Privacy Policy

Yidian Hengtong Privacy Policy

Updated on August 14, 2024

1.Introduction

Yidian Hengtong (Hainan Yidian Hengtong Technology Co., Ltd., hereinafter referred to as "Yidian Hengtong" or "we") provides this privacy policy to introduce how we collect, use, and share information. This privacy policy (hereinafter referred to as the "Policy") will introduce Yidian Hengtong's handling of the following two types of information:

(1) Information collected during the provision of Yidian Hengtong services, including: (i) information about end-users collected by Yidian Hengtong through its software development kits ("SDK"), application programming interfaces ("API"), platforms, services, or technologies from mobile advertising participants such as mobile app developers, programmatic advertising exchanges, ad aggregation platforms, ad demand side platforms, traffic supply side platforms, etc.; (ii) information about interactions between end-users and advertisements collected by Yidian Hengtong through its SDK, API, or other technological means, or collected and transmitted to Yidian Hengtong by its business partners (such as mobile app developers, advertisers, etc., hereinafter referred to as "business partners") or designated third parties; (iii) information generated by end-users when using applications, websites, platforms, or other services of business partners transmitted to Yidian Hengtong by business partners or designated third parties; (iv) information provided to Yidian Hengtong by business partners in the process of using the platforms, technologies, or services provided by Yidian Hengtong. In the Yidian Hengtong service privacy policy, the end-users mentioned in this section are collectively referred to as "users" or "you", and the SDK, API, other technologies, platforms, or services provided by Yidian Hengtong are collectively referred to as "Yidian Hengtong services".

(2) Information collected from website visitors (hereinafter referred to as "visitors" or "you") through the following websites: (i) our website https://www.1dots.cn or any other website carrying this policy; and (ii) any website provided by us to potential customers or business partners for the purpose of providing our services ("Yidian Hengtong website", "website", "websites").

This privacy policy is subject to the terms of service between Yidian Hengtong and you. Before using Yidian Hengtong services or the Yidian Hengtong website, please read this privacy policy. By using Yidian Hengtong services or the Yidian Hengtong website, you confirm that you have read, understood, and agree to this privacy policy.

To further improve our privacy policy and services, we may revise this privacy policy from time to time. If there are significant changes to this privacy policy, we will announce the new policy through the Yidian Hengtong website before it takes effect.

Data protection and ensuring the trust of business partners and you are at the core of Yidian Hengtong's business principles. Therefore, complying with applicable data protection regulations is an important task for us. This policy has been updated and complies with applicable data protection laws, including the European Union General Data Protection Regulation ("GDPR"), the United States Children's Online Privacy Protection Act ("COPPA"), the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Utah Consumer Privacy Act ("UCPA"), the Connecticut Data Privacy Act ("CDPA"), the Brazilian General Data Protection Law ("LGPD"), and other laws and regulations related to the protection of personal information. If our cooperation with you should be subject to European data protection laws, Yidian Hengtong is the data controller of your personal information under the European data protection laws. For the purposes of this privacy policy, "Processor" refers to the processor under GDPR, VCDPA, CPA, CDPA, and UCPA, while "Service Provider" refers to the service provider under CCPA, and "Personal Information Controller" refers to the controller under GDPR, VCDPA, CPA, CDPA, and UCPA, while "Business" refers to the company under CCPA.

2. How and why we collect user information

This privacy policy describes how Yidian Hengtong collects and uses information in the following scenarios:

Based on the nature of the services provided by Yidian Hengtong or any services provided by Yidian Hengtong's business partners, we may collect information directly or through our business partners (e.g., mobile app developers, programmatic advertising trading platforms, ad aggregation platforms, ad demand side platforms, traffic supply side platforms). For example:

(1) When we provide traffic monetization services and mobile advertising aggregation tools for mobile app developers, the developers will embed our SDK into their mobile apps, and we will obtain user information through the SDK;

(2) When we cooperate with programmatic advertising trading platforms, traffic supply side platforms, the programmatic advertising trading platform or traffic supply side platform may share user information with our demand side platform when sending advertising requests;

(3) Our advertisers, ad demand side platforms, programmatic advertising trading platforms, or third-party attribution platforms used by them will share user information with us;

During the provision of Yidian Hengtong services, we do not establish direct contact with users. We will obtain users' authorization and consent for the collection and use of personal information through Yidian Hengtong's business partners (such as mobile app developers using Yidian Hengtong's SDK, programmatic advertising trading platforms, ad aggregation platforms, ad demand side platforms, traffic supply side platforms, etc.). In our cooperation agreements with Yidian Hengtong business partners, we have required them to commit and ensure the legality of the data sources, and they will inform users of the specific circumstances of our processing of personal information in accordance with the requirements of applicable laws, and obtain users' valid consent (separate consent as required by applicable laws when necessary), and ensure that users can revoke such consent at any time.

The Yidian Hengtong service may link to third-party websites, applications, or other third-party content. Please note that we cannot control how third parties process user information, and third parties may have privacy protection regulations that differ from those stated in this privacy policy.

When we collect personal information of business representatives of our partners, such as names and email addresses, our purpose is for business communication with them, including necessary communication to fulfill contracts with our partners.

