《Privacy Policy》


This policy applies only to the CoulChoice App product and related services of Shenzhen QuXin Tiaodong Technology Co., Ltd.

Last updated: March 20, 2024

Effective date: March 20, 2024

If you have any questions, comments, or suggestions regarding this policy or related matters, you can contact us through the following contact information or other various contact methods provided by the platform:

Data Protection Officer's email: QXtd0328@163.com

This Privacy Policy will help you understand the following:
Introduction
1. How we collect and use your personal information
2. How we entrust, share, transfer, and publicly disclose your personal information
3. How we protect your personal information
4. Your rights
5. How we handle personal information of minors
6. How we store your personal information
7. Revision and notification of privacy policies
8. How to contact us
9. Scope of application


Shenzhen QuXin Tiaodong Technology Co., Ltd. (referred to as "we") is well aware of the importance of personal information to you, and we will fully protect your personal information and privacy in accordance with the provisions of laws and regulations. We are committed to maintaining your trust in us and adhere to the principles of consistency between rights and responsibilities, clear purposes, choice and consent, minimal necessity, security assurance, subject participation, openness and transparency, etc. At the same time, we promise that we will adopt corresponding security protection measures to protect your personal information according to mature industry security solutions.

We hope that before using our products and related services, you will carefully read and thoroughly understand this Privacy Policy in order to make appropriate choices.

Introduction

We strictly keep the user information we collect confidential and establish a sound system for protecting user information to provide reliable and trustworthy services for each user:

1. Clear and explicit

We will explain the privacy policy in plain and understandable language as much as possible, so that you can have a clearer understanding of how we protect and handle the information we collect.

2. Safeguarding rights and interests

We will take sufficient and reasonable measures to protect your privacy rights and interests.

3. Respecting users

We respect the freedom of users to exercise their rights, such as the right to choose and the right to be informed, and allow you to manage your personal information.

4. Necessary security

We will only collect necessary information and use this information to provide you with secure and detailed services.

5. Timely and thoughtful

We will listen to your inquiries at any time and provide prompt answers to your questions.

We hope you carefully read the "Privacy Policy" (referred to as "this policy") to understand in detail how we collect and use information, so that you can better understand our services and make choices that truly reflect your intentions. If you have any questions, please contact us.

1. How we collect and use your personal information

In order to provide you with a better product and service experience, we are continuously improving our technology. As a result, we may occasionally introduce new or optimized features that may require the collection and use of new personal information or a change in the purpose or method of using personal information. In this case, we will explain to you the purpose, scope, and use of the corresponding information through methods including but not limited to updating this policy and page prompts, and provide you with a voluntary choice to agree. We will collect and use the information only after obtaining your explicit consent. During this process, if you have any questions, comments, or suggestions, you can contact us through various contact methods provided by us, and we will answer them as soon as possible.

The types of personal information we collect and the rules for collecting and using personal information are as follows:
1. When you publish image content or make comments, we will collect the information you published and display your nickname, avatar, published content, and information.
2. When you use the image publishing function, we will request your authorization for camera, photo, microphone, and view network status permissions. If you refuse to authorize this, you will not be able to use this function, but it will not affect your normal use of other functions.
3. When you choose to establish a follow-up relationship with someone you are interested in, we will collect service log information including your following relationship and sharing history to achieve the above functions and other purposes that we explicitly inform you of.

