Privacy Policy

Last updated: Dec. 13, 2019
Effective date: Dec. 20, 2019

You are welcome to use the services provided by Shanghai Youkun Information Technology Co., Ltd. (hereinafter referred to as "MobTech" or "we"). Our registered address is Room JT6651, Building 2, No. 4268 Zhennan Rd., Jiading District, Shanghai. MobTech strictly complies with laws, regulations and the principles of privacy protection to formulate this Privacy Policy (hereinafter referred to as "this policy"). This policy applies to the processing and protection of personal information that you provide in the course of using our products and / or services, which product and / or services is including but are not limited to developer services, data services, and other products that already exist or occasionally developed.

The security of the personal information of you and your end users is important to us. We respect and protect the privacy of you and / or your end users, and we have always been committed to providing a secure network environment for you and / or your end users. We protect the personal information of you and / or your end users in accordance with the "Internet Security Law of the People's Republic of China" and the laws and regulations of the Internet industry on information protection, and refer to the recommended national standards such as "Information Security Technology Personal Information Security Specifications" (GB/T 35273-2017) / draft for comments. This policy describes the purposes, methods, scope, and information security measures we use to collect, use, save, share, and transfer personal information of you and / or your end users in the products and / or services of this platform, and the rights and methods we provide for you to access, update, delete, and control personal information. In order to make it easier for you to read and understand this policy, we try to use simple and easy-to-understand expressions and define key terms. Please refer to the “Appendix 1: Keyword Definition” of this policy.

You acknowledge and confirm that you have read and fully understood all aspects of this policy at the time of registration. We remind you that we use special “blackened and italicized” reminders for sensitive personal information. Before providing us with any personally sensitive information that belongs to you and / or your end users, please clearly consider that such provision is appropriate and agree that we can process personal sensitive information of you and / or yours end usersfor the purposes and methods described in this policy. With your consent we will collect and use sensitive personal information of you and / or your end users to achieve the relevant functions provided by this platform. We allow you to make disagreement about the collection and use of personal sensitive information of you and / or your end users, but yourrefusing to provide such information may affect the platform to provide you with relevant service functions. For example, if you or your end users do not agree with our collection of geographic location information, we will not be able to provide you or your end users with social sharing of geographical location and intelligent push services in specific regions; if you or your end users do not agree with us to collect the mobile phone number, you will not be able to use SMSSDK's SMS verification basic functions and one-click verification basic functions of the productSeconds Verification.

This policy is integral to the Terms of Service. To protect the rights and interests of you and your end users, please read all the terms of this policy in detail, and complete the registration in accordance with the instructions on the page, after fully understanding its meaning. After completing the registration, you will get the related services provided by Shanghai Youkun Information Technology Co., Ltd. We have added a Compliance Guide to our website documentation to help you use MobTech products or services in a smarter and more private way. If you click the "I agree" button during the registration process, which means you have read and fully accepted all the terms of this policy, and you know and expressly agree that we will process, use and disclose information about you and your users in accordance with the provisions of this policy.  If you do not accept all or part of the terms of this policy, or do not fully understand the meaning of all or part of the terms of this policy, please do not install, use, register or access to products or services we provide, including the MobTech platform, website, etc.

It's important to note that when you use our products and services, we will process two types of personal information, as the description in the first part of this policy "How Do We Collect and Use Personal Information of You and / or Your End Users " for details.

The way we process these categories of personal information will be different, because we have a direct contractual relationship with you, which is different from our indirect relationship with your end users. As our customer, if you use our products or services to provide additional services to your end users, you should separately reach an agreement with your end users on the privacy policy in accordance with applicable laws and regulations. In this regard, MobTech does not assume any legal responsibility. You should clarify to your end users in your privacy policy or a legal document of similar functionality that MobTech's product or service is integrated into your service, and ensure that  the personal information collected through our products or services has been authorized by the end user, and the personal sensitive information has been explicitly authorized by the end user, such as geographic location information.

Special note for end users: Because MobTech's services are part of the developer service, when you click the "I agree" button to accept the developer's user agreement, terms of service and other documents, you also signify your acceptance of this policy.

This policy helps you understand the following:
A. How Do We Collect and Use Personal Information of You and / or Your End Users
B. How Do We Use Cookies and Similar Technologies
C. Authorization and Consent of End Users
D. How Do We Share, Transfer, and Publicly Disclose the Personal Information of You and / or Your End Users
E.How Do We Protect The Personal Information of You and / or Your End Users
F.How Do We Give You The Right to Manage Personal Information
G. How Do We Handle Children's Personal Information
H.How Do We Store Personal Information about You and / or Your End Users
I. How to Modify And Update This Policy
J.How to Contact Us
K. Obligation of Confidentiality
Appendix A: Keyword Definition

 

A. How we collect and use personal information about you and / or your end users

Personal information refers to all kinds of information recorded in electronic or other ways that can identify the identity of a specific natural person or reflect the activity of a specific natural person, either alone or in combination with other information.

