording function	Yes
    Contacts	Determining if Uri is an image Uri in the local address book, otherwise modifying contact avatars	When user first uses contact-related business functions	Yes
    Reading images/album/Granting partial access at runtime (adapted for Android 14)	When users modify avatars by taking photos or uploading files, it needs to read user image storage or album	Pop-up inquiry when user first opens the APP / when using relevant business functions	Yes
    WIFI wireless network	Network connection for various business functions	Pop-up inquiry when user first uses the corresponding function	Yes
    Reading/requesting installation package	Installing APP to user's local phone by obtaining installation package information	Pop-up inquiry by system each time the relevant business is triggered	Yes
    Managing and storing all files on the device	Users can upload files/APPs from their local phone to the cloud phone, requiring reading device storage information	Pop-up inquiry when user first uses this function	Yes

    You can view privacy permission details in the ZWPhone Cloud Phone App [Mine - Settings - About ZWPhone - Privacy Policy] and disable permissions (microphone, camera) in [Mine - Settings - Phone Permission Management]. You can also enable or disable the above permissions through the permission settings provided by your device. For specifics, please refer to the instructions or guidelines from the device and system developer.

    Automated decision-making: Automated decision-making activities also rely on our processing of your usage behavior information, device information, location information, and label information. If we make a decision through automated decision-making that has a significant impact on your user rights, you have the right to request an explanation from us through this Policy's ["9. How to Contact Us"] and the right to refuse decisions made solely through automated decision-making.

3. Exceptions where prior consent is not required:

According to relevant laws and regulations, processing your information does not require your authorization and consent in the following circumstances:

• Directly related to national security or defense security;
• Necessary for concluding or performing a contract where the user is one party;
• Necessary for fulfilling statutory duties or legal obligations;
• Necessary for responding to sudden public health incidents or protecting the life, health, and property safety of natural persons in emergencies;
• Directly related to criminal investigation, prosecution, trial, and execution of judgments;
• Necessary for safeguarding the vital legitimate rights and interests of you or other users, such as life and property, but it is difficult to obtain the individual's consent;
• Collecting user information that you have voluntarily disclosed to the public or that has been legally disclosed within a reasonable scope in accordance with laws and regulations;
• Collecting your user information from legally publicly disclosed information within a reasonable scope in accordance with laws and regulations, such as legitimate news reports, government information disclosure, and other channels;
• Processing user information within a reasonable scope for public interest activities such as news reporting and public opinion supervision;
• Necessary for statistical or academic research conducted by academic research institutions based on public interest, and when providing academic research or description results externally, de-identifying the user information contained in the results;
• Other circumstances stipulated by laws and regulations.

2. How We Use COOKIES or Similar Technologies

Cookies and anonymous identifier tools. A Cookie is a mechanism that supports the server side (or script) to store and retrieve information on the client side. When you use this service, we will send one or more Cookies or anonymous identifiers to your device. When you interact with this service, we allow Cookies or anonymous identifiers to be sent to the Huabang Internet Technology Co., Ltd. server. Cookies usually contain identifiers, site names, and some numbers and characters. By using Cookie technology, Huabang Internet Technology Co., Ltd. can save you from entering repeated information, provide you with more thoughtful services, or help determine the security of your account. Cookies can also help us count traffic information and analyze page design.

We will not use Cookies for any purposes other than those described in this Policy. You can manage or delete Cookies according to your preferences. For details, please see AboutCookies.org. You can clear all Cookies saved on your computer, and most web browsers have functions to block Cookies. However, if you do so, you will need to manually change user settings each time you visit our website, and you may be unable to log in or use services or functions provided by Huabang Internet Technology Co., Ltd. that rely on Cookies due to such modifications.

You can clear your Cookies and restrict our use of Cookies.

3. How We Share, Transfer, or Publicly Disclose Your User Information

Some of our services will be provided by authorized partners. Only to achieve the purposes stated in this Privacy Policy, we may share certain user information of yours with partners to provide better customer services and user experiences. We will only share your user information for legitimate, legitimate, necessary, specific, and explicit purposes, and will only share the user information necessary for providing services. Except for obtaining your separate authorization or as otherwise required by laws and regulations, our partners have no right to use the shared user information for any other purposes.