(4) For the Purpose of Providing Security Functions

To provide you with a more secure and trustworthy product and usage environment, and to provide high-quality, reliable services and information, we will collect information about your usage of products or services and how you use them, and correlate this information. This information includes:

1. Device Information:
During your use of the platform, in order to provide you with services that better meet your needs, interaction displays, search results, recognition of abnormal account states, maintenance of normal platform operations, and protection of your account security, we will receive and record specific permissions granted by you during software installation and use for device-related information (including device model, hardware serial number, operating system version, setting parameters, device configuration, International Mobile Station Equipment Identity (IMSI), Unique Device Identifier (IMEI, OAID, AndroidID), network device hardware address (MAC address), device network information, device environment software and hardware feature information, WLAN access point, Bluetooth, base station, access network type and status, network quality data, and device location-related information (IP address, geographic location information). Because the services we provide are based on geolocation-based mobile social services, you confirm that the successful registration of the "Platform" account is considered as confirming that we are authorized to extract, disclose and use your IP address information.
2. Log Information:
When you use the products or services provided by our website or client, we will automatically collect detailed usage information about our products or services as a network log save. This includes browsing, clicking to view and searching for query content, following and sharing information, posting information, and IP address, browser type, carrier information, language used, access date and time, and web pages visited. Please note that individual device information and log information are not personal information that can identify specific individuals. Therefore, if we combine this information with other information to identify specific individuals or use it in combination with personal information, during the period of combined use, this type of information will be regarded as personal information. Except as authorized by you or as required by law and regulations, we will anonymize and de-identify such personal information.
3. When you contact us, we may save your communication/call records and content or the contact information you leave in order to contact you or help you solve problems. We may also record the solutions and results related to the relevant issues.
4. In order to improve the security of your use of our services and services provided by affiliated companies and partners, protect your or other users' or the public's personal and property safety from infringement, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, etc., more accurately identify violations of laws and regulations or platform-related agreement rules, we may use or integrate your user information, transaction information, device information, relevant network logs, and information shared with affiliated companies or partners that have obtained your authorization or according to law, and then comprehensively judge the transaction risks of your account, conduct identity verification, detect and prevent security incidents, and take necessary record-keeping, auditing, analysis, and disposal measures in accordance with the law.
5. Please note that as our business develops, Platform's functions and services may be adjusted. In principle, when new functions or services are related to our current functions or services, the personal information collected and used will have a direct or reasonable relationship with the original processing purpose. In scenarios where there is no direct or reasonable relationship with the original processing purpose, we will inform you again of the collection and use of your personal information and obtain your consent.

(5) Other Purposes

1. If the information you provide contains other users' personal information, you must ensure that you have obtained legal authorization before providing this personal information to the platform.
2. If we use information for other purposes not mentioned in this policy, or use information collected for specific purposes for other purposes, or actively obtain your personal information from third parties, we will obtain your consent in advance.
3. If we indirectly obtain your information from a third party, we will explicitly require the third party in writing to collect the information after obtaining your consent in accordance with the law, and inform you of the shared information content. For sensitive information, we will require your explicit confirmation before providing it for our use. We will ask the third party to make a commitment on the legality and compliance of the personal information source. If the third party violates this commitment, we will explicitly request the third party to bear corresponding legal responsibilities; at the same time, our professional security team will protect personal information (including sensitive information grading classification, access control for sensitive information use, encryption storage for sensitive information, etc.). We will use protection measures and methods that are no less than those used for protecting personal information of our own users for indirectly obtained personal information.
4. Explanation of platform APP device permission requests:

Read phone state permission: When you run the Android version of the platform APP, we will request this permission to facilitate calling customer service. If you refuse, you can choose to turn off this permission.

Read and write external storage permission: When you use the avatar setting or send pictures in the Android version of the platform APP, you can use or save pictures or files by enabling storage permissions. If you do not enable this permission, you will not be able to use functions related to reading or caching storage cards, but it does not affect your use of other services.

Album permission: When you use the avatar setting or send pictures in the Android or iOS version of the platform APP, you can upload pictures from your device by opening album permissions. If you do not enable this permission, you will not be able to use functions related to uploading and sending pictures, but it does not affect your use of other services.

Camera permission: When you use the avatar setting or send pictures in the Android or iOS version of the platform APP, you can take real-time photos and upload them to set avatars or send pictures by opening camera permissions. If you do not enable this permission, you will not be able to use functions related to taking pictures, but it does not affect your use of other services.