In accordance with the relevant laws and regulations mentioned in the introduction, we will follow the principles of legitimacy, lawfulness, and necessity, and collect and use the personal information of you and / or your end users for the following purposes described in this policy, which information are provided by you in the course of using the platform, generated as a result of your use of the platform, or obtained by us from third parties.

Regardless of how the personal information of you and / or your end users is collected and used in any of the above ways,Mobtech will only collect and use your personal information for business functions described in this policy. We generally only do this with your consent, except in some cases where personal information is collected from you and / or your end users based on legal obligations or where it may be necessary to protect the important interests of you or others.

Please understand that due to changes in business strategy, the functions of products and / or services on this platform may also be changed and developed. If we use the personal information of you and / or your end users for other purposes not specified in this policy, or if the personal information collected for a specific purpose will be used for other purposes, We will inform you in a reasonable way through this platform, and obtain your consent again before we use.

1．   Personal information that you actively provided when providing you with products and / or services

In order to implement the basic business functions of this platform, we may need to collect relevant personal information from you and your end users. The following will detail our basic business functions and the personal information collected to achieve this function. If you or your end users refuse to provide them, you will not be able to use the related products and / or services of this platform.

(1)    Registration and registration

When you sign up for a MobTech account, you need to provide us with your mobile phone number so that we can communicate with you about product usage and payment. Our system automatically stores your information. Please provide detailed and accurate information during registration, and update the registration information in time. All the original input information will be cited as registration information. You will be responsible for any adverse consequences caused by the untrue registration information. It is recommended that you keep your account and do not transfer or lend your account and password to others. If you find that your account has been illegally used, stolen or lost, we recommend that you notify us immediately. You will be responsible for any adverse consequences caused by hacking or your negligent storage of your account and password.

(2)    Developer certification

After you register for this platform, we need to verify your identity before officially using the each functions of SDK. If the developer is a natural person, you need to provide your own name and ID number; if the developer is a legal person, you need to provide the company name, unified social credit code, etc. for real-name authentication; we will call a third-party interface for verification. If the verification is passed, your certification is successful; if the verification is not passed, you will be transferred to a manual connection, we will ask you to further provide a copy of your ID card or business license for review.

(3)MobTech SMS / Authentication

When you use the platform's SMS / authentication services (such as Seconds Verification, SMSSDK) to verify the official identity of your end user, you need the end user to actively provide a mobile phone number to authorize MobTech to obtain SIM, device identification and other related information so that we can Send relevant SMS / authentication services to your end users and ensure billing accuracy.

If the end user wants to further use the services provided by you (App maker) through the address book, such as adding contacts friends, etc. You must take the initiative to explicitly authorize the SMS / authentication service product to obtain the address book information. This product will match mobile phone numbers through your end user's address book, and return the associated mobile phone number to you (App manufacturer), and you (App manufacturer) will provide corresponding services for your end users based on the mobile phone number relationship.

2. Relevant personal information of your end users we collect and use when providing products and / or services to you

In addition to this policy, we also establish MobTech data service system based on the Terms of Service agreed with the developer and the data collected with the authorization of the end user (which is de-identified or anonymized immediately after collection) and obtained by legal means (abstractly data). This data service system will provide you or a third party with data services (such as branding, marketing, commercial real estate, risk control and other services), and make Industry reports such as effect evaluations or behavior model analysis, which can be applied to publishers, industries, specific regions and markets. These industry reports will be presented in an unrecognizable aggregate form, including both self-published by MobTech and customized forms based on your needs.In special cases, we will also make an evaluation result of an end user or a certain type of end user according to the statistical model of MobTech. The evaluation result may be derived from the data obtained from your application, so it has a certain consistency with your application.These evaluation results are calculated based on the data model, used for evaluation purposes, and are aggregated and anonymous.

We will cooperate with third parties and use the processed and processed data of MobTech for commercial purposes in various forms. These cooperation include but are not limited to: cooperation with Advertisers, Advertising Alliances or other Advertising Operators, and Communication Operators , Using data for ad serving and marketing services. The data we share with third parties does not contain any personal privacy or identifiable content.

The personal information we collect and use in providing you with our products and / or services is detailed below. The collection of this personal information will only take place if you confirm that you have obtained the consent of the end user and that the end user has not asked us to refuse the service, request authorization to change, delete personal information, or cancel the account

(1)If the personal information that you or your end user refuses to provide is collected by our basic business functions and the network services provided to achieve that function, then you cannot use the related products and / or services of this platform.

We will collect the information of your end users by calling the relevant interface of the system. The terminal information we have obtained is: SDK version, Operator information, IP address, System platform, System version, Application package name and version, Pre- and post-application time, Independent Device Identification, IOS advertising identifier (IDFA), Network card (MAC) address, International Mobile Equipment Identity (IMEI), Anonymous device identifier (OAID), International Mobile Subscriber Identity (IMSI), Device manufacturer, Device model, Device language, Application list information, Base station information, Sensor information, Bluetooth information, WIFI status information, CPU information, Memory information, Device information, Battery usage.

