Privacy Policy

CC Cloud Phone Privacy Policy

Effective Date: February 5, 2025

Dear user, Hunan Jinshengqian Network Technology Co., Ltd. (hereinafter referred to as "we" or "the Company") respects and protects user privacy. When you use the CC Cloud Phone APP, we will follow the CC Cloud Phone Privacy Policy (hereinafter referred to as "this Privacy Policy") and follow the principles of legality, legitimacy and necessity to publicly and explicitly collect and use your personal information. Thank you for trusting and using the CC Cloud Phone service platform (hereinafter referred to as "this platform"). Please read the content of this Privacy Policy carefully and fully understand the relevant terms.

Introduction

Your trust is very important to us. We are well aware of the importance of personal information to you (the personal information and personal sensitive information referred to in this policy are from the national standard GB/T35273-2020 "Information Security Technology Personal Information Security Specification"), and we will take corresponding security protection measures in accordance with the requirements of laws and regulations to try our best to protect your personal information security and controllability. In view of this, this platform formulates this Privacy Policy (hereinafter referred to as "this Policy/this Privacy Policy"). To facilitate your reading and understanding, we have defined the specialized terms. Please refer to "Appendix 1: Definitions" of this Privacy Policy for the specific content of these definitions.

This policy applies to all products and services provided by this platform. Before using the products or services of this platform, please be sure to read and thoroughly understand this policy, especially the terms marked in bold/bold underlined. You should read them carefully and use the relevant products or services after confirming that you fully understand and agree.

This privacy policy will help you understand the following:

1. How we collect and use your personal information

2. How we share, transfer, and publicly disclose your personal information

3. How we store and protect your personal information

4. Your rights

5. How we handle the personal information of minors

6. How your personal information is transferred across borders

7. Revision of the Privacy Policy

8. How to contact us

9. Self-startup and associated startup instructions

1. How we collect and use your personal information

Personal information refers to various information recorded electronically or otherwise that can identify your identity or reflect your activities alone or in combination with other information. We only collect information necessary to realize product functions based on the principles of legality, legitimacy, and necessity. Collection of personal information

(I) Personal information directly provided by you

1. CC Cloud Phone business functions

The services provided by CC Cloud Phone are cloud phone functions.

2. Personal information and system privacy permissions required for various CC Cloud Phone functions

(1) Personal information involved in using various CC Cloud Phone functions

1) Device information

When you use CC Cloud Phone, in order to ensure your normal use of CC Cloud Phone services, more accurately locate and solve problems you encounter when using CC Cloud Phone services, improve and optimize the service experience of CC Cloud Phone, and protect the security of your account, we will collect device attribute information (such as your hardware model, operating system version, sensor information, device configuration, unique device identifier, international mobile equipment identity code IMEI, network device hardware address MAC, software package name in the software list, software name information) and device connection information (browser type, telecom operator), collect clipboard information through io.flutter.embedding SDK, and obtain sensor information through io.flutter. We may associate the information collected from your various devices so that we can provide you with consistent services on these devices.

2) Log Information

Like most Internet services, our servers automatically record the requests you make when you access CC Cloud Phone, such as 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 the basic information we collect to ensure the normal operation of the software and services.

3) Account Registration Information

Please note that when you use CC Cloud Phone to play mobile games, you may need to register or log in to your game account, and third-party mobile game operators may collect and use your relevant information so that you can use the services they provide. Please rest assured that CC Cloud Phone will not collect or use any of your game account information or other information you provide to third-party mobile game operators. Regarding how third-party mobile game operators collect and use your personal information, it is recommended that you refer to the relevant service agreement and privacy policy of the third-party mobile game operator.

4) Third-party account login information

You can use a third-party account to log in to CC Cloud Phone. At this time, you will authorize CC Cloud Phone to read the public information (such as nickname, avatar) you registered with the third-party account.