3. The personal information we may collect

When you browse or use advertisements of services that use Yidian Hengtong or services provided by Yidian Hengtong's business partners, we and/or our business partners may collect your information. The developers of the applications may choose to share the personal information they collect with us through our SDK. For more information about how the application developers collect, use, share your personal information, and whether you agree to the developer's use of your relevant personal information, please refer to the privacy policy of the relevant application developer. Please note that we require our partners, through our cooperation agreements, to obtain your full consent in advance for the collection and sharing of your personal information that may occur during the use of our services.

(1) When we collect information through the SDK, the types of information we collect may include:

Location information:

[Required information] IP address

[Optional information] Country, time zone, and regional settings (country and preferred language)

Device/Advertising ID:

[Required information] Android ID, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID, and Amazon ID)

[Optional information] International Mobile Equipment Identity (IMEI), MAC address, International Mobile Subscriber Identity (IMSI)

Note: If you restrict your device or application software from obtaining your device/advertising ID based on Article 7 of this policy, we will not collect the corresponding information;

Device information:

[Required information] Device manufacturer, device model, device operating system information, device type, device screen information, device network information, hardware serial number, device sensor information, Limit Ad Tracking (LAT) status, phone boot time, Mobile phone user name summary, device storage capacity information

[Optional information]

CPU type, device battery information, device volume and font size, whether it is an emulator, type of system Build, tags of system Build, user of system Build, radio firmware version, system boot program version number, hardware name, host address, system development code name, system source control version number, device version number displayed, device baseboard name

Application information:

[Required information] Yidian Hengtong partner application package name, application version and features, SDK version

[Optional information]

Whether it is downloaded from an app store, list of installed applications;

Special instructions: For download ads, before displaying, it will be judged whether you have installed the product being promoted by the ad, if already installed, we will not display the ad (we call it display filtering), and when your device requests an ad next time, we will notify the server not to return the corresponding ad, thereby improving user experience. Yidian Hengtong will only report the information related to the ad that has been "display filtered" in this scenario, and will not collect any other information about installed applications.

Usage data:

[Required information] When you interact with the advertisements we promote, we collect information about your interaction with the advertisement, such as browsing, clicking on the relevant information of the advertisement.

Other information:

[Optional information] Device event information (such as system crashes, system activities), timestamps, date and time of your request and source URL, user agent.

Permission Application

Special Note: If you are using a developer application that integrates the Yidian Hengtong SDK, the Yidian Hengtong SDK will apply for the corresponding permissions through the developer application. The developer should inform you about the Yidian Hengtong SDK, the main name, the types and purposes of personal information processing, and the privacy policy, etc., and obtain your consent before using the Yidian Hengtong SDK to carry out related business functions. Due to differences in the information fields collected by different SDK versions and whether they are optional, the specific collection situation is subject to the SDK version used by the developer application you are actually using. Developers must ensure that the user agrees to the Privacy Policy before initializing the Yidian Hengtong SDK. The Yidian Hengtong SDK will only collect information and apply for permissions after the user agrees to the Privacy Policy.

Android operating system application permission list:

Permission: INTERNET mobile network request

Function: [Optional] Mobile network

Purpose and goal: Used for online advertising requests

Invocation timing: After the user clicks to agree to the privacy policy, developers call the SDK functions that require this permission.

Permission: ACCESS_WIFI_STATE - Access to WiFi network changes

Function: [Optional] Listen for WiFi network changes

Purpose and Objective: Used for updating online advertising strategy

Call Timing: After the user clicks to agree to the privacy policy, developers call the SDK functions that require this permission.

Permission: AD_ID Mobile Google Advertising ID

Function: [Optional] Permission to access the mobile Google advertising ID

Purpose and intent: For ad placement and ad monitoring attribution, anti-cheating

Invocation timing: After the user clicks to agree to the privacy policy, developers call this permission when invoking SDK functions that require it.

iOS operating system application permission list:

Permission: NSUserTrackingUsageDescription

Function: [Optional] Obtain device identifiers to identify device information

Purpose and goal: For advertising targeting and anti-cheating

Invocation timing: After the user clicks to agree to the privacy policy, developers call this permission when invoking SDK functions that require it.

(2) When you browse and click on the advertisements we promote, and then download and use the products (such as apps) advertised, we will collect the following information from the advertisers, advertising demand-side platforms, programmatic advertising trading platforms, or their third-party attribution platforms:

Location Information:

[Required] IP address

[Optional] Country, city;

Device/Advertising ID:

[Required] IMEI, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID, and Amazon ID), MAC address;

Device Information:

[Required] Device manufacturer, device model, device operating system information, device language, device type, device network information, device operator;

Application Information:

[Optional] Yidian Hengtong partner's app package name, app version;

Usage Data:

[Required] Timestamps of installation events or other events;

Other Information:

[Optional] User agent.