(2) In addition to the information listed in item (1) of this article, based on the functional differences of different products or services in the Mob Service we provide, the information we collect in the specific scenarios of each product or service is as follows:

1)ShareSDK is a social sharing service we provide that supports one-click sharing and third-party login authorization services in more than 40 major global social platform accounts such as WeChat, Douyin, QQ, Weibo, Facebook, and Twitter. It not only greatly facilitates the service experience of your end users, but also provides you with a real-time understanding of the data such as the number of shares, reflows, and intention sharing of end users for statistical analysis. In order to trace the source of your closed-loop sharing function and help you operate more refined, such as to facilitate your end users to identify the geographical location of social sharing, we will call the relevant interface of the system to collect your end user information, including personal sensitive information: geographical location.

2) SMSSDK is a completely free SMS verification service that integrates the top channels of China Mobile, China Unicom, and China Telecom. It is suitable for your end users login and registration, password retrieval, and payment authentication. In this service, in order to realize the security of SMS verification for your end users and the function of matching with friends in the address book, we will collect the information of your end users by calling the relevant interface of the system, including personal sensitive information: mobile phone numbers and address books. If your end user does not agree with our collection of mobile phone numbers, the SMSSDK service will not function properly.

3) MobLink is a one step service provided by us to realize deep linking on the mobile terminal. It is suitable for your end users to wake up the APP you developed with one click and to connect and transfer data with your developed APP through applets, QR codes, web pages, SMS, etc. To ensure the normal provision of MobLink services, and track the newly installed (registered) end users in real time, implement the traceability of the source, we will collect the information of your end users by calling the relevant interface of the system, including: jump links, parameter information(Cipher text), browser (including built-in browser of the application) UA, application Team ID (iOS), application signature fingerprint (Android), download address (including Application Treasure address), and necessary parameter information for some web pages

4) MobPush is an intelligent push service we provide, which fully supports vendor-level channels such as Huawei, Xiaomi, Meizu, OPPO, VIVO, etc. It is suitable for situations where you need to implement different message pushes for different scenarios and end user groups. In order to push messages to your end users (including your end user shutdown notifications, etc.), divide your end user's behavior into different groups for accurate push, and present "push reports" and "statistical reports" to you, We will collect the information of your end users by calling the relevant interface of the system, including personal sensitive information: mobile phone number, geographical location. If your end user does not agree with our collection of mobile phone numbers, MobPushcannot be used normally with your end user disabling notifications; if your end user does not agree with our collection of geographic locations, MobPush cannot implement the function that push messages targeted at specific regional groups.

5) The Seconds Verification is a product we provide to help you implement one-click verification. This product supports three major operator number authentication and completes three network interconnections at one time, thereby reducing the end users churn rate caused by verification. In order for your end users to quickly and easily register, log in to the APP you developed, and ensure the security of the end user's account, we will call the relevant interfaces of the system to collect your end user information, including operator information, network status, and personal sensitive information: mobile phone number. If your end user does not agree with our collection of mobile phone numbers, our Seconds Verification products cannot provide services.

6) Advertising SDK is an advertising technology service we provide to you so that you can provide traffic services to your end users more accurately or you can provide suitable advertising spaces to advertisers. In order to provide you with traffic quality analysis services and guide advertisers' marketing goals, and provide accurate and comprehensive advertising data analysis reports, we will collect system information of your end users by calling system-related interfaces, including the devices of end users who click on ads Information, but we do not provide personally identifiable information about you and / or your end users, or we aggregate this information so that it does not identify you and / or your end users personally. If you uninstall or close the services of our advertising SDK, the advertising traffic analysis and advertising space provision services related to the APP you developed will not work properly.

(3)Despite the provisions of paragraph (1), paragraph (2) of the agreement in the form of personal information you collect end users, we may, when necessary, to include but not limited to pop-ups, links, and other forms of direct end users explicitly asks you to decide whether we are authorized to collect sensitive personal information of end users.

(4) In order to meet the basic requirements of laws and regulations and provide services, to ensure the security of your account and system operation, and to more accurately prevent phishing website fraud, we will collect relevant information generated by you or your end users during the use of MobTech services to determine the risk of your account, to ensure that MobTech provides you with normal services, statistics of traffic, troubleshooting of abnormal information, and detection, prevention and investigation of fraud, abuse or security incidents, etc. This information includes:

1) Log information

When you or your end users visit and browse the MobTech website or use MobTech products and / or services, we will automatically collect details of your or your end users' use of MobTech products and / or services and save them as web logs, including Internet Protocol (IP) address, browser type, Internet service provider (ISP), reference / exit page, operating system, date / time stamp and click data stream.

