JG Privacy Policy

Last Updated in Aug 15 , 2022

Effective date of the updated version: Aug 15, 2022

Version update tips:

Based on business adjustments , we have updated the Aurora Privacy Policy in accordance with relevant laws, regulations and technical specifications , which mainly include the following: Updated the third-party SDK information for JPush and JVerification Service integration

In order to better protect your personal information, it is recommended that you read the updated privacy policy carefully , especially the terms in black and bold. If you have any objections or questions about the terms of this Privacy Policy, you can communicate with us through the contact information published in Article 10 " How to Contact Us" of this Privacy Policy .

Introduction

You are welcome to use the product and/or service on JG platform (hereinafter referred as “ the Platform ) provided by Shenzhen Hexun Huagu Information Technology Co., Ltd. and its affiliates (hereinafter referred as “ JG ” or “ We , whose registered office is at 14 F, Zhongjian Building, South 02, Community High-tech Zone, Yuehai District, Nanshan District, Shenzhen, Guangdong, 518052 People’s Republic of China.

The Personal Information security of you and your end users are important to us, we will do our best to provide a secure network environment to You and/or your end users.In order to protect you and/or your end users’ personal informations we are committed to abide by the principles of “accountability”,“purpose limitation”,“consent”,“information minimization”,“security” , “subject participation” and “fairness and transparency”, and in accordance with the Network Security Law of the People's Republic of China, the Data Security Law of he People's Republic of China, and the Internet industry's laws and regulations on information protection, and refer to recommended Information Security Technology Personal Information Security Code (GB/T 35273-2020).

JG Privacy Policy (hereinafter referred as “ This Policy ”) applies to the processing and protection of personal information in connection with your use of our products and services. The products and services we offer include but not limited to Developer Services (JPush, Jverification, JG UMS , JG VaaS , JMessage, JAnalytics, IM, JMLink, JShare), Data Services( Yuehu Data , FinTech, iAudience, JG Research), JAlliance and other products and services that already in existence and will be developed from time to time.

This policy states the purpose, method, scope and security measures on how we collect, use, store, share and transfer your and/or your end users’ personal information and how you can use your right and approach to control your personal information, such as your and/or your end users` rights of access, rectification, deletion, etc. We try to use simple and plain language to help you understand this policy and we define key terms, please refer to “Appendix 1: Keyword Definitions”.

We understand that when you register to use our platform, you have read and fully understood this policy. Please notice that we have a special reminder of the sensitive personal information written in blackened and italic, and the terms of significant rights and interestsand about you and your end users’ written in blackened. Prior to providing us with any of your and/or your end users’ sensitive personal information, please make sure that such providing is appropriate and you agree that we may process your and/or your end users` sensitive personal information according to the purpose and mechanism stated in this Policy. We will only collect and use the sensitive personal information of you and/or your end users with consent, in order to provide you and or/ your end users with the relevant functions in the platform. You may disagree with the collection and use of sensitive personal information of you and/or your end users`, however, refusing to provide such information will affect the relevant services of the platform which is provided for you.

Please read and understand the details of the specific products in this policy before using our products and/or services. We want you to make informed decisions about providing the personal information of you and/or your end users when using JG products (or services). We have attached a Compliance Guide to our website documentation to help you use JG products or services in a smarter and more private way. You should immediately stop using the products or services we offer, including the JG platform, website, etc., if you disagree with this policy.

It is important to note that when you use our products and services, we will process two broad categories of personal information:

1. Belong to you as a JG developer customer (or potential developer customer);

2. Your end users` personal includes device information, network information, LBS-information and application information( only for JPush and Jverification ) and additional optional information of your end users, including mobile phone numbers for Jverification and Jmessage use only , chat information ( for IM use only ), APP Application Page Information (for JAlliance only and JAnalytics), APP page and functional events information ( for JAnalytics use only) ) and user sharing information (for JShare use only) .

