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Privacy Policy

Last Updated: December 11, 2024

Published: December 11, 2024

Effective: December 11, 2024

The "Hyperlinks Privacy Policy" (hereinafter referred to as "this policy") only applies to the Hyperlinks products and/or services provided by Shenzhen Guangjiale New Intelligent Technology Co., Ltd. (hereinafter referred to as "we"). Before using this software, please read this policy carefully to understand how we process your personal information. If you are a minor under 14 years old, please read this policy carefully with the accompaniment of your parents or other guardians, fully understand it, and obtain their consent before using the Hyperlinks products and/or services.

Special Reminder:

  • Your consent to this policy only indicates that you have understood the functions provided by Hyperlinks and the necessary personal information required for these functions to operate.
  • For sensitive personal information, we will seek your separate consent through a pop - up window before collection.
  • Corresponding device permissions will not be enabled by default. When it comes to important or sensitive device permissions, we will seek your separate consent through a pop - up window before enabling them when you use the relevant business functions. After the permissions are enabled, you can turn them off at any time on the "My - Settings - System Permission Settings" page or on the device system permission settings page. If you do not agree to enable the permissions corresponding to a certain business function, it will not affect the normal use of other non - related business functions.

This policy will help you understand the following content:

  1. Definitions and Explanations
  2. How We Collect and Use Your Personal Information
  3. How We Share, Transfer, and Publicly Disclose Your Personal Information
  4. How We Protect Your Personal Information
  5. How We Store Your Personal Information
  6. How You Can Exercise Your Rights to Manage Your Personal Information
  7. How We Protect Minors' Personal Information
  8. How Your Personal Information Is Transferred Globally
  9. How We Update This Policy
  10. How to Contact Us
  11. Other Matters

I. Definitions and Explanations

  1. Hyperlinks Products and/or Services: Include the Hyperlinks App (hereinafter referred to as "this software").
  2. Hyperlinks Services: Refer to the services provided by Shenzhen Guangjiale New Intelligent Technology Co., Ltd., the operator of Hyperlinks, to users, hereinafter referred to as "our services".
  3. Shenzhen Guangjiale New Intelligent Technology Co., Ltd.: The operator of Hyperlinks, specializing in intelligent voice and language technology research, software product development, and voice information services. Registered address/common business address: Room 1203, Tower A, Qianhai Excellence Times Square, Xin'an Street, Bao'an District, Shenzhen, Guangdong Province. Contact number: 0755 - 23319820. If you want to know more about our company and platform, you can contact us through the contact information provided in Chapter 11 of this policy.
  4. User: Refers to the user who registers, logs in, and uses this software and enables, browses, or uploads data to the Hyperlinks services. In this policy, you are more often referred to as "you".
  5. Affiliated Company: Refers to any party that directly or indirectly controls us, is controlled by us, or is under the common control with us. Here, "control" and "be controlled" respectively refer to the right to supervise the management policies of a party through voting rights, contracts, or other means.
  6. Account: Refers to the user account you own after completing real - information registration. You are responsible for keeping this user account secure. You shall be legally liable for all actions taken under your account.
  7. Personal Information: Personal information is various information recorded in electronic or other forms related to an identified or identifiable natural person, excluding information that has been anonymized. For the avoidance of doubt, personal information includes but is not limited to sensitive personal information.
  8. Sensitive Personal Information: Sensitive personal information is personal information that, once leaked or illegally used, is likely to infringe on the personal dignity or endanger the personal and property safety of a natural person, including biometric information, religious beliefs, specific identities, medical and health information, financial account information, location tracking information, and the personal information of minors under 14 years old.
  9. Processing of Personal Information: The processing of personal information includes the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.
  10. Personal Information Processor: A personal information processor is an organization or individual that independently determines the purpose and method of processing personal information in personal information processing activities.
  11. Personal Information Subject: A personal information subject refers to the natural person identified or associated with personal information.
  12. Automated Decision - making: Automated decision - making refers to the activity of automatically analyzing and evaluating an individual's behavior patterns, interests and hobbies, or economic, health, and credit status through a computer program and making decisions.
  13. De - identification: De - identification refers to the process of processing personal information so that it cannot be used to identify a specific natural person without additional information.
  14. Anonymization: Anonymization refers to the process of processing personal information so that it cannot be used to identify a specific natural person and cannot be restored.
  15. Device: A device refers to a device that can be used to access the Hyperlinks services, such as a desktop computer, laptop, tablet, or smartphone.
  16. Unique Device Identifier: A unique device identifier (exclusive ID or UUID) refers to a string of characters programmed into a device by the device manufacturer, which can be used to uniquely identify the corresponding device (such as the IMEI number of a mobile device). Unique device identifiers have multiple uses, including providing advertisements when cookies cannot be used.
  17. IP Address: Each device connected to the Internet is assigned a number called an Internet Protocol (IP) address. These numbers are usually assigned based on geographical regions. An IP address can usually be used to identify the location of a device when it is connected to the Internet.
  18. SSL: SSL (Secure Socket Layer), also known as the Secure Sockets Layer, is a security protocol implemented on the Transmission Control Protocol/Internet Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which achieve information confidentiality through the use of public - key and symmetric - key technologies.
  19. Information Collection Technologies: The "automatic collection" described in this policy includes the following methods:
    1. Cookie: A cookie is a small text file that a website server places on the client side (your computer, mobile phone, or other smart terminal) when you browse a web page, which can be used to improve your user experience.
    2. Log Files: Log files store some automatically collected data. This data includes Internet Protocol (IP) addresses, browser types, Internet Service Providers (ISPs), referring/exit pages, operating systems, date/time stamps, and click - stream data.
    3. ET Tag (Entity Tag): An ET Tag is an HTTP header transmitted between an Internet browser and an Internet server, which can be used instead of cookies to track individual users, allowing us to better understand and improve our services.
    4. JavaScript: JavaScript is a programming language used to create more interactive and dynamic web pages. JavaScript can set, read, and delete cookies.