2) Device information

We may collect your end user’s device attribute information [SDK version, Carrier information, IP address, System platform, System version, Application package name and version, Pre and post application time, Independent device identification, IOS advertising identifier (IDFA), Network card (MAC) address , International Mobile Equipment Identity (IMEI), Anonymous Equipment Identifier (OAID), International Mobile Subscriber Identity (IMSI), Device manufacturer, Device model, Device language, Application list information, Base station information, Sensor information, Bluetooth information, WIFI status information, CPU information, Memory information, Device information, and Battery usage] through the Mob Service listed in item (2) of this article [i.e., social sharing (ShareSDK), SMS verification (SMSSDK), deep link (MobLink), message push (MobPush), Seconds Verification, etc.] to investigate security incidents, detect and prevent fraudulent activities, detect and prevent network attacks and abuses to ensure network security and operational security.

We promise that we will never collect or require you to collect some personally sensitive information, including but not limited to personal race, political orientation, religion, belief, personal genetic or biometric data, sexual orientation, etc.

When we use personal information for other purposes not specified in this policy, we will notify you in advance, and we will also ask you to notify your end users and ask for their consent. When we use information collected for a specific purpose for other purposes, we will also notify you in advance and ask you to notify your end users and ask for their consent.

3. Personal information of you or your end users we obtain from third parties

(1) We may collect and use personal information of you or your end users from third parties (our partners) within the scope of your or your end users's authorized consent. We guarantee to handle personal information of you or your end users in strict accordance with the contracts signed with third parties and relevant laws and regulations. At the same time, you and your end users are requested to read the third party's privacy policy and user agreement in detail. If you or your end user refuses to a third party to collect, use or transfer personal information of you or your end user when providing services, it may result in that you or your end user cannot use the corresponding services of MobTech.

(2) We may obtain, appropriately use public information of you or your end users through public channels such as web pages, or obtain business information that your company has publicized from third-party providers to help us better understand Customer base, such as your industry, the size of your business, and the URL of your business website.

4. Exceptions to Authorized Consent

Please understand that in the following situations, in accordance with laws and regulations and relevant national standards, we do not need to obtain your and / or your end users's authorization to collect and use your and / or your end users's personal information:
A) Directly related to national security and national defense security;
B) Directly related to public safety, public health, and major public interests;
C) Directly related to crime investigation, prosecution, trial and judgment enforcement;
D) For the purpose of safeguarding the important legal rights of you or other individuals, but it is difficult to obtain the consent of this person;
E) The personal information of you and / or your end users is disclosed to the public by yourself;
F) Personal information of you and / or your end users collected from legally publicly disclosed information, such as legally news reports, government information disclosure and other channels;
G) Necessary for signing or performing a contract at your request;
H) Necessary for maintaining the safe and stable operation of software and related services, such as finding and handling software and related service failures;
I) Other situations required by laws and regulations.

You are particularly reminded that if the information cannot identify you and / or your end users individually or in combination with other information, it does not belong to the personal information of you and / or yourend users in the legal sense. When the user's relevant information can identify you and / or your end user's personal identity alone or in combination with other information, Or when we use data that cannot be linked to any specific personal information in combination with other personal information of you and / or your end users, during the combined use of this information, it will be processed and protected as personal information of you and / or your end users in accordance with this policy.

B.  How Do We Use Cookies and Similar Technologies

1. Cookie

To make sure our website works, we store small data files called cookies on your computer or mobile device. Cookies usually contain an identifier, a site name, and some numbers and characters. The main functions of cookies are to make it easier for you to use the products and / or services of this platform, and to help websites count the number of unique visitors. Using cookie technology, we are able to provide you with more thoughtful personalized services and allow you to set your specific service options.

When you use our products and / or services, cookies are sent to your device. When you interact with the services we provide to our partners, we allow cookies (or other anonymous identifiers) to be sent to our servers.

We do not use cookies for any purpose other than the purposes described in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies stored on your computer, and most web browsers have a feature that blocks cookies. However, if you do this, you will need to change your user settings every time you visit our website, and you may not be able to log in or use the services or features provided by mob that rely on cookies due to such modifications.

For more information about the types of cookies we use, why, and how we control cookies, see AboutCookies.org.

2. Website beacons and pixel tags

In addition to cookies, we use other similar technologies such as web beacons and pixel tags on our websites. For example, an email we send you may contain a click URL that links to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences and improve customer service. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tags in the email, we can know if the email was opened. If you do not want your activity to be tracked this way, you can unsubscribe from our mailing list at any time.

