Kiraify Tech User Privacy Policy

This Policy will help you understand the following:

I. How We Collect Your Personal Information
II. How We Use Your Personal Information
III. How We Use Cookie, Beacon, Proxy and Other Technologies
IV. How We Share, Transfer and Publicly Disclose Your Personal Information
V. How We Protect Your Personal Information
VI. Location and Duration of Information Storage
VII. How You Access and Manage Your Personal Information
VIII. Statement on Third-Party Liability
IX. How We Protect Minors' Information
X. Application and Update of This Policy
XI. Explanation of Key Terms in This Policy
XII. Contact Us

Overview

The operating entity of Kiraify Tech (hereinafter also referred to as "we") is Hangzhou Qixiao Technology Co., Ltd. We are fully aware of the importance of personal information to you and thank you for your trust in us. Through this Policy, we will explain to you how we collect, store, protect, use and externally provide your information, and explain the rights you enjoy, the key points of which are as follows:

1. To make it easy for you to understand the types and purposes of the information we need to collect when you use our services, we will explain them to you one by one in conjunction with specific services.

2. As needed to provide services to you, we will collect your information in accordance with the principles of legality, legitimacy and necessity.

3. If your information needs to be shared with a third party in order to provide services to you, we will assess the legality, legitimacy and necessity of the third party's collection of information. We will require the third party to take protective measures for your information and strictly comply with relevant laws, regulations and regulatory requirements. In addition, we will obtain your consent or confirm that the third party has obtained your consent in the forms of confirming agreements, text confirmation in specific scenarios, pop-up prompts, etc., in accordance with the requirements of laws, regulations and national standards.

4. If your information needs to be obtained from a third party in order to provide services to you, we will require the third party to explain the source of the information and require the third party to guarantee the legality of the information it provides; if the personal information processing activities we need to carry out in conducting our business exceed the scope of authorization when you originally provided your personal information to the third party, we will obtain your explicit consent.

5. You can access and manage your information, set privacy functions, cancel your account or make complaints and reports through the methods described in this Policy.

You can read the corresponding sections according to the following index to further understand the specific provisions of this Policy:
I. How We Collect Your Personal Information
II. How We Use Your Personal Information
III. How We Use Cookie, Beacon, Proxy and Other Technologies
IV. How We Share, Transfer and Publicly Disclose Your Personal Information
V. How We Protect Your Personal Information
VI. Location and Duration of Information Storage
VII. How You Access and Manage Your Personal Information
VIII. Statement on Third-Party Liability
IX. How We Protect Minors' Information
X. Application and Update of This Policy
XI. Explanation of Key Terms in This Policy
XII. Contact Us
When you use our services, we will collect, store, use and externally provide your information in accordance with the Kiraify Tech User Privacy Policy (hereinafter referred to as "this Policy"). At the same time, through this Policy, we will explain to you how we provide you with services to access, update, manage and protect your information. This Policy is closely related to your use of our services. We recommend that you carefully read and understand all the contents of this Policy and make the choices you deem appropriate. We strive to express ourselves in plain and concise language, and we use bold font to mark the clauses in this Policy that have a significant relationship with your rights and interests and your sensitive personal information to draw your attention.
In order to comply with national laws, regulations and regulatory provisions (for example: to conduct real-name management and security management), and also to provide services to you and improve service quality (for example: to support us in designing new services or improving existing service functions, and to provide and recommend better or more suitable services to you), we need to collect, store, use and externally provide your information. You agree that we process your information in accordance with this Policy, so that you can enjoy high-quality, convenient and personalized services, while better protecting your account and personal information security.