(3) When Yidian Hengtong acts as an advertising demand side platform ("DSP"), a programmatic advertising trading platform, traffic supply side platforms may transmit personal information to us through technologies such as API, which may include:

Location information:

[Required information] IP address

[Optional information] Country, time zone, and regional settings (country and preferred language);

Device/Advertising ID:

[Required information] International Mobile Equipment Identifier (IMEI), Android ID, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID, and Amazon ID), MAC address;

Device information:

[Required information] Device screen information, device manufacturer, device model, device operating system information, device type, device network information, we collect information about your interaction with those advertisements, such as browsing, clicking on relevant information about the advertisement;

Other information:

[Optional information] Other information transmitted by other advertising information exchange platforms or media platforms, user agent.

(4) For partners using Google Ad Manager monetization services, to enhance our service capabilities, with your explicit authorization, we will collect data related to your advertising performance in Google Ad Manager through Google API Services and display it on your account page in our backend. The fields and scope of the data we obtain will be as per your authorization.

We commit to the use of Google API Services, the collection and use of information received will comply with Google API Services User Data Policy

(https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes), including the restrictive use requirements of Google policy disclosures. You can understand all data processing activities involved in our service process through this policy (https://policy.1dots.cn).

(5) When we provide Yidian Hengtong services to our business partners, we may collect the names, positions, email addresses, contact addresses, usernames, and passwords, IP addresses of the contacts representing these business partners when they use Yidian Hengtong services. We collaborate with reputable programmatic advertising trading platforms, ad demand platforms, traffic supply platforms, and other partners. After receiving an advertising request containing your personal information, the advertising information exchange platform or media platform will, where legally permitted, transmit the personal information to Yidian Hengtong for the purpose of creating your profile, personalizing your advertising experience, and subsequently displaying advertisements to you on the internet.

Legal exemptions for processing personal information with consent

In accordance with applicable laws, we have agreed through contracts with our business partners (such as mobile app developers and advertisers using the Yidian Hengtong SDK, etc.) to obtain consent from users or their employees for the processing activities described in this privacy policy. Users or their employees may revoke consent at any time. At the same time, please understand that in the following situations, according to laws and regulations, we process your personal information without needing your authorization consent:

(1) Necessary for the establishment or performance of a contract at your request;

(2) Necessary for the performance of statutory duties or legal obligations, such as those directly related to national security, defense security, criminal investigation, prosecution, trial, and execution of judgments, etc.;

(3) Necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergencies;

(4) To carry out news reporting, public opinion supervision, etc., for the public interest, within a reasonable scope, processing personal information;

(5) Within a reasonable scope, processing personal information that you have made public yourself or other information that has been legally made public (such as legally published news reports, government information disclosure, etc.);

(6) Other circumstances stipulated by laws and regulations.

Special note: According to legal provisions, information that cannot be identified as a specific individual alone or in combination with other information does not belong to personal information. When your information can be identified alone or in combination with other information, or when we combine data that is not associated with any specific individual with your personal information, we will treat it as your personal information and process and protect it in accordance with this privacy policy.

If you are located within the European Economic Area, in necessary cases, we will use your personal information based on the "legitimate interests" stipulated by GDPR. Our legitimate interests include the following: monitoring and preventing fraudulent activities, eliminating technical obstacles in system operation, and ensuring the correct and secure operation of systems and processes.

Sensitive personal information generally refers to information that, if disclosed or used illegally, could easily lead to the infringement of a natural person's dignity or endanger their personal and property safety. The scope of this information varies according to different applicable laws.

Without your consent, we will not collect your sensitive personal information. Our business partners will only transfer or authorize us to process your sensitive personal information after fully informing you of the necessity of processing sensitive personal information and the impact on individual rights and interests, and after legally obtaining your consent.

4. How we use users' personal information

We use users' personal information in the following ways:

Types of personal information:

a: Including all types of personal information described in paragraph 3(1) to (3) of this privacy policy.

Method of use: Based on device information, your device will be identified among other devices. We will use your device information to display advertisements on your device in an automated decision-making manner. We employ de-identification techniques and recommendation algorithms based on machine learning, model prediction, etc., to generate tags, features, and build profiles for you or your interests, and based on these profiles and the calculation results of the recommendation algorithms, we will display personalized advertisements or behavioral advertisements that are relevant to you, in line with your interest preferences, approximate location, or other characteristics. Our recommendation algorithms do not identify the true identity of specific individuals.

We also use industry-standard de-identification, anonymization, and other data security technologies to further process aggregated data, creating a database of features and tags that cannot identify the true identity of specific individuals, conducting group analysis, optimizing algorithm training models, thereby better understanding and analyzing your usage trends and preferences to improve our Yidian Hengtong service quality and develop new products.

b: Contact information, including all types of personal information described in paragraph 3(4) of this privacy policy.

Method of use: We may collect and use the personal information of users who represent our partners and use Yidian Hengtong services (such as employees of our mobile app developers or advertisers) for business contact or direct marketing to them (such as sending marketing emails).

c: Sensitive personal information

Method of use: Without your consent, we will not collect your sensitive personal information.

Our business partners will only transfer or authorize us to process your sensitive personal information after fully informing you of the necessity of processing sensitive personal information and the impact on individual rights and obtaining your legal consent.