II. How We Collect and Use Your Personal Information

As the personal information processor, we will follow the principles of legality, legitimacy, necessity, and good faith to collect and use your personal information for the following purposes.

  1. According to the "Regulations on the Scope of Necessary Personal Information for Common Types of Mobile Internet Applications", Hyperlinks is an "utility tool" App. The complete functional services of Hyperlinks include account registration/login, connecting a recording pen, recording, and voice - to - text conversion. You only need to provide us with the basic and necessary personal information corresponding to each function, except where otherwise required by relevant laws, regulations, and regulatory documents. If you refuse to provide such information, we will not be able to provide you with the corresponding functional services. Please note that if you provide non - personal information, please ensure that you have obtained the consent of the relevant subject. The details of the complete functions of Hyperlinks and the personal information required for processing are as follows:
    1. Account Registration/Login:
      1. Information Scope
        To ensure the security of your personal space, you need to register and log in to your "Hyperlinks account" before you can normally use other services after registration and login, including network synchronization and voice - to - text services. When registering and logging in, you need to provide us with your mobile phone number or email address and enter a verification code so that we can verify your user identity. Such information is necessary for this function. If you do not provide it, you will not be able to complete registration/login. Your account and password will be encrypted and stored on our server, and only you can use them. We recommend that you keep your password information safe to prevent your account from being stolen by others.
    2. Connecting a Recording Pen:
      1. Necessary and Non - necessary Information Scope
        When you connect a recording pen, we will collect your connection log data and recording pen device information (device SN and MAC address) to pair and connect this software with the recording pen. Such information is necessary for the function service of connecting a recording pen. Please note that when you encounter problems during use and need our intervention to solve them, we will need you to provide the aforementioned information.

