Privacy Policy (for SaaS Version)

Privacy Policy

Effective date: October 29, 2021

Important notice

Hangzhou Lingyang Intelligent Service Co., Ltd. (hereinafter referred to as "we" or "Lingyang", registered at Building 3, 969 West Wenyi Road, Wuchang Street, Yuhang District, Hangzhou), highly values the protection of personal information. When you use the services provided by Lingyang (hereinafter "Lingyang Services"), we collect and use your personal information and that of your end users (the "end users of your products") in accordance with this Privacy Policy. This Privacy Policy explains how we handle your personal information and that of your end users. We recommend that you read this Privacy Policy in its entirety to understand how to protect your privacy rights.

This Privacy Policy applies to the software development kit (SDK) service provided by the Lingyang Quick Tracking product.

Before using Lingyang products or services, you must read and fully understand this Privacy Policy. Pay close attention to the terms marked in bold and underlined text. You can use the related products or services only after you fully understand and agree to this policy. If you have any questions about this Privacy Policy, you can contact us using the contact information provided in this policy. If you do not agree with the content of this Privacy Policy, you must stop using Lingyang services.

This Privacy Policy will help you understand the following:

I. How we collect and use your personal information and that of your end users

II. How we use cookies and web beacons

III. How we share, transfer, and publicly disclose your personal information and that of your end users

IV. How we protect your personal information and that of your end users

V. How to manage your personal information and that of your end users

VI. How we handle minors' information

VII. Scope of the SDK service and global statement

VIII. How this Privacy Policy is updated

IX. How to contact us

I. How we collect and use your personal information and that of your end users

We collect information to provide and improve the services you choose. We collect information in the following ways:

1. Information you provide to us

When you activate and use Lingyang services, you may provide information by filling in or submitting forms. This information includes your phone number, email address, enterprise information, product information, promotion channels, and application name.

When you verify your identity as an enterprise account, we may also request your business license, Unified Social Credit Code, enterprise name, business term, region, detailed address, and Alipay information for enterprise verification.

We collect this information to provide you with better services and will use your information for the following purposes:

(1) To provide, maintain, and improve Lingyang services.

(2) We may use your personal information to prevent, detect, and investigate fraud, infringement, security risks, or illegal activities. We may also use it to investigate violations of agreements, policies, or rules with us or our affiliates. This protects the legitimate rights and interests of you, other users, us, and our affiliates.

(3) To contact you to resolve issues.

(4) For other purposes with your permission.

2. Information we collect when you use the service

(1) SDK service provided by the Lingyang Quick Tracking product

Personal information collected:

SDK type	Personal information fields	Purpose	Data protection method
Quick Tracking SDK	OAID, GAID, MAC address, IMEI, Android ID, IDFA, IDFV, OPENUDID, GUID, SIM card International Mobile Subscriber Identity (IMSI) information, hardware serial number, Mobile Country Code (MCC), and Mobile Network Code (MNC)	To uniquely identify devices for data statistics, such as counting new devices.	1. Security is ensured using SSL protocol encryption and HTTPS encryption in transit. 2. Data is desensitized using security measures such as encryption and de-identification.

Permissions used:

Permission name	Product involved	Feature description
ACCESS_NETWORK_STATE	Quick Tracking	Detects the network connection method to avoid sending data during network anomalies, saving traffic and power.
READ_PHONE_STATE	Quick Tracking	Obtains the device's IMEI and hardware serial number to uniquely identify the user and provide statistical analysis services.
ACCESS_WIFI_STATE	Quick Tracking	Obtains the Wi-Fi MAC address. On tablets or TV boxes where a device cannot be identified by IMEI, we use the Wi-Fi MAC address as the unique identifier to provide statistical analysis services.
INTERNET	Quick Tracking	Allows the application to connect to the internet and send statistical data to provide statistical analysis services.

Other non-personal information

In addition to the personal information listed above, the SDK service collects the following non-personal information for different service dimensions: SDK/API/JS code version, browser, Internet Service Provider, platform, timestamp, application version, application distribution channel, device model, sensor parameters, device manufacturer, device operating system version, language and location, time zone and network status (such as Wi-Fi), and usage of the hard disk, CPU, and battery.

(2) Other information

In addition to the information listed above, we may also collect other information from you that is reasonably necessary to provide and improve our services. This includes information you provide when you contact us, your responses to our questionnaires, and information we collect during your interactions with our affiliates and partners. To improve the security of your use of Lingyang services and more accurately prevent phishing websites and trojan viruses, we may assess your account's risk by understanding some of your web usage habits and commonly used software. We may also record some URLs that we consider risky. Note that device information and service log information alone cannot identify a specific natural person. If we combine this type of non-personal information with other information to identify a specific natural person, or use it in combination with personal information, this non-personal information is treated as personal information during the combined use. We will anonymize and de-identify this information, unless we have your authorization or it is otherwise required by law.

3. How we use the information we collect

To comply with national laws, regulations, and regulatory policies, and to provide services to developers and end users, we use personal information in the following situations:

(1) To fulfill the purposes and uses described in "I. How we collect and use your personal information and that of your end users" of this Privacy Policy.