5. How we share and disclose users' personal information

Under circumstances that comply with applicable legal regulations, we may share personal information with third parties for the following purposes and scenarios:

(1) Sharing

When we purchase advertising traffic to provide monetization services for mobile app developers, or when we act as a programmatic advertising trading platform, a traffic supply-side platform, we may share users' personal information with our business partners in order to fulfill our contractual obligations to them. This includes reporting to our business partners on the performance and effectiveness of the advertisements that users interact with, including statistics on traffic quality, and for anti-fraud purposes. The personal information we share is related to the performance and effectiveness of advertisements, such as device information, clicks, impressions, installations, or activations. These business partners may use this personal information about users to statistically analyze interactions with advertisements/websites, evaluate the performance and effectiveness of advertisements that users have seen or interacted with, identify areas of interest to users, better understand the traffic and usage of websites and applications, or user behavior to improve their services. The use of the information we disclose by our business partners is subject to their privacy policies.

We may also use third-party technology service providers (such as cloud service providers) to process personal information for the purpose of ensuring the correct and appropriate operation of systems and processes, as well as for data storage.

We may also share aggregated or anonymized information with third parties based on the terms of this privacy policy.

Types of third parties: advertisers, advertising agencies, attribution service providers, demand-side platforms, affiliated companies of Yidian Hengtong.

Types of information:

①Location information: IP address;

②Device/Advertising IDs: International Mobile Equipment Identity (IMEI), Android ID, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID, and Amazon ID), MAC address;

③Device information: device manufacturer, device model, device operating system information, device type, device screen information, device battery information, device volume and font size, whether it is a simulator, device network information, device sensor information, Limit Ad Tracking (LAT) status, mobile phone boot time, mobile phone user name summary;

④Application information: application package name, application version and features of Yidian Hengtong's partner applications, whether downloaded from the App Store, SDK version;

⑤Usage data: When you interact with the advertisements we promote, we collect data on your interactions with those advertisements, such as browsing, clicking on related information;

⑥Other information: User agent.

Purposes and methods of processing:

①Used for advertising attribution;

②Used for monitoring the quality of advertising delivery;

③Used for targeted advertising.

In particular, if mobile app developers choose to use only our aggregation tool service without selecting our programmatic advertising exchange service or without selling their in-app advertising space to us, other advertising SDK integrated into our SDK require the consent of the mobile app developers, and the collection of relevant information is to be done by the third-party advertising SDK.

Specifically, if a mobile app developer chooses to use only our aggregation tool services without choosing our programmatic advertising exchange services or without selling their in-app advertising space to us, other advertising SDK integrated into our SDK require the consent of the mobile app developer and are collected by the third-party advertising SDK. The list, name, and personal information processing rules of the third-party advertising SDK are as follows:

>Abbreviation of advertising platform: Meta

Developer (name of the processing entity): Meta Platforms Inc., Meta Platforms Ireland Limited

We (herein "we" refers to Meta) collect and process types of information depending on how you use our products. For example, the information we collect is different for a user selling furniture on Marketplace and a user posting Reels short videos on Instagram. Even if you do not have an account, as long as you use our products, we will collect some information about you. The information we collect includes:

Your activities and the information you provide

Friends, followers, and other contacts

Information about apps, browsers, and devices

Information from partners, vendors, and other third parties

Subject to Meta's privacy policy, which can be found at:

https://www.facebook.com/privacy/policy

> The abbreviated name of the advertising platform: Pangle

Developer (name of the processing entity): Bytedance Pte. Ltd.,

The types of personal data we process depend on the circumstances of collection and the nature of the services or transactions requested by our partners.

When you interact with partner websites, we process certain information about you and your device. This information may be automatically collected from your device using our software code (referred to as "Software Development Kit" or "SDK"), or shared with us by other advertising trading platforms (e.g., Google DoubleClick). We also use cookies (text files inserted into your browser when you visit our partners' or customers' mobile applications and websites) and other tracking technologies available on your device.

The information we process about you may include any or all of the following categories:

A: Information obtained automatically from your device

Identifiers: We may process device-specific identifiers such as your IP address, mobile advertising identifiers (such as "Google Advertising ID" on Android phones or "Advertising Identifier" on iOS devices), or our Pangle-specific identifiers assigned to your device by our SDK. Mobile advertising identifiers are provided by your device's operating system and allow companies like Pangle to recognize your device across applications for advertising purposes. In addition to mobile advertising identifiers and similar technologies, Pangle may also obtain information about your device model, operating system (e.g., iOS or Android), language settings of your device, general geographic region, time zone, network type (e.g., 5G or WiFi), your ROM version, screen resolution (to understand which ads are best suited for your device), mobile country code and mobile network code, and the time of your device's last update and boot.

Location data: We may infer your general geographic location based on your device's IP address. With your consent or under the permission granted by applicable data protection laws, we may also use your phone's GPS data to process your precise latitude and longitude.

Internet activity: We may process information about your use of applications and websites, including the name and version of applications or websites integrated with Pangle. We may also process information about your interactions with any advertisements we provide (e.g., information about the ad displayed, viewed, or clicked, such as ad type, location and time the ad was served, whether you clicked on it, and whether you visited the advertiser's website or downloaded the advertiser's application, and any preferences you may have expressed about the ad).

