TalkingData Group Privacy Policy

Updated on: November 30, 2023
Beijing Tengyun Tianxia Technology Co., Ltd. and its affiliated companies (hereinafter collectively referred to as "We" or "TalkingData"), as a company focusing on Internet integrated data services, have always attached great importance to the protection of personal information and privacy in data services. TalkingData understands the importance of personal information to you and will do its utmost to protect your personal information safely and reliably. We are committed to maintaining your trust in us and strictly abide by the following principles to protect your personal information: the principle of consistent rights and responsibilities, the principle of clear purpose, the principle of consent by choice, the principle of minimum sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. When you visit the TalkingData website or register to use any products and services of TalkingData, we will take appropriate security measures to protect your personal information according to the industry's mature security standards. If you have any questions, comments or suggestions, please contact us through the following contact information:
E-mail: support@tendcloud.com
Tel: 400-870-1230 Special tips: The privacy policy of TalkingData Group is only applicable to various products and services provided by TalkingData, including but not limited to: the website, SDK, API, code, tools, product documentation, etc. provided by us, but not applicable to products and services provided by third parties through TalkingData, or products and services pointed to by third-party links on the TalkingData website. In this case, it is recommended that you carefully read and understand the privacy policy of the third party. This privacy policy is closely related to the products and services provided by TalkingData. Please read the following privacy policy carefully to understand how we collect, use, save and transfer information from or about you and your end users. We try to explain to you in a clear, understandable and appropriate way so that you can know your rights and make your choice after reading. Please note that by visiting the TalkingData website or using our services, you have read, understood and agreed to accept this privacy policy. This policy is effective throughout your use of the website and services. If you do not agree with this policy, you should immediately stop using the TalkingData website and the various services described below. Please ensure that you use TalkingData SDK services legally and in compliance with relevant laws, regulations, national standards and requirements of competent authorities. The specific process is as follows: 1. Please upgrade the TalkingData SDK to the latest version. The specific download link is as follows: https://doc.talkingdata.com/posts/catalogue/1075 2. Please complete the SDK usage configuration according to the SDK Integration Document. The TalkingData SDK only makes preparations for the application runtime in the initialization phase, and does not collect any data. You should ensure that after the end user agrees to your Privacy Policy, you can start the analysis capability based on reasonable business scenarios, and use the TalkingData SDK functions in compliance and necessity. For the configuration description of the latest version of initialization configuration and startup analysis capability, see the link: Android： https://doc.talkingdata.com/posts/1025
iOS： https://doc.talkingdata.com/posts/1024 This privacy policy will help you understand the following: 1. How we collect and use your personal information
2. How we use cookies and similar technologies
3. How do we share, transfer and publicly disclose your personal information
4. How we protect your personal information
5. Your rights
6. How we deal with children's personal information
7. How your personal information is transferred globally
8. How to update this policy
9. How to contact us

1、 How we collect and use your personal information:

Personal information refers to various information recorded electronically or in other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information. TalkingData will only collect and use your or your end user's personal information for the following purposes as described in this policy. This service is only available to users in the mainland of the People's Republic of China, except for specially specified overseas/international websites or products. If you are located outside the mainland of the People's Republic of China, or if you use the products of the TalkingData service to provide end users outside the mainland of the People's Republic of China, it may involve different regulatory requirements for the collection, storage, use, sharing, etc. of data and personal information in other jurisdictions. If applicable, you should also comply with the relevant provisions of the Commitment on Compliance of Overseas Personal Information Protection; When we want to use the information for other purposes not specified in this policy, we will ask for your consent in advance. When we want to use the information collected for a specific purpose for other purposes, we will ask for your consent in advance. 1. Provide you with online information services When you visit and browse our website, like most websites, we will -Use cookie technology to store your session/selection information on your computer;
-Some information is automatically collected and stored in log files. This information includes: Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), reference/exit page, operating system, date/time stamp, and click data stream. We use this information to: -Improve your experience of using the website and service quality;
-Help us effectively manage website content;
-Analyze the site activities of group users; 2. Overview of Using TalkingData Services 1) When you register for TalkingData service, we will ask you to provide your personal information, including name, company, email address, password and mobile phone number to create an account. When you contact us later and continue to use the TalkingData service, we may ask you to provide more contact information, including: -Contact person's mailing address, telephone number, title and position;
-Your enterprise information, such as enterprise name and business type;
-Your product information, such as the name, content, category and some characteristics of the mobile application; Promotion channel information, etc. We use this information to: -Send you the registration confirmation;
-Understand and manage accounts;
-Respond to your customer service requirements;
-Understand your enterprise and product requirements to determine applicable products and services;
-Contact you for the purpose of marketing and promotion, and provide you with more information about our products;
-Conduct research and analysis to improve the quality of our website and service; 2) We leave an email on the website to allow you to contact us on your own initiative. When you contact us via email, you may provide personal information, which we will use to respond to your questions and service requirements and improve our website and services. 3. Use TalkingData service detailing 1) TalkingData Analysis Service TalkingData provides data statistics tools and analysis services for mobile applications, including but not limited to application statistics and analysis, mobile advertising monitoring and other services. When you integrate the TalkingData data SDK or API in your application, your application will collect and transmit relevant data of your end users through technical means, and analyze these data through our services to understand the performance of your application on different end devices, using platforms or application distribution channels and the use of users. Relevant data processing is as follows:
Product Functions data type Specific fields Processing purpose
Application statistical analysis Mandatory Basic personal information Unique device identifier (OAID and Android ID), IP address, IDFV, IDFA It is used to generate the unique identification of the desensitized end user for basic analysis.
Other basic data related to applications, devices and networks SDK or API version, platform, timestamp, creation time of system file, application identifier, application version, application distribution channel, application process information, application's IDFA authorization status, application's NFC permission (yes or no), whether the device supports NFC function (yes or no), whether the device supports Bluetooth function (yes or no), device model, terminal manufacturer Terminal device operating system version, session start/stop time, language location, mobile network/country code, time zone, hard disk, CPU and battery usage, network information (connection status of WiFi network or mobile network, BSSID or SSID information connected to WiFi) It is used for rough multidimensional analysis, and provides data reports by region and application version number.
Optional Optional personal information MEID, IMEI, Mac information It is used to identify users more accurately and identify cheating traffic.
App List It is used to identify, analyze and eliminate cheating traffic.
Location information (longitude and latitude, base station SystemID, NetworkID, and BasestationID) It is used to generate more accurate location distribution reports and identify cheating traffic.
Mobile advertising monitoring Mandatory Basic personal information Unique device identifier (OAID and Android ID), IP address, IDFV, IDFA It is used to generate the unique identification of the desensitized end user for basic analysis.
Other basic data related to applications, devices and networks SDK or API version, platform, timestamp, creation time of system file, application identifier, application version, application distribution channel, application process information, application's IDFA authorization status, application's NFC permission (yes or no), whether the device supports NFC function (yes or no), whether the device supports Bluetooth function (yes or no), device model, terminal manufacturer Terminal device operating system version, session start/stop time, language location, mobile network/country code, time zone, hard disk, CPU and battery usage, network information (connection status of WiFi network or mobile network, BSSID or SSID information connected to WiFi) It is used for rough multidimensional analysis, evaluation of advertising effect, and identification, analysis and elimination of cheating traffic.
Optional Optional personal information MEID, IMEI, Mac information It is used to identify users more accurately and identify cheating traffic.
App List It is used to identify, analyze and eliminate cheating traffic.
Location information (longitude and latitude, base station SystemID, NetworkID, and BasestationID) It is used to generate more accurate location distribution reports and identify cheating traffic.