5) Contact information for participating in operational activities

CC Cloud Phone will initiate operational activities for newly launched services and functions from time to time. If you participate in relevant operational activities, we will collect your identity information and contact information through the operational activity interface in order to contact you, and may collect your transaction account information when it is necessary to issue you operational rewards. Different operational activities may collect different information about you. Please refer to the specific rules of the relevant operational activities. If you do not participate in the relevant operational activities, you do not need to provide the above information.

(2) System privacy permissions involved in using various business functions of CC Cloud Phone

The call of system privacy permissions by various business functions (we will enable relevant permissions after your authorization, and you can cancel the authorization in the system at any time. If you cancel the authorization, you will not be able to use the relevant business functions, but you will not be able to use other business functions). You can view the privacy permission details through the CC Cloud Phone App [My-Settings]. You can also turn on or off the above permissions through the permission setting method provided by your device. Please refer to the instructions or guidelines of the device and system developers for details.

(II) Providing you with security

In order to improve the security of your use of products and services provided by us, our affiliates, and our partners, we may use your information for identity authentication, customer service, security prevention, fraud monitoring, credit analysis, etc., to prevent, discover, and investigate fraud, endangering security, illegal or violating our agreements, policies or rules, in order to protect the legitimate rights and interests of you, our other users, us or our affiliates, partners, and the general public.

Please note that when we use information for other purposes not specified in this privacy policy, we will seek your consent in advance.

(III) Exceptions to prior authorization and consent

Please note that in the following circumstances, the collection and use of personal information does not require your prior authorization and consent:

1. Directly related to national security and national defense security;

2. Directly related to public security, public health, and major public interests;

3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;

4. For the purpose of safeguarding your or other individuals’ major legitimate rights and interests such as life and property, but it is difficult to obtain the consent of the person concerned;

5. The personal information collected is disclosed to the public by you on your own;

6. Personal information is collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;

7. Related to the performance of the obligations of the controller of personal information as prescribed by laws and regulations;

8. Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and handling product or service failures;

9. Necessary for conducting legal news reports;

10. Necessary for statistical or academic research in the public interest, and when the results of academic research or descriptions are provided to the outside, the personal information contained in the results is de-identified;

11. Other circumstances prescribed by laws and regulations. II. How we share, transfer, and publicly disclose your personal information

(I) Sharing

Unless you have authorized and agreed in advance, we will not share your personal information with any third party other than CC Cloud's affiliated companies.

1. For companies, organizations, and individuals with whom we share anonymized or de-identified personal information, we will investigate their data security environment, sign strict confidentiality agreements with them, and require them to handle personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

2. Information you actively share with others

You can also use the sharing function to share with your specific or unspecified social friends , including but not limited to the content you browse and search, etc. Please note that when you use third-party services or sharing functions, the third party's processing of personal information will be subject to the privacy policy of the third-party service provider or the corresponding social platform. Please fully consider the credibility of the information recipient before sharing, and it is recommended that you check the privacy policy of the social network or third-party service provider you use to understand how they handle your information so as to make prudent decisions.

We may share your personal information externally in accordance with laws and regulations or mandatory requirements of government authorities.

(II) Transfer

We will not transfer your personal information to any company, organization or individual other than our affiliates, except in the following circumstances:

1. Obtain your explicit authorization or consent in advance;

2. Meet the requirements of laws, regulations, legal procedures or mandatory government requirements or judicial decisions;

3. In the event of mergers, acquisitions or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this personal information protection policy, otherwise we will require the company or organization to re-ask for your authorization and consent.

(III) Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

1. Obtain your explicit consent;

2. Based on laws, regulations, legal procedures, litigation or mandatory requirements of government authorities.

(IV) Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information

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

1. Directly related to national security and national defense security

2. Directly related to public security, public health, or major public interests;

3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;

4. For the purpose of safeguarding the major legal rights and interests of the subject of personal information or other individuals, such as life and property, but it is difficult to obtain the consent of the subject;

5. Personal information disclosed to the public by the subject of personal information on its own initiative;

6. Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure, and other channels.