I. How We Collect Your Personal Information

(1) In the course of your use of Kiraify Tech services, we will collect the information you actively provide when using the services or that is generated because of your use of the services, in order to provide services to you, improve our service quality, and protect your account security:

1. When you register for Kiraify Tech services, we will collect your mobile phone number, SMS verification code, and password information. This information is collected to help you complete registration and protect the security of your account.
2. When you log in using your account password or SMS verification code, we need to collect your account, password and verification code information. If you do not provide such information, you will not be able to log in to your account through these methods and may not be able to continue using our services. When you use the one-click quick login, QR code scanning login, or quick login functions, we need to collect your mobile phone number information; if you do not provide it, your login through these methods will be affected;

3. When you use Kiraify Tech, in order to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize our service experience and protect your account security, we will collect your behavior logs (account information, user sessions, access times, accessed pages, client IP address information) and terminal information (device model, operating system, device identifier, browser information). Such information is basic information that must be collected to provide the services;
16. In accordance with relevant laws, regulations and national standards, in the following circumstances, we may collect and use your personal information in accordance with the law without obtaining your consent:

(1) Directly related to national security or 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, etc.;

(4) For the protection of the life, property and other major lawful rights and interests of you or others, where it is difficult to obtain your own consent;

(5) The personal information collected is disclosed to the public by yourself;

(6) Personal information collected from lawfully publicly disclosed information, such as legitimate news reports, government information disclosure and other channels;

(7) Necessary for signing and performing a contract as requested by you;

(8) Necessary for maintaining the safe and stable operation of the services provided, such as discovering and handling service failures;

(9) Other circumstances provided by laws and regulations.
(2) Others

If you choose to use other services we provide and we need to collect your information based on such services, we will separately explain to you the scope and purpose of information collection and obtain your consent. We will use, store, externally provide and protect your information in accordance with this Policy and the corresponding user agreement. If you choose not to provide the foregoing information, you may not be able to use a certain service or part of the services, but this does not affect your use of other services we provide.
II. How We Use Your Personal Information

(1) In order to comply with national laws, regulations and regulatory requirements, and to provide services to you and improve service quality, or to protect your account security, we will use your information in the following circumstances:

1. To achieve the purposes described in "How We Collect Your Personal Information" in this Policy;

2. To let you know the status of your use of our services, we will send you functional SMS messages such as login reminders, email arrival reminders, and calendar event reminders. You can turn off/on the relevant settings in account settings and function pages, or contact us through the contact information listed in this Policy for assistance.

3. To improve service experience and recommend better or more suitable services to users, we may conduct indirect crowd profiling based on user characteristic tags, which is used to provide users with marketing activity notifications, commercial electronic information or advertisements they may be interested in. If you do not wish to receive such information, you can choose to unsubscribe according to the methods we prompt.

4. To ensure the stability and security of the services, we will use your information for identity verification, security precautions, fraud monitoring, preventing or prohibiting illegal activities, risk reduction, archiving and backup purposes;

5. To invite you to participate in customer surveys related to our services;

6. To report to relevant departments in accordance with laws, regulations or regulatory requirements;

7. We will use desensitization, de-identification and other methods to conduct comprehensive statistics and analytical processing of your information, so as to provide you with more accurate, personalized, smooth and convenient services, or to help us evaluate, improve or design services and operational activities;

(2) When we want to use the information for other purposes not specified in this Policy, we will obtain your consent again in the forms of confirming agreements, text confirmation actions in specific scenarios, etc., in accordance with the requirements of laws, regulations and national standards.

