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HeyTap Clone Phone Privacy Notice

Last updated on: September 1, 2023


Effective date: September 1, 2022

Foreword
Thank you for using Clone Phone. Clone Phone, developed and operated by
Guangdong HeyTap Technology Co., Ltd. ("we", "us", or "our", registered at No. 18
Haibin Road, Wusha, Chang'an, Dongguan, Guangdong, China 523902), is an app
("App", "Platform", or "HeyTap Clone Phone") that allows the user ("you") to
migrate their contacts, pictures, videos, and other data from one device (the source
device) to another (the destination device). We attach great importance to the
protection of your personal information and privacy. We fully understand the
importance of personal information to you. We have developed this Clone Phone
Privacy Notice (this "Privacy Notice") in accordance with applicable laws,
regulations, and national standards.
During your use of this Platform, we may collect, store, use, process, transfer,
provide, disclose, or delete (collectively, "process") your personal information. This
Privacy Notice explains what personal information about you we need to process,
why and how we process it, your rights to manage your personal information and the
methods for you to exercise these rights, and the security measures we use to protect
your personal information.

[Special Notes]
This Privacy Notice is closely related to this Platform. Before using this Platform,
please carefully read and fully understand all the content of this Privacy Notice
and related user service agreements and make the choices that you deem
appropriate.
To provide you with the features and services you request or to comply with laws
and regulations, we will process the necessary personal information relating to
you. This Privacy Notice specifically points out what personal information is
necessary for the use of HeyTap Clone Phone. Please pay special attention to
such information. We do not collect personal information that is not necessary to
provide services. If you do not agree to our collection of personal information in
connection with services other than the basic services, please do not turn on the
extended services.
Please rest assured that app permissions will not be turned on without your
authorization, which means they are turned off by default. If certain sensitive
app permissions are required for the use of our services or features, we will
request your consent to turn them on through a pop-up prompt when you
attempt to use these services or features. After such permissions are turned on,
you may go to the Settings app at any time to turn them off. Your denial of our
permission request does not affect your use of the other unrelated services or
features.
In this Privacy Notice, we will describe the processing of personal information in
connection with our services or features. The clauses governing the processing of
sensitive personal information and those concerning your rights are highlighted
in bold for your special attention. In addition, we have used bold italics to draw
your special attention to sensitive personal information. We will separately ask
for your consent prior to the processing of your sensitive personal information.
We will make continued efforts to improve our technology so as to provide you
with a better experience of using our products or services. To this end, we may,
from time to time, launch new or optimize existing features or services, which
may require us to process other additional information about you or change the
purpose or method of using the personal information we collected. If personal
information collection and processing rules for a specific feature or service are
not described in this Privacy Notice, we will separately explain to you what
personal information we need to process and why and how we process it through
updates to this Privacy Notice, screen pop-ups, on-screen prompts, interactive
procedures, website announcements, and other similar methods. We will provide
you with the option of choosing whether to agree to our processing. We will
process your personal information only after obtaining your express consent.
If you have any questions regarding this Privacy Notice, you may contact us as
set forth under Section 9 "Contact Us". We will revise this Privacy Notice from
time to time. When a material change is made to this Privacy Notice as described
in Section 8, we will show you the change through a push notification, a screen
pop-up, or any other similar method.

This Privacy Notice will help you understand:


1. How We Collect and Use Your Personal Information
2. How We Store Your Personal Information
3. How We Entrust, Share, Transfer, and Disclose Your Personal Information
4. How We Protect Your Personal Information
5. How to Exercise Your Data Subject Rights
6. How We Protect the Personal Information of Minors
7. Third-Party Service Providers and Their Services
8. How to View This Privacy Notice and How We Update It
9. Contact Us
10. Miscellaneous
11. Definitions of Terms