        After completing the pairing and connection of the recording pen, we will only conduct real - time data transmission via Bluetooth when you use this software, including transmitting the recording pen device information directly obtained from the recording pen and the voice information recorded by the recording pen. Such information is necessary for the file transfer service. If you refuse to provide this information, you will not be able to use the file transfer service, but it will not affect your ability to connect the recording pen. The rules for the recording pen product to process your personal information apply to the separate privacy policy supporting the recording pen. If there is no separate privacy policy, please refer to this policy for its processing rules.
      2. Scope of Invoked Permissions
        When you first connect a recording pen, we need to invoke your Bluetooth permission, storage permission, and location permission (Android only). The Bluetooth permission is necessary for the connection and communication between the recording pen and the mobile phone. The storage permission is necessary for caching the binding code for the security verification of the recording pen and storing call records and upgrade package files to ensure the normal operation of related functions. The location permission is necessary for starting the ultra - low - power Bluetooth protocol to identify devices in the area and establish a connection when this Bluetooth component is running. All of the above permissions are system permissions necessary for using the device to connect the recording pen to the mobile phone for normal use. If you refuse, you will not be able to use the corresponding functions.
    3. Recording (After Connecting a Recording Pen):
      1. Information Scope
        When you use the recording function service, we will collect your voice information and/or other recording content you provide. Such information is necessary for recording. If you refuse to provide it, you will not be able to use the recording function. After the recording is completed, the audio data will be stored locally on the recording pen. You can import the audio data from the recording pen into this software by connecting the recording pen to this software.
      2. Scope of Invoked Permissions
        When you use the recording storage function service, we need to invoke your storage permission/SD card permission to store your voice information. This is a system permission necessary for this function service. If you refuse, you will not be able to use the recording storage function.
      3. Third - Party SDKs Used
        The recording location marking function is implemented through the Gaode Map Location SDK, which will directly collect and process your location information to mark the recording location during recording. You can prevent it from collecting your location information by refusing the system permission.
    4. Recording to Text Conversion (After Connecting a Recording Pen):
      1. Information Scope
        When you use the recording to text conversion function service, we will collect your voice information and/or other recording content for voice transcription on the cloud server. At the same time, we will collect the transcribed text information so that you can view the text conversion results. Such information is necessary for the voice - to - text function. If you cannot provide it, you will not be able to use the voice - to - text function.
      2. Scope of Invoked Permissions
        The permissions invoked by this function service are the same as those of the recording function service.
    5. Firmware Gray - scale Upgrade:
      1. Information Scope
        In order to allow some users to experience new hardware functions, we will send new - version firmware to some users in a targeted manner. Therefore, we need to obtain your device serial number.
      2. Scope of Invoked Permissions
        After you agree to this privacy policy, we need to obtain your device information permission. This is a system permission necessary for this function service. If you refuse, you will not be able to use the corresponding function.
    6. Problem Troubleshooting and Security Maintenance:
      1. Information Scope
        When you use the Hyperlinks products and/or services, we will receive and record your relevant device information based on the specific permissions during software installation and use, including in silent state/or background operation, for installation conflict detection, problem troubleshooting and location, and to ensure the security of your account and use. The relevant necessary information includes IP address, mobile phone hardware model, mobile phone system information, mobile phone screen information, operating system information, Hyperlinks App installation information, MAC address, software installation list, IMEI, DFV (iOS), CCID (Android), IMSI (Android), sensor information, service provider network ID, access network method, type and status, and unique device identification code (Android ID/IDFA/OPENUDID/GUID). This is necessary information for problem troubleshooting and security maintenance. If you refuse us to collect the above information, we will not be able to perform security monitoring on this software, which may affect the security of your account use and the timely troubleshooting of related problems.
    7. Operational Statistics and Analysis
      1. Information Scope
        When you use the Hyperlinks products and/or services, we will automatically collect the detailed information of your use of the Hyperlinks products and/or services and save it as network log information. The relevant necessary information includes the Hyperlinks App software version number, input box type, input text type, search query content, network status, operator, language used, access date and time, device crashes, system activities, browsing records, download records, and click records. This is to help us统计 (statistically analyze) the usage of the Hyperlinks products and/or services, troubleshoot problems, ensure service stability and network security, and conduct operational analysis, improvement, and optimization of the product interaction experience through data statistics. This is necessary information for operational statistics and analysis. If you refuse us to collect the above information, we will not be able to perform problem troubleshooting and operational statistics for the Hyperlinks App, which may affect your use security and experience.
  2. Personal Information Processing Instructions
    1. To help you better understand the details of how the above - mentioned function services invoke your personal information through permissions, you can refer to the list below for details. Please note that enabling any permission means that you authorize us to collect and use relevant personal information to provide you with the corresponding service. Once you turn off any permission, it means that you revoke the authorization. We will no longer collect and use relevant personal information based on the corresponding permission, and we will not be able to provide you with the service corresponding to that permission. However, your decision to turn off the permission will not affect the information collection and use that has already occurred based on your previous authorization.

