Update details:
We recently updated the representations in the Privacy Policy in accordance with the law to help you better understand how we process and protect your personal information, in particular:
1. Updated the “Cloud Synchronization Service” by expanding the scope of data eligible for cloud synchronization, to help you better understand how we process and use your personal information within this service.
2. Updated the relevant provisions concerning the “Finding Services” so as to further inform you of how we collect, process, and use your personal information in connection with such services.
SHANGHAI TRANSSION CO., LTD. (hereinafter referred to variously as “cloud service”, "we", "us", or "our") is the provider and operator of this application software and services (hereinafter referred to as "the Software"). We respect your privacy and are committed to ensuring the security of your personal information. In the process of providing the products or services (collectively referred to as "the Services"), we may collect and use your personal information with your consent or as required by applicable laws. This Privacy Policy (hereinafter referred to as "the Policy") is intended to help you understand how we collect, use, disclose, process, and protect the personal information you provide when using cloud service products or services, your rights with respect to that personal information, and how we safeguard those rights. The Policy applies to all cloud service products and services, including applications, mini programs, and web pages for PCs and mobile intelligent terminals, software development kits (SDKs), and application programming interfaces (APIs) for third-party websites and applications, as well as those that may emerge in other forms in the future.
It shall be specially noted that the Policy is not applicable to the services offered to you by third parties. You may receive content or network links from third parties. Please be cautious about whether to access the links, content, products, and services provided by third parties. Before submitting your personal information to any third party, please carefully review its privacy policy.
To ensure that you fully understand the Policy and make your own decisions, we will explain the Policy as clearly as possible by underlying or highlighting the critical information (especially in bold, capital, underlined, and other forms). Moreover, when you use our services for the first time, prompts will pop up, reminding you to pay attention to and understand the core content of the Policy.
Please read the Policy carefully to understand our practices with respect to your personal information before using our products or services, submitting personal information to us, or granting us consent to collect your personal information, and please visit often to stay informed of updates to the Policy. We will post changes to the Policy (if any) through relevant products or websites to keep you informed of the same. By accessing our services after such notice, you agree to the updated privacy policy. You can view the "Update Date" at the top of the Privacy Policy page to confirm the latest update time.
If you have any questions, please feel free to contact us via
privacy@transsion.com
You can also access the Policy via:
[Cloud Service - More - Privacy Policy]
The Privacy Policy will help you understand the following:
I. How We Collect and Use Your Personal Information
II. How We Store and Protect Your Personal Information
III. How We Share, Transfer and Disclose Your Personal Information
IV. How Is Your Personal Information Transferred Across Borders
V. Your Rights to Your Personal Information
VI. How We Process Children's Personal Information
VII. Third-Party Service Providers and Their Services
VIII. Supplements and Updates to the Policy
IX. Joint Controller
X. How to Contact Us
I. How We Collect and Use Your Personal Information
(I) Overview
Cloud service believes that fundamental privacy rights must apply equally regardless of where you live in the world. That's why we treat any information that relates to an identified or identifiable individual as "personal information" no matter where they might live, and that applies particularly to name, identity, location, online identifier, or physical, physiological, genetic, mental, or any other related characteristics that can reasonably be used to identify an individual.
We only collect the information necessary for special, specific, explicit, and legitimate purposes and shall ensure that your information will not be further processed for any other purposes. We will request your consent again if we intend to use your personal information for any purposes not specified herein.
We will collect your personal information, including 1) the information you provide directly (such as the nickname, avatar, name, and telephone number you provide when you sign in to the account and sign up for our marketing activities); 2) the information generated during your use of the Software (such as device information and service log information), which will be automatically collected by us; and 3) the information we acquire from other sources.