C. Authorization and Consent of End Users
As our business partner, you are very clear. In order to provide you and / or your end users with the MobTech service of your choice, we will collect, store and process the end user's personal information from your application in a de-identification or anonymous manner. Therefore, if you accept this policy and integrate our SDK, API or other statistical analysis tools, developer tools into your product, you confirm and guarantee that:

1. You have informed the end user and obtained sufficient, necessary and clear authorization, consent and permission from the end user to allow us to collect and use its information for the purpose of providing services;

2. Unless otherwise provided by applicable law, you have notified the end user and obtained the necessary and sufficient authorization, consent and permission from the end user, allowing us to de-identify the personal information we have collected, allowing us to comply with the premise of complying with relevant laws and regulations The information collected and processed can be used for the service purposes listed in Article 1 of this policy;

3. You have complied with and will continue to comply with applicable laws, regulations and regulatory requirements, including but not limited to the development and publication of relevant policies regarding the protection of personal information and privacy;

4. You have provided end users with an easy-to-operate mechanism for implementing user rights, explaining how and when users can exercise their options, how to access them, correct their personal information, exercise their right to delete, and change the scope of their authorized consent.

D. How Do We Share, Transfer, and Publicly Disclose the Personal Information of You and / or Your End Users

1. Share

We will not share personal information of you and / or your end users in a identifiable form with any company, organization, or individual other than MobTech, except as follows:

(1) Sharing with explicit consent: After obtaining the explicit consent of you and / or your end users, we will share your and / or your end users information with other parties.

(2) We may share personal information of you and / or your end users externally in accordance with laws and regulations, or in accordance with mandatory requirements of government authorities.

(3) To the extent required or permitted by law, in order to protect the interests, property, or safety of you or the public from damage, it is necessary to provide personal information of you and / or your end users to third parties (Industry organization, such as consumer rights protection Departments);

(4) In order to protect national security, public safety and the important legally rights of you and other individuals, you need to share personal information of you and / or your end users;

(5) Sharing with our affiliates: Personal information of you and / or your end users may be shared with mob's affiliates. We only share necessary personal information and are subject to the purposes stated in this policy. If an affiliate wants to change the purpose of processing personal information, it will again ask you and / or your end users for authorization.

Our affiliates include: Guangzhou Zhangtao Network Technology Co., Ltd.

(6) We may hire trusted third-party suppliers, consultants or other service providers ("Partners") to provide us with the necessary maintenance, support and services to provide better customer service and optimize the user experience. We will only share information about you and / or your end users for legitimate, proper, necessary, specific, and clear purposes, and only share information necessary to provide the service. Our partners are not authorized to use the shared information for any other purpose.

At present, our partners include the following types:

1) Authorized partners in advertising and analysis services.

We will not share the personally identifiable information of you and / or your end user (referring to the information that can identify you and / or your end user, such as name or electronic E-mail, through which you and / or your end user can be contacted or identified ) with the partners who provide advertising and analysis services, unless we have your and / or your end user's permission.You and / or your end users agree that we will provide these partners with information about their advertising coverage and effectiveness, such as device information of the end users who click on the ads, but we will not provide your and / or your end users personally Identity information, or we will aggregate this information so that it does not identify you and / or your end users individually.For example, only after advertisers agree to abide by our advertising guidelines can we tell advertisers how effective their ads are, or how many people have seen their ads or installed apps after seeing them, or cooperate with these Partners provide non-personally identifiable demographic information (such as "25-year-old male in Beijing who likes software development") to help them understand their audience or customers.

2) Suppliers, service providers and other partners.

We send information to suppliers, service providers, and other partners who support our business globally. This support includes providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customers services, convenient payment or academic research and surveys.

3) Data service consulting partners.

With the permission of you and / or your end users, we have the right to share the personal information of you and / or your end users with partners who need our data service consultation. For example, the partner will send the encrypted data provided by us to the collaborating media end to collide and match the group data, and push the information to the end user.

The encryption technology we use is a common technology in the industry, so there is no need to decrypt it at any link, and technically these encryption technologies cannot be decrypted, even if decrypted, the results obtained are not unique.

4) Personal financial business analysis partner.

With the permission of you and / or your end users, we have the right to share the personal information of you and / or your end users with partners who need us to provide personal financial business analysis. For example, we will match the confidence labels in our database (Confidence labels are based on big data model analysis results of data obtained from our various channels. Completely guarantee the authenticity and accuracy of the data of each channel, and the confidence label does not have high accuracy) to the authorized end users of personal financial business partners based on their requirements, and calculate the rating for the end user that the partner has authorized based on the label set and algorithm.

For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.

2. Transfer

We will not transfer personal information about you or your end users to any company, organization, or individual except for the following:

(1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

(2) Need to be transferred in order to protect national security, public safety and the important legal rights of you and other individuals;

(3) In the case of merger, acquisition or bankruptcy liquidation, if it involves the transfer of personal information, we will require new companies and organizations holding your personal information to continue to be bound by this privacy policy, otherwise we will require the company, organization Ask for your consent again. If there is any change in the collection and processing of personal information stipulated in this statement, the company or organization will ask you for authorization again.

3. Public disclosure

We will not publicly disclose personal information about you or your end users for the following:

(1) After obtaining your explicit consent.