      System Permission Corresponding Business Function Purpose of Invoking Permission Permission Request Timing
      Bluetooth Recording Pen Connection Function Used to connect the recording pen and communicate with it When connecting the recording pen
      Storage Permission Recording Pen Connection Function, Recording Used to cache the binding code for the security verification of the recording pen to ensure normal connection to the recording pen, and to store upgrade package files to ensure the normal operation of related functions When connecting the recording pen, when storing recordings
      SD Card Permission Recording Store upgrade package files to ensure the normal operation of related functions; When storing recordings
      Location Permission Recording Pen Connection Function, Recording Start the ultra - low - power Bluetooth protocol to ensure normal connection to the recording pen; provide recording location marking service When connecting the recording pen, when using the recording location marking service
      Notification Permission Recording/Message Push Enable quick access to the recording state through push notifications and push important messages After completing a recording
      Floating Window Permission Subtitle Floating Window Allow users to view transcribed content through the subtitle floating window even when they exit the app When clicking the subtitle floating window button
    2. According to applicable laws and regulations, we will technically process your personal information so that it cannot be used to accurately identify a specific user. We will conduct academic research or statistical analysis on the anonymized or de - identified information (including using anonymized or de - identified voice information for model algorithm training) to better improve product functions and service capabilities.
    3. According to relevant laws and regulations, in the following situations, processing your personal information does not require your consent:
      • It is necessary for concluding or performing a contract to which the individual is a party, or for implementing human resources management in accordance with legally formulated labor rules and regulations and legally concluded collective contracts;
      • It is necessary for performing legal duties or obligations;
      • It is necessary for responding to a sudden public health event or protecting the life, health, and property safety of natural persons in an emergency;
      • It is for the purpose of public interest, such as news reporting and public opinion supervision, and the personal information is processed within a reasonable scope;
      • It is for processing personal information that an individual has publicly disclosed on their own or that has already been legally disclosed, within a reasonable scope as stipulated by this law;
      • Other situations stipulated by laws and administrative regulations.
    4. You can click to view the "Hyperlinks Personal Information Collection List" to quickly understand the basic situation of our collection of your personal information, including the types of information, purposes of use, and usage scenarios.
    5. Other Instructions
      • To ensure that this app can receive client - pushed information normally when it is closed or running in the background, this app must use the (auto - start) function. There will be a certain frequency of actions to wake up this app for auto - start or associated start through system - sent broadcasts. This is necessary for achieving the functions and services.
      • When you open content - type push messages, after obtaining your explicit consent, you will be redirected to open the relevant content. Without your consent, there will be no auto - start or associated start.
      • When you open files downloaded inside this app, a third - party app will be associated and started.

