Privacy Policy

1. Introduction

Anhui Xunliyun Network Technology Co., Ltd ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile applications, website, and related services (collectively, the "Services").

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Services.

2. Information We Collect

2.1 Information You Provide Directly

We may collect information you provide directly to us, including:

• Name, email address, and contact information when you create an account
• Profile information and preferences
• Communications and messages you send to us
• Feedback and survey responses
• Payment information for premium services

2.2 Information Collected Automatically

When you use our Services, we may automatically collect certain information, including:

• Device information (device type, operating system, unique device identifiers)
• Usage data (features accessed, time spent, click patterns)
• Location data (general geographic location based on IP address)
• Log data (access times, error logs, referring URLs)
• Cookies and similar tracking technologies

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Analytics providers
• Advertising partners
• Social media platforms (if you choose to link your account)
• Business partners and service providers

3. How We Use Your Information

We use the information we collect for various purposes, including:

• Providing, maintaining, and improving our Services
• Processing transactions and sending related information
• Sending technical notices, updates, and support messages
• Responding to your comments, questions, and customer service requests
• Communicating about products, services, and events
• Monitoring and analyzing trends, usage, and activities
• Detecting, investigating, and preventing fraudulent or unauthorized activities
• Personalizing and improving your experience
• Delivering targeted advertising and measuring ad effectiveness

4. Advertising and Third-Party Analytics

4.1 Advertising Platforms

We work with various advertising platforms to display ads within our mobile applications. These platforms may collect information about your device and your use of our Services to provide personalized and non-personalized advertisements. The advertising platforms we use include:

4.2 Types of Ads We Display

Our mobile applications may display the following types of advertisements:

• Splash Ads: Full-screen advertisements displayed when the application launches or during transitions
• Rewarded Video Ads: Video advertisements that users can watch voluntarily in exchange for in-app rewards or benefits
• Interstitial Ads: Full-screen advertisements displayed at natural transition points in the application flow
• Banner Ads: Rectangular display advertisements displayed at the top or bottom of the screen
• Native Ads: Advertisements designed to match the visual style and format of the application content

4.3 Analytics Services

We use third-party analytics services to understand how users interact with our Services. These services may include:

• Google Analytics
• Firebase Analytics
• Adjust
• AppsFlyer
• Mixpanel
• Amplitude

These analytics services may collect information about your device, your usage patterns, and your interactions with our applications and advertisements.

5. Data Sharing and Disclosure

We may share your information in the following circumstances:

• With Service Providers: We share information with third-party vendors, consultants, and service providers who perform services for us
• For Legal Compliance: We may disclose information if required by law, court order, or governmental regulation
• To Protect Rights: We may disclose information to protect our rights, privacy, safety, or property, or that of our users
• Business Transfers: In connection with a merger, acquisition, or sale of assets, user information may be transferred
• With Your Consent: We may share information with third parties when you provide us with your consent to do so
• Aggregate Information: We may share aggregated or anonymized information that cannot reasonably identify you

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

We regularly review and update our security measures to ensure the protection of your data. In the event of a data breach that may affect your personal information, we will notify you in accordance with applicable laws and regulations.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. When we transfer your information to other countries, we will take appropriate safeguards to ensure that your information is protected in accordance with this Privacy Policy and applicable laws.

8. Your Rights and Choices

8.1 Access and Correction

You may have the right to access, correct, or delete your personal information. To exercise these rights, please contact us using the information provided in the "Contact Us" section.

8.2 Opt-Out of Marketing Communications

You can opt out of receiving promotional communications from us by following the unsubscribe instructions in those messages or by contacting us directly.

8.3 Device Permissions

Most device permissions can be managed through your device settings. You may be able to control permissions for:

• Location services
• Push notifications
• Camera and photo access
• Microphone access
• Storage access

8.4 Analytics and Advertising Opt-Out

You may opt out of certain analytics and advertising tracking by:

• Using the opt-out options provided by advertising platforms
• Adjusting your device's advertising identifier settings
• Using privacy-focused browser settings or extensions

9. Application Market Compliance

9.1 Google Play Store Compliance

Our applications published on Google Play comply with Google's Developer Program Policies, including:

• Play Console Data Safety requirements
• Family Link requirements for child-directed apps
• AdMob and Google Play services policies
• Privacy and Security requirements
• User-generated content policies
• Permissions requirements and data use limitations

9.2 Apple App Store Compliance

Our applications published on the Apple App Store comply with Apple's App Store Review Guidelines, including:

• App Privacy nutrition labels requirements
• Tracking transparency requirements (App Tracking Transparency framework)
• Children's privacy requirements (including COPPA compliance)
• Data storage and encryption requirements
• User interface and user experience guidelines
• Advertising and monetization policies

9.3 Age Restrictions and Verification

Our Services are not directed to children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under these ages without appropriate parental consent.

For applications designed for or likely to be used by children, we implement additional protections in compliance with:

• Children's Online Privacy Protection Act (COPPA)
• EU General Data Protection Regulation (GDPR) - Article 8
• California Consumer Privacy Act (CCPA) - Age-verified provisions
• UK Age Appropriate Design Code
• Other applicable child protection laws

10. Regional Privacy Laws Compliance

10.1 European Union - General Data Protection Regulation (GDPR)

If you are located in the European Economic Area (EEA), the following GDPR provisions apply:

• Lawful Basis for Processing: We process your data based on legitimate interest, contractual necessity, or your consent
• Data Subject Rights: You have rights to access, rectification, erasure, restriction, portability, and objection
• Data Protection Officer: You may contact our Data Protection Officer for GDPR-related inquiries
• Data Breach Notification: We will notify supervisory authorities and affected users within 72 hours of a breach
• Legal Representatives: We maintain appropriate representation within the EU as required

10.2 California - California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)

If you are a California resident, you have the following rights under CCPA/CPRA:

• Right to Know: Request disclosure of personal information collected, used, disclosed, or sold
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt out of the sale or sharing of personal information
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit Use: Limit the use of sensitive personal information
• Non-Discrimination: Equal service and pricing regardless of exercising your rights

We do not sell personal information in the traditional sense. However, sharing data with advertising partners for targeted advertising purposes may constitute "sharing" under CCPA/CPRA.

