This policy only applies to our products or services, if you have any questions, comments or suggestions, please contact us through point eight (How to contact us) to obtain contact information.

Release date: December 14, 2022

Last updated: December 21, 2022

Effective date: December 28, 2022

This Privacy policy will help you understand the following:

I. Introduction

2. How do we collect and use your Personal information

How do we share, transfer and publicly disclose your personal information

How do we protect your personal information

5. How do you manage your Personal information

6. How do we handle minors' personal information

7. How to store Personal Information

Eight, how to contact us

Ix. Supplementary Provisions

I. Introduction

1. We may revise this policy from time to time in accordance with laws and regulations or business adjustments. When there are major changes to this policy, we will show you the changed content in the form of reminders or messages in a prominent position after the version update. Major changes referred to in this policy include but are not limited to: major changes in our service model, such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.; Significant changes in our control, such as changes in ownership due to mergers and acquisitions; The main object of personal information sharing, transfer or public disclosure has changed; Significant changes in your rights to participate in the processing of personal information and the way in which they are exercised; We are responsible for handling personal information security departments, contact methods and complaint channels change.

2. You need to understand that we will collect, use, process and store your personal information in accordance with the changed Privacy Policy only after you confirm and agree to the changed Privacy Policy; You have the right to refuse to agree to the changed Privacy Policy, but please be aware that once you refuse to agree to the changed privacy Policy, you may not be able to or can not continue to fully use the relevant services and functions, or can not achieve the service effect intended to achieve the product.

3. Please understand that we do not promote the use of users under the age of 18. If you are a minor under the age of 18, please do not register to use. If you are a minor under the age of 18 and have registered an account, you can contact us by obtaining the contact information in point 8 (How to contact us).

2. How do we collect and use your Personal information

1. Please understand that we will collect and use your personal information for the purposes described in this policy in accordance with the principles of legality, legitimacy, necessity and transparency. As our business evolves, changes may be made to the functionality of the application and the services provided. In principle, if we use your personal information for other purposes not specified in this Policy, when the new function or service is related to the function or service currently provided by us, the personal information collected and used will be directly or reasonably related to the original purpose of processing. In cases that are not directly or reasonably related to the original purpose of processing, we will once again inform you in a reasonable manner about the use of your personal information and obtain your consent.

2. In general, we will collect and use your personal information in the following scenarios:

2.1 Account Registration and login

When you register and/or log in to your account, in order to help you complete the registration and/or login, you need to provide your mobile phone number or third-party account information, we will send SMS verification code to verify whether your account is valid and used to create or log in to the account; You need to understand that the mobile phone number and verification code matching results are your personal sensitive information, and we collect such information based on the requirements of laws and regulations. If you refuse to provide such information, you may not be able to register an account and use related products and/or service functions.

2.2 Transaction Function

When you purchase membership services, you need to use the payment function; At that time, we will collect the order information generated when you pay, such as: payment method, payment amount, payment merchant, payment order number, payment time, payment status.

We collect this information to help you successfully complete your transaction, to protect the security of your transaction, and to follow up with order information and provide customer service. We will do our best to ensure the security of this information and will not be disclosed or used for any other purpose.

Here, we need to specifically explain to you that when you use the bank card payment, you can enter the bank card number, click the Service agreement - Bank agreement/Lianlian payment Service agreement/privacy policy, understand its details before payment.

2.3 Feedback

If you have any feedback about the products and/or services, you can give feedback through "Feedback" in the App. You need to provide a description of your comments to help us understand the problem you have raised and find a solution. In order to respond to your comments in a timely manner, you need to provide us with your mobile phone number so that we can contact you and resolve the issue in a timely manner. If you refuse to provide it, we may not be able to provide you with timely feedback on complaints, appeals or consultation results.

2.4 Your Personal Information indirectly collected from third parties

When some of our products or services are provided by or jointly provided by third party business partners, we may collect some of your information indirectly from some of our business partners and provide information about you when other parties use our products and/or services in order to conduct business as necessary and reasonable.

We will strengthen the security of personal information (including sensitive information reporting, sensitive information encryption storage, access control, etc.). We will use no less protective means and measures for the protection of indirectly acquired personal information than we do for our own users' personal information.