III. How We Share, Transfer, and Publicly Disclose Your Personal Information

  1. Entrusted Processing
    To provide you with more comprehensive and high - quality products and services, we may entrust third parties (including companies, organizations, and individuals) to process some of your personal information. For the third parties we entrust to process your personal information, we will sign strict data processing agreements with them, clearly specifying the purpose, duration, processing method, types of personal information, protection measures, and the rights and obligations of both parties. We will also supervise the personal information processing activities of third parties and require them to process your personal information only in accordance with our requirements, this policy, and other relevant confidentiality and security measures, and not to process personal information beyond the agreed purpose and method. If you refuse our third - party service providers to collect the personal information necessary for providing services, you will not be able to enjoy the services provided by these third parties during your use of the Hyperlinks products and/or services.
  2. Sharing
    We will not share your personal information with third parties (including companies, organizations, and individuals) except in the following situations:
    1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with third parties.
    2. Sharing in legal situations: We will share your personal information with third parties in accordance with the requirements of laws, regulations, litigation disputes, or administrative and judicial authorities.
    3. Sharing with affiliated companies: To integrate with our other products or services and provide you with better services, or to protect the personal and property safety of our affiliated companies, other users, or the public, your information may be shared within our affiliated companies. We will only share your personal information within our affiliated companies for specific, clear, and legal purposes within the scope stated in this policy, and only share the information necessary for providing services. For the information shared with affiliated companies, we will require them to take protection measures no less than those stated in this policy and strictly comply with relevant laws, regulations, and regulatory requirements. If an affiliated company wants to change the purpose of personal information processing, it will need to seek your authorization and consent again.
    4. Sharing with authorized partners: Only for the purposes stated in this policy, some of our services will be provided jointly by us and authorized partners. We will share your personal information with partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and only share the personal information necessary for providing services. Our partners have no right to use the shared personal information for any other purposes.
    For the companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this policy, and other relevant confidentiality and security measures, not to process personal information beyond the agreed purpose and method, and to ensure that their processing activities do not violate the laws, regulations, national standards, and other regulatory documents related to personal information protection and data security in the People's Republic of China. In principle, the companies, organizations, and individuals with whom we share personal information have no right to use the personal information we share for any other purposes outside of this policy.
  3. Transfer
    We will not transfer your personal information to any third parties (including companies, organizations, and individuals) except in the following situations:
    1. Transfer with explicit consent;
    2. Transfer as required by applicable laws, regulations, legal procedures, mandatory administrative or judicial requirements;
    3. In the event of a merger, acquisition, or bankruptcy liquidation of the provider of this product service, or other situations involving merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will notify you of the name or full name and contact information of the recipient and require the new recipient holding your personal information to continue to be bound by this policy. If the recipient changes the original purpose or method of processing, we will require the recipient to seek your authorization and consent again.
  4. Public Disclosure
    We will only publicly disclose your personal information in the following situations:
    1. With your separate consent or based on your active choice, we will publicly disclose your personal information;
    2. In the case of legal requirements, legal procedures, litigation, or mandatory requirements from government authorities, we will publicly disclose your personal information.
    3. If we determine that you have violated laws, regulations, or the relevant agreement rules of this product seriously, or to protect the personal and property safety of users of this product and its affiliated companies or the public, we will disclose your personal information in accordance with laws, regulations, or the relevant agreement rules of this product, including relevant violations and the measures we have taken against you.
  5. Exceptions to Prior Authorization Consent for Entrusted Processing, Sharing, Transfer, and Public Disclosure of Personal Information
    In the following situations, prior authorization consent is not required for entrusted processing, sharing, transfer, and public disclosure of your personal information.
    1. It is related to our performance of obligations stipulated by laws and regulations;
    2. It is directly related to national security and national defense security;
    3. It is directly related to public safety, public health, and major public interests;
    4. It is directly related to criminal investigation, prosecution, trial, and judgment execution;
    5. It is for the purpose of protecting your or other individuals' major legitimate rights and interests such as life and property, but it is difficult to obtain your consent;
    6. You have publicly disclosed your personal information to the public on your own;
    7. It is for collecting personal information from legally publicly disclosed information, such as through legal news reports and government information disclosure channels.
    Please note that according to the law, the external entrusted processing, sharing, transfer, and public disclosure of anonymized personal information do not fall under the scope of personal information processing activities. The storage and processing of such data do not require additional notice to you and your consent.

IV. How We Protect Your Personal Information

  1. We attach great importance to users' privacy and personal information protection and will take reasonable measures to protect users' personal information. Except as otherwise stipulated by laws, regulations, or this policy, we will use various security technologies and procedures to establish a sound management system to protect your personal information from unauthorized access, use, or disclosure. Without your permission, we will not disclose your personal information to third parties. We will use professional encryption storage and transmission methods for relevant information to ensure the security of users' personal information.
  2. You understand and agree that, without disclosing the privacy information of individual users, we have the right to conduct technical analysis on the entire user database. Only the user data that has been analyzed and anonymized will be used commercially.
  3. Data Security Measures
    1. We have adopted industry - standard security protection measures, including establishing reasonable institutional norms and security technologies, to prevent your personal information from being accessed, used, or modified without authorization and to avoid data damage or loss.
    2. We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. 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.
    3. The Internet is not an absolutely secure environment, and email, instant messaging, and communication methods with other users are not encrypted. We strongly recommend that you do not send personal information through these methods. Please use a complex password to help us ensure the security of your account.
    4. The Internet environment is not 100% secure. We will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are breached, resulting in unauthorized access, public disclosure, modification, or destruction of information and damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.
    5. In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the cause of the security incident, the possible harm, the types of personal information involved, the measures we have taken or will take, the suggestions and measures you can take to protect yourself and reduce risks, etc. We will promptly notify you of the incident - related information via email, text message, phone call, or notification. When it is difficult to notify each personal information subject individually, we will issue an announcement in a reasonable and effective manner. At the same time, we will also take the initiative to report the handling situation of the personal information security incident to the regulatory authorities as required. Please note that according to applicable laws and regulations, if measures can be taken to effectively avoid the harm caused by information leakage, modification, or loss, we may not notify you.