You have the right to decide whether to provide your personal information when using our products or services or when we request it. You are not required to provide personal information to cloud service at any time. However, choosing not to provide it may prevent cloud service from being able to provide you with certain products or services or respond to issues you may encounter and limit our ability to resolve them. We will only collect and use your personal information for the purposes stated herein. The following are examples explaining why we collect your personal information:
(II) Cloud Service’s Main Service Functions and Information Collection and Usage Scenarios
The main purpose of the Software is to provide you with online data backup, file storage, sharing and download services.
1. Providing Account Login Services
To utilize the functions and services of the Software and benefit from its convenience, please log in to our services through the supported system account service. In this scenario, we will collect the open ID, nickname, avatar, as well as the email address and phone number information associated with your system account. We will use this account to establish a binding relationship with cloud services and various functions, and generate a user ID for you to facilitate logging in and accessing our services and web pages. In the event of any changes to the service content, we will provide you with the relevant notifications via the email address you have registered with us.
Please review the privacy policy of such services to understand how they collect and utilize your personal information. If you refuse to provide the said information, you would not be able to use some functions, but you can still browse the Software in guest mode (i.e., you are not a registered user).
2. Providing Cloud Service
(1) Cloud synchronization: Subject to your authorization, the cloud synchronization feature will assist you in automatically synchronizing certain data stored on your device, including: contact information in your address book (contact names and contact details), WLAN information (SSID and WLAN passwords), voice recorder data (audio files and audio file names), calendar entries (event names, times, locations, and event descriptions), NFC card information, and MPESA billing data (expenditures, income, and account balances). You may disable any such functionality at any time via the Cloud Services interface. Please be advised that the types of data supported for cloud synchronization may vary depending on the software version. In the event of any discrepancy, the information displayed on the service interface shall prevail.
To assist you in distinguishing data sources, we need to obtain information about the devices on which your account may be logged in. This includes IMEI, SN, GAID, device ID, and your phone model. Such information will be used to help you distinguish, view, and manage cloud sync data across different devices.
(2) Cloud backup and restore: Should you enable the cloud backup and restore service, we will assist you in backing up relevant device settings, including your call logs and content, SMS, MMS, installed software list, application data, media library, contacts, and system settings, in accordance with your instructions. Based on the features you utilize, we will request access to your storage, SMS, MMS, and media library permissions. These permissions are essential for the corresponding cloud backup functionalities. You may revoke your authorization at any time by navigating to [Settings > App Management > Application List > Cloud Services]. If you enable the full-device backup service, we will assist you in backing up all the data on your device in accordance with your authorization. To assist you in distinguishing data sources, we need to obtain information about the devices on which your account may be logged in. This includes IMEI, SN, GAID, device ID, and your phone model. Such information will be used to help you distinguish, view, and manage cloud sync data across different devices.
(3) Cloud drive:f you enable the cloud drive service, you will be able to upload, store, share, download, and manage your audio and video files, images, and documents through this service. We will store your content based on your authorization, allowing you to view, manage, and utilize it. If you have enabled this service, we will provide memory-saving suggestions based on your app usage frequency and device memory status to help you better manage your device's storage.
(4) Recycle bin: If you choose to delete your synced contacts, notes, and other content, we will retain them in the recycle bin for [30] days. During this period, you may opt to restore the data or permanently delete it. If no action is taken within the specified period, we will no longer retain the data stored in the recycle bin after the expiration.
3. Finding Service
By opting to enable the “Find Device” feature through this Service, you will, in the event your device is lost, be able to log in to this Service from any Internet‑connected device or access the desktop client to locate and lock your device, or to erase the data stored on your device.
(1) Find phones
If you have enabled the mobile location and device‑finding functionality, you may, subject to the capabilities and conditions supported by your device, use this Service to view the location of your device. When you enable this feature, we will need to request permission to access your device’s geographic location in order to support the reporting of its location information. This permission is necessary for the function. You may revoke your authorization by navigating to [Settings-Accessibility] at any time.