According to the type of your mobile application and your requirements for statistical analysis options, in order to provide multi-dimensional analysis capabilities, your end user data may also include: user gender, age, user triggered specific events, device status information, error reports, page views, etc. If you use our products or services to collect more personal information from your end users, you should disclose it in your privacy policy in accordance with laws and regulations and obtain the authorization of the end users. In order to realize the purpose of analysis service and protect the personal information of end users, the data collected by TalkingData analysis service will form its own user identifier on the end user's equipment side for de identification processing, and send the above data in encrypted form to TalkingData server, which will be displayed by TalkingData in the form of aggregated data and analysis report, You can check the relevant statistics and analysis results by logging into the account on our website. In the brand advertising value analysis service, without the authorization and consent of the end user, we will not collect and store device feature tag information or local regional orientation information. We don't use packets to sniff browser pages; No fingerprint tracking of browser or device; Exposure pages are not captured. In any case, our service will not operate or change cookies under the domain name of a third party (especially Google), nor will it assist or intentionally allow a third party to carry out such operations. 2) Easy certification service The easy authentication service of TalkingData can meet a variety of authentication and authentication scenarios in APP, such as one click login, local number verification, SMS verification code, user real name authentication and other functions. For the privacy guide of Easy Authentication Service, see Easy Authentication Privacy Guidelines 。 3) Industry reporting services We will establish a TalkingData database based on the data collected by the analysis service and the data obtained through other legitimate channels, and make performance evaluation or behavior mode analysis reports (collectively referred to as "industry reports") applied to publishers, industries, specific regions and markets. Industry reports will be presented in the form of unrecognizable aggregations, including those independently released by TalkingData and those customized according to your needs. In particular, we will also make evaluation results of some application or some type of application based on the statistical model of TalkingData. The evaluation results may be derived from the data obtained from your application and thus show a certain consistency with your application. However, these evaluation results are calculated based on the data model, used for evaluation purposes, and are aggregated and anonymous. 4) Smart Data Market We have established an intelligent data market for the data demander to realize online transactions or data services for the data and data derivatives (whether in the form of data, tools or application software, collectively referred to as "data products") owned by TalkingData itself or licensed by the legal obligee. We guarantee that the ownership of the data products provided by us is clear and comply with the relevant laws and regulations on personal information protection. Generally, the data products that the data market conducts transactions and authorizes to use are de identified data products. In particular circumstances, if it is necessary to obtain personal information data, it should obtain the explicit authorization of the relevant individuals and be limited to obtaining access within a specific scope. At the same time, we try our best and reasonably prudently to require the data obligee of the third party to ensure that the data products meet the above requirements. 5) Consulting services We provide solutions, professional consulting services and consulting services such as Tengyun University. When providing these services, we may ask you to provide additional personal information to understand your enterprise or products. Please decide whether to provide them according to the demand scenario of consulting services. 6) TalkingData big data application service In addition to the specific services mentioned above, we will establish a TalkingData database based on the data collected by the services provided and the data obtained through other legitimate channels, and conduct big data processing through aggregation, cleaning, de identification processing, and intelligent computing to form a customer tag information database or statistical analysis database. On the basis of our own database, we provide industry customers with various forms of big data application services, such as: a. Data marketing services, using big data capabilities, promote accurate advertising marketing, build target customer groups, effectively analyze the characteristics of target customer groups, and improve marketing effects; b. Intelligent location service, which uses TalkingData's powerful human-oriented data and geographic information data, combined with classic models and prediction algorithms, to solve the problem of physical store location, store diversion and other scenarios; c. For other data services, we make full use of homomorphic encryption, data security island solutions and other technical capabilities to assist the demander in discovering the deep value of data through multiple contacts. By comprehensively analyzing the characteristics of private domain traffic users' multi terminal behavior, we provide a variety of data services, and build a comprehensive user data platform, including but not limited to data model building services, data asset management services Risk control assessment services, etc. You should know that with the development of big data industry, our big data services will update and iterate or introduce new service methods. In any case, TalkingData will strictly comply with national laws and regulations and big data industry standards. 4. Rights related to collecting personal information Due to different system requirements, you may also need to obtain relevant permissions to collect personal information using TalkingData service. Android system permissions:
Permission name Purpose of authority
INTERNET Used to allow applications to network and send statistics.
ACCESS_NETWORK_STATE It is used to allow applications to detect network connection status and suspend data transmission in case of abnormal network status.
READ_PHONE_STATE It is used to generate the unique identification of the desensitized end user.
ACCESS_WIFI_STATE It is used to generate the unique identification of desensitized end users and identify cheating traffic.
WRITE_EXTERNAL_STORAGE It is used to store device information and record logs.
ACCESS_FINE_LOCATION (optional) It is used to correct the geographical distribution data of end users, make report data more accurate, and identify cheating traffic.
ACCESS_COARSE_LOCATION (optional) Used to identify cheating traffic.
GET_TASKS (optional) It is used for more accurate statistics of end-user activity.