V. How We Store Your Personal Information

This product and/or service is only provided to the Chinese mainland region (for the purposes of this policy, excluding the Hong Kong Special Administrative Region, the Macau Special Administrative Region, and Taiwan Region). In principle, the personal information collected and generated within the People's Republic of China will be stored within the People's Republic of China and will not be transferred across borders.

  1. Location of Information Storage
    In accordance with the provisions of laws and regulations, the information and data collected about you will be stored on our servers in the Chinese mainland region within the People's Republic of China. The following situations are exceptions:
    • There are clear provisions in laws and regulations;
    • We have obtained your explicit authorization;
    • You take active actions such as cross - border transactions via the Internet.
  2. Duration of Information Storage
    Generally speaking, we will retain your personal information for the period necessary to achieve the processing purposes described in this policy during your use of the Hyperlinks products and/or services, unless otherwise stipulated by applicable laws, regulations, or national regulatory documents. Specific reference regulations include:
    1. Article 21, Chapter 3 of the "Cybersecurity Law" stipulates that technical measures shall be taken to monitor and record the network operation status and network security incidents, and the relevant network logs shall be retained for no less than six months as required.
    2. Article 31, Chapter 2 of the "E - Commerce Law" stipulates that commodity and service information and transaction information shall be kept for no less than three years from the date of completion of the transaction; if laws and administrative regulations provide otherwise, such provisions shall prevail.
    After the above - mentioned period expires, or when you actively request to delete your personal information or cancel your account, we will delete your personal information as soon as possible in accordance with the requirements of applicable laws and regulations, unless applicable laws, regulations, or national regulatory documents require the information to be retained for a longer period. However, in the following situations, we will change the storage time of personal information to comply with legal requirements:
    • To comply with applicable laws, regulations, and other relevant provisions;
    • To comply with court judgments, rulings, or other legal procedures;
    • To comply with the requirements of relevant government agencies or legally authorized organizations;
    • We have reasonable grounds to believe that it is necessary to comply with laws, regulations, and other relevant provisions;
    • For purposes reasonably necessary to enforce relevant service agreements or this policy, safeguard the public interest, and protect the personal and property safety or other legitimate rights and interests of our customers, us, other users, or employees.

After you discontinue using Hyperlinks, we will stop collecting and using your information, except as otherwise provided by laws, regulations, or regulatory authorities.

When the relevant services of Hyperlinks cease operation, we will notify you by means including sending notices and announcements, and delete your personal information retained on the server within the time limit required by laws and regulations.

VI. How You Can Exercise Your Rights to Manage Your Personal Information

  1. According to relevant Chinese laws, regulations, and standards, you have several rights in personal information processing activities, including:
    • You have the right to know and decide regarding personal information processing, and you have the right to restrict or refuse others from processing your personal information, except as otherwise provided by laws and administrative regulations;
    • You have the right to request the transfer of your personal information to a personal information processor you designate;
    • If you find that your personal information is inaccurate or incomplete, you have the right to request the personal information processor to correct or supplement it;
    • You have the right to request the deletion of your personal information;
    • You have the right to require the personal information processor to explain its personal information processing rules.
  2. We ensure that you can exercise the aforementioned rights over your personal information and provide you with relevant operation paths. Specifically, you can refer to the following steps for related operations:
    1. View, correct, and supplement your personal information:
      • Click "Settings" in the bottom navigation bar.
      • Click on your account name.
      • Click on the data you need to edit.
    2. Obtain a copy of your personal information
      You have the right to obtain a copy of your personal information. You can contact our customer service in the manner described in Chapter XI of this policy, and we will process your request within 15 business days.
    3. Transfer your personal information
      You have the right to request the transfer of your personal information to a personal information processor you designate. If the conditions specified by the national cyberspace administration are met, we will provide you with a transfer channel. You can contact our customer service in the manner described in Chapter XI of this policy, and we will process your request within 15 business days.
    4. Change the scope of your authorized consent or withdraw authorization
      You can withdraw your authorization by changing the privacy settings in this software. Specifically, you can operate as follows: Android users:
      • Go to "Settings" - "App Management" on your phone.
      • Find Hyperlinks and click to enter.
      • Click "Permissions" to enter the permissions page of Hyperlinks, where you can set all invoked permissions.
      iOS users:
      • Go to "Settings" on your phone.
      • Find Hyperlinks and click to enter, where you can set all invoked permissions.
      Please note that the specific closing methods may vary depending on the device model and system version you use.