1. How We Collect and Use Your Personal


Information
We will protect your personal information in accordance with national laws and
regulations and the principles of legitimacy, lawfulness, and necessity. Only with your
consent and for the purpose of providing you with the services or features stated in
this Privacy Notice will we collect and use personal information that is (1) directly
provided by you during your use of this Platform, (2) automatically generated during
your use of the services or features provided by this Platform, or (3) legally obtained
from third parties. The information we collect depends on the context of your
interactions with us and the choices you make, including your privacy settings
and the products and features you use.
Please note that if you provide other people's personal information to us, you
must ensure that you have obtained their authorization.
If the following clauses explicitly state that relevant information about you is
stored only locally, then the information is collected and processed only locally
on your device and will not be uploaded to our servers. Such information is not
bound by this Privacy Notice. We aim here to provide clarification on any questions
you are likely to have and to be transparent about our processing of personal
information.
To provide you with the features/services you request or to comply with laws and
regulations, we will process the necessary personal information relating to you. This
Privacy Notice specifically points out what personal information is necessary for you
to use the features/services. Please pay special attention to such information.
1.1 Basic features

In the basic service mode, we only collect personal information that is necessary to
provide you with the basic features or services or that must be collected as stipulated
by laws and regulations.
(1) Device pairing
To support data transfer from one mobile device to another, the App allows you to
pair one device to another. When pairing the source device to the destination device,
you need to permit the App to access your location information and wireless data so
that it can obtain information about nearby hotspots and initiate a request for
connecting the source device to the destination device. Then you need to permit the
App to use the source device's camera to scan the QR code on the destination device.
Such information will be processed only on your devices and will not be uploaded to
our servers.
(2) Data migration
The App allows you to migrate your data including contacts, pictures, videos, and
calendar events from one device to another. When you use the data migration feature,
the App will need to access your data including contacts, pictures, videos, and
calendar events. Such information will be processed only on your devices and will not
be uploaded to our servers.

You may refer to the "Personal Information We Collect" table below to gain a
quick understanding of the personal information that will be collected and used
in connection with the features or services of HeyTap Clone Phone.
Personal Information We Collect
Related Purpose of Information Collection Method Sensitive
Feature/Scenario Collection Personal
Information
Device pairing To allow the App to collect Directly provided by Location
device identification you (only processed information
information temporarily locally on your and Wi-Fi
generated so as to connect devices) network data
the source device to the
destination device through
the hotspot offered by the
latter.
Data migration To transfer user data, Directly provided by Pictures,
including pictures, videos, you (only processed videos,
contacts, calendar events, locally on your contacts, and
and app data, from the devices) calendar
source device to the events
destination device.

1.2 Required app permissions

When you use HeyTap Clone Phone, we may request certain app permissions as
necessary to provide you with the required features or services. Please rest assured
that we will request only the authorized scope of permissions and, if needed, collect
related information. We will collect your sensitive personal information only after
obtaining your consent separately. After such permissions are turned on with your
consent, you may go to the Settings app at any time to turn them off to withdraw your
consent. (The operation paths to manage app permissions may vary according to the
device model and operating system version, so the actual operation paths are subject
to the device you use.) After you withdraw your consent, we will cease to use the
permissions. The following lists the app permissions we may request:
Required permission: Camera.
Related feature/service: Device pairing.
Purpose of permission request: To allow you to use the camera to scan QR codes
for device pairing.
Ask before turning on the permission: Yes.
Ability to turn off the permission: You can go to "Settings - Privacy & Security" to
turn it off.
Impact of turning off/denying permission: You will not be able to use the camera to
scan QR codes for device pairing.

Required permission: Location Services.


Related feature/service: Device pairing.
Purpose of permission request: To allow the source device to obtain information
about nearby hotspots and initiate a request for connecting to the destination device.
Ask before turning on the permission: Yes.
Ability to turn off the permission: You can go to "Settings - Privacy & Security" to
turn it off.
Impact of turning off/denying permission: Automatic device pairing and
connection will fail.

Required permission: Local Network.


Related feature/service: Device pairing.
Purpose of permission request: To allow the App to discover nearby devices so that
you can manually connect the source device to the destination device.
Ask before turning on the permission: Yes.
Ability to turn off the permission: You can go to "Settings - Privacy & Security" to
turn it off.
Impact of turning off/denying permission: You will not be able to manually
connect the source device to the destination device.