We have different ways of processing personal information in these categories because we have a direct contractual relationship with you, which is different from our indirect relationship with your end users. As our customers, if you collect further information from your end users by providing services to your end users with our product or service, you shall reach the additional consent through your privacy policy in accordance with applicable laws and regulations, if you do not require your end users to agree to the content of this policy, you should stop using our products and/or services .

This policy describes:

1. How We Collect & Use Your and/or Your End Users` Personal Information

2. Cookies & Similar Technologies

3. Authorization and consent of End User

4. How We Share, Transfer and Disclose Your and/or Your End Users` Personal Information

5. How We Store Your and/or Your End Users` Personal Information

6. How We Protect Your and/or Your End Users` Personal Information

7. How to Access & Control Your Personal Information

8. How We Process Children's Personal Infor ma tion

9. Updates to This Policy

10. How to Contact Us

11. Other Legal Grounds of Personal Information Processing (EEA Only)


Appendix 1: Keyword definition

1. How We Collect & Use Your and/or Your End Users` Personal Information?

We will comply with the relevant laws and regulations mentioned in the introduction and abide by the “fairness and transparency” principle and out of the following purposes as described in this policy, we will collect and use the personal information belong to you as a JG developer customer (or potential developer customer), your end users’ personal information and the personal information belong to you and/or your end users we obtained from third parties.

Regardless of how we collect and use personal information from you and/or your end users, we would usually do so by obtaining consent . In some cases, we may collect and use your and/or your end users’ personal information without consent based on legal obligations or in order to protect your or any other individual`s vital interest.

Please understand that in order to better provide technology and services to you and / or your end users, or due to changes in business strategies, the functions of products and / or services on this platform may also be changed and developed. If we want to use the personal information of you and / or your terminal users for other purposes not specified in this policy, or the personal information collected for specific purposes will be used for other purposes, or our processing methods will change, we will inform you in a reasonable way through this platform, and obtain your consent again before use. Please inform your users and obtain the authorization of users.

(1) Information belong to you as a JG developer customer (or potential developer customer)

In order to realize the basic business functions of the platform, we may need to collect and use relevant personal information from you. The following is a specific description of our basic business functions and the types of your personal information. If you refuse to provide such information you may not be able to use the related products and/or services of the platform.

Register or login

When you register or login for an JG account, you need to provide your mobile phone number and verification code to complete the account registrationt.You may also need to provide us with your name, company name and location, email address so that we can communicate with you for product experience and payment. According to relevant laws and regulations, when you are an enterprise user,you also need to provide enterprise business license information for developer real-name authentication.

Security protection

When you visit and browse JG website, we automatically collect the information during your use of JG products and/or services for ensuring the security of your account and system. The information are stored as network log, including Internet Protocol (IP) address, browser types, Internet service provider (ISP), reference/exit page, operating system, date/time stamp and click data stream.

 

(2) Your end users` personal information

In order to realize the basic business functions of the platform, we may need to collect and use relevant personal information from your end users. Following is a specific list of our basic business functions and the types of personal information we collect and use. We would collect and use the personal information only if you have confirmed that the end users` consent are already obtained.

JPush: JPush Service enables APP to push messages and notifications. When your APP integrates the JPush SDK, JPush SDK will collect and use the necessary personal information and push messages or notifications to your end users through encrypted channels. The personal information collected and used by JPush SDK includes:

  1. a. Device parameters and system information ( see Appendix 1 : Keyword Definition,the same below ) : which is used to identify the user's device type, device model, system version, etc., to ensure that the message is sent accurately.
  2. b. Device identifiers: they are used to identify unique users to ensure accurate delivery of push and accurate statistics of push information.
  3. c. Network information and LBS-information: they are used for optimizing the net connection between SDK and JG server, it ensures the service stability and continuity; for realize the zone-pushing function.
  4. d. APP installation list and active status information: when a device has multiple APP push links active, we use the combined link technology to randomly combine them into one link to save power and traffic for users. We provide you with intelligent push function, through this information to recommend push content more in line with your user needs, and reduce the interference of useless push information to your users. You can choose to turn on or close this service (See Aurora ' Compliance Guidelines and Privacy Policy ' link: https://docs.jiguang.cn/jpush/client/Android/android_jghgzy ).