      Please understand that after you perform the above operations, we will no longer be able to provide you with the services corresponding to the withdrawn consent or authorization, but it will not affect the personal information processing that has already been carried out based on your previous authorization.
    5. Cancel your account
      You have the right to cancel your Hyperlinks account. You can contact our customer service in the manner described in Chapter XI of this policy to assist you in canceling your account. After receiving your request, we will need you to provide your account (mobile phone number) and SMS verification code to verify your identity. After successful verification, we will complete the cancellation for you within 15 business days. To ensure security, we need you to provide corresponding means to prove your identity and the legitimacy of your request. After your successful cancellation, we will delete your personal information as soon as possible in accordance with the requirements of laws and regulations.

      You can also cancel your account by following these steps:
      • Click "Settings" in the bottom navigation bar.
      • Click on your account name.
      • Click the "More" button in the upper - right corner.
      • Click the "Cancel Account" button in the "More" menu.
      Please note that to ensure the security of customer service and online/offline activities and traceability of responsibilities, according to the time requirements of the activities you participate in (including but not limited to theme activities and points - for - gifts activities) (for example, the same user cannot participate in an activity repeatedly within half a year), we will continue to retain the personal information you provided in customer service and activity participation for half a year or for the time period specified by the relevant activities you participated in. After reaching the aforementioned time limit, we will delete this information.
    6. Turn off message notifications
      You have the right to turn off message notifications in this product. Specifically, you can refer to the following steps for related operations:
      • Go to "Settings" - "Notifications" on your phone.
      • Find Hyperlinks and click to enter. You can choose to turn off or turn on notifications on this interface.
    7. Respond to your above requests
      We will adopt appropriate technical measures to ensure that you can view, supplement, correct, delete, or copy and transfer your personal data, or apply to us to supplement, correct, delete, copy, or transfer relevant information through the feedback or complaint channels published by the Hyperlinks products and/or services. After receiving your application, we will process it according to the procedure. To ensure security, we will first ask you to verify your identity. We need you to provide your account (mobile phone number) and SMS verification code. After successful verification, we will process your request. We will respond within 15 business days. In principle, we will not charge a fee for your reasonable requests, but for multiple repeated requests beyond a reasonable limit, we will charge a certain cost fee as appropriate. We will reject requests that are unreasonably repetitive, require excessive technical means (for example, developing a new system or fundamentally changing the current practice), pose risks to the legitimate rights and interests of others, or are highly impractical (for example, involving information stored on backup tapes).

      If you are unable to view, supplement, correct, delete, copy, transfer your personal information, change the scope of your authorized consent or withdraw authorization, cancel your account, turn off message notifications, or if you need to view, supplement, correct, delete, copy, transfer other personal information generated during your use of Hyperlinks, or if you believe that we have violated any laws, regulations, or agreements regarding the collection or use of your personal information, you can contact us through the official feedback channels of the relevant products or services we have announced.

Please note that in the following situations, we will not be able to respond to your requests:

  1. Related to our fulfillment of obligations stipulated by laws and regulations;
  2. Directly related to national security and national defense security;
  3. Directly related to public safety, public health, and major public interests;
  4. Directly related to criminal investigation, prosecution, trial, and judgment execution;
  5. We have sufficient evidence to show that you have subjective malice or abuse your rights;
  6. To protect your or other individuals' major legitimate rights and interests such as life and property, but it is difficult to obtain your consent;
  7. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
  8. Involving trade secrets.

VII. How We Protect Minors' Personal Information

  1. We attach great importance to the protection of minors' personal information and will protect minors' personal information in accordance with relevant national laws and regulations.
  2. We consider anyone under 18 years old to be a minor. According to relevant laws and regulations, if you are a minor aged 14 or above, we will obtain your or your guardian's consent before collecting your personal information. When you, your parents, or other guardians request us to correct or delete a minor's personal information, we will take timely measures to correct or delete it, except as otherwise provided by laws and administrative regulations.
  3. If you are a minor under 14 years old (hereinafter referred to as a child), we will obtain the consent of your parents or other guardians before collecting your personal information.
  4. When processing children's personal information, we will take the following measures for protection: In addition to complying with the agreements in this policy regarding users' personal information, we will also uphold the principles of just necessity, informed consent, clear purpose, security assurance, and legal utilization. We will strictly follow the requirements of laws and regulations such as the "Regulations on the Protection of Children's Personal Information Online" for storage, use, and disclosure. We will not retain children's personal information for longer than necessary to achieve the purposes of collection and use. After the expiration date, we will delete the children's personal information.
  5. If you are the parent or guardian of a minor and have any questions, opinions, suggestions, or needs for complaints or reports regarding the matters described in this policy, please provide feedback to us in the manner described in Chapter XI.