10.3 Brazil - Lei Geral de Proteção de Dados (LGPD)

If you are located in Brazil, the LGPD applies to our processing of your personal data:

• Legal basis for processing as required by LGPD Article 7
• Rights of data subjects including access, correction, deletion, and portability
• Data protection impact assessments when required
• Notification of data breaches to the national authority and affected individuals
• Designation of a data protection officer when required

10.4 South Africa - Protection of Personal Information Act (POPIA)

If you are located in South Africa, POPIA governs our processing of your personal information:

• Processing conditions including consent, legitimate purpose, and proportionality
• Rights of data subjects including access, correction, and deletion
• Information officer registration and compliance
• Cross-border transfer restrictions
• Breach notification requirements

10.5 Thailand - Personal Data Protection Act (PDPA)

If you are located in Thailand, the PDPA applies to our processing of your personal data:

• Legal basis for processing as required by PDPA Section 24
• Rights of data subjects including consent, access, correction, and deletion
• Data breach notification requirements
• Cross-border transfer restrictions
• Appointment of a data protection officer when required

10.6 Australia - Privacy Act 1988 and Australian Privacy Principles

If you are located in Australia, the Privacy Act 1988 and Australian Privacy Principles (APPs) apply:

• Open and transparent management of personal information
• Anonymity and pseudonymity options where practicable
• Collection of solicited personal information
• Notification of the collection of personal information
• Use and disclosure of personal information
• Cross-border disclosure of personal information
• Adoption, use, and disclosure of government-related identifiers
• Quality of personal information
• Security of personal information
• Access and correction of personal information

10.7 China - Personal Information Protection Law (PIPL)

If you are located in China, PIPL applies to our processing of personal information:

• Legal basis for processing including consent and legitimate interests
• Rules for sensitive personal information processing
• Personal information subject rights including access, correction, deletion, and portability
• Personal information protection impact assessments
• Cross-border transfer rules and security assessments
• Data localization requirements where applicable
• obligations of personal information processors

10.8 Other Jurisdictions

We are committed to complying with applicable privacy laws in all jurisdictions where we operate. If you are located in a jurisdiction not specifically mentioned above, this Privacy Policy still applies to our collection and use of your information.

11. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you
• Whether there is a legal obligation to which we are subject
• Whether retention is advisable in light of our legal position
• Applicable industry standards and practices

12. Cookies and Similar Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities and to enhance your experience. You can control cookies through your browser settings. However, disabling cookies may affect the functionality of our Services.

Types of Cookies We Use:

• Essential Cookies: Required for basic functionality
• Analytics Cookies: Help us understand how visitors interact with our Services
• Advertising Cookies: Used to deliver relevant advertisements
• Preference Cookies: Remember your settings and preferences

13. Third-Party Services and Links

Our Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We may also provide additional notice through in-app notifications or email.

Your continued use of our Services after any modification indicates your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically for the latest information on our privacy practices.

15. Consent Management

15.1 Obtaining Consent

Where required by applicable law, we will obtain your consent before collecting, using, or sharing your personal information. Consent may be obtained through:

• Clear affirmative action (opt-in)
• Acceptance of terms and conditions
• In-app consent prompts and forms
• Device permission requests

15.2 Managing Your Consent

You may withdraw your consent at any time by:

• Adjusting your privacy settings within our applications
• Contacting us directly
• Uninstalling our applications
• Adjusting your device permissions

Withdrawal of consent may affect your ability to use certain features of our Services.

15.3 Consent for Children

For applications that may be used by children, we implement age gates and obtain appropriate parental consent as required by applicable laws, including COPPA, GDPR Article 8, and other child protection regulations.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Anhui Xunliyun Network Technology Co., Ltd

Address:
Shop 102, Building 16, Rongke City Phase I
Furong Community, Economic and Technological Development Zone
Hefei, 230000
China

Business Support:
Email: support@xunliyuntech.com

Enterprise Clients:
Email: zhangbao@xunliyuntech.com

Website:
https://xunliyuntech.com

17. Special Provisions for Mobile Applications

17.1 Advertising ID

Our mobile applications may access and use your device's advertising identifier (IDFA on iOS, GAID on Android) for advertising and analytics purposes. You can reset your advertising identifier or opt out of interest-based advertising through your device settings.

17.2 In-App Purchases

Our applications may offer in-app purchases. All transactions are processed through the respective app store (Google Play or Apple App Store) and are subject to their respective terms and privacy policies.

17.3 Offline Functionality

Some features may require an internet connection. We may collect usage data when you use these features to improve our Services.

17.4 Background Processes

Our applications may run background processes for purposes including push notifications, ad serving, and analytics. You can manage background app refresh settings through your device.

18. Disclaimer

This Privacy Policy is provided for informational purposes and does not constitute legal advice. The applicable privacy laws and regulations in your jurisdiction may provide you with additional or different rights. We recommend consulting with a legal professional regarding your specific situation.