Jverification :The product integrates the capability in mobile phone number authentication of the three major ISPs in China and the third-party security verification capabilities to realize one-key login and number authentication of end users , verify user account and behavior security.The personal information collected and used by Jverification SDK includes:

  1. a. Device parameters / system information and device identifier: which used to verify user account and behavior security , and determine whether user behavior is a batch automated operation of machine programs.
  2. b. Network information and LBS-information : which are used for optimizing the net connection between SDK and JG server, it ensures the service stability and continuity; for analyzing the failure reason of verification request;at the same time, such information is desensitized and establish abnormal and virtual device identification models to realize traffic anti-fraud technology.
  3. c. Mobile phone number:which used to complete one-key login and number authentication, and identify the risks of your end users.
  4. d. User biometric trajectory information: In order to realize the behavior verification service, the user's sliding, clicking, mouse movement trajectory and other information generated during the operation verification process will be collected (the JiYan SDK provided by our partner collects it by itself, but we not).
  5. e. APP Installation List Information: In order to provide you with intelligent authentication services , we need to identify the end user application environment through this information, help your website and APP to identify and block batch automated operations of machine programs.

In order to ensure the stable operation and function realization of the Jverification service , we will acess the SDK and API provided by the partner . You and(or) your end users express their understanding and approval.We will conduct strict security testing on the information SDK and API of partners, and to agree on strict data protection measures with the partner to process the personal information in accordance with this policy and any other relevant confidentiality and security measures. The details of the partners we have access to are as follows. We recommend that you read the relevant privacy policies ( please note: the privacy policies of the following partners may be irregularly due to the changing situation, please pay attention and check) :

a.Volcano Engine API

Subject of information use: Beijing Volcano Engine Technology Co., Ltd.

Processing method: entrusted processing

Use information: mobile phone number , IP

Purpose of use: To provide end-user risk identification services

Volcengine Privacy Policy Link: https://www.volcengine.com/docs/6256/64902

b.JiYan SDK

Subject of information collection: Wuhan Jiyi Network Technology Co., Ltd.

Collection method: SDK collects itself

Collect information: device information, device network information, device environment information, user biometric trajectory information, other information ( verification timestamp, installation package name )

Purpose of use: to provide security risk control and behavior verification services

Geetest Privacy Policy Link: https://www.geetest.com/Private

Industry application services : The personal information we collect based on this Policy is de-identified or anonymized to form data products to provide data solutions for various vertical industries. Including Yuehu Data, FinTech, iAudience,Aurora research, JAlliance. When you use our industry application services, you may need to provide us with your end-user encrypted mobile phone number, IMEI number, so that we can feedback the analysis results through data analysis. Please inform your end users in advance and obtain legal authorization when applying for the aforementioned data services from us. In the financial technology service scenario, we will work with qualified credit agencies and financial institutions to analyze your financial risk control information.

We draw to your attention that in order to realize the above business functions, JG SDKs require the end users to switch on the permissions of “network access”, “device information” and/or “device`s location”, so that we can collect the “device information”, “network information” and/or “ LBS-information ”. If your end users are not willing to provide the above information, they can switch off the permissions of “network access”, “device information” and/or “device`s location”.

We warrant that,except as expressly agree in this policy, we will never collect or ask you to collect the following sensitive personal information, including but not limited to personal races, political preferences, religions, beliefs, personal genetic data or biometric data, sexual orientation and other sensitive personal information.

Prior to processing personal information for other purposes which are not stated in this policy, we will notify you in advance and will also inform you to obtain your end users` consent. When we need to use information collected for other purposes, we will notify you in advance and ask you to notify your end users to obtain their consent.