Required permission: Read calendar events.


Related feature/service: Data migration.
Purpose of permission request: To allow the App to read calendar events on the
source device and transfer them to the destination device.
Ask before turning on the permission: Yes.
Ability to turn off the permission: You can go to "Settings - Privacy & Security" to
turn it off.
Impact of turning off/denying permission: The App will not be able to read the
calendar events on the source device, failing to transfer them to the destination device.

Required permission: Read contacts.


Related feature/service: Data migration.
Purpose of permission request: To allow the App to read your contacts on the
source device and transfer them to the destination device.
Ask before turning on the permission: Yes.
Ability to turn off the permission: You can go to "Settings - Privacy & Security" to
turn it off.
Impact of turning off/denying permission: The App will not be able to read the
calendar events on the source device, failing to transfer them to the destination device.

Required permission: Photos.


Related feature/service: Data migration.
Purpose of permission request: To allow the App to access the pictures and videos
on the source device and transfer them to the destination device.
Ask before turning on the permission: Yes.
Ability to turn off the permission: You can go to "Settings - Privacy & Security" to turn it
off.
Impact of turning off/denying permission: You will not be able to transfer pictures
and videos from the source device to the destination device.

Required permission: Send notifications.


Related feature/service: Data migration.
Purpose of permission request: To notify you of the data migration progress so as to
prevent the interruption of the process.
Ask before turning on the permission: Yes.
Ability to turn off the permission: You may go to "Settings – Notifications
Management" to turn it off.
Impact of turning off/denying permission: The data migration process will be
interrupted if the App keeps running in the background for a long time.

Required permission: Wireless data.


Related feature/service: Device pairing.
Purpose of permission request: To allow the source device to connect to the
destination device through the hotspot offered by the latter.
Ask before turning on the permission: Yes.
Ability to turn off the permission: You may go to "Settings - WLAN - Apps Using
WLAN & Cellular" to turn it off.
Impact of turning off/denying permission: Connecting the source and destination
devices will fail.

1.3 Other legal bases for personal information processing

According to relevant laws and regulations, we can collect, store, use, process,
transmit, share, disclose, or delete (collectively, "process") your personal
information without your consent on the following legal grounds:
(1) As necessary to enter into a contract at your request or to perform the contract to
which you are a party;
(2) As necessary for us to comply with a legal obligation or duty;
(3) As necessary to respond to public health emergencies or to protect the life, health,
and property of natural persons in emergencies;
(4) The processing of personal information is within a reasonable scope and intended
for news reports, public opinion supervision, and other similar tasks carried out in the
public interest;
(5) The personal information that we process has been made public by you or
otherwise legally disclosed and is within a reasonable scope;
(6) Other circumstances as specified by laws and regulations.

2. How We Store Your Personal Information

2.1 Where we store your personal information

According to laws and regulations, we will store your personal information collected
and generated during our operations within the mainland of the People's Republic of
China ("Chinese mainland") on our servers deployed in the Chinese mainland. Where
we comply with laws, regulations, and the relevant rules of regulatory authorities, we
may provide your personal information to entities outside the Chinese mainland only:
(1) when laws and regulations explicitly allow us to do so; (2) after we separately
obtain your consent; or (3) when the products and/or services you use require the
global transfer of personal information and you provide your personal information to
entities outside the Chinese mainland of your own volition. We will strictly require
the data recipients to process your personal information in compliance with relevant
laws and regulations in addition to this Privacy Notice.