To the extent technically feasible, we may provide you with services such as remotely playing a sound, enabling “Lost Mode,” and remotely erasing data. In such cases, we will need to obtain certain information from your device, including CPU details, IMEI, and serial number (SN). To verify that the operation is being performed by you personally, when you use the remote data‑erasure feature or disable “Lost Mode,” you will be required to enter your account credentials (username and password) for authentication.
If you have enabled the lock‑screen snapshot feature, when the number of incorrect password attempts on your device reaches the maximum limit and the device has entered “Lost Mode”, we will, subject to the availability of network connectivity on the device, upload the photographs captured by the device. You may access and download such photographs via the web‑based interface of this Service to assist you in locating your device. Please be advised that your photographic information will be retained within our Service for a period of thirty (30) days only.
If “Lost Mode” has been enabled, this Service will initiate a local check on the device to determine whether the SIM card has been changed. If a SIM card change is detected on your device, this Service will identify the current device phone number and upload it to the cloud, where it will be stored for thirty (30) days to enable you to view your device information and assist you in re‑establishing contact with your device.
(2)Find accessory devices
If your accessory device (such as Bluetooth earphones) has been bound to your account via the Welife service, then, upon enabling the “Find Device” feature, you may use this Service to locate the position of the accessory. At this time, we will collect and store your device’s MAC address and device identifier for the purposes of binding the device, obtaining its physical location information and battery status, and displaying such information within this Service for your review.
(3)Data recovery
If you enable the “Find Phone” service, within specific operating regions and when your mobile device is in a lost state, you may use this Service to perform data recovery. Upon your login to our web‑based service, and in accordance with your remote instructions, this Service will upload the following from the lost device: system settings, local files stored on the device, local system data, a list of third‑party applications installed on the device, and the local cached data of specified third‑party applications (including WhatsApp, Instagram, Facebook, and Truecaller).
4. Providing Cloud Storage Subscription Service
This service offers a paid subscription for storage space. When you subscribe to a membership package, we will record your account information, order details (including order number, product name, price, and date), payment status, and usage status of the order . Such information will be used to process your order payment, display the status of your subscribed package, facilitate order management, and provide after-sales support for your orders. If you have enabled auto-renewal feature, we will subscribe to subsequent related services based on your order status.
Please be aware that payment services are provided by third-party payment service providers. Please carefully read and understand the relevant agreements before providing information to these providers.
Should you encounter any issues during usage, you can submit your concerns via the Feedback feature. We will collect your feedback, country, device model, and cloud service version number to offer you solutions or explanations.
5. Providing Participation in Promotional Activities
From time to time, we will initiate or provide promotional activities. When you participate in these activities, we will collect information you voluntarily provide to us through the activity interface, such as your name and contact details. This information is mainly for us to get in touch with you and to award prizes. Should you refuse to provide the information required to participate in the promotional activity, we may be unable to provide you with the Services, prizes, or rewards. However, this will not affect your use of other functions of the Software.
6. Messaging push service
We may also push service notifications and other messages to you based on your device identifier, operating system version, current device username, network information, and information related to your use of the app. To unsubscribe from notifications, activities, and other messages, go to Settings > Notification Center > Notification Management to withdraw your consent. Methods of opting out may vary by version.
We will compile statistics on the number of data items you have synchronized to the cloud within a specified period, and present you with a preview card displaying an overview of the data synchronized during that period.
If you choose to synchronize your MPease bills within the cloud synchronization feature, we will use client‑side algorithms to generate an overview of your bills for the specified period. Please be advised that such data will be read and processed entirely on the device.
7. Improving Our Products or Services
To ensure that you are able to use our products and services properly and assist us in analyzing product performance and optimizing product functions, we will automatically collect the device and service log information. This includes:
(1) Information about your device and SIM card: When you start using the Software, we receive and record information about your mobile device (including brand, model, OS version, unique device identifier (UDID), CPU model, settings, system language, network device hardware address, and IP address of the mobile phone, app version number of cloud service, and software and hardware characteristics), the Google Advertising ID (GAID) of the hardware device, and information about the location of the mobile device (including the country or region where your mobile phone is authorized, and network access mode) based on how you interact with the Software and the specific permissions granted when installing and using the Software.