(V) Third-party software development kits (SDKs) we have accessed

1. In order to adapt to the use of CC Cloud Phone and third-party platform services on different mobile devices, to achieve your mobile device identity authentication, mobile device security, login to third-party platform accounts, sharing information through third-party platforms, and payment security, CC Cloud PhoneApp has accessed or may access third-party SDKs in the future. The above-mentioned third-party SDK providers include mobile communication operators and third-party payment institutions.

III. How we store and protect your personal information

(I) Storage period

We will continue to store your personal information for you during your use of CC Cloud Phone products and services.

If you cancel your account or actively delete the above information, we will store your information in accordance with the Cybersecurity Law and other laws and regulations. After you cancel your account or actively delete the above information, we will no longer use your personal information for commercial purposes and delete or anonymize your personal information within a reasonable period of time, unless otherwise provided by laws and regulations.

(II) Storage area

Your personal information is stored in Taiwan, China. If we need to transfer your personal information overseas, we will strictly comply with the provisions of laws and regulations and ensure the security of your personal information.

(III) Security measures

1. We collect, use, store and transmit user information in accordance with the principles of legality, legitimacy and necessity, and inform you of the purpose and scope of use of relevant information through the user agreement and privacy policy.

2. We will take appropriate security measures and technical means that meet industry standards to store and protect your personal information to prevent your information from being lost, unauthorized access, public disclosure, use, modification, damage, loss or leakage. We will take all reasonable and feasible measures to protect your personal information. We will use physical, management and encryption technologies to ensure the confidentiality of data.

3. We will establish a special management system, process and organization to ensure information security, train and assess employees on data security awareness and security capabilities, strengthen employees' awareness of the importance of protecting personal information, strictly limit the scope of personnel who access information, require them to comply with confidentiality obligations, and conduct reviews.

4. We remind you that the Internet is not an absolutely safe environment. When you interact with other users through social software, you are not sure whether the third-party software completely encrypts the transmission of information. Please pay attention to ensure the security of your personal information. We recommend that you do not send personal information in this way to avoid personal information leakage. Please use a complex password to help us ensure the security of your account and personal information.

5. We also ask you to understand that in the Internet industry, due to technological limitations and rapid development and various possible malicious attacks, even if we do our best to strengthen security measures, it is impossible to always guarantee 100% security of information. Please understand that the system and communication network you use when using our products and/or services may have security problems in other links beyond our control.

6. If a security incident such as personal information leakage occurs, we will activate the emergency plan to prevent the security incident from expanding and inform you in the form of push notifications, announcements, etc.

(IV) Security Incident Notification

1. We will formulate an emergency plan for network security incidents to promptly deal with security risks such as system vulnerabilities, computer viruses, network attacks, and network intrusions. When an incident that endangers network security occurs, we will immediately activate the emergency plan, take appropriate remedial measures, and report to the relevant competent authorities in accordance with regulations.

2. The leakage, damage, and loss of personal information are company-level major security incidents. We will be responsible for regularly organizing working group members to conduct security plan drills to prevent such security incidents from occurring. If unfortunately, it happens, we will activate the emergency plan with the highest priority, form an emergency response team, trace the cause and reduce losses in the shortest time.

3. After the unfortunate occurrence of a personal information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the treatment measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, and remedial measures for you in accordance with the requirements of laws and regulations. We will promptly inform you of the relevant situation of the incident through the contact information you have reserved, such as in-site notification, SMS notification, phone or email. If it is difficult to inform you one by one, we will take reasonable and effective ways to issue an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

IV. Your rights

In accordance with relevant laws, regulations, standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights to your personal information:

(I) Access and change your personal information

You can access your personal information in the following ways: access and change account information (including but not limited to nickname, avatar, gender, and personal signature):

You can access and change your account information (including but not limited to gender, birthday, address, mobile phone number, avatar).

When you find that the personal information we process about you is wrong, you have the right to correct the wrong or incomplete information. After verifying your identity, you can make corrections in CC Cloud Phone by yourself, or submit your correction application to us through [My]-[Online Customer Service].

