Release date: June 1, 2024 Effective date: June 1, 2024

As the provider of the Cloud Phone SDK, Hunan Xiaosuan Technology Information Co., Ltd. (hereinafter referred to as "Xiaosuan Technology" or "we") deeply respects and is committed to protecting the security of your personal information. The term "Cloud Phone SDK products and/or services" referred to in this Privacy Statement includes providing SDK packages and API services for developers to access the Cloud Phone Service. The Cloud Phone SDK provides developers with a fast, comprehensive cloud phone technology solution, enabling cloud phone-related business scenarios by calling client SDK interfaces. After developers integrate the Cloud Phone SDK into their developed and/or operated applications and products (including apps, mini programs, web pages, etc., collectively referred to as "applications" or "developer applications"), the Cloud Phone SDK may collect and process data from end users (hereinafter referred to as "you"). In the above scenario, the developer, as the "personal information processor," decides the purpose and method of processing user data. In the process of providing developers with specific business functions of the Cloud Phone SDK, we only collect data on behalf of the developer and process the data according to the developer's entrusted and instructions. We hope to use this Privacy Policy to clearly and accurately explain to you how we collect, process, and protect all the information you provide when using developer applications integrated with the Cloud Phone SDK.

Special statement: This Privacy Policy cannot replace the privacy policy of the Developer's app. Developers should disclose their privacy policies to you regarding their applications, declaring how they collect, process, and protect your personal information. If you seek access to your data, or attempt to correct, modify, or delete incorrect data, or if you do not wish to continue using an app integrated with the Cloud Phone SDK, please contact the relevant developer (personal information processor) directly.

This Privacy Policy will help you understand the following content

1. How we collect and use personal information
2. How we share, transfer, and publicly disclose personal information
3. How do we store and protect personal information?
4. Your rights
5. How to update this Privacy Policy
6. How to contact us

1. How do we collect and use personal information?

(1) To help developers provide corresponding functions and services to end users If you use a developer application with integrated Cloud Phone SDK, the Cloud Phone SDK will collect the following information on behalf of developers through programmatic means:

We will not ask you to proactively submit personal information. The information we collect cannot individually identify the identity of a specific natural person, and based on the technical characteristics of this SDK, it objectively cannot obtain any information that can independently identify a particular natural person during operation.

Cloud Phone SDK permission list:

(2) Ensure service security, optimize and improve service objectives To help developers provide the above functions and services to end users, and to more accurately identify and resolve issues encountered by developers and end users when using Xiaosuan Cloud Mobile SDK products and services, we aim to improve and optimize the dual experience of Xiaoshuan Cloud Mobile SDK products and services on both the developer and end user sides, more accurately locating and resolving problems end-users encounter when using Xiaosuan Cloud Mobile SDK services, improving and optimizing the service experience, and enhancing the Xiaosuan Cloud Mobile SDK Service security, preventing, detecting, investigating fraud, security hazards, illegal or violations of agreements, policies, or rules with us, in order to protect the legitimate rights and interests of developers, end users, us or our affiliates, partners, and the public. We collect end-user device information, location information, log information, and other information related to the login environment.

(3) Anonymization of Personal Information Without publicly disclosing or providing end-user personal information externally, Xiaosuan Technology has the right to mine, analyze, and utilize the anonymized user database (including commercial use), to collect statistics on product/service usage, and to share anonymized statistical information with the public or third parties.