(2) Service log information:When you use the Software, such as our online after-sales service, online ordering, online customer service communications, and other services, we will automatically collect information about how you use our service and save it as service logs. This includes the time of the first activation, access time, number of times you open the software, duration of use, file transfer speed, event information (errors, crashes, restart, upgrade), browsing history, subscription status, and other log information generated by your device. Additionally, if you use the upload/share feature, we will obtain details such as the file type and name.
We may also collect other information needed for the reasonable improvement of our products or services. This includes feedback provided when you contact customer service and responses when you participate in questionnaires. We may combine information from one service with that of another to provide you with better services, content, and recommendations.
(III) Other Situations where Your Information May Be Collected
Where permitted by laws, we may collect your personal information from other individuals, business entities, public channels, or other third parties indicated by you, other partners who help us provide our products or services or assist us in ensuring information security and preventing frauds, and other legitimate avenues. We will inform you and collect your information with your consent.
We may also collect other information about you, your device, or your use of the Services in other ways that will be described to you at the time of collection for your consent.
To improve our product layout and offer you better services, we may carry out researches, statistical analyses, and predictions on the collected information in an anonymized manner (including machine learning or model algorithm training based on anonymized data). We will take technical measures and other necessary actions to process the collected personal information so that such information cannot identify any individual person and cannot be recovered. As permitted by applicable laws and regulations, we do not need to inform you separately for your consent for the use of such anonymized data.
II. How We Store and Protect Your Personal Information
1. How we store your personal information
We will store your personal information that we collected upon your consent in accordance with the relevant national laws and regulations concerning personal privacy and data protection. We may also store the personal information we collect in countries or regions other than the country in which we do business, provided that local laws and regulations do not prohibit such storage.
Currently, cloud service may store your personal information in India, Russia, and Frankfurt. Specifically:
The personal information we collect and generate in the course of our operations in India will be stored on servers located in India.
The personal information we collect and generate in the course of our operations in Russia will be stored on servers located in Russia.
The personal information we collect and generate in the course of our operations outside India and Russia will be stored on servers located in Frankfurt.
We may use the servers in other areas or countries depending on our business development, and in such cases, we will update the Policy accordingly.
Whether personal information is stored in the country where we do business or in another country or region without violating the law, we will store it in accordance with the relevant laws and regulations regarding data storage. We will take necessary security measures considering the characteristics, scope, purposes of personal information processing, the possible risks in processing personal information, and the serious consequences in case of any damages. For example, we will encrypt and de-identify the collected personal information before storage. We will store the information only necessary for our business development within the minimum retention period unless otherwise permitted by laws or you agree to extend the retention period. We will delete or take other appropriate measures to delete data that exceeds the retention period or that you request us to delete, provided that this does not violate the relevant laws and regulations.
2. How we protect your personal information
We will also take other necessary measures to protect your personal information from misuse, unauthorized access, modification, disclosure, or destruction.
We implement security measures designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical and physical safeguards to protect your personal information by considering the nature, processing methods, and security of the personal information. We will continuously strive to improve these measures to keep your personal data secure.
It should be noted that no measures can absolutely guarantee the avoidance of data storage security incidents. In the event of a security breach, we will report to the appropriate regulator in accordance with the requirements of relevant laws and regulations, and provide the type of personal data involved in the data breach, the number of data subjects, the possible consequences of the data breach, and the remedial measures we intend to take in accordance with the requirements of the supervisory authorities. We will take all possible measures to remedy or mitigate the damages and consequences caused by a data breach. If permitted or required by laws, we will promptly inform you of the consequences or significant damage that may be caused to you as a result of a data breach, so that you can take appropriate measures to protect your rights to the greatest extent.