Location permission: When you use the remote control function in the Android or iOS version of the platform APP, you can view the approximate distance between the remote control parties by opening location permissions. If you do not enable this permission, you will not be able to use this function, but it does not affect your use of other services.

Microphone permission: When you use the voice service in the Android or iOS version of the platform APP, you can record personal profile voice messages, send voice messages, or make voice calls by enabling microphone permissions. If you do not enable this permission, you will not be able to use functions related to voice input, but it does not affect your use of other services.

Bluetooth permission: When you use the Android or iOS version of the platform APP, we will obtain this permission to connect the application to the CoulChoice intelligent device and provide you with the function of directly controlling the device. If you do not enable this permission, you will not be able to use this function, but it does not affect your use of other services.

View network state permission: When you use the Android or iOS version of the platform APP, we will obtain this permission to view all network states, such as existing and connected networks. If you do not enable this permission, you will not receive timely notifications of changes in network status, but it does not affect your use of other services.

You understand and agree that the above services may require you to enable access to your location information (geographic location), camera, album and storage, microphone (voice), phone status, and network status on your device to collect and use information related to these permissions. You can check the status of these permissions in the "Settings-App Permissions" of your mobile phone, and you can decide to turn them on or off at any time. Please note that when you enable any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you turn off any permission, you cancel the authorization, and we will no longer collect and use relevant personal information based on the corresponding permission, and we will be unable to provide the service corresponding to that permission. However, your decision to turn off permissions will not affect the information collection and use based on your previous authorization.

You understand and agree that the functions and service scenarios we provide to you are constantly being upgraded. If we do not expressly state the personal information that needs to be collected in the above scenarios, we will provide you with another prompt or obtain your consent through page prompts or interactive design to clearly indicate the content, scope, and purpose of information collection.

Android operating system application permission request and usage instructions:
To ensure the safe and stable operation of CoulChoice intelligent devices, we may apply for or use relevant operating system permissions of the Android system. To protect your right to know, we will display and explain the relevant operating system permissions that the product may apply for or use through the following content, and you can manage the relevant permissions according to your actual needs:

1. Access network
android.permission.INTERNET
• Permission function description: access network connection, which may generate GPRS traffic.

2. Recording
android.permission.RECORD_AUDIO
• Permission function description: record sound through the microphone of the phone or headset.

3. Get network status
android.permission.ACCESS_NETWORK_STATE
• Permission function description: get the network information status, such as whether the current network connection is valid.

4. Get Wi-Fi status
android.permission.ACCESS_WIFI_STATE
• Permission function description: get the current Wi-Fi access status and information about WLAN hotspots.

5. Change Wi-Fi status
android.permission.CHANGE_WIFI_STATE
• Permission function description: change Wi-Fi status.

6. Wake lock
android.permission.WAKE_LOCK
• Permission function description: allow the program to continue running in the background after the phone screen is turned off.

7. Modify sound settings
android.permission.MODIFY_AUDIO_SETTINGS
• Permission function description: modify sound setting information.

8. Auto startup on boot
android.permission.RECEIVE_BOOT_COMPLETED
• Permission function description: allow the program to automatically run on boot.

9. Write external storage
android.permission.WRITE_EXTERNAL_STORAGE
• Permission function description: allow the program to write to external storage, such as writing files to an SD card.

10. Use vibration
android.permission.VIBRATE
• Permission function description: allow vibration.

11. Make phone calls
android.permission.CALL_PHONE
• Permission function description: allow the program to enter phone numbers from a non-system dialer.

12. Camera permission
android.permission.CAMERA
• Permission function description: allow access to the camera for taking photos and videos.

13. Use Bluetooth
android.permission.BLUETOOTH
• Permission function description: allow the program to connect to paired Bluetooth devices.

14. Bluetooth management
android.permission.BLUETOOTH_ADMIN
• Permission function description: allow the program to discover and pair new Bluetooth devices.