B: Information obtained from other sources

We may sometimes receive information about you from other sources. For example, if the law allows third parties to disclose this information to us, we may receive information about you from third parties (e.g., advertising exchanges that share data with us for the purpose of providing advertising services).

The information we receive from these sources may include identifiers (such as your IP address or mobile advertising identifier), information about your internet activity (such as information about your interactions with third-party websites, applications, and advertisements), and inferences and attributes related to your preferences and information (such as your approximate age and gender).

Subject to the Pangle Privacy Policy at https://www.pangleglobal.com/zh/privacy/enduser-en.

>Advertising platform abbreviation: Admob & Ad manager

Developer (entity responsible): Google LLC and its affiliated companies

We (referring to Google) collect information about the apps, browsers, and devices you use when accessing Google services, in order to provide useful features such as automatic product updates, dimming the screen when the battery is low, and so on.

The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information (including carrier name and phone number), and app version number. We also collect information about your interactions with Google services through your apps, browsers, and devices, including IP addresses, crash reports, system activity, and the date, time, and referrer URL of your requests.

When your Google services on your device communicate with our servers (for example, when you install an app from the Play Store, or when the service checks for automatic updates), we collect this information. If you use an Android device with Google apps installed, your device regularly communicates with Google servers to provide information related to your device and its connection to Google services. This information includes your device type and carrier name, crash reports, the apps you have installed, and other information about how you use your Android device (depending on your device settings).

Subject to the Admob privacy policy at https://policies.google.com/privacy

>Appnext advertising platform abbreviation: Appnext

Developer (processing entity name): Appnext PTE. Ltd,

Device and application information: This category includes the type and model of your device, system language, device operating system (e.g., Android or iOS), SDK version, mobile carrier name, mobile browser installed on the device (e.g., Chrome or Safari), application history and usage information (e.g., information about applications running and installed on the device), information about mobile application downloads and installations, and any information about in-app events (e.g., in-app purchases).

Advertising information: This category includes information about online advertisements and personalized content we have provided to you (or attempted to provide). It includes the number of times ads have been served to you, on which page the ad appeared, whether you viewed, clicked, or otherwise interacted with the ad, ad engagement history, and whether you visited the advertiser's website, downloaded the application, or purchased a product or service advertised.

Location information: Appnext collects information about your approximate location (e.g., city and country/region). For example, we may use your IP address to identify your approximate location. This information does not tell us the exact location of your device. The information is sent as a normal part of internet traffic. Additionally, we also collect implicit location information, which allows us to infer that you are interested in a certain location or that you may be at that location; this information does not actually tell us the exact location of your device. Furthermore, Appnext may collect precise location information from your device (using GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, beacon signals, and cellular tower IDs, which can be used to derive or estimate precise location or other geolocation information). When end-users enable location services for mobile applications or websites using our SDK (you typically must choose to turn on device-based location services).

Log information: This category includes the application or website accessed, session start/stop times, timezone, and network connection type (e.g., WiFi, cellular network), as well as cookie information.

Information from advertising partners ("advertisers") and other third parties: This category includes information we receive from publishers, advertisers, and other partners who help us provide you with advertisements and personalized content and identify you on browsers and devices. This may include some pseudonymous advertising identifiers that advertisers or other third-party advertising platforms choose to share with us. This information is also used to enhance data points about specific unique browsers or devices.

Subject to Appnext's privacy policy at

https://www.appnext.com/privacy-policy-oem-operators/

(2) Disclosure

We will disclose your personal information in accordance with legal requirements to comply with court summonses, other similar legal procedures, or government requests; or, when we believe that the disclosure of relevant personal information is required by law or necessary to protect our rights, property, the rights, or that obtain all or part of our business through merger, acquisition, reorganization, or other forms.

For the purposes of this privacy policy, our affiliated companies may also obtain users' personal information.

6. International Data Transfer

If you are located within the European Economic Area, the information we collect about you will be transferred to or accessed from countries outside the European Economic Area, including the United States and other countries that have not been deemed by the European Commission to provide an adequate level of protection for personal data. However, we will take appropriate measures to ensure that your personal data is adequately protected in accordance with applicable laws. In the event of legal requirements, our business partners (such as mobile app developers and advertisers using the Yidian Hengtong SDK) will obtain your consent for the transfer of your personal data outside the European Economic Area, including to Yidian Hengtong, Yidian Hengtong's affiliated companies, or other recipients as stipulated in this privacy policy. You may withdraw your consent at any time.

7. Your Information Rights

If you are located within the European Economic Area, you have the following rights (subject to a few exceptions as stipulated by the GDPR): (i) to access, modify, or delete personal information; (ii) to restrict or object to the processing of your personal information; and (iii) to request an electronic copy of your personal information to be provided to yourself or a third party. Additionally, you have the right to lodge a complaint with the data protection authority in your European Economic Area country regarding the processing of your personal information.

If you are a resident of California, United States, starting from January 1, 2020, you have the following rights:

(i) Exercise relevant consumer rights, such as: by sending an email to yidianhengtong@126.com, you can request to know, disclose, obtain, and delete data collected in the past 12 months; and (ii) request to prohibit the sale of your data.