( 3 ) Your personal information obtained from third parties

We may collect and use your personal information from third parties (our partners) with your authorized consent. We guarantee that your personal information will be processed in strict accordance with the contract with third parties and relevant laws . please read the third-party privacy policy and user agreement carefully. If you refuse that we process the personal information from third parties, you may not use related services from JG.

We may obtain or properly use your public information from publicly-available sources like web pages, or obtain the business information that your company has publicly disclosed from third-party providers which helps us better understand our customers, such as your industry, the size of your business, and the URL of your business website.

( 4 ) Exemptions of obtaining consent

Please understand that we collect and use the personal information of you and/or your end users in accordance with laws and regulations and relevant national standards without the consent of you and/or your end users in the following cases:
Directly related to public safety, public health, and significant public interest;
To protect the vital interest(such as health and property) of you or of other individuals, where the information subject is incapable of giving consent;
The personal information collected by you and/or your end users is disclosed to the public by yourself;
The personal information of you and/or your end users collected from legally publicly disclosed information, such as legitimate news reports, public government information, etc.;
Perform the contract according to your requirements;
It is necessary to maintain the safety and stability of software and related services, such as discovering and disposing the faults of software and related services;
Other circumstances as stipulated by laws and regulations.

In particular, please notice that if the information cannot be related to identify you and/or your end users, this information does not belong to your and/or your end user's personal information in legal terms; when you and/ or your end users’ related information are able to be related to identify you and/or your end users, or when we combine your and/or your end user's personal information with the data, that are not related to any nature personal, this information will be treated and protected as personal information of you and/or your end user in accordance with this policy during the combined use.

2. How we use similar technologies like cookies?

When you use our services, we store a text file called cookie on your computer or mobile device to keep your site working. Cookies may contain identifiers, site names, and some numbers and characters. We use cookies to improve user experience in the platform`s products and/or services. Meanwhile it can be used to count the number of independent visitors to our website. We are able to provide you with a more thoughtful and customized service and allow you to set your specific service options with cookie technology.

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

We do not use cookies for any purpose other than those stated in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies stored on your computer, most web browsers can block cookies. However, if you do this, you need to change the user settings yourself each time you visit our website, and you may not be able to log in or use the services and /or functions provided by JIGUANG that depend on cookies.

For more information about the types and reason of cookies and how to control, please see AboutCookies.org .

3. Authorization and consent of end user

As a business partner, you understand that in order to provide you and/or your end users with the JG service, we will collect, store and process personal information from end users of your app in a de-identification or anonymization manner. Therefore, prior to accepting this policy and integrating our SDK, API or other statistical analysis tools and developer tools into your product, you acknowledge and warrant that:

3.1 You have informed the end user and obtained sufficient, necessary and explicit authorization, consent and permission from the end user to allow us to collect and use the information for the purpose of providing the service

3.2 Except as required by applicable law, you have informed the end user and obtained the necessary authorization, consent and permission from the end user which allow us to de-identify the collected personal information, to use the information that we collected and processed for the purposes of the services listed in Article 1 of this Policy in comply with relevant laws and regulations;

3.3 You have complied with and will continue to comply with applicable laws, regulations, and regulatory requirements, including but not limited to formulating and publishing policies regarding to the protection of personal information and privacy protection

3.4 You have provided end users with a mechanism to exercise their right s in a n easy manner, which explains how and when they can exercise their right to opt-out, access, rectification, deletion to their personal information and change their consent scope, etc.