Since no website, Internet transmission, computer system, or wireless connection is absolutely secure, in addition to the necessary security measures we take, users need to be more aware of privacy and security risks. For example, if you are redirected to a third party's website, link, product, or service through our service, please be careful and read the terms of agreement of such website, link, product, or service carefully for the security of any data information collected by such website, link, product or service, and we will not be liable for any data security issues caused by such third party. If you find that certain content, advertisements, or features of our website, products, or services may be provided by third parties and may endanger your privacy and security, please contact us promptly and we will give priority to dealing with them in accordance with the law.
III. How We Share, Transfer and Disclose Your Personal Information
We will share, transfer, and disclose your personal information to the minimum extent and only when it is necessary for operations or required by laws. We will not share, transfer, or disclose your personal information unless otherwise required or permitted by applicable laws and regulations in the following circumstances:
1. How we share your personal information
We do not sell any personal information to third parties. To offer you timely service, we may share your personal information with our affiliates. We will only share your information with our affiliates for lawful purposes clearly stated and only as necessary to provide the Services subject to the purposes stated in this Privacy Policy. For any purposes not covered herein, we will make explicit statements in the privacy policy or notice for the specific product or service.
We may share necessary personal information with authorized third-party partners (including technical service providers, payment service providers, etc. ) to perform certain functions or provide you with better service and user experience. Specifically, to enable you to complete order payments, we will share your order information and order status with the payment service providers. Our cloud service providers will assist us in ensuring the proper operation of the service. We will embed software development kits (SDKs) or other similar applications of our authorized partners in the Software (we will conduct strict security checks on these SDKs or applications to ensure the security of the data). Specifically:
|
S/N |
Third-party SDK sources |
Purpose of collecting personal information |
Types of personal information collected |
Privacy Policy link |
|
1 |
Account services SDK |
Account for convenient login |
Open ID of the account |
https://render.palm.tech/account-basic-agreement/policy.html |
We will share that information to the minimum extent and only when it is necessary for operations or required by law. Before sharing, we will sign stringent confidentiality agreements with our authorized partners, requiring them to take relevant confidentiality and security measures to process personal information in accordance with the Policy and the applicable laws of your jurisdiction. Moreover, we will require them to provide data security functions and information security qualifications (such as classified protection assessment, information security management system, etc.). When embedding SDKs or any other similar applications of our authorized partners in the Software, we will do our due diligence to request the SDKs that obtain the information to protect the security of your data.
We may also share your non-personal information with third parties to provide evaluation, analysis, or other business services. For example, we may use the aggregated information to help our partners (such as advertising service providers) understand the effectiveness, feedback, and usage trends of their services.
In the event of a merger, acquisition or bankruptcy and liquidation, transfer of assets, or other related transactions involving the transfer of personal information, we will require by agreement or other appropriate measures that the company or organization newly holding your personal information continues to be bound by the Policy and that such subject takes confidentiality and security measures no less stringent than those required by the Policy to handle personal information.
2. How we transfer your personal information
Cloud service will not transfer your information to any other party unless:
(1) your express consent is obtained.
(2) we have provided prominent notice via email and/or our website or by means of another appropriate method to inform you of any changes in your ownership of, rights to, and choices regarding your personal information when cloud service is involved in a merger, acquisition, or sale of all or part of its assets that may affect your personal information.
(3) the transfer has been stated in the Privacy Policy or otherwise notified to you.
3. How we disclose your personal information
Cloud service may disclose your personal information as required by law, legal procedures, litigation, and/or government departments and authorities. We may also disclose your personal information if the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance.
In addition, we may share your personal information with the following people:
(1) our lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.
(2) investors and other related third parties, if actual or potential sales or other transactions with another company occur and are related to entities within the TECNO group.
(3) other third parties, for example, when specific information is disclosed to them under your authorization.