2.5 To provide you with security features to ensure your safer use of products/services

In order to provide you with safer and more reliable products and use environment, to protect you or other users or the public's personal and property safety from network attacks/intrusions, network fraud, phishing websites, website vulnerabilities, computer viruses and other security risks, to better prevent and identify violations of laws and regulations and platform rules, to provide quality and reliable services and information, We collect and associate or integrate information about the products or services you use and how you use them, including:

Collect your device information (including app list, Android) ID), device model, operating system, read SD content, unique device identifier, login IP address, version number of the app, method of accessing the network, type and status, network quality data, device accelerator (such as gravity sensing equipment), operation log, service log information (such as information you search and view in the software, service fault information, referral URL, etc.) Information) and other log information. This is the basic information that must be collected to provide services.

Application list: Used to judge before requesting authorization for wechat login. If you do not agree to the privacy policy or do not use wechat login, you will not read and execute the code of the application list.

Device information: We will receive and record device-related information (including device model, operating system version, device setup identifier, unique device identifier, network device hardware address and other software and hardware characteristics information) and device-location information (such as IP address, WLAN access point, base station, geographic location information) that you use according to the specific permission granted by you during use. Please note that this information is the basic information we must collect to provide services and ensure the normal operation of products;

Log information: We will collect your relevant network log information, including App crashes, system activity information, device networking, browsing history, click history, software usage history and IP address information. We collect the above information for better security maintenance and optimization of this product and/or service, to provide you with a better experience. The above log information is the basic information collected to provide services. If you do not want the above log information to be collected by us, we may not be able to provide normal services to you.

It should be noted that individual device information and log information are information that cannot identify a specific natural person, so individual device information and log information are not "personal information" as referred to in this policy. If we combine such non-personal information with other information to identify a specific natural person, or use it with personal information, during the period of combined use, such non-personal information will be regarded as personal information, and unless authorized by you or otherwise provided by laws and regulations, we will anonymize and de-identify such personal information;

Other information: In order to prevent malicious programs and necessary for safe operation, we will collect application sources, transaction information, device information, and crash log information to comprehensively determine your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, audit, analysis and disposal measures in accordance with the law.

2.6 Exceptions to consent

According to laws and regulations, the collection and use of your personal information does not require your consent in the following circumstances:

(1) related to the performance of obligations stipulated by laws and regulations;

(2) directly related to national security and national defense security;

(3) related to public safety, public health and major public interests;

(4) related to criminal investigation, prosecution, trial and execution of judgments;

(5) In order to protect the life, property and other major legitimate rights and interests of you or other users, but it is difficult to get my consent;

(6) The personal information involved is disclosed to the public by you;

(7) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure channels;

(8) necessary for the conclusion and performance of the contract at your request;

(9) necessary to maintain the safe and stable operation of the products or services provided, such as discovering and disposing of faults of the products or services;

(10) Other circumstances stipulated by laws, regulations and regulatory policies.

How do we share, transfer and publicly disclose your personal information

1. Share

We will not share your personal information with any third party company, organization or individual except in one or more of the following circumstances:

1.1 At your own request, or with your prior express authorization or consent;

1.2 Related to our performance of obligations stipulated by laws and regulations;

1.3 Directly related to national security and national defense security;

1.4 Directly related to public safety, public health and major public interests;

1.5 Directly related to criminal investigation, prosecution, trial and execution of sentences;

1.6 In order to protect the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to get the consent of the person;

1.7 Your personal information that you disclose to the public on your own;

1.8 Collecting personal information from legally publicly disclosed information, such as through legal news reports, government information disclosure and other channels.

1.9 Sharing with Partners: In order to provide you with more complete and high-quality products and services, some of our services will be provided by partners. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and will only share personal information necessary to provide services. We will take reasonable security controls on the software kits (SDKS) and application program interfaces (apis) through which partners obtain information to protect data security. At the same time, we will clearly require in the cooperation agreement signed with the partner to comply with the relevant laws and regulations to protect and process your personal information. We will require that our partners have no right to use the shared personal information for any other purpose.

1.10 SDK technical Documentation

When providing services for users of Android system, in order to ensure the realization of relevant functions of the App and the safe and stable operation of the app, we may access software development kits (SDKS) provided by third-party SDK providers to achieve relevant purposes. There is no third-party SDK service provider to access this product.