(2) Disclosure based on law: We may publicly disclose personal information of you or your endusers in the case of legal, legal procedures, litigation or mandatory requirements of government authorities.

4. Personal information exempted from obtaining consent to be shared, transferred, or publicly disclosed according to law

Please understand that in the following situations, in accordance with laws and regulations and national standards, we do not need to obtain your authorization and consent to share, transfer, and publicly disclose personal information of you and / or your end users:

(1) Directly related to national security and national defense security;
(2) Directly related to public safety, public health, and major public interests;
(3) Directly related to crime investigation, prosecution, trial and judgment enforcement;
(4) For the purpose of safeguarding the important legal rights of you or other individuals, but it is difficult to obtain the consent of this person;
(5) Personal information that you disclose to the public;
(6) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

E. How Do We Protect The Personal Information of You and / or Your End Users

1. We have used industry-standard security protection measures to protect the personal information provided by you and your end users, and prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable measures to protect the personal information of you and your end users. For example, when data (such as credit card information) is exchanged between your browser and the Service, it is protected by SSL encryption; we also provide https secure browsing methods for official websites; we use encryption technology, anonymization and other means to ensure data Confidentiality; we use trusted protection mechanisms to prevent data from being maliciously attacked; we have established special management systems, processes and organizations to ensure information security. For example, we strictly limit the scope of people who access information, require them to comply with confidentiality obligations and conduct reviews; and we organize security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information. In the event of a security incident such as personal information leakage, we will launch an emergency plan to prevent the expansion of the security incident and notify you in the form of push notifications, announcements, etc.

2. We have obtained the following certifications: “Recordal Certificate for the Protection of Information System Security Level” (Third Level) issued by the Shanghai Public Security Bureau.

3. Our data security capabilities: build a security defense around the data life cycle, covering data processing stages such as data collection, transmission, storage, use, transfer, archiving, and deletion.

4. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain personal information about you and / or your end users for as long as necessary to achieve the purposes stated in our cost policy, unless we need to extend the retention period or as permitted by law.

5. The Internet is not an absolutely secure environment, and e-mail, instant messaging, and communication with other users are not encrypted. We strongly recommend that you do not send personal information in this way. Please use complex passwords to help us keep your account secure.

6. We will regularly update the reports on security risks and personal information security impact assessments. You can get it by sending an email to notice@mob.com.

7. The Internet environment is not 100% secure, and we will make every effort to ensure or guarantee the security of any information you and / or your end users send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, which resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.

8. After the unfortunate occurrence of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impacts of the security incident, the measures we have taken or will take, and the suggestions you can use to prevent or reduce risk, the remedies for you, etc. We will promptly inform you about the incident by email, phone, push notification, etc. When it is difficult to notify the individual information subject one by one, we will take a reasonable and effective way to make an announcement.

9.At the same time, we will also actively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

We attach great importance to the management of personal information by you and / or your end users, and make every effort to protect the rights of you and / or your end users to query, access, modify, delete, complain, report and set privacy functions for personal information to enable you and / or your end users to protect your privacy and information security.

1. Direct users of MobTech

(1) Query and change your personal information

You have the right to access your personal information, except for the exceptions provided by laws and regulations. If you want to exercise data access rights, such as you want to access or edit the corporate / profile information and payment information in your account, change your password, add security information, etc., you can do it yourself in the developer's background, or by calling the customer service 400-685-2216, or by sending an email to notice@mob.com. When you access the relevant information, we may ask you to verify your identity in order to protect your account.

Please understand that some of your requests may not be responded due to technical limitations and legal and regulatory requirements. Some of your information may be inaccessible due to legal and regulatory requirements and legitimate reasons such as information security.

(2) Delete your personal information

In any of the following situations, you can submit or send an email to notice@mob.com to contact customer service and request to close or delete the personal information you provided:

1) We collect and use personal information in violation of laws and regulations;
2) We collect and use personal information in violation of the agreement with you;
3) We share or transfer personal information with third party  in violation of laws and regulations, or the agreement with you. We will immediately stop the sharing and transfering and notify the third party to delete it in time;
4) We have publicly disclosed your personal information in violation of laws and regulations or your consent. We will immediately stop the public disclosure and issue a notice requesting the relevant receiver to delete the corresponding information.

When deleting related information, we may ask you to verify your identity to protect your account security. Once the above deletion request is responded, your personal information will be deleted except for the information required by laws and regulations.

(3) Change the scope of your authorization

Each business function often needs to collect some basic personal information in order to operate. For the collection and use of your personal information, you can contact customer service by calling customer service phone number 400-685-2216 to request withdrawal of consent.

After you withdraw your consent, we will no longer collect and use your corresponding personal information, but please understand that after you withdraw your consent or authorization, we cannot continue to provide you with the specific functions and / or service. Your decision to withdraw your consent will not affect the processing of personal information previously based on your authorization.