III. How We Use Cookie, Beacon, Proxy and Other Technologies

To give you a more relaxed access experience, when you visit our website or use the services provided, we may identify your identity through small data files. Doing so can save you the step of repeatedly entering registration information, or help determine your account security status. These data files may be Cookies, Flash Cookies, or other local storage provided by your browser or associated applications (hereinafter collectively referred to as "Cookies"). Please understand that some of our services can only be implemented by using Cookies. If your browser or browser add-on services allow, you can modify the degree of acceptance of Cookies or reject our Cookies.The "Help" section in the toolbar of most browsers will tell you how to prevent your browser from accepting new Cookies, how to have your browser notify you when you receive a new Cookie, or how to disable Cookies altogether. In addition, you can disable or delete similar data used by browser add-ons (such as Flash Cookies) by changing the settings of the browser add-ons or by visiting the provider's web page. However, in some cases, doing so may affect your secure access to our website and use of the services we provide.
Our website may also contain some electronic images (hereinafter referred to as "web Beacons"). Using web Beacons can help the website count users who browse web pages or access certain Cookies. We will collect information about your web page browsing activities through web Beacons,such as the address of the page you visit, the location of the referring page you previously visited, your browsing environment and display settings. If you use services provided by third parties rather than us through our website or APP, in order to do our best to ensure your account security and give you a safer access experience, we may use dedicated network protocols and proxy technology (hereinafter referred to as "Proxy Technology"). Using Proxy Technology can help you identify high-risk sites known to us and reduce the risks of phishing, account leakage, etc. caused thereby. At the same time, it is more conducive to protecting the common rights and interests of you and third parties, and preventing criminals from tampering with the normal service content between you and the third party you wish to access, such as ad injection and illegal content tampering caused by insecure routers, illegal base stations, etc. In this process, we may also obtain and save relevant information about your computer, such as IP address and hardware ID.
IV. How We Share, Transfer and Publicly Disclose Your Personal Information

(1) Sharing

We undertake to keep your information strictly confidential. Except as otherwise provided by laws, regulations and regulatory authorities, we only share your information with third parties in the following circumstances. Third parties include our affiliates and other partners. If your information needs to be shared with a third party in order to provide services to you, we will assess the legality, legitimacy and necessity of the third party's collection of information. We will require the third party to take protective measures for your information and strictly comply with relevant laws, regulations and regulatory requirements. In addition, we will obtain your consent, or confirm that the third party has obtained your consent, in the forms of confirming agreements, text confirmation in specific scenarios, pop-up prompts, etc., in accordance with the requirements of laws, regulations and national standards.

1. Certain products or services may be provided by third parties or jointly provided by us and third parties. Therefore, only by sharing your information can we provide the products or services you need. Solely for the purpose of external processing, we may share your personal information with third-party partners (third-party service providers, contractors, agents, advertising partners, application developers, etc., for example, communication service providers that send emails or push notifications on our behalf, and map service providers that provide us with location services) (who may not be located in your jurisdiction), so that they process the above information for us in accordance with our instructions, privacy policy and other relevant confidentiality and security measures, and use it for the following purposes:

To provide you with our services;

To achieve the purposes described in the section "How We Use Your Personal Information";

To perform our obligations and exercise our rights under the Kiraify Tech Service Agreement or this Policy;

To understand, maintain and improve our services.

If we share your information with the above third parties, we will use encryption, anonymization and other means to protect the security of your information.

2. As our business continues to develop, when transactions such as mergers, acquisitions, and asset transfers result in the sharing of your personal information with third parties, we will inform you of the relevant circumstances through push notifications, announcements and other forms, and continue to protect your personal information in accordance with laws, regulations and standards no lower than those required by this Policy, or require the new administrator to continue to protect your personal information.

3. We will use the collected information for big data analysis.For example, we will use the collected information for analysis to form city heat maps or industry insight reports that do not contain any personal information. We may make public and share with our partners statistically processed information that does not contain identity-identifying content, to understand how users use our services or to let the public understand the overall usage trends of our services.

4. With your prior explicit consent, we will share your information with third parties within the scope of your authorization, to the extent permitted by laws and regulations and not contrary to public order and good customs.

(2) Transfer

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

(1) Obtaining your explicit consent in advance;

(2) According to laws, regulations or mandatory administrative or judicial requirements;

(3) In the case of asset transfer, acquisition, merger, reorganization or bankruptcy liquidation, if personal information transfer is involved, we will inform you of the relevant circumstances and require the new company or organization holding your personal information to continue to be bound by this Policy. If the purpose of using personal information is changed, we will require that company or organization to obtain your explicit consent again.