If you are a resident of Virginia, United States (effective from January 1, 2023), or if you are a resident of Colorado or Connecticut, United States (effective from July 1, 2023), you can exercise the following rights regarding personal information:

Confirm whether we are processing your personal information and access this information;

Correct inaccuracies in your personal information;

Delete your personal information;

Obtain a copy of the personal information you have provided to us; and request that we do not process your personal information for the purposes of: (i) personalized advertising, (ii) selling your personal information, or (iii) creating user profiles that could have a significant legal or similarly significant effect on you.

As stipulated by the VCDPA, CPA, and CDPA, you have the right to exercise these rights without discrimination.

You may (i) exercise your rights regarding the aforementioned personal information by sending a written request to yidianhengtong@126.com; and (ii) click this link to request the cessation of personalized advertising, the sale of your personal information, and the creation of user profiles that could have a significant legal or similarly significant effect on you. If you fail to provide valid information when exercising these rights, which would enable us to provide an effective response, we may deny your request. If you have a disagreement, you may further submit a written appeal to yidianhengtong@126.com.

If you are a resident of Utah, United States, starting from December 31, 2023, you can exercise the following rights regarding your personal information with us:

Confirm whether we are processing your personal information and access that information;

Delete your personal information;

Obtain a copy of the personal information you have provided to us; and

Request that we refrain from processing your personal information for the purposes of: (i) targeted advertising, or (ii) selling your personal information.

You have the right to exercise these rights without discrimination as stipulated by the UCPA.

Settings for targeted advertising

Regardless of the country or region you are in, you can opt out of interest-based advertising through the following methods.

Instructions on opting out

You can choose to opt out of receiving interest-based or behavioral advertising from Yidian Hengtong on devices that support such functionality by following the instructions below.

Your iOS mobile device offers a "Limit Ad Tracking" setting. On Android devices, your settings may allow you to "opt out of interest-based ads." If you enable this setting on your device, Yidian Hengtong will not use application information collected from your device to infer your interests or to serve targeted advertising to your devices based on inferred interests.

Your mobile web browser may also offer a "Do Not Track" browser setting. If this setting is enabled on your browser, Yidian Hengtong will not use mobile web browser information collected from your browser to infer your interests or to serve targeted advertising to your devices based on inferred interests. If you have any questions about your information rights, please contact yidianhengtong@126.com.

8. Security of User Personal Information

Protecting your personal information security is our top priority. To prevent unauthorized access, use, disclosure, or destruction of your personal information, we will implement strict security measures. We will adopt physical, technical, and administrative measures that comply with relevant laws and industry standards. For example, we will use firewalls, encryption technology, and other automated software designed to prevent fraud and identity theft; we only store information on devices and in locations that can provide a high level of protection. We also implement strict monitoring of data access through video and other electronic surveillance methods at the periphery and entrances to buildings.We will minimize the storage of sensitive information on our servers to protect your privacy. We will also require our partners to contractually protect user data.

Yidian Hengtong may retain information related to you that we collect from our business partners to provide services, conduct internal analysis, comply with legal obligations, resolve disputes, and execute contracts (such as settlements). We will only retain your personal information for as long as necessary, and the retention period for personal information collected about you under this privacy policy does not exceed 2 years. The criteria for determining the retention period include: (i) the duration for which personal information needs to be retained to provide services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to legal, contractual, or other similar obligations to retain data (for example: mandatory data retention laws, government requirements to retain data related to investigations, or data that must be retained for litigation or disputes).

9. Protection of Minors

The Yidian Hengtong service primarily targets adults and we do not actively or deliberately collect information about minors, nor do we create user profiles or personalized recommendations for them. In the scenarios where we disclose personal information collection, we distinguish specific information subjects through device information, not by age. In scenarios where our partners transmit and share data with us, we explicitly require our partners to formulate specific minor information protection policies according to the actual situation of their own products and services, and adopt stricter data desensitization and encryption technologies to protect minors.

If the end user is a minor under the applicable laws, please make sure to read the privacy policy of the developer's application or the advertiser's application that has integrated Yidian Hengtong products and services or cooperates with Yidian Hengtong for advertising, together with the parents or other guardians, carefully before using the application, and use the application or provide personal information only after obtaining the consent of the guardian.

We protect minors' personal information in accordance with the relevant laws and regulations applicable, and will only collect, use, store, share, transfer, or publicly disclose minors' personal information when permitted by law, with the explicit consent of parents or other guardians, or when necessary to protect minors. If we find that we have collected minors' personal information without prior verifiable parental consent, we will take measures to delete the information as soon as possible.

If you are a parent or other guardian of a minor and have questions about the personal information of the minor you are supervising, please contact us through the contact information provided in this privacy policy.

If you are a user in the United States, we guarantee compliance with the Children's Online Privacy Protection Act (COPPA). If our business partners (e.g., application developers) target users under the age of 13, they must make the relevant COPPA settings on the Yidian Hengtong platform when using Yidian Hengtong services, so that Yidian Hengtong can ensure that the processing of persistent identifiers collected from users of these applications complies with COPPA regulations, including not using them for targeted advertising or for tracking users for that purpose. In addition, we will not deliberately collect other personal information (such as accurate location information) from applications that we know are targeted at children under the age of 13.