4. How We Share, Transfer, and Disclose Personal Information about You and/or Your End Users?
4.1 Sharing

Except as described in this policy, information about you and/or your end users will not be shared with third parties in an identifiable form. Except for the following situations:

       Sharing by obtaining explicit consent. Unless agreed by you and/or your end users, we will not share information about you and/or your end users with others;

       We may share information about you and/or your end users in accordance with applicable laws and regulations ;

      To the extent permitted or required by law, it is necessary to provide personal information of you and/or your end user to third parties (including consumer protection Departments and other authorities) in order to protect the interests, property or safety of you or the public;

       Personal information disclosed by you and/or your end users or from other legal public sources;

      We may share the information with third parties in anonymization form that can not identify you and/or your end users;

     Sharing with our affiliates: Information about you and/or your end users may be shared with JIGUANG’s affiliates. We only share the necessary information and are bound by the purposes stated in this Policy. The affiliate company shall obtain consent from you and/or your end users if the purpose of processing information is changed;

     We may work with a trusted third-party vendor, consultant or other service provider (“Contract Partner”) 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 of you and/or your end users for legitimate, necessary, and specific purposes, and will only share the information necessary to provide the services. Our partners do not have the right to use the shared information for any other purpose .

If you disagree that your necessary personal information to be collected by our partners when providing the services, you may be unable to use the services provided by the partner through this platform.

Currently, our partners include the following types:

Advertising Promotion Partner: In order to target the crowd and conduct advertising accurately, we may provide the IMEI number of your end user to the advertising promotion service provider.

Information service partners: In order to provide the ability to store large files offline for JMessage users, we may transfer the information such as live chat content (pictures, videos, files) of your end users to service providers.

Social media partners: In order to achieve the cross-platform sharing function of JShare, we may transfer the shared content of your end users to social media partners.

JPush and JVerification service partners: In order to better realize JPush and JVerification services, we have integrated the service capabilities of our partners. Some service developers and customers can choose whether to integrate these services provided by partners according to their actual conditions. The final choice of the developer and customer shall prevail. ("Access Partner SDK Directory")

 

We will sign non-disclosure agreement strictly with those third companies, organizations and individuals, with which we share information and they must process information in accordance with our instructions, privacy policy and any other relevant confidentiality and security measures.

4.2 Transfer

We will not transfer personal information of you and/or your end users to any company, organization or individual, except the following situations:

      Explicit consent is obtained from you and/or your end users;

      Personal information disclosed by you and/or your end users or from other legal public sources; or to comply in accordance with applicable laws and regulations;

    In the event of a merger, acquisition or bankruptcy liquidation, personal information transfer may be involved, in which case we will require new companies and organizations that hold your personal information to continue to be bound by this Policy. If there is any change in the way of collection and processing of personal information stated in this Policy, the company or organization will obtain your or/and your end users’ consent once again.

4.3 Public disclosure

Subject to applicable laws and regulations, we will not disclose information of you and/or your end users publicly unless your explicit consent is obtained from you and/or your end users.

5. How we store personal information about you and/or your end users?

5.1 Storage location

In principle, the personal information we collect and generate only within the territory of the People's Republic of China and will be stored in the territory of the People's Republic of China. Our service is not available in any other countries and regions and is not intended to be used in any specific area except within the territory of the People's Republic of China. You are solely responsible for the extent of your use of our service and are responsible for complying with any applicable laws, including but not limited to any local laws.

5.2 Storage Term

We store personal information of you and/or your end users only for the minimum term necessary for the purposes described in this policy or in accordance with applicable laws and regulations. However, part of personal information of you and/or your end users may be stored longer in order to comply with applicable laws and regulations and other relevant regulations and it is necessary for legal claims, protection of public interest, personal property safety or legal rights of our customers, us, our affiliates and other users or employees.

6. How we protect the personal information of you and/or your end users?

We have taken industry-standard security measures to protect the information you provide to prevent unauthorized access, breach, misuse, alteration, damage or loss. We will take all reasonable and practicable steps to protect your and/or your end users’ data. For example, the data exchange between your browser and the serve is protected by SSL encryption; we also provide https secure browsing for the jiguang.cn website; we make encryption to ensure data confidentiality; we use trusted protection mechanisms to prevent data from being maliciously attacked; we deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we regularly conduct security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

We have obtained the certifications of "Information System Level Protection Level 3" and "ISO 27001 Information Security Management System Certification" and "SDK Information Security Certificate".

Our data security capabilities: we build security defenses based on the data life-cycle, which covers all data processing stages: data collection, transfer, storage, using, circulation, archiving, and deletion.