2. Transfer

In principle, we will not transfer control of your personal information to other companies, organizations and individuals, except in the following circumstances:

2.1 At your own request, or with your prior express consent or authorization;

2.2 Related to our performance of obligations under laws and regulations;

2.3 Directly related to national security and national defense security;

2.4 Directly related to public safety, public health and major public interests;

2.5 Directly related to criminal investigation, prosecution, trial and execution of sentences;

2.6 In order to protect the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to get the consent of the person;

2.7 Your personal information that you disclose to the public;

2.8 Collecting personal information from legally publicly disclosed information, such as through legal news reports, government information disclosure and other channels;

2.9 Transfer in case of company merger, acquisition or bankruptcy liquidation, change of operating entity.

Please note: If the transfer is necessary for the above reasons, we will inform you of the purpose and type of the transferred information and the recipient of the information (if sensitive information is involved, we will also inform the content of the sensitive information involved) before the transfer, and transfer it after obtaining your consent, except as otherwise provided by laws and regulations.

3. Public disclosure

3.1 Public disclosure refers to the behavior of releasing information to the society or to an unspecified group. We will not publicly disclose your personal information except for the necessary disclosure of necessary matters such as the need to punish illegal accounts, fraud, etc., and display relevant information, and the content you publish publicly. If there are reasonable reasons for public disclosure, we will not disclose your personal information. Before public disclosure, we will inform you of the purpose and type of publicly disclosed information (if it involves your personal sensitive information, we will also inform you of the content of the sensitive information involved), and disclose it publicly after obtaining your authorization and consent, except as otherwise provided by laws and regulations or as otherwise agreed in this policy;

3.2 For your publicly disclosed personal information, we will carefully review its legitimacy, rationality and legality at the first time after receiving the application for public disclosure, and adopt the strictest personal information security protection measures and means to protect it during and after public disclosure.

4. Exceptions to the sharing, transfer and public disclosure of your personal information

Please be aware that according to the provisions of laws and regulations, the sharing, transfer, and public disclosure of your personal information do not require your prior authorization and consent under the following circumstances:

4.1 Directly related to national security and national defense security;

4.2 Directly related to public safety, public health and major public interests;

4.3 Directly related to criminal investigation, prosecution, trial and execution of judgments; Or according to the requirements of laws and regulations, administrative organs, public security laws and other competent authorities;

4.4 In order to protect the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to get your consent;

4.5 Personal information is disclosed to the public by yourself or collected from legal open channels (such as legal news reports, government information disclosure channels);

4.6 as necessary to enter into and perform the relevant agreement or other written documents with you;

4.7 Other circumstances as provided by laws and regulations.

4. How do we protect your personal information

1. We attach great importance to the security of your personal information, and will strictly abide by relevant laws and regulations, and will strive to take reasonable security measures (including technical and management aspects) to protect your personal information, and prevent the personal information you provide from being improperly used or unauthorized access, public disclosure, use, modification, damage, loss or disclosure.

2. We will use encryption technology, anonymization processing and relevant reasonable and feasible means that are no less than that of industry peers to protect your personal information, and use security protection mechanisms to prevent your personal information from malicious attacks.

3. We will establish a special security department, security management system, data security process to ensure the security of your personal information. We adopt a strict data use and access system to ensure that only authorized personnel can access your personal information, and conduct security audits of data and technology in a timely manner.

4. Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that due to technical limitations and possible malicious means, in the Internet industry, even if we do our best to strengthen security measures, it is impossible to always ensure 100% security of information. We will do our best to ensure the security of the personal information you provide to us.

5. You acknowledge and understand that there may be problems with the systems and communication networks you use to access our Services due to factors beyond our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information, including but not limited to not disclosing your account information and related personal information to others. If you find that your personal information, especially your account information, has been leaked, please contact customer Service immediately so that we can take appropriate measures according to your application.

6. We will formulate emergency response plans, and immediately initiate emergency response plans when user information security incidents occur, and strive to prevent the impact and consequences of these security incidents from expanding. In the event of a user information security incident (leakage, loss), we will inform you in a timely manner in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce risks, and the remedial measures for you. We will timely inform you of the relevant events by push notification, email, letter, SMS and other relevant forms. If it is difficult to inform you one by one, we will make announcements in a reasonable and effective manner.

5. How do you manage your Personal information

We attach great importance to the management of your personal information, and do our best to protect your rights to query, access, modify, cancel your account, and complain about your personal information, so that you have the ability to protect your privacy and information security.

1. Access to your personal information

You have the right to access your personal information unless otherwise required by laws and regulations or judicial or administrative authorities. You can access your personal information by yourself in the following ways:

1.1 Account Information: If you wish to access or edit personal information in your account, you can do so through the "I" page after logging in to your account;

1.2 Usage information: You can query your usage information through our product related pages;

1.3 Other Information: If you encounter operational problems in the process of access and need to obtain other aforementioned inaccessible personal information content, you can contact us at any time through customer service. We will review the problem as soon as possible and reply to you in a timely manner after verifying your user identity.