IOS system permissions:
Permission name Purpose of authority
network Used to allow applications to network and send data.
IDFA It is used to generate the unique identification of the desensitized end user.
Location information (optional) It is used to correct the geographical distribution data of end users, make report data more accurate, and identify cheating traffic.
WIFI information (optional) Used to identify cheating traffic.
You should understand and confirm that we will collect only after you apply for permission through the application function page of the TalkingData service installation and obtain the authorization and consent of the end user. You should also inform your end users that if they do not want to collect the above information, they can refuse or withdraw their consent by closing the corresponding permissions. 5. Exceptions to personal information collection and use authorization According to relevant laws and regulations, your authorization and consent are not required to collect your personal information under the following circumstances: 1) Directly related to national security and national defense security; 2) Directly related to public safety, public health and major public interests; 3) Directly related to criminal investigation, prosecution, trial and judgment execution; 4) It is difficult to obtain my consent for the purpose of protecting the life, property and other major legitimate rights and interests of the personal information subject or other individuals; 5) Based on the necessity of academic research, and the results of academic research or description have been de identified; 6) The personal information collected is disclosed to the public by yourself; 7) Collect personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels; 8) Necessary for the performance of the contract you signed; 9) It is necessary for maintaining the safe and stable operation of products or services provided by TalkingData, such as finding and handling product or service failures; 10) Other circumstances stipulated by laws and regulations. 6. Indirect acquisition of personal information and authorization and consent of end-user data You are very clear that for the purpose of using our data statistics and analysis, you need us to collect, store and process personal information from the end users of your applications. Therefore, you must promise: 1) You have obtained sufficient and necessary authorization, consent and permission from the end user to use the purpose required by us to perform the service;
2) You have obtained the necessary and sufficient authorization, consent and permission of the end user to allow us to process the collected data anonymously and aggregatively;
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 relevant policies on personal information protection and privacy protection;
4) You have disclosed and explained to the end users, allowing us to de identify and aggregate the collected data and build a TalkingData database to provide data services, but at the same time you should provide the end users with an easy to operate selection mechanism to explain how and when users can exercise their choice, It also explains how and when to modify or withdraw the selection after exercising the option, so that users can choose to agree or disagree to collect and use their personal information for commercial purposes. If your violation of the above commitments causes your end users to claim any form of claims or claims against us, or causes us to be involved in legal or administrative procedures, you will be responsible for a comprehensive solution and compensate us for any form of losses we may suffer as a result.