We will take all reasonable and practicable steps to ensure that unrelated personal information is not collected. Unless an extension is required or permitted by laws, we will never retain information of you and/or your end users longer than necessary to fulfill the purposes stated in this Policy.

The Internet is not an absolute ly safe environment, and email, instant messaging and other communication with other users are not encrypted. We strongly recommend you do not send personal information in this way. Please use complex passwords and change your password regularly to help us keep your account secure.

We will regularly update and disclose relevant content of reports on security risks, privacy impact assessment, etc. You can also get the relevant information through E-mail: support@jiguang.cn.

The Internet environment is not absolutely safe and we will do our best to ensure or guarantee the security of any information you send to us. Although we have made necessary and reasonable efforts, personal information may still be stolen, illegally possessed or misused, which pose a risk to you and your end users in terms of personal, property and reputation. You understand the above risks and assume to take the risk on your own.

If the personal information security incident occurs, we will promptly notify you according to the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or will take, the proposal of how you can prevent and reduce the risk, remedies provide for you, etc. We will notify you the incident in a timely manner by email or push notification. If it is difficult to notify personal information subject one by one, we will publish announcement in a reasonable and effective way.

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

7. How to Access & Control Your Personal Information

We attach great importance to the management of personal information by you and/or your end users and we do our best to protect your rights to information access, information rectification, information erasure, restriction of processing information and to information portability, in order to protect your and/or your end users` privacy and information security.

7.1 For the direct user of JIGUANG

7.1.1   Access and rectification of your personal information

You have the right to access your personal information, except as provided by laws and regulations. If you want to exercise data access right, such as you wish to access or edit corporate/personal information and payment information in your account, change your password, add security information, or close your account, you can access the JIGUANG User Center to do this.

If you are unable to access your personal information through the above link, you can send us an email at support@jiguang.cn. Before accessing relevant information, we may ask you to ensure your account security.

Please understand that due to technical limitations and legal or regulatory requirements, some of your requests may not be able to respond. Some of your information may not be accessible due to legal and regulatory requirements and information security.

7.1.2 Deletion of your personal information

In any of the following situations, you can contact us through E-mail at support@jiguang.cn to delete your personal information:

       We collect and use personal information in violation of laws and regulations;

       We collect and use personal information in violation of the agreement with you;

      We share and transfer your personal information to third parties in violation of the laws and regulations or in violation of the agreement with you, we will immediately stop the sharing and transfer, and notify the third party to delete;

     We disclose your personal information to public in violation of the laws and regulations or in violation of the agreement with you, we will immediately stop the public disclosure and issue a notice requesting the relevant recipient to delete the corresponding information.

When deleting relevant information, we may verify your identification to protect your account. Once the request of deletion is responded, your personal information will be deleted except for information required by law and regulations.

7.1.3 Change of your consent scope

Each business function needs basic personal information. For the collection and use of your personal information, you can send an email at support@jiguang.cn to contact customer service to withdraw consent.

When you withdraw your consent, we will no longer collect and use your corresponding personal information, but please understand that when you withdraw your consent, we will not be able to continue to provide you with the specific functions and/or service. Your decision of withdrawing your consent will not affect the processing of personal information which has been authorized before.

7.1.4 Closure of your account

You can close your previously registered account at any time. You can contact customer service by email at support@jiguang.cn. You should be aware that closure of your JIGUANG account will result in you permanently loss of your access to your account and the data in your account. We will provide you with an account closure 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 close your account, we will continue to optimize our products and inform you through the page announcement. After closing the JIGUANG account, we will stop providing products or services for you, and delete your personal information as soon as possible or anonymize it as requested by you, except required by laws and regulations.

7.1.5 Get a copy of your personal information

You have the right to obtain a copy of your personal information, you can always send an email to support@jiguang.cn to contact our customer service. Under technical premise, such as data interface matching, we can also directly transfer a copy of your personal information to your designated third party upon your requirements.