(3) Public Disclosure

Except for displaying winners' mobile phone numbers in desensitized form when publishing the list of winners of prize activities, in principle we will not publicly disclose your information. If public disclosure is indeed necessary, we will inform you of the purpose of the public disclosure, the type of information to be disclosed and the sensitive information that may be involved, and obtain your explicit consent.

(4) Entrusted Processing

To improve information processing efficiency, reduce information processing costs, or improve information processing accuracy, we may entrust our capable affiliates or other professional institutions to process information on our behalf.We will require the entrusted company to comply with strict confidentiality obligations and take effective confidentiality measures through written agreements, on-site audits and other means, and prohibit it from using such information for purposes not authorized by you. When the entrustment relationship is terminated, the entrusted company no longer retains personal information. We undertake to be responsible for this.

(5) In accordance with relevant laws, regulations and national standards, in the following circumstances, we may share, transfer, and publicly disclose your personal information in accordance with the law without obtaining your consent:

(1) Directly related to national security or 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, etc.;

(4) For the protection of the life, property and other major lawful rights and interests of you or other individuals, where it is difficult to obtain the consent of the person concerned;

(5) Personal information that you disclose to the public by yourself;

(6) Personal information collected from lawfully publicly disclosed information, such as legitimate news reports, government information disclosure and other channels.
V. How We Protect Your Personal Information

We provide corresponding security safeguards for your information to prevent loss, improper use, unauthorized access or disclosure of information.

(1) We strictly comply with laws and regulations to protect the communication secrets of users. We have used security protection measures that meet industry standards to protect the personal information you provide, and to prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information. We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected.

(2) We will use various security protection measures within a reasonable level of security to ensure information security. For example, we use encryption technology (such as TLS, SSL), anonymization and other means to protect your personal information.

(3) We have established dedicated management systems, processes and organizations to ensure information security. For example, we strictly limit the scope of personnel who can access information, require them to comply with confidentiality obligations, and conduct reviews. We will only retain your personal information for the period necessary to achieve the purposes described in this Policy, unless the retention period needs to be extended or is permitted by law. The Internet is not an absolutely secure environment, and instant messaging methods are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use complex passwords to help us keep your account secure.

(4) We have formulated an emergency response plan for personal information security incidents, and regularly organize relevant internal personnel to conduct emergency response training and emergency drills, so that they can master their job responsibilities and emergency handling strategies and procedures. In the unfortunate event of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, remedial measures for you, etc. We will promptly inform you of the relevant circumstances of the incident by email, letter, telephone, push notification, etc. When it is difficult to inform personal information subjects one by one, we will publish announcements in a reasonable and effective manner. At the same time, we will also proactively report the handling of personal information security incidents to the regulatory authorities as required. At the same time, we will also proactively report the handling of personal information security incidents to the regulatory authorities as required.

(5) Please be sure to properly keep your login name and other identity elements. When you use our services, we will identify your identity through your login name and other identity elements. Once you leak the foregoing information, you may suffer losses and may incur legal consequences adverse to you. If you find that your login name and/or other identity elements may or have been leaked, please contact us immediately so that we can take corresponding measures in time to avoid or reduce the relevant losses.
VI. Location and Duration of Information Storage

(1) Location of Information Storage

In compliance with the provisions of laws and regulations, we store users' personal information collected within the territory within the territory. If personal information needs to leave the territory, we will separately obtain your authorized consent.

(2) Duration of Information Storage

Generally speaking, we only retain your personal information for the shortest time necessary to achieve the purposes. However, in the following circumstances, we may change the storage time of personal information due to the need to comply with legal requirements:

1. To comply with applicable laws, regulations and other relevant provisions;

2. To comply with court judgments, rulings or other legal procedures;

3. To comply with the requirements of relevant government agencies or legally authorized organizations;

4. We have reason to be certain that it is necessary to comply with laws, regulations and other relevant provisions;

5. For purposes reasonably necessary to enforce the relevant service agreement or this Policy, safeguard social public interests, and protect the personal and property safety or other lawful rights and interests of our customers, us or our affiliates, other users or employees.