2、 How we use cookies and similar technologies

1、Cookie To ensure the normal operation of the website, we will store a small data file named Cookie on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, websites can store data such as your preferences or selected goods or services. The above cookie technology is limited to the cookie range of web browser, and we will not use Flash cookie technology for data storage. We will not use cookies for any purpose other than those stated in this policy. You can manage or delete cookies according to your preferences. For details, see AboutCookies.org. You can clear all cookies saved on your computer. Most web browsers have the function of blocking cookies. However, if you do this, you need to personally change the user settings each time you visit our website. For details on how to change browser settings, please visit the function options of each browser. In addition to cookies, emails we send to you may contain clickable URLs that link to our website content. If you click this link, we will track this click to help us understand your product or service preferences and improve customer service. If you don't want your activities tracked in this way, you can unsubscribe from our mailing list at any time. 2. Do Not Track Many web browsers are equipped with the Do Not Track function, which can release Do Not Track requests to websites. At present, the major Internet standards organizations have not established relevant policies to specify how websites should respond to such requests. But if your browser has enabled Do Not Track, all our websites will respect your choice.

3、 How do we share, transfer and publicly disclose your personal information

1. Share We will not share your personal information with any other company, organization or individual, except for the following circumstances: 1) After obtaining your explicit consent, we will share your personal information with other parties. 2) We may share your personal information according to laws and regulations or mandatory requirements of the competent government departments. 3) Share with our affiliates: Your personal information may be shared with TalkingData affiliates. We will only share necessary personal information and are bound by the purpose stated in this privacy policy. If the subsidiary wants to change the purpose of processing personal information, it will ask for your authorization again.
Our subsidiaries include: Suzhou Tengyuntianxia Data Technology Co., Ltd 4) Sharing with advertisers, advertising alliances or other operators (collectively referred to as "business partners"): we will cooperate with such authorized partners to use the processed and processed de identification data in the TalkingData database for commercial use in various forms, such as using the data to optimize advertising and improve marketing effects. Unless we get the permission of you and the end user, we will not share personal identity information (refers to information that can identify personal identity, such as name or e-mail, through which you can contact individuals or identify individuals) with business partners. We will provide these partners with information about their advertising coverage and effectiveness, instead of providing personally identifiable information, or we will summarize this information so that it will not identify individuals. For example, only after advertisers agree to abide by our advertising guidelines can we tell advertisers how effective their ads are, or how many people have seen their ads or installed apps after seeing them, or provide these partners with demographic information that cannot identify themselves (for example, "25 year old men in Beijing like software development" ）To help them understand their audience or customers. Such information cannot identify your and/or your end user's personal identity alone or in combination with other information, and it does not belong to your and/or your end user's personal information in the legal sense. For companies, organizations and individuals with whom we share personal information after obtaining the authorization and consent of the personal information subject, we will sign a strict confidentiality agreement, requiring them to handle personal information in accordance with our instructions, this privacy policy and any other relevant confidentiality and security measures. 2. Assignment We will not transfer your personal information to any company, organization or individual, except for the following circumstances: 1) Transfer with explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties; 2) In case of merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy, otherwise we will require the company or organization to ask for your authorization consent again. 3. Public disclosure We will only publicly disclose your personal information under the following circumstances: 1) After obtaining your explicit consent;
2) Law based disclosure: We may publicly disclose your personal information in the case of mandatory requirements of laws, legal procedures, lawsuits or government authorities.
3) In case of emergency, it is reasonably judged to protect the legal rights and security of us, our agents, customers, end users or others.
4) We file a lawsuit or arbitration against users to safeguard our own or other users' legitimate rights and interests;

4、 How we protect your personal information

1. Data confidentiality measures taken by us There is no transmission method on the Internet, or the electronic storage method is 100% secure. Although we have made reasonable efforts, it may still be stolen, illegally owned or abused, which may cause personal, property and reputation losses to you and your users. You have understood the above risks and are willing to take them. We will adopt the prevailing and reasonable standards in the industry to protect the security and confidentiality of the information we store. Including but not limited to: firewall and data backup measures; Access permission restrictions of the data center; Encrypt the identification information of the mobile terminal. We have established and improved the data security management system, including the classification, encryption and storage of user information, the division of data access rights, the designation of internal data management systems and operating procedures, and strict process requirements from the acquisition, use and destruction of data to avoid the illegal use of user privacy data. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for the period necessary to achieve the purpose described in this policy, unless the retention period needs to be extended or permitted by law. We have also established a training mechanism for regularly holding security and privacy protection training to improve employees' awareness of personal information protection. We will review, update and disclose TalkingData security risk and personal information security impact assessment report from time to time. 2. Emergency disposal and early warning If an unfortunate personal information security incident happens, we will inform you of the basic situation and possible impact of the security incident, the emergency response we have taken or will take, other relevant disposal measures, and remedial measures for you in a timely manner through the website letter/your reserved contact information, etc. according to the requirements of laws and regulations. If it is difficult to inform individual information subjects one by one, we will take a reasonable and effective way to issue an announcement and will take the initiative to report the disposal of personal information security incidents to the relevant regulatory authorities. If you find that your personal information is leaked, please contact us immediately through the contact information agreed in this statement, so that we can take corresponding measures in a timely manner.