VIII. How Your Personal Information Is Transferred Globally

In principle, the personal information collected and generated within the People's Republic of China will be stored within the People's Republic of China and will not be transferred across borders. If it is indeed necessary to provide your personal information overseas due to business needs, etc., we will inform you of the name or full name, contact information, processing purpose, processing method, types of personal information of the overseas recipient, and the ways and procedures for you to exercise your rights stipulated by this law against the overseas recipient. After obtaining your separate consent and meeting the conditions required for cross - border provision stipulated by laws and regulations, we will transfer your personal information to overseas jurisdictions outside the country/region where you use the product and/or service, or allow your personal information to be accessed from these jurisdictions.

Please note that such jurisdictions may have different personal information protection - related laws and regulations. We will comply with the requirements of relevant laws and regulations in the jurisdiction to ensure that your personal information is fully protected. If there are no personal information protection - related laws and regulations in such jurisdictions, we will try our best to ensure that your personal information receives sufficient and equivalent protection as in the People's Republic of China.

IX. How We Update This Policy

  1. To provide you with better services, the Hyperlinks products and/or services will be updated and changed from time to time. We will revise this policy accordingly, and these revisions will form part of this policy. However, without your explicit consent, we will not reduce the rights you should enjoy under this policy.
  2. After this policy is updated, we will release the updated version on Hyperlinks and remind you again to read the updated privacy policy through announcements of new version features in the app store or pop - up windows so that you can keep abreast of the latest version of this policy. If you disagree with this policy or have objections to the modified or updated content of this policy, you can choose to stop using the Hyperlinks products and/or services or cancel your Hyperlinks account. However, please note that your actions and activities before account cancellation or service discontinuation will still be governed by this policy.
  3. For major changes, we will also provide more prominent notifications (we will explain the specific changed parts of this policy through methods including but not limited to emails, text messages, or special prompts on the browsing page).

    Major changes referred to in this policy include but are not limited to:
    1. Significant changes occur in our service model. Such as the purpose of personal information processing, the types of personal information processed, and the way personal information is used;
    2. Significant changes occur in our ownership structure, organizational structure, etc. Such as changes caused by business adjustments, bankruptcy mergers and acquisitions, etc.;
    3. The main objects of personal information sharing, transfer, or public disclosure change;
    4. Significant changes occur in your rights and the ways to exercise them in personal information processing;
    5. The department responsible for personal information security, contact information, and complaint channels change;
    6. The personal information security impact assessment report indicates high risks;
    7. Changes are made in response to national policies or legal norms with the release and implementation of policies or laws.

X. How to Contact Us

To better protect your personal information, we have established a dedicated department for network security and personal information protection. If you have any questions or suggestions regarding this policy or your personal information during your use of Hyperlinks, please contact us through the following contact information:

Contact Phone: 0755 - 23319820

Contact Email (Person in Charge of Personal Information Protection): felix@huobailing.com

Contact Address: Room 1203, Tower A, Qianhai Excellence Times Square, Xin'an Street, Bao'an District, Shenzhen, Guangdong Province

If you are not satisfied with our response, especially if you believe that our personal information processing behavior has damaged your legitimate rights and interests, and we cannot provide you with a satisfactory response and refuse to improve after you have provided feedback to us, you can file a complaint and report to the relevant regulatory authorities.

XI. Other Matters

Any disputes related to this policy shall be resolved through friendly negotiation between the two parties. If negotiation fails, you agree to submit the dispute or controversy to the people's court with jurisdiction at the place where this privacy agreement is signed.

If any court with jurisdiction rules or judges that any provision of this policy is invalid, that provision will be removed from this policy, but the invalidity of that provision will not affect the validity of the remaining provisions of this policy. The remaining provisions of this policy will continue to be enforced.

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