If parents or guardians find that their children have provided their personal information to us without consent, parents or guardians should contact us promptly. We will take reasonable measures to ensure that this information is deleted from our records.

10. Marketing Promotion

If you are our business partner, we may periodically send you information about our products, services, and content that may interest you via email. If applicable laws require us to obtain your consent before sending you marketing information, we will only send you such information after receiving your consent.

If you do not wish to receive such marketing information, you can unsubscribe at any time by following the instructions provided in the marketing emails or by sending an email to yidianhengtong@126.com requesting to stop receiving such information.

Yidian Hengtong Website Privacy Policy

1. Introduction

This Yidian Hengtong website privacy policy applies to the collection and use of information by the website, including the information collected and used when you browse and use the Yidian Hengtong website. If the provisions of European data protection laws are applicable, Yidian Hengtong is the data controller of your personal information under the European data protection laws. If you have any questions, comments or suggestions, please contact us through the following contact information: Email: yidianhengtong@126.com

2. Information We Collect

When you visit the Yidian Hengtong website, personal information you actively provide (such as: name, date of birth, personal identification number, address, phone number, email address, occupation, educational background, work experience, and other related information) will be collected. Some information that you do not actively provide, such as browser type, domain, IP address, pages visited, and the duration of browsing using different technologies and methods, including the collection of IP addresses, Cookies, internet tags, and browsing data. To improve our service quality, we need your personal information to fulfill your personal needs and provide better services. Yidian Hengtong has the right to take measures to verify the accuracy of the information you provide. If the information you provide is someone else's personal information, we assume that you have obtained their permission. Information transmission on the Yidian Hengtong website may not be confidential, so the information you transmit may be read or intercepted by others.

3. How we use your personal information

Based on our legitimate interests, you may need to provide us with your personal information for the following purposes: (i) to provide you with Yidian Hengtong's products, services, or relevant information; (ii) to register you for related events or training; (iii) to contact and respond to your requests and inquiries; (iv) for business management, including data analysis; (v) to provide you with personalized access and assistance when using our website; or (vi) to help us understand our users and improve our website.

We will regularly send you information about our products, services, and content that may interest you via email. If required by applicable laws, we will only send you marketing information after obtaining your consent, and we will seek your consent before sending such marketing information.

If you do not wish to receive such marketing promotions, you can unsubscribe at any time by following the instructions provided in the marketing information or by sending an email to yidianhengtong@126.com requesting to stop receiving such promotional information.

4. Disclosure of Your Personal Information

In accordance with applicable legal requirements, we may share your personal information with third parties other than Yidian Hengtong affiliated companies.

We may engage third parties to provide services to us, including companies that assist with the development and operation of the Yidian Hengtong website at the program and technical levels, service providers that assist with technical services to analyze website usage, and email service providers. Such third parties may obtain your personal information. Our affiliated companies may also obtain your personal information through the Yidian Hengtong website or in connection with the Yidian Hengtong website pursuant to the purposes set forth in this Privacy Policy.

We may also share aggregated or anonymized information with other third parties in accordance with the terms of this Privacy Policy.

For the purposes of this Privacy Policy, our affiliated companies may also obtain users' personal information.

The network servers used in the operation of the Yidian Hengtong website automatically identify (your) computer based on the IP address. However, once you leave the Yidian Hengtong website, we will not be able to identify (your) computer based on that IP address. If we believe that you have attempted or already abused or damaged the website, we will conduct investigations and cooperate with relevant law enforcement agencies to protect our legal rights and interests.

At the same time, we will provide your personal information in accordance with legal requirements or as permitted by law in response to a court summons, other similar legal procedures, or government requests; or we believe that, in accordance with legal provisions, or to maintain our and/or other third parties' (including consultants, law enforcement agencies, judicial supervision departments) legal rights and security, such information disclosure is necessary. We may also transfer your personal information to third parties that acquire all or part of our assets, shares, or that succeed to all or part of our business through merger, acquisition, reorganization, or other means.

5. International Transfer

If you are located within the European Economic Area, the personal information we collect, including information collected from the Yidian Hengtong website, will be transferred to countries outside of the European Economic Area, including to Singapore where the Yidian Hengtong website servers are located, and to other countries that have not been deemed by the European Commission to provide an adequate level of protection for personal data. By using this website, you explicitly agree to the transfer of your personal information to recipients outside of the European Economic Area, including to Yidian Hengtong,Yidian Hengtong's affiliated companies, and other recipients as specified in this privacy policy.

6. Your Information Rights

You have the right to access, modify, rectify, or delete any personal information we may have collected about you. To exercise these rights, please contact yidianhengtong@126.com.

If you are located within the European Economic Area, you will have the following rights (subject to a few exceptions): (i) to request access to, rectify, or erase your personal information; (ii) to restrict or object to the processing of your personal information; and (iii) to request the electronic copy of your personal information to be transferred to another organization or a third party. Additionally, you have the right to lodge a complaint with the data protection authority in your European Economic Area country regarding the processing of your personal information.