(II) Change the scope of your authorization and consent

You can give or withdraw your authorization and consent at any time.

1. Unbind the CC Cloud Phone account from the third-party account.

2. As mentioned above, some functions of the products and services we provide require the relevant permissions of your device (including: storage, phone, camera, microphone, the specific functions of the product shall prevail). You can withdraw (or stop) the continued authorization of this permission at any time after authorization. For example, you can turn off the above permissions through the permission settings provided by your device. You can also permanently withdraw all authorizations for us to continue to collect your personal information by canceling your account through [My]-[Online Customer Service].

You need to understand that when you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the personal information processing previously carried out based on your consent or authorization.

(III) Deleting your personal information In the following circumstances, you may request us to delete your personal information. You may contact us at any time through [My] - [Online Customer Service]:

1. If we collect, use, share or transfer your personal information in violation of laws, regulations or your agreement with you;

2. If we collect and use your personal information without your consent;

3. If our handling of personal information violates our agreement with you;

4. If we disclose your personal information publicly in violation of laws, regulations or your agreement with you, you have the right to request us to immediately stop the public disclosure and issue a notice requiring the relevant recipient to delete the corresponding information.

5. If you no longer use our products or services, or you cancel your account;

6. If we no longer provide you with products or services. If we decide to respond to your request for deletion, we will also notify the entity that obtained your personal information from us and request it to delete it in a timely manner, unless otherwise provided by laws and regulations or these entities obtain your independent authorization.

After you delete information from our services, we may not immediately delete the corresponding information in the backup system, but will delete the information when the backup is updated.

(IV) Cancel your account

1. You can cancel your previously registered account at any time.

You can cancel your registered CC Cloud Phone account.

You can cancel your registered CC Cloud Phone account by contacting the official online customer service. CC Cloud Phone promises to complete the verification and processing within no more than 15 days. If your account involves disputes, including but not limited to complaints, reports, lawsuits and investigations by national authorities, CC Cloud Phone has the right to terminate the account cancellation on its own.

Once you cancel your account, you will not be able to use the CC Cloud Phone products and services that can only be used with this account, so please be careful. Account cancellation does not mean that the account behavior and related responsibilities before the account is cancelled are exempted or reduced.

2. If you want to cancel the game account logged in when trying a mobile game operated by a third party through CC Cloud Phone, you need to apply to the third party to cancel the account.

3. Account cancellation process: a. Enter CC CloudAPP and click "My"; b. Click Settings in the upper right corner; c. Click Account and Security; d. Click Account Cancellation; e. Click "I have agreed to the cancellation rules" to complete the account cancellation.

(V) The right to be informed in advance of the cessation of product and service operations

CC Cloud Phone is willing to accompany you all the time. If CC Cloud Phone products and services are forced to cease operation due to special reasons, we will notify you on the main page of the product or service or send you an email or other appropriate way to reach you, and will stop collecting your personal information. At the same time, we will delete or anonymize your personal information in accordance with legal provisions.

(VI) Respond to your above request

For security reasons, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. If you are not satisfied, you can also contact us through [My]-[Online Customer Service] or through the following channels.

In principle, we do not charge fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost fee depending on the situation. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, require the development of new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are extremely impractical (for example, involve information stored on backup tapes).

In the following circumstances, we will not be able to respond to your request in accordance with laws and regulations: 1. Related to the performance of the obligations of the personal information controller as required by laws and regulations;

2. Directly related to national security and national defense security;

3. Related to public safety, public health, major public interests, etc.

V. How we handle the personal information of minors

CC Cloud Phone attaches great importance to the protection of minors' information.

Our products and services are mainly for adults. If you are a minor under the age of 18, before using CC Cloud Phone products and services, you should read this privacy policy carefully under the supervision and guidance of your parents or other guardians, and use our products and services under the guidance and supervision of your guardians after obtaining the consent of your guardians.