(1) Sharing

We attach great importance to protecting your user information. We will only provide your user information to third parties for legitimate, legitimate, necessary, specific, and explicit purposes. For companies, organizations, and users that receive the user information we provide, we will sign strict confidentiality agreements with them, requiring them to process the information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures.

1. To achieve the purposes stated in this Policy, we may access applications provided by third-party service providers (such as in the form of embedded code, plugins, H5, SDK, etc.) to provide you with better customer services and user experiences. The circumstances where we may entrust processing or share user information to achieve our services are as follows:

1. Used for third-party account login recognized by Huabang Internet Technology Co., Ltd.;
2. Used to collect device information and log information with your consent;
3. Used to optimize product performance and service quality, including improving hardware networking capabilities, reducing server costs, hot fixing functions, security analysis, service optimization, enhancing user experience, etc.;
4. Used for account security and product reinforcement services, including network monitoring, domain name resolution, anti-hijacking, anti-spam and anti-cheating, encryption and decryption services, etc.;
5. Third-party SDK service providers. To ensure the provision of services described in the purposes of this Privacy Policy, we may access software development kits (SDKs) provided by third parties to achieve relevant functions and better improve customer services and user experiences. At this time, these third-party SDK service providers may collect your user information on behalf of ZWPhone or for one or more purposes of this Privacy Policy. Currently, the third-party SDKs we access mainly include the following types:
   • a. One-click login function: To provide you with account login - one-click login function, the third-party SDK service provider may obtain your necessary device information and network-related information;
   • b. Third-party account login function: To provide you with third-party account login function, the third-party SDK service provider may obtain your necessary device information and network-related information;
   • c. Account security services: To ensure your account security, the third-party SDK may collect your necessary device information, network-related information, log information, and geographic location information to provide account security services;
   • d. Advertising-related services, including advertising display, advertising statistics, and monitoring, etc.;
   • e. Payment services: To ensure your smooth purchase of goods/services and virtual goods on the platform, third-party payment service providers (such as Alipay SDK) may collect your device information (such as Android ID, MAC address, OAID), network information, and operator information to achieve smooth payment completion and ensure payment security.
   • f. Product module performance optimization, including improving hardware networking capabilities, hot fixing functions, interaction analysis, network performance, and network error monitoring, etc.
6. Our services may access or link to other products of Huabang Internet Technology Co., Ltd. or services provided by third parties. Including:
   • (1) You can use the "Share" function to share certain content of this product service to other products of Huabang Internet Technology Co., Ltd. or third-party products or services, or you share content from other products or services of Huabang Internet Technology Co., Ltd. or third-party products or services to ZWPhone;
   • (2) Providing links to you through service announcements or other methods, enabling you to link to other products or services of Huabang Internet Technology Co., Ltd., third-party products or services, or websites;
   • (3) Other circumstances of accessing third-party services. For example, third parties we access may collect your user information. When you use such services provided by third parties in our services, you agree that they will directly collect and process your information. We will evaluate the legality, legitimacy, and necessity of such third-party services collecting user information, require these third parties to take protective measures for your user information, and strictly comply with relevant laws, regulations, and regulatory requirements.

The above third-party services are operated by the relevant third parties. Your use of such third-party services (including any information you provide to such third parties) is subject to the third party's own service terms and user information protection rules (not this Policy). You need to read their terms carefully. This Policy only applies to the user information we collect and does not apply to any services provided by third parties or third-party information usage rules. If you discover risks in these third-party services, we recommend that you terminate the relevant operations to protect your legitimate rights and interests and contact us in a timely manner.

3. To better protect the physical and mental health of minors, guide minors to use the Internet healthily, and prevent minors from misusing or borrowing adults' relevant information, we may attempt to contact their guardians based on requests from minor guardians or our need to proactively protect minors, and inform their guardians of relevant service account information, online duration, online behavior, etc., for reminders, confirmation, and handling.