(2) To ensure and improve the security and stability of products and services provided by us and our affiliates. We use your information to protect the legitimate rights and interests of you, us, our affiliates, and the public from harm. This includes preventing, detecting, and investigating security risks, such as phishing websites, fraud, infringement, network vulnerabilities, computer viruses, network attacks, and network intrusions. We also use it to identify violations of laws, regulations, or our agreements and rules. For these purposes, we may use or integrate your device information, location information, service logs, and other information shared by our affiliates with your authorization or as permitted by law. We also take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

(3) If we intend to use personal information for other purposes not specified in this Privacy Policy, we will notify you in advance. We will also require you to notify your end users and obtain their consent.

4. How to use the Lingyang SDK service in compliance with regulations

To ensure that your app is legally compliant when using the Lingyang SDK service, you must complete the following three steps:

1. Ensure that you upgrade the Lingyang SDK to the latest version that meets new regulatory requirements.

2. Inform users in your Privacy Policy that you use the Lingyang SDK. You can use the following reference text:

SDK name: Lingyang Quick Tracking SDK

Service type: SDK service

Type of personal information collected: OAID, GAID, MAC address, IMEI, Android ID, IDFA, IDFV, OPENUDID, GUID, SIM card IMSI information, hardware serial number, MCC, and MNC

Privacy Policy link: https://www.lydaas.com/wow/z/lydaas/default/personal-information-protection?spm=a1z24v7z.27090185.6248881200.26.5eb356d2ruUlgW

3. Configure delayed initialization to ensure that the Lingyang SDK is initialized only after the user agrees to your Privacy Policy.

You must use the Lingyang SDK service in compliance with the instructions above. You are solely responsible for any risks that arise from non-compliant use and for any losses that Lingyang incurs as a result.

II. How we use cookies and web beacons

To provide you with a more convenient access experience, we may use small data files to identify you when you visit the Lingyang platform or use Lingyang services. This practice saves you from re-entering registration information and helps determine the security of your account. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively, "cookies").

Please understand that some of our services can only be implemented using cookies. If your browser or browser add-on service allows, you can open your browser's settings, select privacy settings, and check "Do Not Track" or disable cookies. This will prevent your data from being tracked by us. Web pages often contain electronic images known as "single-pixel GIF files" or "web beacons". We use web beacons to collect information about your web browsing activities, such as the address of the page you visit, the address of the referring page you previously visited, the time you spend on the page, your browsing environment, and your display settings.

III. How we share, transfer, and publicly disclose your personal information and that of your end users

1. Sharing

We are obligated to keep your information confidential. We will not sell or rent your information or your end users' information to third parties for their marketing or illegal purposes. We will not share your end users' personal information with any third party, except in the following cases:

(1) We have obtained prior consent or authorization from the personal information subject.

(2) It is required by law, regulation, or an administrative or judicial authority.

(3) If your end user is a qualified intellectual property complainant and has filed a complaint, we may disclose information to the respondent at the respondent's request to handle possible rights disputes.

(4) Sharing your end user's information is necessary to provide the service or handle disputes between your end user and other parties.

(5) In compliance with laws and regulations, we may share your personal information and that of your end users with our affiliates. This sharing is limited to the purposes stated in this Privacy Policy.

2. Transfer

We will not transfer your end users' personal information to any third party, except in the following cases:

(1) We have obtained the explicit consent of your end user.

(2) In the event of a merger, acquisition, or bankruptcy liquidation that involves the transfer of personal information, we will require the new company or organization that holds your end users' personal information to continue to be bound by this Privacy Policy. Otherwise, we will require that company or organization to obtain authorization and consent from your end users again.

3. Public disclosure

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

(1) We have obtained your or your end user's explicit consent.

(2) Disclosure based on law: We may publicly disclose your personal information or that of your end users if required by law, legal proceedings, litigation, or mandatory government requests.

(3) In an emergency, if we reasonably determine that it is necessary to protect the important legitimate rights and interests of us, our customers, end users, or others.

IV. How we protect your personal information and that of your end users

To ensure the security of your information and that of your end users, we use reasonable physical, electronic, and administrative security measures that meet industry standards to protect your information. We make every reasonable effort to prevent your information and that of your end users from being leaked, damaged, or lost. Data exchanged between your browser and our servers is protected by SSL protocol encryption. We provide secure browsing for our website using the HTTPS protocol. We use encryption technology to enhance the security of personal information. We use trusted protection mechanisms to prevent malicious attacks on personal information. We deploy access control mechanisms to ensure that only authorized personnel can access personal information. We also conduct security and privacy protection training courses to strengthen our employees' awareness of the importance of protecting personal information.

We have an industry-leading, data-centric security management system that is built around the data lifecycle. We have also established a compliance system based on relevant laws, regulations, and standards. We enhance the security of the entire system from multiple dimensions, including organizational structure, system design, personnel management, and product technology.

The information we collect is stored in a secure operating environment that is not open to the public. To prevent unauthorized access to your information, we store it on servers that are protected by firewalls and may be encrypted. However, no system is absolutely secure. Please understand that "perfect security measures" do not exist on the internet. Even with our best efforts, it may not be possible to prevent illegal access to your personal information and that of your end users. In addition, because we cannot verify the truthfulness of others' statements, we may be misled by unreliable, deceptive, or illegal information.