5、 Your rights

In accordance with the relevant laws, regulations and standards of China, as well as the prevailing practices of other countries and regions, we guarantee that you can exercise the following rights on your personal information: 1. Access your personal information You can access your personal information on your own by logging in to your account and entering the "Account Management" page, except for exceptions stipulated by laws and regulations. We will provide you with other personal information generated during your use of our products or services as long as we do not need too much investment. If you want to exercise data access, please send an email to【 support@tendcloud.com 】。 2. Correct or supplement your personal information When you find that there is an error in your personal information collected by us, or your personal information needs to be updated and supplemented, you can log in to your account and enter the "Account Management" page to correct or supplement by yourself. The correction of some special information may not be self operated. You can contact us according to or through this privacy policy or various contact information published on the TalkingData website. To ensure the security of your account, we may require you to verify your identity. 3. Delete your personal information You can cancel your authorization to collect and use your personal information by canceling your account and setting OPT-OUT privacy on TalkingData website, and we will stop using and delete your personal information. Please note that we may not delete the corresponding information from the backup system immediately, but will delete it when the backup is updated. In the following cases, you can request TalkingData to delete your personal information: 1) If we deal with personal information in violation of laws and regulations;
2) If we collect and use your personal information without your consent;
3) If our handling of personal information violates the agreement with you;
4) If you no longer use our products or services, or you cancel your account;
5) If we no longer provide you with products or services. If we decide to respond to your request for deletion, we will also notify the third party sharing your personal information to us as far as possible, and require such third party to delete your personal information in a timely manner, unless otherwise provided by laws and regulations, or such third party has obtained your independent authorization. If you cannot access, update or delete such personal information through the above path, you can contact us at any time through TalkingData customer service. We will reply to your visit request within 15 working days. Despite the above provisions, in order to resolve disputes, implement user agreements, and comply with technical requirements related to safe operation, we may still retain some data for a reasonable time to the extent permitted by law. 4. Change the scope of your authorization and consent Each business function requires some basic personal information to complete (see "Part I" of this policy). For the collection and use of additional collected personal information, you can give or withdraw your authorization consent in specific services at any time. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous personal information processing based on your authorization. You can refuse commercial advertisements through OPT-OUT channel（ http://www.talkingdata.com/optout.jsp?languagetype=zh_cn ） 5. Account cancellation You can cancel your previously registered account at any time. You can contact: support@tendcloud.com After canceling the account, we will stop providing products or services for you, and delete your personal information according to your requirements, unless otherwise specified by laws and regulations. 6. Get a copy of your personal information You have the right to obtain copies of your personal basic data, personal identity information, personal health and physiological information, and personal education information by sending a request to TalkingData contacts. On the premise of technical feasibility, such as data interface matching, we can also directly transfer your copy of personal information to the third party designated by you according to your requirements. 7. Automatic decision of constraint information system TalkingData makes automatic decisions (such as commercial information push) based on the authorized and legally collected personal information through the information system, algorithm and other non manual automatic decision-making technologies to achieve labeling or portrait processing. This behavior constitutes the unrecognizability of data and does not share, transfer or disclose any of your personal information to any third party. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide appropriate remedies. If you do not want to participate in such targeted advertising information push, please cancel it through the following OPT-OUT channels（ http://www.talkingdata.com/optout.jsp?languagetype=zh_cn ） 8. Respond to your request above To ensure security, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. We will reply within 15 working days. If you are not satisfied, you can also complain through Part IX. For your reasonable request, we do not charge a fee in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. We may reject those requests that are unprovoked and repetitive, require too many technical means (for example, need to develop new systems or fundamentally change the current practices), bring risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes). Under the following circumstances, we will not be able to respond to your request according to the requirements of laws and regulations: 1) Directly related to national security and national defense security;
2) Directly related to public safety, public health and major public interests;
3) Directly related to criminal investigation, prosecution, trial and judgment execution;
4) There is sufficient evidence to show that you have subjective malice or abuse of rights;
5) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations.
6) Involving trade secrets.