4. We and our affiliated companies or users of the same account system have highly consistent data security protection measures and management levels. To jointly provide services to you, improve the security and convenience of your product use, and ensure a consistent service experience, under the premise of complying with legal requirements, we will share your user information between affiliated companies or users of the same account system. In this case, we will only share necessary user information. If we share your sensitive user information or the recipient changes the use and processing purposes of user information, we will seek your authorization and consent again.

For users of the same account system, to fulfill regulatory requirements, ensure account security, conduct consistent displays, and be able to contact you, based on your valid authorization, we may share your account-related information.

(2) Third-Party Software Development Kits (SDKs) We Access

To adapt to using ZWPhone Cloud Phone on different mobile devices and third-party platform services, achieve mobile device identity authentication, mobile device security, logging into third-party platform accounts, sharing information through third-party platforms, and payment security, ZWPhone has accessed third-party SDKs. The above third-party SDK providers include mobile communication operators and third-party payment institutions. Some third-party SDKs may invoke your device permissions and collect your device information (such as network device hardware address MAC, Advertising Identifier IDFA, Vendor Identifier IDFV, Anonymous Device Identifier OAID, Integrated Circuit Card Identifier ICCID, Android ID, hardware serial number, and other device identifiers), to enable you to normally use corresponding functions on different mobile devices or third-party platforms. The types of device permissions invoked by different third-party SDKs and the information obtained may vary, and may include obtaining your location information, reading/writing your external storage card, reading your phone status and identity, viewing WLAN connections, retrieving running applications/Bluetooth. For the specific types of device permissions invoked by third-party SDKs and how they collect and use your user information, please refer to the relevant service agreements and privacy policies of the third-party SDKs. If you wish to learn more about the third-party SDKs we access, please read the list of third-party SDKs accessed by the ZWPhone APP.

(3) Entrusted Processing and Joint Processing

To better provide services to you, we may entrust third-party partners to process your user information. We will only entrust third-party partners to process your information for legitimate, legitimate, necessary, specific, and explicit purposes. We will strictly limit the information processing purposes of the entrusted party and require the entrusted party to take sufficient data security protection measures. If the third-party partner uses your information for purposes not entrusted by us, it will seek your consent separately. The authorized partners we entrust include authorized partners for advertising and analysis services. Under the premise of complying with industry-standard security technologies, we will entrust these partners to process information related to advertising delivery, advertising effectiveness, and advertising reach rates. Without your valid authorization, we will not entrust third-party partners to process information that can directly identify your user identity. If you actively leave your contact information, address, or other user information to specific third-party partners for them to contact you, they will directly process your user information.

In joint processing scenarios, we will also sign relevant agreements with partners that comply with laws and regulations and fulfill relevant user information protection obligations.

(4) Exceptions where prior authorization and consent are not required for sharing, transferring, or publicly disclosing user information

In the following circumstances, sharing, transferring, or publicly disclosing user information does not require prior authorization and consent from the user information subject:

• Directly related to national security or defense security;
• Necessary for concluding or performing a contract where the user is one party;
• Necessary for fulfilling statutory duties or legal obligations;
• Directly related to public safety, public health, or major public interests. For example: Necessary for responding to sudden public health incidents or protecting the life, health, and property safety of natural persons in emergencies;
• Directly related to criminal investigation, prosecution, trial, and execution of judgments;
• Necessary for safeguarding the vital legitimate rights and interests of you or other users, such as life and property, but it is difficult to obtain the individual's consent;
• Processing user information voluntarily disclosed by the user or otherwise legally disclosed within a reasonable scope in accordance with laws and regulations, such as legitimate news reports, government information disclosure channels, etc.;
• Other circumstances stipulated by laws and regulations.

4. How to Exercise Your Rights Related to User Information

During your use of ZWPhone, we will provide you with corresponding operation settings to manage your user information based on the specific circumstances of ZWPhone, so that you can access, copy, transfer, correct, supplement, delete, or withdraw your relevant user information.

1. Right to Access You have the right to access your user information, except in circumstances stipulated by laws and regulations. You can access or edit user profile information in your account through "ZWPhone Cloud Phone - Mine - Avatar - Edit Profile."