15. Get accurate location
android.permission.ACCESS_FINE_LOCATION
• Permission function description: receive satellite location information through GPS chips, with an accuracy of within 10 meters.

16. Get Task Information
android.permission.GET_TASKS
• Permission Function Description: Allows the application to get the current or recently run applications.

17. Modify System Settings
android.permission.WRITE_SETTINGS
• Permission Function Description: Allows the application to read and write system settings.

18. Get Device Identification Code
android.permission.READ_PHONE_STATE
• Permission Function Description: Allows access to the device identification code (including IMEI/Android ID/IDFA/IDFV/OPEN UDID/GUID/OAID/MEID, advertising ID, SIM card phone number, IMSI, ICCID, device serial number) in order to provide related services such as identifying carriers and binding devices.

iOS Operating System Application Permission Request and Usage Instructions

To ensure the safe and stable operation of CoulChoice smart devices, we may request or use relevant permissions of the iOS system. To protect your right to know, we provide the following explanations of the permissions that the product may request and use. You can manage the relevant permissions according to your actual needs:

1. NSBluetoothAlwaysUsageDescription
• Permission Function Description: Use Bluetooth functionality to connect to Bluetooth devices.

2. NSBluetoothPeripheralUsageDescription
• Permission Function Description: Use Bluetooth functionality to connect to Bluetooth devices (compatible with versions prior to iOS 13).

3. NSCameraUsageDescription
• Permission Function Description: Use the camera.

4. NSLocationAlwaysUsageDescription
• Permission Function Description: Allow the app to always access the geographic location.

5. NSLocationUsageDescription
• Permission Function Description: Allow the app to access the geographic location.

6. NSLocationWhenInUseUsageDescription
• Permission Function Description: Only obtain the geographic location when the app is in use.

7. NSMicrophoneUsageDescription
• Permission Function Description: Use the microphone.

8. NSPhotoLibraryAddUsageDescription
• Permission Function Description: Add content to the photo library.

9. NSPhotoLibraryUsageDescription
• Permission Function Description: Read content from the photo library.

Exceptions to Obtaining Authorized Consent

You fully understand and agree that we may collect and use your personal information without your authorized consent under the following circumstances, and we may not agree to your requests for correction/modification, deletion, cancellation, withdrawal of consent, or information retrieval:

1. Related to national security and defense.

2. Related to public safety, public health, or major public interests.

3. Related to criminal investigations, prosecutions, trials, and enforcement of judgments.

4. Necessary for the protection of the vital interests of individuals or other individuals, but it is difficult to obtain your personal consent.

5. The collected personal information is voluntarily made public by you.

6. Collected from legally disclosed information, such as legal news reports, government information disclosure channels, etc.

7. Necessary for signing a contract at your request.

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

9. Necessary for legitimate news reporting.

10. Necessary for academic research institutions to carry out statistics or academic research based on public interests, and when providing academic research or describing results to the public, the personal information included in the results is de-identified.

11. Other circumstances as stipulated by laws and regulations.

Please be aware that according to applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify specific individuals and cannot restore it, or if we may de-identify the collected information for research, statistical analysis, and prediction, to improve the platform's content and layout, provide support for business decisions, and improve our products and services (including using anonymous data for machine learning or model algorithm training), such use of the processed data does not require separate notification and your consent.

If we cease the operation of the platform product or service, we will promptly stop any further collection of your personal information, and notify you of the cessation of operation through individual notifications or announcements. We will delete or anonymize the personal information we hold.
How do we entrust the processing, sharing, transfer, and public disclosure of your personal information?

(1) Entrusted Processing

Certain modules or functions of the platform are provided by external suppliers. For specific details, please refer to Chapter 10 of this policy, "SDK Technical Specifications." We will require companies, organizations, or individuals entrusted with the processing of personal information to handle your personal information in accordance with our requirements, this personal information protection policy, and any other relevant confidentiality and security measures.