(4) Exceptions requiring prior authorization and consent Please note that in the following cases, collecting and using personal information does not require prior authorization or consent from the end user:

1. Directly related to national security and national defense security;
2. Necessary for the conclusion and performance of contracts in which the individual is a party;
3. Necessary for the performance of statutory duties or obligations;
4. To respond to public health emergencies or as necessary in emergencies to protect the life, health, and property safety of natural persons;
5. Cases directly related to criminal investigation, prosecution, trial, and judgment enforcement;
6. For the purpose of protecting the life, property, or other major legitimate rights and interests of end users or individuals, but it is difficult to obtain the individual's consent;
7. Collect personal information that end users themselves disclose to the public or have already legally disclosed within a reasonable scope in accordance with laws and regulations;
8. Collect end-users' personal information from legally disclosed information within a reasonable scope in accordance with laws and regulations, such as legitimate news reports, government information disclosure, and other channels;
9. Conduct news reporting, public opinion supervision, and other actions for the public interest, and process personal information within reasonable limits;
10. When academic research institutions conduct statistical or academic research for the public interest and provide academic research or descriptive results externally, de-identifying the personal information contained in the results;
11. Other circumstances stipulated by laws and regulations. We will notify end users and obtain their consent before using information for purposes not specified in this Privacy Policy.

2. How do we share, transfer, and publicly disclose personal information?

(1) Sharing Unless you have given prior consent or comply with other laws and regulations, we will not share your personal information with third parties other than Xiaosuan Technology, except where processing makes it impossible to identify a specific individual and cannot be recovered. For companies, organizations, and individuals with whom we share personal information, we investigate their data security environments, sign strict confidentiality agreements, and require them to handle personal information in accordance with the law.

1. Personal information we may share under the following circumstances, with the authorization and consent of the end user: Certain of our services will be provided by authorized partners solely for the purposes stated in this privacy policy. We may share certain personal information of end users with partners to provide better customer service and user experience. We will only share end users' personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only personal information related to the provision of services. Our partners have no right to use shared personal information for any other purpose. Currently, our authorized partners include the following types: (1) Service platform or service provider. Xiaosuan's products are integrated with a wealth of third-party services. When the end user chooses to use the third-party service, the end user authorizes us to provide this information to the third-party service platform or service provider, so that they may provide services to the end user based on the relevant information. (2) Software/Hardware/System Service Providers. When third-party software/hardware/system products or services are combined with Xiaosuan Technology's products or services to provide services to end users, with the end user's authorization, we will provide the necessary personal information of the end user to the third-party software/hardware/system service provider for the end user's use of the services, or for us to analyze product and service usage to enhance the end user's experience.

2. For companies, organizations, and individuals with whom we share personal information, we will investigate their data security environments, sign strict confidentiality agreements, and require them to handle personal information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.

(2) Transfer We will not transfer the personal information of end users to any company, organization, or individual other than affiliated companies, except in the following cases: Obtaining explicit authorization or consent from the end user in advance; Meeting the requirements of laws, regulations, legal procedures, mandatory government requirements, or judicial rulings; If we or our affiliates are involved in transactions such as mergers, divisions, liquidations, acquisitions or sales of assets or businesses, and end users' personal information may be transferred as part of such transactions, we will ensure the confidentiality of such information at the time of transfer and do our best to ensure that new companies or organizations holding end users' personal information continue to be bound by this privacy policy; otherwise, we will require the company or organization to seek authorization and consent from the end user again.

(3) Public disclosure We will only publicly disclose the personal information of end users under the following circumstances: Obtaining separate consent from the end user; Based on laws, regulations, legal procedures, litigation, or mandatory requirements from government authorities.

(4) Exceptions where prior authorization and consent are obtained for sharing, transferring, or publicly disclosing personal information In the following circumstances, sharing, transferring, or publicly disclosing personal information does not require prior authorization and consent from the end user:

1. Directly related to national security and national defense security;
2. Necessary for the conclusion and performance of contracts in which the individual is a party;
3. Necessary for the performance of statutory duties or obligations;
4. Directly related to public safety, public health, or major public interests. For example: in response to public health emergencies, or in emergencies necessary to protect the life, health, and property safety of natural persons;
5. Directly related to criminal investigation, prosecution, trial, and judgment enforcement;
6. Cases where it is difficult to obtain the individual's consent for the protection of significant legitimate rights and interests such as the life or property of the personal information subject or other individuals;
7. Processing personal information that individuals have disclosed themselves or other legally disclosed within a reasonable scope in accordance with laws and regulations, such as through legitimate news reports, government information disclosure, and other channels;
8. Circumstances otherwise stipulated by laws or administrative regulations.