2.2 How long we store your personal information

Pursuant to laws and regulations, we will retain your personal information for the
minimum period needed to provide you with the required products/services. We will
delete or anonymize your personal information upon the expiration of the retention
period or when it can be deleted unless otherwise specified by applicable laws or
regulations. When you use the features or services provided by the App, related
personal information will be processed only on your device, and it will not be
uploaded to our servers.
We determine the minimum retention period mainly based on the following: (1) The
purposes for which the personal information is processed have been fulfilled or are
unable to be fulfilled, or the processing becomes unnecessary due to business changes
or discontinuance; (2) It is necessary for us to maintain relevant transaction and
activity records to address your information query requests or complaints you might
raise in the future; (3) You authorize us to retain the personal information for a longer
period; (4) Laws or administrative regulations have otherwise specified the retention
period for personal information.
If, during your use of this Platform, your actions constitute a serious violation of laws,
regulations, or agreements, policies, or rules relating to this Platform, the records of
your violations as well as your credit records from relevant platforms and personal
information will be retained for the maximum period permitted by law.
If we stop some or all of the services of this Platform for special reasons, we will
publish an announcement on this Platform at least 30 days in advance, and we will
stop collecting your personal information and no longer use it for commercial
purposes. Within the minimum time limit permitted by laws and regulations, we will
delete or anonymize the personal information we hold that relates to this Platform,
unless otherwise specified by laws and regulations.
3. How We Entrust, Share, Transfer, and
Disclose Your Personal Information

3.1 How we entrust third parties to process personal

information

To provide you with better and more premium platform services, we may entrust our
affiliates or other professional service providers to process personal information on
our behalf. For example, we may hire service providers to help us provide technical
and customer support services. We will require the entrusted party (a company,
organization, or individual) to observe strict confidentiality obligations and take
effective confidentiality measures through a written agreement, on-site audits, or any
other means as required by the law. We will require the party to process your personal
information only within the scope of entrustment and not to use your personal
information for their own benefit. In the written agreement, we will strictly define the
purpose for which the processing is carried out, the time limit, the processing method,
the type of personal information, protection measures, and the rights and obligations
of the two parties. We will supervise the entrusted party's processing of personal
information.

3.2 How we share personal information

To provide you with better and more premium platform services, we may share your
personal information with our affiliates, partners, and other third parties. We will
share your personal information only for legitimate, proper, necessary, specific, and
explicit purposes, and, where explicitly required by laws and regulations, we will
separately obtain your consent before we do so. Such third parties will have no right
to use your personal information shared by us for any other purpose. We will sign a
data protection agreement with each third party to clarify their responsibility and
obligation to protect your personal information.
When our partners provide services to you, if you do not allow them to collect
the personal information necessary to provide specific services, you may not be
able to use this Platform or enjoy the services that they provide.
We will not share your personal information with any third party except in the
circumstances as described below or unless this Privacy Notice specifies otherwise.

3.2.1 Sharing with our affiliates

To provide you with a more complete and greater variety of features of or


relating to this Platform, we may legally share the necessary personal
information with our affiliates from time to time through interfaces or offline
channels. For example, in order for our affiliates to provide you with services
and meet the user identification requirement of regulators, or in order for us and
our affiliates to jointly provide or recommend services and products to you, we
may need to share your personal information with the affiliates. We will only
share the necessary personal information, and we will do so only for the
purposes stated in this Privacy Notice.

3.2.2 Sharing in other circumstances

Should we be legally required to comply with laws and regulations, legal procedures,
litigations, and/or mandatory requirements of public institutions and government
authorities, we may share your personal information to the least necessary extent.
We may also disclose your personal information if we sincerely believe that
disclosure is necessary to protect our users or to detect, prevent, and deal with fraud,
unauthorized use of our products, violation of our terms or policies, or other harmful
or illegal activities. (To the extent and only as expressly permitted by local data
protection laws, we will collect, use, or disclose your personal information without
your consent.) This may include providing information to public institutions or
government agencies and communicating with our partners about the reliability of
your account to prevent fraud, violations, and other harmful acts committed in or out
of our products.