6、 How we deal with children's personal information

We have made it clear in the service premise that minors are not allowed to register as our users. Informed, we will not collect and use data on children. If your application is designed and developed for children, you must ensure that you take necessary technical measures to ensure that the registration and use of the application by the end user are carried out by the child's guardian. At the same time, you have formulated sufficient user agreements and privacy policies to fulfill your obligation to inform, In the case of collecting children's personal information with the consent of parents, we will only use or publicly disclose this information when it is permitted by law, explicitly agreed by parents or guardians, or necessary to protect children. Although local laws and customs have different definitions of children, we regard anyone under the age of 14 as a child. If we find that we have collected children's personal information without the prior consent of verifiable parents, we will try to delete relevant data as soon as possible.

7、 How your personal information is stored and transferred globally

1. Storage location In principle, the personal information we collect and generate in the People's Republic of China will be stored in the People's Republic of China. In the process of providing services, we may transfer the data collected from you or your product end users to our affiliated entities or other third parties outside your jurisdiction. Such transfer will be within the scope of laws and regulations, and will process and provide adequate protection for your personal information according to this policy. If you or your product end users are located outside the jurisdiction of the People's Republic of China, or if you or your product end users are located within the jurisdiction of the People's Republic of China, but we need to transfer to outside the jurisdiction of the People's Republic of China, you should agree or obtain the consent of the end users about this international transfer. We strongly recommend that you consult local professionals to ensure that this transfer in or transfer out meets local data protection requirements. In particular, when the international transfer involves the European Union or the United States, please pay attention to the legal provisions of these countries and regions on personal information data protection. 2. Storage time We only store your and your end user's personal information for the purpose described in this privacy policy and the shortest period specified by laws and regulations. After the storage period expires, we will delete or anonymize the personal information according to the requirements of applicable laws and regulations. However, if the laws and regulations provide otherwise, or you and your end users are otherwise authorized to agree, we may extend the storage period of your and your end users' personal information.

8、 How to update this policy

We have the right to adjust this privacy policy at any time according to changes in services, adjustments in applicable laws and policies, and other affected factors. Without your explicit consent, we will not reduce your rights under this privacy policy. Any update of this privacy policy will be published on this website by marking the update time, Therefore, please check and understand your privacy policy at any time. If you do not agree to accept this privacy policy, please stop accessing and using our services. For major changes to this privacy policy, we will notify them in a more significant way (such as pop-up prompts on the first level page or messages on the site). Major changes referred to in this policy include but are not limited to: 1. Our service model has undergone significant changes. For example, the purpose of processing personal information, the type of personal information processed, and the use mode of personal information;
2. Significant changes have taken place in our ownership structure and organizational structure. Such as business adjustment, bankruptcy M&A, etc;
3. The main objects of personal information sharing, transfer or public disclosure have changed;
4. Your right to participate in personal information processing and the way you exercise it have changed significantly;
5. When the responsible department, contact information and complaint channel for handling personal information security change;
6. When the personal information security impact assessment report indicates that there is a high risk. This policy is an important part of the TalkingData Terms of Service.

9、 How to contact us

If you have any questions, suggestions or complaints about our privacy policy, please contact【 support@tendcloud.com 】。 We have set up a special department for personal information protection (or personal information protection specialist), and you can contact it through the following ways:【 td_legal@tendcloud.com 】Generally, we will reply within 15 working days. If you are not satisfied with our reply, especially if you think that our personal information processing has damaged your legitimate rights and interests, you can also complain or report to regulatory authorities such as Netcom, Telecom, public security and industry and commerce, or you Have the right to submit the dispute to Beijing Arbitration Commission for arbitration in Beijing in accordance with its then effective arbitration rules.

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