7.1.6 Opt-out of direct marketing

You can choose not to receive promotional emails from JIGUANG by following the unsubscribe/opt-out instructions in these emails. You can also opt-out by sending an email to support@jiguang.cn to contact customer service. Please note that even if you decide to opt-out of promotional communications, we may also send you non-promotional information related to our terms of service or privacy policy updates, security alerts, and other notices related to your access to or use of our products and services.

7.1.7 Respond to your request

For the account safety, we need to verify your identity before handling your request. You may be required to provide a written request or through other ways to prove your identity. We will, in principle, give you the feedback within 15 days after receiving your request after verifying your identity.

7.2 If you are an end user of an application using JIGUANG products or services, not a direct customer of JIGUANG, we suggest you:

    According to your application provider's privacy policy, send your request related to your personal information directly to the relevant application provider for processing and assistance. After receiving the relevant request from your application provider and verifying the authenticity of the request, JG will immediately cooperate with the application provide and respond the request.

7.3 In principle, we do not charge a fee for your reasonable request from you and/or your end user.

We may refuse the request that (1) is unreasonably repetitive;(2)need too much technical means (for example, need to develop a new systems or fundamentally change to the existing practices);(3) may lead to risks to other individuals` legitimate right; or very impractical (for example, involving information stored on backup tapes) .

We are not able to respond to your and/or your end user's request in the following situations:

       Related to our performance of obligations under laws and regulations;

       Directly related to public safety, public health, and significant public interests;

       We have sufficient evidence to prove that you have subjective malice or abuse of your rights;

      It is difficult to obtain the consent of the person for the protection of the life and property of you or other individuals;

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

      Trade secrets related.

7.4 If you and/or your end user have doubts about the realization of the above rights , you may contact us in accordance with the relevant contact information in the way described in Article 10 of this policy.

8. How we process children's personal information?

We have made it clear in the service agreement that children are not allowed to register as our users, and we do not collect personal information from end users under the age of 14. Please pay attention and be cautious. Although different local laws define children differently, we treat anyone under the age of 14 as a child. If we become aware that we have unknowingly collected personal information from a child under the age of 14, we will promptly delete the information, excepted required by laws.

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

If your app is designed and developed for children under the age of 14, make sure that your end user is a guardian who have read and agreed the app's privacy policy, and consent to provide child personal information to us for keep our service working.

9. How we update and modify this policy?

F or providing you with better service, the platform and related services will be updated and changed from time to time. We will revise this policy in due course. These amendments are part of this policy and have the same effect as this policy. Without your explicit consent, we will not reduce the rights of you and/or your end users in accordance with this Policy.

Once we update our policy, we will release an updated version on the official website and remind you of the updated content in an appropriate manner before the updated terms become effective, so that you can keep up to date with the latest version of this policy.

For major changes, we will also provide more noticeable notifications (including for certain services, we will send a notification by email or in the form of a letter or announcement to indicate the specific changes to the privacy policy). Therefore, please feel free to review and understand the policy you are subject to. If you do not agree to this Policy, please stop accessing and using our services.

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

    Our service model has been significantly changed, such as the purpose of processing personal information, the type of personal information is processed, how personal information is used, etc.;

     We have significant changes in ownership structure, organizational structure, etc. Such as the change of owner which is caused by business adjustments, bankruptcy, mergers, etc.;

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

      Significant changes in your rights to participate in the processing of personal information and how you exercise your rights;

      When the responsible department, contact methods and complaint channels related to the personal information security are changed;

      The privacy impact assessment report indicates that there is a high risk.

10. how to contact us

We hope to resolve any disputes related to our data protection practices. JG has built a dedicated privacy protection team. You can contact us by sending an email to our privacy team at compliance@jiguang.cn or by writing a letter (To: Compliance Section, Address: 14th Floor, Zhongjian Building, 006 South Twelfth Road, High-tech Zone, Yuehai Street, Nanshan District, Shenzhen, Tel: 0755-83881462), ask your questions or ask for help.