In the unfortunate event of a personal information security incident, we will inform you or your end users as required by law. We will inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you and your end users to prevent and reduce risks, and remedial measures for you and your end users. We will inform you and your end users of the incident by email, letter, phone, or push notification. If it is difficult to inform each personal information subject individually, we will issue a public announcement in a reasonable and effective manner. At the same time, we will also report the handling of the personal information security incident as required by the relevant regulatory authorities.

We take reasonable and feasible measures to avoid collecting irrelevant personal information. We retain your personal information and that of your end users only for the period necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law. The criteria we use to determine this period include the following:

1. To fulfill the service purposes related to you, maintain corresponding service and business records, and respond to your possible business needs.

2. To ensure the security and quality of the services we provide to you.

3. Your agreement to a longer retention period.

4. The existence of other special agreements on the retention period.

After your personal information exceeds the retention period, we will delete your personal information or anonymize it in accordance with applicable laws.

V. How to manage your personal information and that of your end users

You can access and manage your information in the following ways.

1. Query, correct, and supplement your information. We strive to enable you to review, correct, or supplement the information you have provided to us. To review, correct, or supplement your information, you can visit our website and log in to your account to perform these operations. If a right cannot be exercised on the account page, you can contact us using the contact information provided in this Privacy Policy, and we will assist you with the corresponding operation.

2. Close your account and delete your personal information.

If you no longer want to use our products, you can contact us using the contact information provided in this Privacy Policy to submit a request to close your account. We typically respond to your request within 15 business days. For your account security, we will need to verify your identity to process your request, which requires you to submit sufficient and valid identity information. After your account is closed, we will no longer provide services to you. If you want us to delete your personal information, you can also submit a request to us to delete your personal information.

3. Obtain a copy of your personal information.

You have the right to obtain a copy of your basic personal information by sending us a request. If it is technically feasible, for example, through data interface matching, we can also directly transfer a copy of your personal information to a third party that you specify at your request.

If your end user needs to obtain a copy of their personal information, they can send a request to us. After we complete the end user's identity verification, we will provide a copy of their personal information.

VI. How we handle minors' information

We take the protection of minors' personal information very seriously. If your application is developed for minors, you must take the necessary steps to ensure that you have obtained consent from their guardians for registration and use by your end users. At the same time, you must fulfill the corresponding notification obligations in your privacy policy. Note that as an application for minors, you must also comply with the review standards and guidelines for applications for minors in the application marketplace to avoid affecting your application's listing or normal operation.

Due to current technology and business models, it is difficult for us to proactively identify minors' information. If a minor's guardian discovers that a minor's personal information has been collected without authorization, the guardian can notify us to delete it. If we discover such a situation ourselves, we will also proactively delete it.

VII. Scope of the SDK service

Our SDK provides services to developers within mainland China, and we store your data within mainland China. To avoid violating local regulatory provisions because you are unfamiliar with the data protection laws and policies of your end users' country or region, we strongly recommend that you use Lingyang services only within mainland China (which for the purposes of this policy excludes Hong Kong Special Administrative Region, Macao Special Administrative Region, and Taiwan). If you use Lingyang services outside of mainland China, you must comply with the legal requirements for cross-border data transfer and assume all possible risks. If this causes any form of loss to Lingyang, you are responsible for providing us with full compensation. If you provide services in the European Union (EU), our business may require us to transfer your end users' personal data to countries outside the EU. These countries may offer different levels of data protection than EU countries. As the processor of your end users' personal data, we will take appropriate measures to ensure that we fulfill our confidentiality obligations and that measures such as standard contractual clauses are implemented.

VIII. How this Privacy Policy is updated

We may adjust or change this Privacy Policy from time to time. Any updates to this Privacy Policy will be published with an updated date. Unless otherwise required by law or regulation, the adjusted or changed content will take effect 7 days after notification or publication. We will not limit your rights under this Privacy Policy without your explicit consent. For major changes, we will provide a more prominent notice, such as public announcements on our website or client homepage, or pop-up notifications.

Major changes referred to in this Privacy Policy include, but are not limited to, the following:

1. Significant changes to our service model, such as the purpose of processing user information or the way user information is used.

2. Significant changes in our control or organizational structure, such as changes in ownership caused by business adjustments, bankruptcy, or mergers.

3. Changes in the main parties with whom personal information is shared, transferred, or publicly disclosed.

4. Significant changes in your rights to participate in the processing of personal information and how you can exercise them.

5. Changes in our responsible department for user information security, its contact methods, and its complaint channels.

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

IX. How to contact us

If you have any questions, suggestions, or complaints about this Privacy Policy, please contact the "Hangzhou Lingyang Intelligent Service Co., Ltd. Personal Information Protection Project Team". Mailing address: Hangzhou Lingyang Intelligent Service Co., Ltd. Personal Information Protection Project Team, Building 3, 969 West Wenyi Road, Yuhang District, Hangzhou. We will respond within 15 business days of receiving your inquiry.

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