3.3 How we transfer personal information

We do not transfer your personal information to any company, organization, or


individual, except in the following situations:
1. The transfer is made at your request and in compliance with the requirements of
relevant government authorities;
2. We are required to provide your personal information by applicable laws,
regulations, legal procedures, and mandatory administrative or judicial
requirements;
3. When we are in the process of a merger, acquisition, or bankruptcy liquidation,
and if such process requires the transfer of your personal information, we will
require the new company or organization that holds your personal information to
continue to be bound by this Privacy Notice; otherwise, we will require this
company or organization to obtain your authorization or consent again.

4. How We Protect Your Personal Information

4.1 Our data protection measures

We adopt technical and organizational measures that are reasonable and actionable to
protect the information we collect in connection with our services. We have
introduced safeguards that meet industry standards to protect the personal information
provided by you from unauthorized access, disclosure, use, or alteration, or from
damage or loss. We take all reasonable and actionable measures to protect your
personal information. For example:
1. We use mainstream security means such as SSL to encrypt many of our services.
We regularly review our practices regarding information collection, storage, and
processing (including physical security measures) to protect our systems from
unauthorized access or alteration.
2. Subject to relevant regulations, we have appointed a person in charge of personal
information protection and set up a personal information protection task force.
We have also established internal control processes to ensure compliance with the
principle of least privilege. We strictly control access to personal information and
only grant access permissions to our employees and the personnel of an
authorized service provider, both of whom need to access personal information in
order to help us process such information. The aforementioned employees and
personnel are subject to strict contractual confidentiality obligations. If they fail
to perform these obligations, they may be held legally liable or be terminated.
Personal information access logs will be kept and audited periodically.
Employees who need to access sensitive personal information must obtain
permission from relevant management personnel. In addition, we take technical
measures to prevent people from accessing, modifying, copying, or downloading
such information without authorization.
3. The security of your information is very important to us. Therefore, we will
continue our efforts to protect the security of your personal information and
implement safeguards such as encrypting stored data and using end-to-end
encryption during transmission to protect your information from unauthorized
access, use, or disclosure. In addition, certain encrypted data is inaccessible to
anyone other than the user.
4. When transmitting and storing personal information of special types, we will use
security measures such as encryption. When storing your personal biometric
information, we will take technical measures to process it, such as only storing a
summary of your personal biometric information.
5. We carefully select business partners and service providers and include our
requirements for personal information protection in our business contracts, audits,
or assessments.
6. Internally, we publish and implement data security regulations to define the
standards and requirements for protecting user data (including users' personal
information).
7. We conduct security and privacy protection training, tests, and publicity activities
to raise our employees' awareness of the importance of personal information
protection.
8. We use international and industry-recognized standards to protect your personal
information and actively acquire security and privacy protection certifications.
We have established sound mechanisms to ensure smooth coordination and
communication with regulators, third-party security service providers, and
security evaluation and certification organizations to promptly defend against and
deal with information security threats so as to protect your personal information
and privacy.

4.2 Notification and response to personal information

security events

Please note that although we take reasonable measures to protect your information, no
websites, internet transfers, computer systems, or Wi-Fi connections are 100 percent
secure.
In the event of any security breach of your personal information, we will promptly
inform you of the event in accordance with applicable laws and regulations, including
the situation and the possible impact of the event, the measures taken or to be taken
by us, suggestions on how you can prevent and reduce risks, and remedies available to
you. We will promptly inform you of such information through push notifications.
When it is difficult to inform each personal information subject concerned, we will
publish an announcement in a reasonable and effective manner. We will also report
the handling of the event in accordance with the requirements of regulatory
authorities.

5. How to Exercise Your Data Subject Rights


We respect your rights to your personal information, and we do our best to protect
your rights. To this end, we provide you with a variety of ways to make privacy
settings and personal information management more secure and convenient for you to
ensure the security of your personal information. Please note that the operation
paths may vary according to the operating system and software version. In
addition, we may adjust the operation paths from time to time to improve your user
experience. Therefore, the operation paths described below are for your reference
only. If you have any questions regarding the operation paths or ways of exercising
your rights, you may contact us as set forth under Section 9 "Contact Us" of this
Notice. We will respond to your data subject rights requests as long as your requests
comply with relevant laws and regulations and are technically feasible.

5.1 Right to access, rectify, and complete your personal

information

1. You may open HeyTap Clone Phone and choose "More - Privacy Notice" to view
this Privacy Notice unless laws or administrative rules specify that the data must
be kept confidential or there is no need to keep you informed of the data, or
unless your access request would hinder state institutions from performing their
statutory duties.

5.2 Right to copy and transfer your personal information

You have the right to copy and transfer your personal information. If you need a copy
of your personal information, please refer to Section 9 "Contact Us" below and send
us a request. We will provide you with a copy in a timely manner. If you request us to
transfer your personal information to a specified data processor, we will complete the
transfer as long as it complies with the conditions stipulated by the Cyberspace
Administration of China.
5.3 Right to change the scope of authorization or withdraw

consent

The performance of each service function requires certain basic personal information
(see the "How We Collect and Use Your Personal Information" section of this Privacy
Notice). You can change the scope of the personal information you authorize us to
continue to collect or withdraw your authorization by deleting your information,
turning off app permissions, or by other means. Specifically:
1. Managing app permissions: You may go to "Settings - Privacy & Security" to
turn off relevant app permissions so as to withdraw your consent to our use of
such app permissions.
Please note that if you withdraw your consent, we may no longer be able to provide
you with the related services. We will also no longer process related personal
information, but the withdrawal of your consent will not affect the lawfulness of data
processing based on consent before its withdrawal.

5.4 Right to complain

You have the right to file a complaint by contacting us in the manner disclosed in this
Privacy Notice. We will respond within 15 working days from the date we receive
your complaint. If you are not satisfied with our reply, particularly if our processing
of your personal information damages your legitimate rights and interests, you can
also file a complaint or report it to regulatory authorities such as the Cyberspace
Administration of China, a relevant public security organ, and the State
Administration for Market Regulation, or file a lawsuit with the court with
jurisdiction.

5.5 Right not to be subjected to automated decision-making

In some service features, we may only rely on the automated decision-making


mechanisms enabled by information systems or algorithms to make decisions without
human involvement. If you think that the decisions significantly affect your legitimate
rights and interests, you can contact us as set forth under Section 9 "Contact Us"
below.
5.6 Transfer of data subject rights of deceased persons to

their close relatives

Provided any user of HeyTap Clone Phone dies and they have not informed us of any
arrangements in writing or through any other reasonable method before they die, their
close relatives may, for the sake of their own legitimate interests, contact us as set
forth under Section 9 "Contact Us" for guidelines on how to exercise the rights of the
deceased data subject, including rights to access, copy, rectify, and delete personal
information.

5.7 How we respond to your requests

If you are unable to access your personal information, or withdraw your consent, or if
you have any questions when exercising any of your data subject rights, you may
contact our customer service representatives as set forth under Section 9 "Contact
Us". Please note that after receiving your request, we may first verify your identity for
security reasons and then handle your request within 15 working days.
In general, we do not charge a fee for handling your reasonable requests. However,
for repeated requests exceeding reasonable limits, we may charge a fee to cover the
costs of handling such requests depending on the actual situation. We may reject
unreasonably repeated requests, requests that require excessive technical means (such
as developing a new system or fundamentally changing existing practices), requests
that present risks to the legitimate rights and interests of others, or very unrealistic
requests. Should we choose to reject your request, we will state the reason in our
reply. In addition, we may choose not to respond to your request if it directly involves
any issues that directly concern public interests, such as national security, national
defense, public health, and criminal investigations, or if responding to your request
may result in serious damage to the legitimate rights and interests of you or any other
individual or organization.
If you have any questions, concerns, or suggestions regarding your data subject rights
or if you request us to make an explanation regarding this Privacy Notice, you can
contact us as set forth under Section 9 "Contact Us". We will provide an explanation
in a timely manner.
6. How We Protect the Personal Information of
Minors
HeyTap Clone Phone is not intended for children. Please note that due to technical
limitations and other objective factors, HeyTap Clone Phone may not be able to
actively identify the age of users. We will never use the internet or other means to
collect, store, use, transfer, or disclose children's personal information without reason.
If you are a parent or legal guardian of a child or if you otherwise find that any
information collected, stored, or used by us may contain the personal information of a
child, you can promptly contact us in the manner disclosed in this Privacy Notice, and
we will do everything we can to delete the relevant data as soon as possible.