If you have questions, suggestions or complaints about your account information, personal information or other documentation technology or you want to exercise your rights, you can contact us t h rough email at support@jiguang.cn or through other channels we have stated. In general, we will respond within 15 working days.

For individuals in the EEA, you have the right to complain to the lead data protection authority or bring a case before the competent court in accordance with applicable data protection laws.

11. Other legal basis for handling personal information (EEA only)

Please pay special attention: When you process personal information, if you meet any of the following conditions, please comply with the General Data Protection Regulation (GDPR):

      You are in the European Economic Area ("EEA"), regardless of whether the processing is carried out in the EU;

      Offering goods or services (whether paid or not) to individuals at the EEA, or monitoring their behavior within the EEA;

      Not in the EEA, but in a place where Member State law applies by virtue of public international law. (such as embassies or consulates of EEA member states).

If you and/or your end users are from the EEA, the legal basis for our collection and use of the above personal information will depend on the personal information and the specific context in which we collect the information.

However, we usually only do so if we need personal information to perform the contract with you and/or your end users, or if we are in compliance with our legitimate interests and are not overridden by the interests or fundamental rights and freedoms of you and/or your end users, or we have obtained your and/or your end users` consent. In some cases, we may also be obligated to collect personal information from you and/or your end users, or we may need personal information to protect the vital interests of you or other individuals. For instance, we may be requested to offer personal information by public authority or making respond as requested by law enforcement.

If you have questions about our legal basis for collecting and using your and/or your end users' personal information or if you need further information, please contact us according to the information listed in the introductory of this Policy.


Appendix 1: Keyword Definition

The specific words used in this policy is defined as follows:

1. We or JG: Shenzhen Hexun Huagu Information Technology Co., Ltd.

2. Affiliates: it refers to a subsidiary company or other affiliated enterprise within the scope of the consolidated statement with Shenzhen Hexun Huagu Information Technology Co., Ltd. A ny company or other entity which controls, is and will be controlled by or is under common control with JIGUANG .

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

4. You: means the registered user who uses our products and/or services and the purchaser of the paid service.

5. Your End User: An end user of an application that refers to the JG Platform product or service.

6. JG or the platform: refers to the JG platform.

7. Personal Information: Information that is electronically or otherwise recorded that can be used alone or in combination with other information to identify a natural person or to reflect the behavior of a natural person. Personal information includes personal basic information, personal identification information, personal biometric information, network identity information, personal health information, personal education and occupation information, personal property information, personal communication information, contact information, personal online records, personal device Information, personal location information, etc. For the avoidance of doubt, personal information includes, but is not limited to, personally sensitive information.

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

9.Sensitive personal information: It refers to the personal information endangers personal life and property safety and easily lead to the damage to personal reputation, physical and mental health damage or discriminatory treatment, once it is leaked. Sensitive personal information includes personal property information, personal health information, personal biometric information, personal identity information, network identifier information, etc.

10.Device parameters and system information : device type, device model, system version, and related hardware information.

11. Device identifiers : IMEI, IDFA, Android ID, GID, MAC, OAID, VAID, AAID, IMSI, MEID, UAID, SN, ICCID, SIM information. UAID ( Uniform Anonymous Identifier ) is a unified anonymous identifier for telecom operators.

12.App information: Application crash information, notification switch state, APP application list and active state, APP application page information, APP function event related information.

13.Internet information: IP address, Wifi information, base station information, DNS address, DHCP address.

14. Location information: latitude and longitude.

15. De-identification: It refers to the technical processing of personal information. The personal information subject cannot be identified without additional information after this processing.

16.Anonymization: It refers to the process of making personal information subject unrecognizable through the technical processing of personal information, and the processed information cannot be recovered.

17.Mainland China: It refers to the mainland of the People's Republic of China for the purposes of this policy only, excluding the Hong Kong Special Administrative Region, the Macao Special Administrative Region and the Taiwan region.