2. Correct or supplement your personal information

When you find that the information you provide us is incorrect, incomplete, or updated, you can use this section "1. Changes are made in the manner set out in "Access to your Personal Information". We will reply promptly after review.

3. Cancel your account

You can cancel your account through "Account Cancellation" in the "My" - "Account Management" page. You acknowledge and understand that the behavior of canceling your account is irreversible. After you cancel your account, you will not be able to log in and use our products with this account. All information under this account will be deleted or anonymized. If you have any questions during the cancellation process, you can contact customer service in time.

4. Right to withdraw consent

Based on your personal consent to the processing of personal information, you have the right to withdraw your consent. You can withdraw your consent by contacting us through the in-app [My] - [Contact Us]. The withdrawal of consent by an individual shall not affect the validity of the personal information processing activities that have been carried out on the basis of the individual's consent before the withdrawal.

5. Report complaints

If you think that your personal information rights may be infringed, or you find clues that infringe on personal information rights, you can enter the complaint report in "Report" - "Select report type". We may refuse some requests that are unwarranted and repetitive, bring risks to the legitimate rights and interests of others, or are very unrealistic. Or give us feedback about the situation through "feedback".

6. In the following circumstances, according to the requirements of laws and regulations, we will not be able to respond to your request:

6.1 Related to national security and national defense security;

6.2 Related to public safety, public health and major public interests;

6.3 Related to criminal investigation, prosecution, trial and enforcement of judgments;

6.4 There is sufficient evidence that the personal information subject has subjective malice or abuse of rights;

6.5 Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;

6.6 Involving trade secrets.

6. How do we handle minors' personal information

Our products and/or services do not encourage the registration of users under the age of 18. Any minor under the age of 18 should not register for a personal account and/or use our products and/or services. If you are a minor under the age of 18 and have registered an account, please contact us by obtaining the contact information in Point 8 (How to contact Us). If we find that we have collected the personal information of minors, we will try to delete the relevant data and freeze the relevant account as soon as possible, and ask the guardian of the minors to fulfill their guardianship obligations.

7. How to store Personal Information

1. We store your personal information collected and generated during our domestic operations in the territory of the People's Republic of China in accordance with laws and regulations. At present, we will not transfer the above information overseas. If there is a cross-border transfer of personal information in the future, we will strictly comply with the relevant provisions of the laws and regulations of the People's Republic of China and obtain your explicit authorization.

2. In general, we will only retain your personal information for the shortest period necessary to achieve our purpose, and personal information beyond the corresponding period will be deleted or anonymized for processing. However, in the following cases, we may change the storage time of personal information in order to comply with legal requirements:

2.1 To comply with relevant provisions of applicable laws, regulations, policies and other normative documents;

2.2 In order to comply with the decisions of administrative organs or similar authorized organizations, judgments and rulings of judicial organs, awards of arbitral organs or other legal procedures;

2.3 We have reason to believe that we need to comply with relevant laws and regulations;

2.4 For the implementation of the relevant service agreement or this policy, to safeguard the public interest, to protect the personal and property safety or other legitimate rights and interests of our customers, us or our affiliates, other users or employees and other third parties;

2.5 When the operation stops, we will notify you in the form of push notification, website announcement, etc., and delete or anonymize your personal information within a reasonable period of time.

3. I would like to explain to you that the pictures/videos you have edited in the app will only be stored locally on the mobile terminal, and our server will not store them. Please take good care of the edited files.

8. How to contact us

You can contact us in the following ways and we will respond to your request within 15 days:

1, If you have any questions, comments or suggestions about the content of this policy, you can contact us in the App "Settings" - "feedback" or "Settings" - "Contact".

2, you can also contact us through the following information:

Contact email: AvadaKedavraa@126.com

9. Supplementary Provisions

The interpretation of this policy and dispute resolution shall be governed by the laws of the People's Republic of China. Any dispute in connection with this policy shall be settled by both parties through friendly negotiation. If no settlement can be reached through negotiation, you hereby agree to submit the dispute to the Nanshan District People's Court of Shenzhen.

If any provision of this Policy is found or determined by any court of competent jurisdiction to be 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.

The headings of this Policy are designed for convenience only and do not affect the meaning or interpretation of any provision of this Policy.