We will only collect, use, and publicly disclose the personal information of minors when permitted by law, with the explicit consent of parents or guardians, or when necessary to protect minors. If we find that we have collected the personal information of minors without the prior verifiable consent of parents, we will take measures to delete the relevant information as soon as possible.

If at any time the guardian has reason to believe that we have collected the personal information of minors without the consent of the guardian, please contact us through [My]-[Online Customer Service], and we will take measures to delete the relevant data as soon as possible.

VI. How to transfer your personal information across borders

The personal information we collect about you will be stored in Taiwan, China. If it involves cross-border, we will strictly follow the provisions of laws and regulations, conduct data outbound security assessments, and ensure the security of your personal information. We will ensure that your personal information is adequately and equally protected within the territory of the People's Republic of China. For example, we will ask for your consent to the cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfer.

VII. Amendment and Notification of Privacy 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 or substantial reduction of your rights under this policy, we will notify you on the main exposure page of the product or service or send you an email or other appropriate way to reach you. If you do not agree to such changes, you can stop using CC Cloud Phone products and services. If you continue to use our products and/or services, you agree to be bound by the revised privacy policy.

Major changes referred to in this policy include but are not limited to: 1. Major changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way personal information is used, etc.;

2. We have major changes in ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy and mergers and acquisitions, etc.;

3. Changes in the main objects of personal information sharing, transfer or public disclosure;

4. Major changes in your rights to participate in the processing of personal information and the way they are exercised;

5. When the responsible department, contact information and complaint channel for handling personal information security changes;

6. When the personal information security impact assessment report indicates a high risk.

After this policy is updated, we will archive the old version of this policy for your reference.

VIII. How to contact us

The growth of CC Cloud Phone is inseparable from the joint efforts of users from all parties. We are very grateful for your contribution to CC Cloud Phone data updates and usage feedback.

You can feedback your suggestions on CC Cloud Phone products and problems encountered during use through [My]-[CC Cloud Customer Service] to help us optimize product functions and services and enable more users to use our products and services more conveniently.

Appendix 1: Glossary

1. Personal information refers to various information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person alone or in combination with other information. Personal information includes name, date of birth, ID number, personal biometric information, address, communication contact information, communication records and content, account password, property information, credit information, whereabouts, accommodation information, health and physiological information, transaction information, etc.

2. Personal sensitive information refers to personal information that, once leaked, illegally provided or abused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment. Generally, personal information of children under 14 years old (inclusive) and information involving the privacy of natural persons are personal sensitive information.

3. De-identification refers to the process of technically processing personal information so that the subject of personal information cannot be identified without the help of additional information.

4. Anonymization refers to the process of technically processing personal information so that the subject of personal information cannot be identified and the processed information cannot be restored. Information obtained after anonymization of personal information does not belong to personal information.

5. Affiliates refer to the operator of CC Cloud Phone, Hunan Jinshengqian Network Technology Co., Ltd. ("Jinshengqian Technology") and other companies that have an affiliated relationship with CC Cloud Phone, either singly or collectively. "Association" refers to any subject (including individuals, companies, partnerships, organizations or any other entities), that is, the subject it directly or indirectly controls, or the subject that directly or indirectly controls it, or the subject that is directly or indirectly controlled by the same subject. The aforementioned "control" means that through holding voting rights, contracts or other means, directly or indirectly have the power to instruct or instruct others to make instructions on the management and decision-making of the relevant subject, or other relationships that in fact constitute actual control.

6. Affiliates and partners refer to our affiliated companies, investment companies, alliance members, partners and other trusted third-party suppliers, service providers and agents.

IX. Self-start and associated startup instructions

In order to let users know more about our activities, new features, benefits and other messages more quickly, we have associated the message push function. Users can choose to turn it on or off when they install our APP. In order to ensure that this application can normally receive the broadcast information pushed by the client when it is closed or running in the background, this application must use the (self-start) capability, and there will be a certain frequency of broadcasts sent by the system to wake up this application to start or associate startup behavior, which is necessary for the realization of functions and services.

Hunan Jinshengqian Network Technology Co., Ltd.