2. Right to Correction When you find that the processing of your user information by us is incorrect, you can contact online customer service for information modification.

4. Right to Withdrawal

After withdrawal of authorization, we will be unable to continue providing you with the services corresponding to the withdrawn authorization and will no longer process your corresponding information. However, your decision to withdraw authorization will not affect the prior information processing conducted based on your authorization.

5. Right to Cancellation If you decide to stop using ZWPhone, you can cancel your account. Account cancellation can be achieved in "ZWPhone Official Website - Account Security - Account Cancellation." After successfully submitting the cancellation application, if there is no login activity for 15 days, the cancellation will be completed. You can also cancel with the assistance of online customer service in "ZWPhone - Customer Service Center."

After submitting the application, we will respond within 3 working days. After account cancellation, data in this account cannot be recovered, including but not limited to asset information such as electronic wallet balance. The account information content will also be completely cleared. This cancellation operation cannot be revoked. Please apply with caution.

6. Right to Copy and Portability

You have the right to copy the user information we collect. Under conditions stipulated by laws and regulations, and in compliance with instructions and conditions specified by national cyberspace authorities, if technically feasible, you can also request us to transfer your user information to another entity designated by you.

7. Right to Advance Notice of Product and Service Cessation

If this service ceases operation due to special reasons, we will notify you within a reasonable period through the main page of the product or service, in-app messages, or by sending emails or other appropriate methods that can reach you, and stop collecting your user information. At the same time, we will delete or anonymize the collected user information in accordance with legal provisions.

9. If you have other needs for access, copy, transfer, correction, supplementation, or deletion, or have any questions or difficulties during your use of this service, you can contact us through the feedback channels listed in the "How to Contact Us" section of this Policy. We will reply within fifteen working days after verifying your user identity.

10. Except as otherwise provided by laws and regulations, when you correct, supplement, or delete your user information or apply for account cancellation, we may not immediately correct, supplement, or delete the corresponding information from the backup system, but will do so when the backup is updated. Once the relevant information is deleted or the account is canceled, it cannot be recovered. Please operate with caution.

5. How We Store Your User Information

1. Storage Period

We will store your user information for the period necessary to provide services, but in cases where laws and regulations provide otherwise for the storage period, you agree to retain for a longer period, to ensure service security and quality, achieve dispute resolution purposes, or where it is technically difficult to achieve, after the above storage period expires, we will extend the storage period in accordance with laws, agreements, or within a reasonable scope.

After exceeding the storage period, we will delete your user information or perform anonymization processing in accordance with legal provisions.

2. Storage Location

In principle, user information collected and generated within the People's Republic of China will be stored within the People's Republic of China. If your user information may be transferred to overseas jurisdictions in the country/region where you use the product or service, or accessed from these jurisdictions, we will strictly fulfill the obligations stipulated by laws and regulations and obtain your separate consent in advance in accordance with legal provisions. Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will transmit your user information in accordance with current Chinese laws and ensure that your user information receives protection equivalent to that within the People's Republic of China. For example, we will request your consent for cross-border transfer of user information or implement security measures such as data de-identification before cross-border data transfer.

6. How We Protect Your User Information

We attach great importance to information security, have established a dedicated security team, and take all reasonable and feasible measures to protect your user information:

1. Data Security Technical Measures

We will collect, use, store, and transmit user information based on the "minimization" principle and inform you of the purposes and scope of relevant information use through user agreements and privacy policies.

We attach great importance to information security. We have established a dedicated team responsible for researching and applying various security technologies and procedures. We conduct security background checks on security management leaders and key security positions. We have established a complete information security management system and internal security incident response mechanism. We will adopt appropriate industry-standard security measures and technical means to store and protect your user information to prevent your information from being lost, unauthorized access, public disclosure, use, damage, loss, or leakage. We will take all reasonable and feasible measures to protect your user information. We will use encryption technology to ensure data confidentiality; we will use trusted protection mechanisms to prevent data from malicious attacks.

We will conduct data security awareness training, assessment, and capability training for employees to strengthen their understanding of the importance of protecting user information. We will perform identity authentication and permission control on employees processing user information and sign confidentiality agreements with employees and partners who access your user information, clarifying job responsibilities and codes of conduct to ensure that only authorized personnel can access user information. If there is a breach of the confidentiality agreement, cooperation with Huabang Internet Technology Co., Ltd. will be immediately terminated, and relevant legal liabilities will be pursued. Confidentiality requirements are also imposed on personnel accessing user information upon leaving their positions.

We remind you to pay attention: the Internet is not an absolutely secure environment. When you interact your geographic location or trajectory information with other users through third-party social software, emails, SMS, etc., embedded/installed in ZWPhone, it is uncertain whether the third-party software fully encrypts the information transmission. Please ensure the security of your user information.

We also ask you to understand that due to technical limitations and rapid development in the Internet industry, as well as various possible malicious attack methods, even if we do our utmost to strengthen security measures, it is impossible to always guarantee 100% security of information. Please understand that the systems and communication networks you use when using our products and/or services may have security issues in other links beyond our control.

According to our security management system, user information leakage, damage, or loss incidents are classified as major security incidents. Once occurred, the company's highest-level emergency plan will be activated, and a joint emergency response team composed of the security department, legal department, and other departments will handle it.

2. Security Incident Notification

We will formulate a network security incident emergency plan to promptly handle system vulnerabilities, computer viruses, network attacks, network intrusions, and other security risks. When a network security incident occurs, we will immediately activate the emergency plan, take corresponding remedial measures, and report to relevant competent authorities in accordance with regulations.

User information leakage, damage, or loss is a company-level major security incident. We will regularly organize working group members to conduct security plan drills to prevent such security incidents. If unfortunately it occurs, we will activate the emergency plan at the highest priority, form an emergency response team, trace the cause in the shortest time, and minimize losses.

In the unfortunate event of a user information security incident, we will promptly inform you of the basic situation of the security incident and possible impacts, the processing measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you, in accordance with legal requirements. We will promptly inform you of the relevant incident situation through in-app notifications, SMS notifications, phone calls, emails, and other contact methods you have provided. When it is difficult to notify individually, we will take reasonable and effective methods to publish announcements. At the same time, we will proactively report the handling of user information security incidents to regulatory authorities as required. Please understand that, according to legal provisions, if the measures we take can effectively avoid harm caused by information leakage, tampering, or loss, unless required by regulatory authorities to notify you, we may choose not to notify you of the user information security incident.

7. Protection of Minors

Our products and services are primarily targeted at adults. We will only process minors' user information with permission from laws and regulations and consent from parents or other guardians.

If you are a minor under 14 years old, before using ZWPhone, you should have your parents or other guardians carefully read, or under the supervision and guidance of your parents or other guardians, jointly carefully read this Privacy Policy and the "ZWPhone Children's User Privacy Policy" and use our products and services or provide information to us with the consent of your parents or other guardians.

If we discover that we have collected user information from minors under 14 years old without prior verifiable consent from parents or other guardians, we will take measures to delete the relevant information as soon as possible. If at any time a guardian has reason to believe that we have collected a minor's user information without guardian consent, please contact us through ZWPhone [Mine] - [Contact Customer Service]. We will take measures to delete the relevant data as soon as possible.

8. Revision of This Policy

Our privacy policy may change.

Without your explicit consent, we will not reduce the rights you should enjoy under this Privacy Policy. We will publish any changes to this Privacy Policy on this page.

For major changes, we will notify you through the main exposure pages of the product or service, in-app messages, or by sending emails or other appropriate methods that can reach you. If you disagree with such changes, please immediately stop using ZWPhone products and services.

Major changes referred to in this Policy include but are not limited to:

• Major changes in our service model. Such as the purposes of processing user information, types of user information processed, methods of using user information, etc.;
• Major changes in our ownership structure, organizational structure, etc. Such as owner changes caused by business adjustments, bankruptcy, mergers and acquisitions, etc.;
• Major changes in the main entities to which user information is provided externally, transferred, or publicly disclosed;
• Major changes in your rights to participate in user information processing and the methods of exercising them;
• Changes in the department responsible for processing user information security, contact methods, and complaint channels;
• When the user information security impact assessment report indicates high risks.

9. How to Contact Us

1. The growth of ZWPhone cannot be separated from the joint efforts of users and experts. We greatly appreciate your contributions to ZWPhone data updates and usage feedback.

2. If you have any opinions or suggestions on ZWPhone or any part of this agreement, you can contact us via the company's customer service department email: zwphone@163.com.

3. In general, we will reply within fifteen working days after receiving your questions, opinions, or suggestions and verifying your user identity. Disputes related to this agreement should be resolved through friendly negotiation. If negotiation fails, complaints to consumer rights protection departments or litigation to the people's court with jurisdiction at the location of HONG KONG BETTENS TECHNOLOGY CO.,LIMITED.

User Information Refers to various information recorded electronically or otherwise related to identified or identifiable natural persons, excluding information after anonymization processing. User information includes name, date of birth, ID number, user biometric identification information, address, communication contact information, communication records and content, account password, property information, credit information, trajectory information, accommodation information, health physiological information, transaction information, etc.

Sensitive User Information Refers to user information that, once leaked or illegally used, is likely to lead to infringement of natural persons' personal dignity or harm to personal and property safety, including biometric identification, religious beliefs, specific identities, medical health, financial accounts, trajectory information, etc., as well as user information of minors under 14 years old.

Device Refers to devices that can be used to use ZWPhone products and/or services, such as desktop devices, tablets, or smartphones.

Device Information May include device attribute information of the terminal device you use to install and run ZWPhone (such as hardware model, operating system version and system status, device configuration, International Mobile Equipment Identity IMEI, International Mobile Subscriber Identity IMSI, network device hardware address MAC, Advertising Identifier IDFA, Vendor Identifier IDFV, Mobile Equipment Identifier MEID, Anonymous Device Identifier OAID, Integrated Circuit Card Identifier ICCID, Android ID, hardware serial number, and other device identifiers), device connection information (such as browser type, telecommunications operator, language used, WIFI information), and device status information (such as device application installation list, device sensor information).

Log Information Refers to requests automatically recorded by our servers when you access ZWPhone, such as your IP address, browser type and language used, hardware device information, operating system version, network operator information, date, time, duration of your access to the service, and other information provided, generated, or retained when you use our products or services.

Cookie Refers to a mechanism that supports the server side (or script) to store and retrieve information on the client side, extending Web-based client/server applications by adding simple, persistent client states. The server sends a state information along with the HTTP object returned to the client, which is saved by the client. The state information specifies the URL range valid under that state. Thereafter, HTTP requests initiated by the client within that range will return the current value of that state information from the client to the server, and this state information is called a Cookie.

Location Information Refers to precise location information obtained through GPS information, WLAN access points, Bluetooth, base stations, and other sensor information, as well as rough geographic location information obtained through IP address or other network information.

User Profile Refers to the process of collecting, aggregating, and analyzing user information to analyze or predict specific natural person user characteristics, such as profession, economy, health, education, user preferences, credit, behavior, etc., forming a user characteristic model. Directly using specific natural person's user information to form the natural person's characteristic model is called direct user profiling. Using user information from sources other than specific natural persons, forming the natural person's characteristic model with data from the group they belong to, is called indirect user profiling.

De-identification Refers to the process of processing user information so that it cannot identify a specific natural person without additional information.

Anonymization Refers to the technical processing of user information so that the user information subject cannot be identified, and the processed information cannot be restored. Information obtained after anonymization processing of user information does not belong to user information.

Affiliated Companies Refers singly or collectively to ZWPhone operator HONG KONG BETTENS TECHNOLOGY CO.,LIMITED and other companies in an affiliated relationship with the company. "Affiliated relationship" means, for any entity (including users, companies, partnerships, organizations, or any other entities), the entities it directly or indirectly controls, or that directly or indirectly control it, or that are directly or indirectly controlled by the same entity. The aforementioned "control" refers to, through holding voting rights, contracts, or other means, directly or indirectly possessing the power or factually constituting actual control over the management and decision-making instructions of the relevant entity or instructing others to make such instructions.

Thank you again for your trust and use of ZWPhone!