After the account is closed or deleted, we will process your personal information in accordance with the above "Personal Information Subject Cancels Account". When our products or services cease operation, we will promptly stop collecting your personal information, notify you through push notifications, announcements and other forms, and delete or anonymize your personal information within a reasonable period.
VII. How You Access and Manage Your Personal Information

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

(1) Access Your Personal Information

You have the right to access your personal information, except in exceptional circumstances provided by laws and regulations. If you want to exercise your right of data access, you can access it yourself in the following ways:

1. Account information: If you wish to access your account information or change the sender name settings, you can perform such operations through Account Settings -- Account Information;

2. Address book contacts: If you wish to access contact information, you can log in to your account and visit the Address Book page to access the corresponding contact names, email addresses, mobile phone numbers and other information;

If you want to know more ways to access your personal information, you can follow the relevant guidelines in the Help Center. If you cannot access your personal information through the above methods, or you want to know the source of the above personal information, the purposes for which it is used, or the identity or type of third parties that have obtained the above personal information, you can contact us through the contact information listed in this Policy, and we will try our best to fulfill your request.

(2) Correct Your Personal Information

When you find that the personal information about you that we process is incorrect, you have the right to make corrections on your own or request us to make corrections. You can make corrections through the methods listed in "(1) Access Your Personal Information". If you cannot correct your personal information through the above methods, you can contact us through the contact information listed in this Policy, and we will try our best to fulfill your correction request.

(3) Delete Your Personal Information

In the following circumstances, you can make a request to us to delete your personal information:

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

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

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

4. If you no longer use our products or services, or you have cancelled 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 and require them to delete it in a timely manner, unless otherwise provided by laws and regulations, or these entities have obtained your independent authorization.

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

(4) Change the Scope of Your Authorized Consent

You can give or withdraw your authorized consent at any time. Some information is necessary for using Kiraify Tech services, but the provision of most other information is up to you. You can change the scope of your authorization for us to continue collecting information or withdraw your authorization by deleting information, turning off device functions, etc. After you withdraw your authorization, we cannot continue to provide you with the services corresponding to the withdrawn authorization, nor will we process your corresponding information. However, your decision to withdraw your authorization will not affect the information processing previously carried out based on your authorization.

(5) Personal Information Subject Cancels Account

Where the conditions agreed in the Kiraify Tech service agreement and the provisions of relevant national laws and regulations are met, your Kiraify Tech account can be closed or cancelled. After the account is closed or cancelled, we will suspend providing products or services to you; we can also, at your request, promptly delete your personal information or anonymize it, unless otherwise provided by laws and regulations or otherwise agreed by both parties. If you need to close or cancel your Kiraify Tech account, please log in to the web version of Kiraify Tech, find "Settings - Account and Security - Account Security", and close or cancel the account on your own; or contact us through the contact information listed in this Policy, and we will complete the closing or cancellation work for you after confirming your identity and true intention.

(6) Exceptions

For your reasonable requests, in principle we do not charge fees, but for requests that are repeated many times and exceed reasonable limits, we will charge a certain cost fee depending on the circumstances. For requests that are repeated without reason, require excessive technical means (for example, requiring the development of new systems or fundamentally changing current practices), bring risks to the lawful rights and interests of others, or are very impractical (for example, involving information stored on backup tapes), we may refuse them. In the following circumstances, in accordance with the requirements of laws and regulations, we will not be able to respond to your request:

1. Directly related to national security or 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, etc.;

4. For the protection of the life, property and other major lawful rights and interests of the personal information subject or other individuals, where it is difficult to obtain the consent of the person concerned;

5. The personal information collected is disclosed to the public by the personal information subject themselves;

6. Personal information collected from lawfully publicly disclosed information, such as legitimate news reports, government information disclosure and other channels;

7. Necessary for signing and performing a contract as requested by the personal information subject;

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. The personal information controller is a news organization and it is necessary for carrying out legitimate news reporting;