(2) Sharing

We will not share your personal information with companies, organizations, and individuals other than platform service providers, except in the following circumstances:

1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

Currently, our authorized partners include the following types:

Authorized partners in advertising and analytics services. Without your permission, we will not share your personal identity information with partners who provide advertising and analytics services. We will entrust these partners to process information related to advertising coverage and effectiveness, but we will not provide your personal identity information, or we will de-identify this information so that it does not identify you personally. These partners may combine the above information with other data lawfully obtained by them to perform the advertising services or decision recommendations entrusted by us:

①Personal information types shared in advertising: nickname, avatar

②Personal information types shared by analytics service providers: gender, age, location

We will conduct strict security checks on application programming interfaces (APIs) and software development kits (SDKs) used by authorized partners to obtain relevant information. We will also agree with authorized partners on strict data protection measures to ensure that they handle personal information in accordance with our commissioned purposes, service descriptions, this privacy policy, and any other relevant confidentiality and security measures.

(3) Transfer

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

1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.

2. In the event of a merger, acquisition, bankruptcy liquidation, or other situations involving merger, acquisition, or bankruptcy liquidation, if it involves the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy. Otherwise, we will require the company, organization, or individual to seek your authorization and consent again.

(4) Public Disclosure

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

1. With your explicit consent or authorization;

2. If we determine that you have violated laws, regulations, or platform-related agreement rules, or if it is necessary to protect the personal and property safety of the platform, its affiliated companies, users, or the public, we may disclose your personal information under the circumstances where you have given your consent in accordance with laws, regulations, or platform-related agreement rules. This includes relevant violations and the measures that the platform has taken against you.
Exceptions to the prior authorization for sharing, transferring, and publicly disclosing personal information

The following circumstances do not require your prior authorization for sharing, transferring, or publicly disclosing your personal information:

1. Related to national security and defense;

2. Related to public safety, public health, and significant public interests;

3. Related to criminal investigations, prosecutions, trials, and enforcement of judgments;

4. Necessary for the protection of your or other individuals' vital interests, but it is difficult to obtain your consent;

5. Personal information that you voluntarily disclose to the public;

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

According to legal provisions, if we use technical measures and other necessary measures to process personal information in a way that the data recipient cannot re-identify specific individuals and cannot be restored, the sharing, transfer, and public disclosure of such processed data do not require separate notification and consent from you.

How We Protect Your Personal Information

We have implemented industry-standard security measures to protect the personal information you provide, prevent unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information.

1. We will use encryption technology, anonymization processing, and other reasonably feasible methods not lower than industry peers to protect your personal information and use security protection mechanisms to prevent malicious attacks on your personal information.

2. We will establish dedicated security departments, security management systems, and data security processes to ensure the security of your personal information. We have strict data usage and access systems to ensure that only authorized personnel can access your personal information.

3. Despite having taken the above reasonable and effective measures and complied with the standards required by relevant laws and regulations, please understand that due to technological limitations and possible malicious means, in the internet industry, even with the best efforts to strengthen security measures, it is impossible to guarantee 100% security of information. We will do our best to ensure the security of the personal information you provide to us.

4. You understand and acknowledge that the systems and communication networks you use to access our services may encounter problems beyond our control. Therefore, we strongly recommend that you take proactive measures to protect the security of personal information, including using complex passwords, regularly changing passwords, and not disclosing your account passwords and related personal information to others.

5. We will formulate emergency response plans and immediately initiate them in the event of a user information security incident, striving to prevent the impact and consequences of such security incidents. Once a user information security incident (leakage or loss) occurs, we will promptly notify you in accordance with the requirements of laws and regulations, including the basic situation and possible effects of the security incident, the measures we have taken or will take to deal with it, suggestions for you to prevent and reduce risks, and remedies for you. We will inform you of the event-related information through push notifications, emails, letters, text messages, and other forms. When it is difficult to notify each individual, we will make reasonable and effective announcements. At the same time, we will report the disposal of user information security incidents to the relevant regulatory authorities as required.