(4) Cancel your account

You can cancel your previously registered account at any time. You can call customer service at 400-685-2216 to do so. You should be aware that cancelling your MobTech account will cause you to permanently lose access to the account and the data in the account. We will provide you with an account cancellation service after verifying your identity and negotiating with you to process the assets in your account. In order to provide you with a more convenient way to log out, we will continue to optimize our products in the future, and inform you through page announcements. Except for the exceptions provided by laws and regulations, after cancelling your MobTech account, we will stop providing you with products or services, and delete your personal information or anonymize it as soon as possible according to your requirements.

(5)Obtain a copy of personal information

You have the right to get a copy of your personal information, you can contact customer service by email at notice@mob.com at any time. Under the premise of technical feasibility, such as data interface matching, we can also directly transfer a copy of your personal information to your designated third party according to your requirements.

(6) Reject targeted push

You can opt out of receiving promotional emails from MobTech by following the unsubscribe / opt-out instructions in these emails. You can also opt out by contacting customer service by emailing notice@mob.com. Please note that even if you opt out of promotional communications, we may still send you non-promotional information related to our Terms of Service or Privacy Notice updates, security alerts, and other notices related to your access to or use of our products and services.

(7) Respond to your above request

For security reasons, we may require to verify your identity before processing your request. You may need to provide a written request or otherwise prove your identity. For all your requests under this section, in principle, we will receive your request and provide feedback within 15 days after verifying your user identity.

2.If you are an end user of an application using MobTech products or services, and not a direct customer of MobTech, we recommend that youshould:

(1)Promptly provide your independent claim certification documents obtained through your legal channels. We may require you to verify your identity. We will respond your your related requests after verifying with your application provider and ensuring the security of customer accounts ; or

(2)In accordance with the privacy policy of the application provider, please send requests related to your personal information directly to the relevant application provider for processing and assistance.

3. In principle, we will not charge a fee for the above reasonable requests from you and / or your end users. The requests that are unreasonably repetitive, require excessive technical means (for example, need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes) may be rejected by us.

We will not be able to respond to requests from you and / or your end users in the following cases,:
(1) Related to our performance of our obligations under laws and regulations;
(2) Directly related to national security and national defense security;
(3) Directly related to public health and public health and major public interests;
(4) Directly related to crime investigation, prosecution, trial and execution of judgments;
(5) We have sufficient evidence to show that you have subjective intent or abuse of rights;
(6) For the purpose of safeguarding the important legal rights of you or other individuals, but it is difficult to obtain the consent of this person;
(7) Responding to your request will cause serious damage to the legal rights of you or other individuals and organizations;
(8) Involving commercial secrets.

(4) If you and / or your end users have questions about the realization of the above rights, you can contact us according to the relevant contact information in the method described in Article J of this policy.

G. How Do We Handle Children's Personal Information

We have clearly stated in the Terms of Service that we do not accept the registration of children and become our users, and in principle we do not accept the personal information of end users under 14 years of age provided by you. Please pay attention and provide personal information carefully. Although the concept of children is defined differently by laws and customs, we consider anyone under 14 years of age to be a child. If we collect personal information from a child under the age of 14 unknowingly, we will delete the data in time, unless we are required by law to retain such data.

If you believe that we have collected information from a child under the age of 14 by mistake or accident, please contact us in time.

If your application is designed and developed for children under 14 years of age, please ensure that your end users are the guardian who have read and agreed to the application's privacy policy, and authorize and agree to provide children's personal information to us to realize the application related function.

H. How Do We Store Personal Information about You and / or Your End Users

1. Storage location

In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. This service is not available in all countries and is not guaranteed to be available in any particular location. You are free to choose the scope of your use of this service and you are responsible for compliance with any applicable laws, including but not limited to any local laws.

2.Storage period

We only retain personal information about you and / or your end users for the shortest period necessary for the purposes described in this policy and the shortest period required by laws and regulations. However, in the following cases, and only for the purpose related to the following cases, we may need to retain your personal information or some information for you and / or your end users for a long time:

(1) to comply with applicable relevant laws and regulations, and other relevant regulations ;

(2) to comply with the requirements of court judgments, rulings or other legal procedures;

(3) to comply with the requirements of relevant government agencies or other competent authorities;

(4) to implement the relevant service agreement or this privacy policy, safeguard the public interest, handle complaints / disputes, for the reasonable and necessary purpose to protect the personal or property safety or legal rights of our customers, us or our affiliates, other users or employees.

I. How to Modify And Update This Policy

In order to provide you with better services, this platform and related services will be updated and changed from time to time, and we will amend this policy in due course. These amendments form part of this policy and have the same effect as this policy. Without your explicit consent, We will not reduce your rights and / or your end users' rights under this privacy policy.

After updating this policy, we will issue an updated version on the official website, and remind you of the updated content in an appropriate way before the updated terms take effect, so that you can know the latest version of this policy in time.