7. Third-Party Service Providers and Their


Services
This Platform and our services therein may contain links to third-party websites,
products, or services. You can choose whether to access or use any website, product,
or service provided by a third party. The operators of the third-party websites that this
Platform redirects you to and the providers of the third-party services that you access
through this Platform have their own privacy policies. When you access a third-party
website or use a third-party app, the website or app may obtain and use your personal
information. Such acts are out of our control and not bound by this Privacy Notice.
Before submitting personal information to third parties, please refer to their privacy
policies.
We will use commercially reasonable efforts to require such third parties to take
measures to protect your personal information, but we cannot guarantee that they will
take protection measures as per our requirements. Before using third-party services,
please carefully read their privacy policies to determine whether to use or continue to
use such services.
8. How to View This Privacy Notice and How
We Update It

8.1 How to view this Privacy Notice

In HeyTap Clone Phone, you may tap "More - Privacy Notice" to view this Privacy
Notice.

8.2 How we update this Privacy Notice

We reserve the right to update or modify this Privacy Notice from time to time. To
provide you with better services, we will make updates and changes to our Products
and/or Services from time to time, and we will revise this Privacy Notice accordingly
from to time.
In the event of any change to this Privacy Notice, we will inform you through
reasonable methods, such as using this Platform to push a notification to you and
displaying a pop-up prompt when you use this Platform so that you can promptly
understand all the changes. You can check the latest updates in "Update history" at the
beginning of this Privacy Notice.
Please note that we will process your personal information in accordance with the
updated Privacy Notice only after obtaining your consent. Without your express
consent, we will not diminish your rights under this Privacy Notice.

9. Contact Us
If you have any questions, complaints, or suggestions regarding this Privacy Notice or
our privacy practices, you may contact us using either of the following methods. We
will respond within 15 working days.
Contact through the Data Subject Rights Platform. To better protect your rights and
interests, we have specifically established the Data Subject Rights Platform at
https://brand.heytap.com/privacy-feedback.html. If you have any questions regarding
personal information protection, you may sign in to the platform to contact us.
10. Miscellaneous
10.1 The interpretation of this Privacy Notice and the resolution of disputes arising
from and related to this Privacy Notice shall be governed by the laws of the People's
Republic of China (excluding the laws of Hong Kong SAR, Macao SAR, and
Taiwan). Any disputes arising out of or relating to the conclusion and performance of
this Privacy Notice shall be resolved through friendly consultation between the two
Parties. Should the consultation fail, either Party shall have the right to refer the
dispute to the People's Court with jurisdiction in the place where the alleged
defendant is domiciled.
10.2 All headings in this Privacy Notice are intended solely for convenience and ease
of reference and shall not have any effect on the interpretation of any clause in this
Privacy Notice.

11. Definitions of Terms


Personal information: Any information that is recorded electronically or otherwise
and is related to identified or identifiable natural persons, but excludes anonymized
information.
Sensitive personal information: Personal information that, once leaked or unlawfully
used, is likely to result in damage to the personal dignity, physical wellbeing, or
property of any natural person, and includes, among others, information such as
biometric identification, religious belief, special identity, medical records, financial
accounts, whereabouts, as well as the personal information of minors under the age of
14.
Affiliate: Any company that is controlled by or controls, either directly or indirectly,
Guangdong HeyTap Technology Co., Ltd., or that is under the direct or indirect
control or significant influence of the same entity as Guangdong HeyTap Technology
Co., Ltd. "Control" means having the ability, directly or indirectly, to influence the
management of the affiliate, whether through ownership, voting shares, contracts, or
other means approved by China's people's courts.

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