3. How do we store and protect personal information?

We place great importance on information security and adhere to strict security standards, using industry-standard security measures to protect the information you provide, and employing various reasonable technical, operational, and management security measures to safeguard the information we collect. Prevent unauthorized access, public disclosure, use, modification, damage, or loss of information.

(1) Location of Information Storage In accordance with laws and regulations, we store personal information collected and generated within the territory of the People's Republic of China. Currently, we do not transmit the above information abroad. If the developer transmits the above information overseas, the developer shall fulfill the relevant compliance obligations. (2) Storage Period We retain your information only for the period necessary to provide services to developers. After exceeding the storage period agreed upon with the developer, or upon receiving the developer's instructions, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations. (3) Safety measures

1. We attach great importance to the security of user information and will strive to take reasonable security measures (including technical and managerial aspects) to protect your information, preventing your information from being misused or unauthorized access, publicly disclosed, used, modified, damaged, lost, or leaked.
2. We will use industry-standard encryption technologies, anonymization, and other reasonable and feasible methods to protect your information, and employ security mechanisms to prevent malicious attacks.
3. We will establish dedicated security departments, security management systems, and data security processes to ensure your information security. We implement strict data usage and access protocols to ensure that only authorized personnel can access your information, and conduct timely security audits of data and technology.
4. Although the above reasonable and effective measures have been taken and the standards required by relevant laws have been complied with, please understand that due to technical limitations and possible malicious means, in the internet industry, even with every effort made to strengthen security measures, it is impossible to always guarantee 100% security of information. We will do our utmost to ensure the security of the information we provide. You acknowledge and understand that the systems and communication networks you use to access our services may encounter issues due to factors beyond our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your user information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account passwords or other information to others.
5. We will develop emergency response plans and immediately activate them in the event of user information security incidents, striving to prevent the impact and consequences of such incidents from escalating. Once a user information security incident (such as leakage or loss) occurs, we will promptly inform you in accordance with laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks independently, and remedial measures for you. We will promptly inform you of the incident-related information via push notifications, emails, letters, SMS, and other means. If it is difficult to notify each individually, we will issue announcements in a reasonable and effective manner. At the same time, we will report the handling of user information security incidents as required by relevant regulatory authorities.
6. We hereby specially remind you that the user information protection measures provided in this Privacy Policy apply only to this service. Once you leave a page related to the Service and browse or use other websites, products, services, or content resources, we have neither the ability nor the obligation to protect any information you submit from software or websites outside the Service, regardless of whether you log in, browse, or use such software or websites based on links or guidance from the Service.

4. How do we handle minors' personal information?

Xiaosuan Technology places great importance on protecting minors' information. The products and services of the Xiaosuan Cloud Mobile SDK are mainly aimed at adults. If the end user is a minor under 14 years old, please carefully read the Developer Application Privacy Policy and this Privacy Policy together under the supervision and guidance of parents or other guardians before using the developer application with the integrated Xiaosuan Cloud Mobile SDK, and only use the Developer Application or provide personal information with the guardian's consent. If we discover that minors' personal information has been collected without prior verifiable parental consent, measures will be taken to delete the relevant information as soon as possible. If at any time a guardian has reason to believe that we have collected minors' personal information without their consent, please contact us through official channels and we will take measures to delete the relevant data as soon as possible.