For significant changes, we will also provide more prominent notifications (including for certain services, we will send notifications via email explaining specific changes to the privacy policy).

Significant changes referred to in this policy include, but are not limited to:

1. Major changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, how personal information is used, etc .;

2. We have undergone major changes in terms of ownership structure and organizational structure. Such as business adjustment, bankruptcy mergers and acquisitions, etc.

3. The main objects of personal information sharing, transfer or public disclosure have changed;

4. Your rights to participate in the processing of personal information and how you exercise them have changed significantly;

5. When our responsible department, contact method and complaint channel for handling personal information security change;

6. When the personal information security impact assessment report indicates high risk.

We will also archive older versions of this policy for your review. This policy is an important part of the MobTech service agreement. All rights not expressly granted in this privacy policy are reserved by MobTech.

J. How to Contact Us
If you have any questions, comments or suggestions about this policy, please contact us via:

We have set up a dedicated department for personal information protection (or a personal information protection commissioner), and you can contact them through the following methods: Relevant person in charge of the business: Chun Ling; Phone: 400-685-2216; Email: datacommissioner@mob.com;

If you have questions, suggestions or complaints about your account information, personal information or other document technology or exercise your rights, you can contact us by sending an email to notice@mob.com or other special instructions. Generally, we will reply within 15 days.

If you are not satisfied with our response, especially our processing of personal information has harmed your legitimate rights and interests, you can also seek solutions through the following external channels: reports and complaints to the regulatory authorities, such as Network Information Office, Communications Authority, Public Security Bureau, and Bureau of Industry and Commerce,  or file a lawsuit with the Jiading District People's Court in Shanghai.

K. Obligation of Confidentiality

Youare welcome to sign a special "Non-Disclosure Agreement" with us to clarify our rights and obligations. If we violate the agreement and disclose confidential information to a third party and cause direct economic damage to you, you have the right to claim compensation through legal channels.

Appendix A: Keyword definition

Specific words used in this policy have the following meanings:

1. We or MobTech: Shanghai Youkun Information Technology Co., Ltd.

2. Affiliated companies: Subsidiaries or other affiliated companies within the scope of consolidated statements with Shanghai Youkun Information Technology Co., Ltd. Any one of the above companies now controls, is controlled by, or is under common control with, any of them.

3. Control: refers to the ability to directly or indirectly influence the management of the company mentioned, whether through ownership, voting shares, contracts or other legally recognized methods.

4. You: means registered users of our products and / or services and purchasers of paid services.

5. Your End User: means the end user of the MobTech platform product or service application.

6. MobTech or this platform: refers to the MobTech platform.

7. Personal information: refers to all kinds of information recorded electronically or otherwise that can identify the identity of a specific natural person or reflect the activity of a specific natural person, either alone or in combination with other information. Personal information includes basic personal information, personal identification information, personal biometric information, network identification information, personal health and physiological information, personal education work information, personal property information, personal communication information, contact information, personal online records, personal commonly used equipment Information, personal location information, etc. For the avoidance of doubt, personal information includes, but is not limited to, sensitive personal information.

8. Personal information subject: refers to a natural person identified by personal information.

9. Personal sensitive information: refers to personal information that, if leaked, illegally provided or abused, may endanger personal and property safety, which could easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment. Personal sensitive information includes personal property information, personal health and physiological information, personal biometric information, personal identification information, and network identification information.

Examples of personal sensitive information (not personal information we collect, only for illustration):

Examples of personal sensitive information
Personally identifiable information	ID card, military officer's card, passport, driver's license, Taiwan compatriot card, return permit, work permit, social security card, residence permit, etc.
Network identity information	Combination of personal information subject account, password, password protected answer, user personal digital certificate, etc.
Personal property information	Account information, identification information (password), deposit information (including fund data, payment collection records, etc.), income sources, income levels, real estate information, transaction and consumption records, credit information, credit information , Flow records, etc., and virtual property information such as virtual currencies and virtual transactions
Personal health physiological information	Relevant records generated by individuals due to medical treatment, such as illness, hospitalization records, doctor's orders, test reports, surgery and anesthesia records, nursing records, medication records, drug food allergy information, fertility information, past medical history, diagnosis and treatment, family medical history, Current medical history, history of infectious diseases, etc., as well as information related to personal health status, etc.
Personal biometric information	Personal genes, fingerprints, voice prints, palm prints, auricles, iris, facial recognition features, etc.
other information	Sexual orientation, marriage history, religion, undisclosed criminal records, communication records and content, contacts, friends list, group list, whereabouts, web browsing history, accommodation information, precise positioning information, etc.

10. De-identification: refers to the process of processing personal information so that it cannot identify the subject of personal information without the aid of additional information.

11. Anonymization: refers to the process of making personal information subject unable to be identified through the technical processing of personal information, and the processed information cannot be restored.

12. China or Within the territory of China: refers to the mainland of the People's Republic of China for the purpose of this policy only, excluding the Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan.