Privacy Protection Policy Version Updated: 2025-01-08 Effective Date: 2025-01-08 AnGallery Privacy Policy Hangzhou Shaoan Technology Co., Ltd. ("the Company", "we", "us" or "this App") operates this application and respects and protects the personal privacy of all users who use the service. To provide you with more accurate and useful services, we will collect, use and disclose your personal information in accordance with this Privacy Protection Policy. We handle such information with a high degree of care and diligence. Except as provided in this Privacy Policy, we will not disclose or provide this information to third parties without your prior consent. We may update this Privacy Policy from time to time. By agreeing to use the App's service terms, you are deemed to have agreed to all contents of this Privacy Policy. This Privacy Policy is an integral part of the App's service terms. Special notice: Please read this Privacy Protection Policy carefully (especially the bolded or underlined parts) and make sure you understand how we process your personal information. If you have any questions while reading or using the service, please contact our customer service. If you disagree with any provision of the policy, you should stop accessing and using the service immediately. This policy will help you understand: 1. Definitions 2. How we collect and use your personal information 3. How we share, transfer, and publicly disclose your personal information 4. How we protect and retain your personal information 5. Your rights 6. Protection of minors 7. How this policy is updated 8. How to contact us 1. Definitions Personal Information: Information that can be used alone or in combination with other information to identify a specific natural person or reflect the activities of a specific natural person. The types of personal information referred to in this Privacy Policy are listed in the section "How we collect and use your personal information." Sensitive Personal Information: Information that, once disclosed, unlawfully provided or misused, may endanger personal or property safety, lead to reputational harm, physical harm, or discriminatory treatment. In this policy, sensitive personal information may include network identity information (account name, account nickname and related passwords), other personal contact information (such as email, location), and so on. We will highlight such items in bold or otherwise call them out in the policy where appropriate. 2. How we collect and use your personal information During App development and upgrades, we continuously improve product features. We will collect and use your personal information only for the purposes described in this policy: 1) Provide services, product development and service optimization: for example, when our system encounters faults, we record and analyze information generated during failures to optimize our services. 2) Security protection: for identity verification, security prevention, anti-fraud detection, archival backup, and customer security services. For example, security software you install may detect malicious programs or viruses or help identify fraud. 3) Evaluate and improve advertising delivery and other promotional activities. 4) Software management: such as software authentication and updates. 5) Invite you to participate in surveys related to our services. (A) Device permissions we may use When the App runs, certain features may require permissions. We are strict and conservative about permission requests. We will request only permissions necessary for the feature. If you decline a permission, only the corresponding feature may be affected. Possible permissions and purposes include: 1. Installed apps list: used for feature requirements; no data is uploaded by default; ad delivery may use app lists to optimize ads. 2. Network access: to fetch backend data and upload data, which may use mobile data. 3. Read external storage: dynamically requested for reading user data when using relevant features, to ensure App functionality. 4. Write external storage: dynamically requested for storing data to support App functionality. 5. Network state information: to ensure basic App services and integrated SDKs work correctly. 6. Phone state: for basic App services and to ensure integrated SDKs operate correctly. 7. Camera: to take photos and videos. 8. Microphone: dynamically requested to record video files. 9. Location: network-based or GPS/Wi-Fi assisted location for app features and integrated SDKs. 10. Clipboard access: local use for copy/paste functionality. 11. Accelerometer/gravity sensor: for orientation and motion detection to support App behaviors. (B) Improve our product or service We may obtain other information reasonably necessary to improve our products or services, including feedback you provide when contacting customer support, survey responses, and information authorized from our partners. We may associate information collected from different devices to provide a consistent experience across your devices. (C) Provide you with security protection To improve service security, protect you, other users or the public from physical or property harm, and better prevent phishing, fraud, vulnerabilities, viruses, attacks or intrusions, we may use or aggregate your personal information, device information, network logs, app usage frequency, crash reports, installation statistics, performance data and source information to assess account and transaction risk, verify identity, detect and prevent security incidents, and take necessary recording, auditing, analysis and disposition measures in accordance with law. For example, we analyze abnormal account activity, multi-device logins, or abnormal traffic to protect your account. (D) Other purposes If we wish to use your personal information for purposes not described in this policy, we will seek your additional consent as required by law. Exceptions to consent Under applicable law, in the following circumstances we may collect and use your information without obtaining your prior consent: 1. Matters related to national security or defense security; 2. Matters related to public safety, public health, or major public interests; 3. Matters related to criminal investigation, prosecution, trial, and enforcement of judgments; 4. When it is necessary to protect an individual's life or property and obtaining consent is difficult; 5. When necessary to ensure the secure and stable operation of the products or services, such as discovering and resolving product or service faults; 6. When necessary for legitimate news reporting; 7. When necessary for academic research by institutions for public interest, and where results provided to third parties are de-identified; 8. Other situations as provided by law. 3. How we share, transfer, and publicly disclose your personal information (A) Sharing and disclosure We do not share your personal information with any company, organization or individual outside the Company, except in the following situations: 1. With your explicit consent (including your guardian where applicable) or when you choose to provide it; 2. Where required by