If you are a resident of California, United States, starting from January 1, 2020, you have the following rights:

(i) To exercise relevant consumer rights, such as: by sending an email to yidianhengtong@126.com, to request to know, disclose, obtain, and delete data collected in the past 12 months; and (ii) to request to prohibit the sale of your data: Please do not sell my data.

If you are a resident of Virginia, United States (effective from January 1, 2023), or if you are a resident of Colorado or Connecticut, United States (effective from July 1, 2023), you can exercise the following personal information rights with us:

• To confirm whether we are processing your personal information and to access this information;

• To correct inaccuracies in your personal information;

• To delete your personal information;

• To obtain a copy of the personal information you have provided to us; and

• To request that we refrain from processing your personal information for the purposes of: (i) personalized advertising, (ii) selling your personal information, or (iii) creating user profiles that have a significant legal or similarly significant effect on you.

As stipulated by VCDPA, CPA, and CDPA, you have the right to exercise the aforementioned rights without discrimination.

You may (i) exercise your aforementioned personal information rights by sending a written request to yidianhengtong@126.com; and (ii) click this link to request to prohibit personalized advertising, to prohibit the sale of your personal information, and to prohibit user profiles that have a significant legal or similarly significant effect on you. If you fail to provide valid information for us to provide effective feedback when exercising the aforementioned rights, we may refuse to honor your request. If you have a disagreement, you may further send a written appeal to yidianhengtong@126.com.

If you are a resident of Utah, USA, starting from December 31, 2023, you can exercise the following rights regarding your personal information with us:

- Confirm whether we are processing your personal information and access that information;

- Request the deletion of your personal information;

- Obtain a copy of the personal information you have provided to us; and

- Request that we refrain from processing your personal information for the purposes of: (i) targeted advertising, or (ii) selling your personal information.

As stipulated by the UCPA, you have the right to exercise these rights without discrimination.

7. Your Personal Information Security

We commit to protecting your personal information security. We employ various protective technologies and procedures to safeguard your personal information, preventing unauthorized access, use, or disclosure of your personal information. We will only retain your personal information for as long as necessary, and for any personal information collected on our website, we will retain it for one year.

8. Protection of Minors

This website will not intentionally collect personal information from minors. Any personal information you provide about minors must be obtained with the prior consent of the minor's parents or guardians. The definition of minors is determined by the laws applicable to this privacy policy.

9. Use of Cookies and Other Tracking Technologies

When you visit the Yidian Hengtong website, Yidian Hengtong may use cookies or other technologies (collectively referred to as "Cookies") to collect your personal information.

10. External Websites and Links

This website may contain links and pointers to websites operated by third-party vendors and other third parties ("External Websites"). Yidian Hengtong is not responsible for the validity of External Websites or the content of External Websites (including any webcasts or other forms of content transmitted or received from any External Website). If you have any questions about the relevant links or content on External Websites, please contact the administrators of the External Websites. If a third party has notified Yidian Hengtong that it intends to link to Yidian Hengtong's homepage and Yidian Hengtong has not refused, then Yidian Hengtong allows that third party to link to Yidian Hengtong's homepage. Yidian Hengtong reserves the right to revoke this consent at any time, including the links to its homepage. Any External Websites provided by this website are for your convenience only. Any links or pointers contained in this website do not imply endorsement of the External Websites.

11. Copyright

All website content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video, as well as all arrangements thereof, are the exclusive property of Yidian Hengtong or its respective content providers and are protected by copyright laws of the Hong Kong Special Administrative Region and international copyright laws. All software used on the website is the property of Yidian Hengtong or its respective software suppliers and is protected by copyright laws of the Hong Kong Special Administrative Region and international copyright laws, as well as other relevant laws and treaties. Website users are not permitted to send/upload any content that infringes upon the copyright or other intellectual property rights of others to this website.

12. Trademarks

All trademarks, service marks, and commercial names used on the website (collectively referred to as "Marks") are the exclusive property of Yidian Hengtong. These Marks must not be used on any non-Yidian Hengtong products or services, or on any other products or services that may cause consumer confusion, or in any way that disparages or discredits Yidian Hengtong's reputation.

13. Online Behavior

As Yidian Hengtong believes that any individual restricting or prohibiting others from using this website, Yidian Hengtong has the right to prohibit such behavior. You agree to use this website solely for lawful purposes and agree not to engage in the aforementioned prohibited activities. You agree not to upload or disseminate any illegal, harmful to others, threatening, abusive, harassing, defamatory, vulgar, obscene, with clear sexual implications, blasphemous, hateful, racist, ethnically discriminatory, regionally discriminatory, or any other type of inappropriate information to this website, including but not limited to any information that incites illegal activities, such as any that constitutes a criminal offense, civil liability, or other violations of applicable local, state, national, or international laws.

14. Termination of Use

Yidian Hengtong reserves the right to terminate or suspend your access to all or part of the website without notice and without liability for any violation of applicable laws, this privacy policy, or actions that harm other users, third parties, retailers, sponsors, licensors, service providers, or the website's interests.

Given the rapid development of internet technology and the updating of privacy-related regulations, we will update this privacy policy periodically. All revisions will be announced on the website at https://policy.1dots.cn.