IV. How Is Your Personal Information Transferred Across Borders
For the purposes described in the Privacy Policy, we may transfer your personal information to the resources or servers mentioned in Section III of the Policy for storage or processing, and we may also transfer your personal information to third-party service providers and business partners, and therefore your data may be transferred to other countries or regions, subject to compliance with applicable laws and regulations in your region and with your authorized consent. The privacy laws in these countries or regions may differ, and the jurisdictions in which these servers are located may or may not protect personal information to the same extent as those in your jurisdiction. However, we will still strive to protect your personal information based on our Privacy Policy and carry out the cross-border transfer and other processing of corresponding information as required by the laws of the country or region where the personal information is located.
If we transfer personal information outside of your jurisdiction, whether to our affiliates or to a third-party service provider, we will comply with the relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers are subject to the requirements of applicable local data protection laws.
V. Your Rights to Your Personal Information
As a data subject, you have a number of rights with respect to personal information such as confirmation, access, correction, deletion, withdrawal of consent, complaints (hereinafter referred to as "requests"), etc. We fully understand and respect these rights, which are also subject to specific exclusions and exceptions in accordance with applicable law. We will also take active steps to ensure that your rights are effectively guaranteed. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we charge no fees for your legitimate requests. However, for repeated requests exceeding reasonable limits, we will charge a reasonable fee to the extent permitted by applicable laws based on actual administrative costs as appropriate. We may deny requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes in current practices), pose a risk to the legal rights of others or are highly impractical, or violate mandatory legal requirements.
1. Right to confirm and access: We inform you of how we collect and process your personal information via this Privacy Policy or through privacy policies or notices for specific product service scenarios. You have the right to confirm or reject such collection and processing by checking the box or via other methods. However, if you reject the service, some functions that require your express authorized consent before use may no longer be available. The personal information you have provided to us can be accessed directly from the interface of our products or services. In case of a failure to access information, email us at privacy@transsion.com, and we will deal with your request promptly.
2. Right to correct and delete: When your personal information changes, or when you find that the information we collected and processed is inaccurate or incomplete, you have the right to request that we make corrections or additions. For some of your personal information, you can correct and amend it directly on the relevant function page of the product or service. You have the right to request us to delete your personal information when we have achieved the purpose of collecting your personal information or it is no longer necessary, or when you find that we have collected or processed your personal information in violation of the provisions of laws and regulations or the terms of the Privacy Policy. For any information you cannot access to correct or delete, email us at privacy@transsion.com to request a correction or deletion.
It should be noted, however, that we may not be able to approve your request for deletion in certain cases, such as the deletion of transaction data, as we are legally obliged to keep records of transactions in compliance with applicable local laws. Please also note that if you request the deletion of your information from our products and services, due to certain applicable local laws and technical limitations, we may not immediately delete the corresponding information from our backup systems, but we will securely store your personal information and prevent its further processing until the backup systems are updated and your information can be deleted or anonymized.
3. Right to withdraw consent: For our different products or services to perform the corresponding functions, we will require the necessary personal information in accordance with the applicable local laws. This is described in "How We Collect and Use Your Personal Information" of the Privacy Policy. You may withdraw consent previously granted to us for specific purposes, including the collection, use, and/or disclosure of your personal information in our possession or control, by deleting the information, disabling relevant functionalities, or withdrawing the consent request. Email us at privacy@transsion.com for relevant operations. We will process your request within a reasonable time after you send it, and then will not collect, use, and/or disclose your personal information according to your request.
Withdrawing your consent may result in an inability to continue to access certain and/or all cloud service’s functions. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
4. Right to complain: You have the right to lodge a . complaint by sending us an email via privacy@transsion.com. We will respond promptly to your complaint. If you are not satisfied with our response, especially if our personal information processing practices have harmed your legitimate rights and interests, you may also file a complaint or report to the local statutory personal data protection authority, or file a lawsuit with a court of competent jurisdiction.