Our Data Security Capabilities

1. Content Security: We have purchased third-party services, including: Using Alibaba Cloud to improve our content security storage and protection capabilities.

2. Data Security: We use Alibaba Cloud services to ensure basic data security services. Additionally, for user privacy data, we encrypt it using international standard encryption methods to further protect data storage.

3. Access Security: All requests are transmitted using HTTPS, and authorization access mechanisms are added to the business.

We will take all reasonable and feasible measures to ensure that we do not collect irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law.

The internet environment is not completely secure, and we will do our utmost to ensure or guarantee the security of the information you send to us. If our physical, technical, or managerial protective facilities are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information, and causing damage to your legitimate rights and interests, we will assume corresponding legal responsibilities.

If you discover that your personal information, especially your account or password, has been leaked, please immediately contact platform customer service so that we can take appropriate measures according to your request.
Four, Your Rights

In accordance with the relevant laws, regulations, and prevailing practices in China, we guarantee your rights to exercise the following rights regarding your personal information.

(1) Access to Your Personal Information

You have the right to access your personal information, except for exceptions stipulated by laws and regulations. If you want to exercise the right of data access, you can access it by:

Personal Profile – If you want to access or edit your personal profile, including nickname, constellation, age, address, etc., you can perform such operations through the "Personal Profile" section on the personal homepage after logging into your account.

Dynamic Information – You can access or clear your dynamic posting history through the "Community" section after logging into your account.

If you are unable to access your personal information through the above paths, you can contact us through platform customer service at any time. We will review the relevant issues as soon as possible and reply to your access request within 15 working days after verifying your user identity by a dedicated person.

(2) Correction of Your Personal Information

When you find errors in the personal information we handle about you, you have the right to request correction. You can submit a correction application through the methods specified in "(1) Access to Your Personal Information" above.

If you are unable to access your personal information through the above paths, you can contact us through platform customer service at any time. We will review the relevant issues as soon as possible and reply to your access request within 15 working days after verifying your user identity by a dedicated person.

(3) Deletion of Your Personal Information

You can delete part of your personal information through the methods specified in "(1) Access to Your Personal Information" above. In the following situations, you may request us to delete personal information:

1. If our handling of personal information violates laws and regulations;

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

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

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

5. If we no longer provide products or services to you.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to promptly delete it, unless otherwise provided by laws and regulations or unless these entities have obtained your independent authorization.

After you delete your personal information from our products or services, we may not immediately delete the corresponding information from the backup system in accordance with legal requirements, but we will delete this information when the backup is updated.

(4) Change the Scope of Your Authorized Consent

1. You can turn off permissions such as location, camera, microphone, album access through the operating system of your device to change the scope of consent or revoke your authorization. After revoking the authorization, we will no longer collect information related to these permissions. You can also revoke the authorization by canceling your account.

2. Certain business functions and services require your information to be completed. When you revoke your consent or authorization, we will no longer be able to provide you with the corresponding functions and services and will no longer process your relevant personal information. However, your decision to revoke consent or authorization will not affect the processing of personal information based on your previous authorization.

(5) Account Cancellation by the Subject of Personal Information

You can cancel your account by going to "Settings" - "Account Cancellation". Before you cancel your account, we will verify your personal identity, security status, and device information. For the process and content of account cancellation, please refer to the prompts on the cancellation page. You understand and agree that the act of canceling your account is irreversible. After you cancel your account, we will delete relevant information about you or anonymize it, except as otherwise provided by laws and regulations.

(6) Personal Information Subject Obtaining a Copy of Personal Information

You have the right to obtain a copy of your personal information. If you need to obtain a copy of the personal information collected by us, you can contact us. The customer service representative will verify your personal information and submit the copy of your personal information to you through online customer service. On the premise of complying with relevant legal provisions and technical feasibility, we will provide you with a copy of your personal information according to your request.