law, litigation or judicial/administrative requests; for example, if we determine you have violated laws or the App rules or to protect the safety of our users or the public, we may disclose relevant personal information and actions taken; 3. Shared with our affiliates: only necessary personal information will be shared and subject to the purposes in this policy. If affiliates change the purpose of processing, we will re-seek your consent; 4. Shared with authorized partners: some services are jointly provided with authorized partners. We will share only personal information necessary to provide those services. Our partners are prohibited from using the information for unrelated purposes. Current categories of authorized partners include vendors, service providers and other partners who support our business (infrastructure, analytics, customer service, location services, research). We sign strict data protection agreements with them and require them to follow our instructions and this Privacy Policy. If we share sensitive personal information or partners change purposes, we will obtain your authorization again. We embed third-party SDKs or similar tools to enable third-party login, push notifications, social sharing, location services, and other functions. These SDKs are subject to separate privacy policies and we perform security checks before embedding them. Examples of SDKs we use: - Umeng+ Mobile Analytics SDK (Umeng Tongxin (Beijing) Technology Co., Ltd.) Purpose: analytics; collected fields include device identifiers (DEVICE_ID, CCID, SN, MAC, AndroidID, IDFA, OPENUDID, OAID, GUID, SIM IMSI, IMEI), location data, operator, postal/region codes, clipboard, accelerometer, coarse location, etc. Data is collected after user consent, de-identified and transmitted securely. Privacy: https://www.umeng.com/page/policy - Umeng+ APM SDK (Umeng Tongxin (Beijing) Technology Co., Ltd.) Purpose: performance monitoring and analytics; similar collection fields and secure handling as above. Privacy: https://www.umeng.com/page/policy - Huawei AppGallery Connect Auth Service (Huawei Software Technologies Co., Ltd.) Purpose: email login verification; collects device identifier (AAID), user email and password, provider info (ProviderUid, avatar, nickname, ProviderAccessToken), AGC auth info (AgcUid, avatar, nickname, AgcAccessToken, AgcRefreshToken). Privacy: https://developer.huawei.com/consumer/cn/doc/AppGallery-connect-Guides/agc-auth-android-sdksecurity-0000001053372658 - Huawei Cloud LTS Log Service (Huawei Cloud Computing Technologies Co., Ltd.) Purpose: APP log reporting to Huawei Cloud; collected data includes device model, device name, OS name/version, APP version/name, Wi‑Fi state. Privacy: https://console.huaweicloud.com (B) Transfer We will not transfer your personal information to any other company, organization or individual except in the following cases: 1. With your explicit consent; we may transfer your personal information to other parties after obtaining your consent; 2. In merger, acquisition or bankruptcy events, we will require the new holder of your personal information to continue to be bound by this policy or we will obtain your re-consent. (C) Public disclosure We will publicly disclose your personal information only in limited circumstances, with industry-standard safeguards, such as: 1. Disclosure according to your request and with your explicit consent; 2. Disclosure required by mandatory laws, administrative or judicial requests; we will review such requests to ensure lawful basis and request proper legal documentation (subpoena, probes) where appropriate. (D) Exceptions to prior consent for sharing, transfer, or disclosure According to law, we may share, transfer or disclose personal information without obtaining prior consent in the situations listed in Section 2 (exceptions) above, and where the information has been de-identified in accordance with law so that the recipient cannot re-identify the data subject. 4. How we protect and retain your personal information Technical safeguards We adopt industry-standard technical and management measures to protect personal information confidentiality and security, including but not limited to: SSL/transport encryption, encrypted data storage, access control, physical protection, backups, log auditing, and least-privilege access, together with personnel security management, audits and security training. Storage location and retention period We normally store personal information within the People's Republic of China. If cross-border transfer is necessary, we will notify you in advance and obtain consent when required. We retain personal information only for as long as necessary to achieve the purposes described in this policy or as required by law; after the retention period expires we will delete it or de-identify it unless otherwise required by law. Security incident handling In the event of a personal information security incident, we will perform legal notifications and take necessary remedial measures, including reporting to supervisory authorities and providing guidance to affected users. 5. Your rights You have the following rights regarding your personal information: - Access and obtain copies; - Correct inaccurate or incomplete information; - Delete or request anonymization (where applicable); - Request restriction of processing; - Withdraw consent (where processing is based on consent); - Data portability where applicable. To exercise these rights, contact us using the methods in Section 8. We will verify your identity and respond within a reasonable period (common requests are answered within 15 business days). 6. Protection of minors We pay special attention to protecting minors' personal information. If you are under 18, please ensure that your parent or guardian is aware of and agrees to this Privacy Policy before using related services. If we discover a minor has provided personal information without guardian consent, we will promptly delete the related information. 7. How this Privacy Policy is updated (A) We may revise this policy from time to time. We will not reduce your existing rights without your explicit consent. (B) After updates, we will display changes at login or during version updates via push notifications or pop-ups. Continued use indicates acceptance of the updated policy. If updates involve collection of additional sensitive personal information (call logs, contacts, location, etc.), we will request your consent again. (C) For material changes, we will provide a more prominent notice (SMS, in‑app message, login page pop-up) and keep prior versions available for review. Material changes include: service model changes, major organizational or affiliate changes, main purposes or methods of personal information processing, changes to rights or ways to exercise them, changes to responsible departments or contact channels, or when a high-risk personal information impact assessment results. 8. How to contact us If you have questions or suggestions, you can contact us: (a) Email: shaoanlimited@gmail.com (b) In‑App "Feedback" feature We will verify your identity and respond, typically within 7 business days.