5. Right to control your privacy settings
You have the right to control your privacy settings, which allow you to restrict our collection, use, disclosure, or processing of your personal information. For example, you can choose to enable or disable the permissions such as "Contacts", "Storage", and "Messages". You can also get more detailed information about the security status of your device in Settings. If you have previously agreed to enable permissions or agreed to our use of your personal information based on the aforementioned business situation, you can change permissions via Settings > Application Management > Permission Management or by contacting us at privacy@transsion.com.
6. Right to cancel a service or an account
Request cancellation of your account via the cancellation path provided in the Services or by contacting us at privacy@transsion.com. Please be careful when you cancel your account. You understand that after you cancel your account, we will stop providing products and services based on that account. Unless otherwise required by applicable laws in your region, we will delete the corresponding personal data under your account at the same time. If you sign in to the Services through a third-party account, please request the third party to cancel your account.
7. Right in some jurisdictions
Please pay attention that you may have the following data subject rights under applicable laws in certain jurisdictions:
(1) Right to restriction of processing. You have the right to request our restriction on your personal information processing. We will review the reasons for your request. If the reasons are in accordance with applicable data protection laws, we will process your personal information only to the extent permitted by such laws and will notify you before lifting the restriction on processing.
(2) Right not to be subject to automated decision-making. You have the right to refuse automated processing of your information, including performance analysis and other automated processing that may have a legal or similar impact on you.
(3) Right to data portability. You have the right to request the transfer of your personal information to another data controller in a structured and commonly used format.
While we also have the right to refuse to process your request, we may reject some of your requests where an exemption applies or where we comply with applicable laws. For example, some requests are manifestly unfounded or excessive or require disclosure of third-party information.
VI. How We Process Children's Personal Information
We do not provide products and services for children under the age of 14 or the equivalent legal age under the law in your jurisdiction (the legal definition of a child varies from country to country, and we will define a child based on the laws and regulations of the country or region in which we do business). We do not actively collect personal data from children and do not use it for marketing purposes. If you find that you have transferred information about children to us, email us at privacy@transsion.com, and we will remove the information as soon as possible. If we find that we have collected children's personal information, we will also remove the relevant content as soon as possible.
VII. Third-Party Service Providers and Their Services
When you use our products or services (such as subscribed services), you may receive links to third-party websites or content and services provided by third parties other than us, and some products or services may be provided in the form of SDKs or other means. You can choose whether to access or accept websites, products, and services provided by third parties based on your judgment. Our Privacy Policy does not apply to products and services provided by any third party. Since we do not have substantial control over a third party, we cannot be responsible for the collection and processing of your personal information by that third party. When you submit any information to that third party, please be aware of that third party's privacy policy and take care to protect your personal information.
VIII. Supplements and Updates to the Policy
We reserve the right to update or modify the Policy from time to time as our business, technology, applicable laws, and operations change. In the event the Policy is modified, we will publish the latest version here (on this page) or notify you separately through other means. Please regularly check this page or the notifications we send you to stay informed of updates to the Privacy Policy. The Privacy Policy is subject to change, but we will not diminish your rights under the Policy without your express consent.
We will seek your express consent as required by applicable laws before we collect other information from you or use or disclose your information for a new purpose. If you continue to use products and services on the website, mobile device, and/or any other devices, you will be bound by the updated Privacy Policy.
The content of our products or services stated in the Agreement may change depending on the type of product and system version you are using, or the requirements of local laws and regulations.
IX. How to Contact Us
If you have any suggestions, questions, or concerns about our Privacy Policy or practices regarding the protection of personal information, contact us at:
Email: privacy@transsion.com (Note: The email is used for receiving emails related to our Privacy Policy or our information protection only)
We will review your request regarding privacy or personal information as soon as possible and reply to you within 15–30 days after verifying your user identity. If your request involves complex or significant issues, we may ask you for further information.
If you are not satisfied with our response, especially if your legitimate interests have been violated by us, you can seek a solution from the relevant data protection supervisory authority in your jurisdiction. If you make the above inquiry to us, we will provide you with information on the relevant complaint channels that may apply to your case.
Thank you for your time to read our Privacy Policy!