Constraints on Automated Decision-Making in Information Systems

In certain business functions, we may make decisions solely based on non-human automated decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will provide appropriate remedies.

Complaints and Reports

If you believe that your personal information rights may have been infringed upon or if you discover any clues regarding the infringement of personal information rights, you can click on the other party's avatar or more options in the information flow or dialogue box to provide relevant information for reporting. We will verify and handle your complaints and reports within 15 working days. If you are not satisfied with the results, you can also initiate a complaint through platform customer service. We may refuse requests that are unfounded, pose risks to the legitimate rights and interests of others, or are highly impractical. In the following circumstances, in accordance with legal requirements, we will be unable to respond to your requests:

1. Related to the obligations of the personal information controller under laws and regulations;

2. Directly related to national security and defense;

3. Directly related to public safety, public health, and major public interests;

4. Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;

5. Where the personal information controller has sufficient evidence to demonstrate subjective malice or abusive exercise of rights by the personal information subject;

6. In order to protect the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain consent from the individual concerned;

7. Responding to the personal information subject's request would cause serious harm to the legitimate rights and interests of the personal information subject or other individuals or organizations;

8. Involving trade secrets.

How We Handle Personal Information of Minors

Our products, websites, and services are intended for adults aged 18 and above. Any minors under the age of 18 are not allowed to create their own user accounts or use our services. If we discover or verify any minors registering or using our products, we will take measures such as account cancellation and information deletion to prohibit or restrict the use by minors.

How We Store Your Personal Information

(1) In accordance with the provisions of laws and regulations, we store your personal information collected and generated during the operation within the territory of the People's Republic of China. Currently, we do not transfer the aforementioned information overseas. If we do transfer information overseas, we will follow relevant national regulations or seek your consent.

(2) We only retain your personal information for the period necessary to provide the "platform" and services:

We will retain relevant information during the period when you have not withdrawn, deleted, or canceled your account. After the necessary period, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations.


Revision and Notification of Privacy Protection Policy

In order to provide you with better services, the platform and related services will be updated and changed from time to time. We will revise this privacy policy in a timely manner. These revisions constitute part of this privacy protection policy and have the same effect as this privacy policy. Without your explicit consent, we will not reduce the rights you are entitled to under the current effective privacy policy.

After the update of this privacy protection policy, we will release the updated version on the platform and remind you of the updated content in an appropriate manner so that you can timely understand the latest version of this privacy policy.

For significant changes, we will also provide more prominent notifications (including sending notifications via SMS to explain the specific changes to the personal information protection policy) where applicable.

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

1. Significant changes in our service mode, such as the purpose of processing personal information, types of personal information processed, and ways personal information is used;

2. Significant changes in our ownership structure, organizational structure, etc., such as business adjustments, bankruptcy and mergers causing changes in ownership, etc.;

3. Major changes in the main objects with whom personal information is shared, transferred, or publicly disclosed;

4. Significant changes in your rights regarding participation in the processing of personal information and how these rights are exercised;

5. Changes in the department responsible for the security of personal information, contact methods, and complaint channels;

6. When the personal information security impact assessment report indicates high risks.
How to Contact Us

If you have any questions or suggestions regarding this policy or related matters, we have established a dedicated department for the protection of personal information. You can contact us through the following complaint channels:

Personal Information Protection Officer's Email: QXtd0328@163.com

We will handle and respond to your complaints properly and promptly within 15 working days after verifying your user identity.

If you are not satisfied with our response, especially if you believe that our handling of personal information has harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit with the court having jurisdiction over the defendant's domicile.

Nine, Scope of Application

This privacy policy applies to all services provided by CoulChoice. However, please note that this privacy policy does not apply to services provided by other companies or individuals, and those services are subject to the privacy policies of the respective companies or individuals.