5. Your rights

In accordance with relevant Chinese laws, regulations, standards, and practices in other countries and regions, we will strive to coordinate, support, and ensure that end users exercise the following rights regarding their personal information:

(1) The right to access, correct and supplement, reproduce, and cancel the account Given that end users use Xiaosuan Cloud Mobile SDK services through developer applications and do not register or log in to Xiaosuan Technology accounts when using the service, to ensure the end user's rights to access, correct, supplement, copy their personal information, and cancel their developer application account, we require developers to commit to providing convenient implementation methods in this Privacy Policy and other agreements with developers. If the end user wishes to access, correct, supplement, copy their personal information, or cancel their developer application account, they must do so through the means provided by the developer to fulfill their rights. If the developer fails to provide as promised, the end user may contact us through the method listed in 7. How to contact us. We will do our best to coordinate, support, and ensure the end user's rights are realized.

(2) Right to delete To ensure the rights of end users to delete their personal information, we require developers to commit to providing convenient implementation methods in this Privacy Policy and other agreements with Developers. If the end user wishes to delete their personal information, it should be done through the above rights provided by the developer. If the developer fails to provide it as promised, in the following situations, the end user may contact us via the method listed in 7. How to contact us and request deletion of personal information:

1. If we process their personal information in violation of laws, regulations, or agreements with end users;
2. If our processing objectives have been achieved, cannot be achieved, or are no longer necessary to achieve them;
3. If we stop providing products or services, or if the shelf life has expired;
4. If the end user withdraws their consent;
5. Other circumstances stipulated by laws and administrative regulations. When end users delete information from our services, we may not immediately delete the corresponding information from the backup system, but will delete it during backup updates. End users are asked to know and understand that if the retention period stipulated by laws, administrative regulations, or the provisions of this privacy policy has not expired, or if deletion of personal information is technically difficult, we will stop processing except for storage and taking necessary security protection measures.

(3) Withdrawal of consent Each business function requires some basic personal information to be completed. For the collection and use of additional personal information, end users may grant or withdraw their authorized consent at any time. End users can directly disable device system permissions we may invoke as described in this Privacy Policy or other authorization settings provided by the developer application (if applicable), change the scope of consent, or withdraw their authorization. Once the end user withdraws consent, we can no longer provide the corresponding services to the end user and will no longer use the user's personal information. However, the end user's decision to withdraw consent does not affect the personal information processing previously carried out based on their consent.

(4) Right to carry To ensure the rights of end users to transfer their personal information, we require developers to commit to providing convenient implementation methods in this Privacy Policy and other agreements with Developers. If the end user wishes to transfer their personal information, it should be done through the means provided by the developer to fulfill the above rights. If the developer fails to provide it as promised, the end user can contact us through the methods listed in 7. How to contact us. We will do our best to coordinate, support, and ensure the realization of these rights. Under the conditions stipulated by laws and regulations, and in compliance with the instructions and conditions set by the national cyberspace administration, if technically feasible, the end user may also request that our personal information be transferred to other entities designated by the end user.

(5) Prior notice of the right to stop operating products and services. Xiaosuan Cloud Mobile SDK is willing to always accompany developers and end users. If, for special reasons, the Xiaosuan Cloud Mobile SDK product ceases operation, we will notify developers and end users within a reasonable period via the product or service homepage, internal message, email, or other appropriate means to reach them. We will also stop collecting end-user personal information and delete or anonymize collected personal information in accordance with legal requirements.

(6) The right to interpretation End users have the right to request explanations regarding the personal information processing rules. End users can contact us through the methods listed in 7. How to contact us.

6. How to Update This Privacy Policy

(1) To provide better services to developers and users, this service will be updated and changed from time to time. We will revise this Privacy Policy in due course. Such changes constitute part of this Privacy Policy and have the same effect as this Privacy Policy. (2) After this privacy policy is updated, we will publish the updated version on relevant pages of this service to ensure you can stay updated with the latest version. If you continue to use the Service, you are deemed to have accepted the full content of this revised Privacy Policy. However, if the updated content requires additional user information from you, we will still seek your consent again in a prominent manner.

7. How to contact us

If you have any questions, comments, or suggestions regarding the contents of this Privacy Policy, you may contact us by sending an email to armcloud@vmos.cn. We will respond within 15 working days ("Response Period").