10. The personal information controller is an academic research institution, and it is necessary for carrying out statistics or academic research in the public interest, and when it externally provides the results of academic research or description, the personal information contained in the results is de-identified;

11. Responding to your request will cause serious damage to the lawful rights and interests of you or other individuals or organizations;

12. There is sufficient evidence that you have subjective malice or are abusing your rights;

13. Involving infringement of others' trade secrets or personal privacy;

14. Other circumstances provided by laws and regulations;
VIII. Statement on Third-Party Liability

Please note that our third-party partners (such as third-party service providers, contractors, agents, advertising partners, application developers, etc.) may have their own privacy protection policies. When you view web pages created by third parties or use applications developed by third parties, these third parties may place their own Cookies or web Beacons. These Cookies or web Beacons are not under our control, and their use is not governed by this Policy. We will strive to require these entities to take protective measures for your personal information, but we cannot guarantee that these entities will necessarily take protective measures as we require. Please contact them directly to obtain details about their privacy policies. If you find that web pages created by these third parties or applications developed by third parties pose risks, it is recommended that you terminate the relevant operations to protect your lawful rights and interests.

IX. How We Protect Minors' Information

1. We expect parents or guardians to guide minors in using our services. We will protect the confidentiality and security of minors' information in accordance with the provisions of relevant national laws and regulations.

2. If you are a minor, it is recommended that you ask your parents or guardians to read this Policy, and use our services or provide us with your information on the premise of obtaining the consent of your parents or guardians.For information collected with the consent of parents or guardians, we will only use or publicly disclose such information where permitted by law, explicitly consented to by parents or guardians, or necessary to protect your rights and interests. If your guardian does not agree with your use of our services or provision of information to us in accordance with this Policy, please immediately stop using our services and notify us in time so that we can take corresponding measures.

3. If you are a parent or guardian of a minor, when you have questions about the processing of the information of the minor under your guardianship, please contact us through the contact information in this Policy.

X. Application and Update of This Policy

This Policy applies to the relevant products or services provided by Kiraify Tech, including web, wap, PC client, mobile client and other versions of products and services. Certain products and services have their specific privacy policies. If there is any inconsistency between this Policy and the privacy terms of a specific service, the privacy policy of that specific service shall prevail.

When the following major changes occur, we will update this Policy in due course:

(1) Changes in our basic situation, such as changes in ownership caused by mergers, acquisitions, or reorganizations;

(2) Changes in the scope, purpose, and rules of collecting, storing, and using personal information;

(3) Changes in the objects, scope, and purposes of externally providing personal information;

(4) Changes in the ways you access and manage your personal information;

(5) Changes in data security capabilities and information security risks;

(6) Changes in the channels and mechanisms for user inquiries and complaints, as well as external dispute resolution institutions and contact methods;

(7) Other changes that may have a significant impact on your personal information rights and interests.

Due to our large number of users, if this Policy is updated, we will notify you by APP push notifications, pop-up prompts, sending emails/short messages, or publishing announcements on our official website. In order for you to receive notifications in a timely manner, it is recommended that you notify us promptly when your contact information is updated. The changed policy content will take effect 7 days after the expiration of the publicity period. If you continue to use our services after the update of this Policy takes effect, it means that you have fully read, understood and accepted the updated policy and are willing to be bound by the updated policy.

You can view this Policy on the homepage of our official website. We encourage you to review our privacy policy each time you use it.

XI. Explanation of Key Terms in This Policy

1. "Identity elements" in this Policy refer to the information elements we use to identify you, such as your mobile phone number, account number, password, and SMS verification code.

2. "Sensitive personal information" in this Policy refers to personal information such as mobile phone number, name, bank account number, account address, email communication records, property information, transaction information, precise location information, etc.

XII. Contact Us

If you have any questions, comments or suggestions, or complaints and reports related to the data security of this product, please contact us through the following contact information:

Email: info@kiraify.cn

We will properly and promptly handle the issues you feedback. Under normal circumstances, we will respond within 30 days after verifying your identity.

Last updated: April 5, 2020