TopChat AI - Privacy Policy

Effective date: December 10, 2022

You are welcome to start using the products and services provided by "Packhorse Tech Co.,Ltd"! Packhorse Tech Co.,Ltd (hereinafter referred to as us), we will use the "TopChat AI-Privacy Policy" (hereinafter referred to as "this policy") to help you understand how we collect, use and store your personal information and what rights you have.

This policy applies to products or services provided by "TopChat AI " (hereinafter referred to as "this product"). If we and the related products or services developed by us use the products or services provided by this product but there is no independent legal statement and privacy policy, this policy also applies to that part of the products or services.

This policy is closely related to your use of our services. We recommend that you carefully read and understand the entire content of this policy, and start using it after confirming your full understanding and agreement. We strive to use easy-to-understand, concise and concise text to express, and use bold fonts to mark the terms in this policy that have a significant relationship with your rights and interests to remind you of your attention.

Your use or continued use of our services means that you agree to our collection, use, storage and sharing of your relevant information in accordance with this policy.

This policy will help you understand the following:

1. How we collect and use your information

2. Information storage

3. Information Security

4. How we use information

5. External provision

6. Your rights

7. Change

8. Protection of minors

9. Contact us

1. How we collect and use your personal information

When you use our products and/or services, we need/may need to collect and use your personal information including the following two types:

1. In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;

2. In order to provide you with additional functions of our products and/or services, you have chosen to authorize us to collect and use information. If you refuse to provide, you will not be able to use the relevant additional functions or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services.

You understand and agree:

1. We are committed to creating a variety of products and services to meet your needs. Because we provide you with a wide range of products and services and the specific products/services that different users choose to use, there are differences in the range of specific products/services. Correspondingly, basic/ Additional functions and the type and scope of personal information collected and used will be different, please refer to the specific product/service function;

2. In order to bring you a better product and service experience, we are constantly striving to improve our technology, and then we may launch new or optimized functions from time to time, and may need to collect and use new personal information or change Purpose or method of using personal information. In this regard, we will separately explain to you the collection purpose, scope and use method of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with a way to choose your consent, and after obtaining your express consent Collect and use. In this process, if you have any questions, comments or suggestions, you can contact us through the various contact methods we provide, and we will answer you as soon as possible.

We will implement the following functions of this policy to collect and use your personal information:

(1) Help you become our user

In order to comply with the requirements of laws and regulations, when you register as our user, you need to provide your phone number to create an account for this product. For services that require the account of this product to be used, we may verify your user identity based on the above information provided by you to ensure that we are providing services for you.

When you use this product, in order to maintain your basic information and improve your service experience, you can complete network identification information (such as avatar, user name and login password, etc.).

Authorized login: We may share your account information (avatar, nickname, and other information shared with your consent) with a third party with your consent, so that you can easily register or log in to a third-party account. In addition, we may obtain your account information from a third party based on your authorization, and bind it to your product account, so that you can directly log in, use our products and/or services, or implement it through a third-party account. Interoperability of related rights and interests between accounts. We will use your relevant information within the scope of your authorization and consent in accordance with the agreement with the third party.

(2) Provide you with product or service information display

During your use of our services, in order to understand the suitability of the product and identify the abnormal status of your account, we may request you to provide or automatically collect your usage and store it as a web log information, including:

1.2.1 Our product integrates Youmeng+SDK (Youmeng Tongxin (Beijing) Technology Co., Ltd.), according to your specific operations in software installation and use, Youmeng+SDK needs to collect your device Mac address and install List, unique device identification code (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) to provide statistical analysis services, and to calibrate the accuracy of report data through geographic location to provide basic anti-cheating services.

1.2.2 Our product integrates pangolin advertising SDK. In order to provide you with valuable advertising services that meet your needs, when you agree to this privacy policy, you authorize and agree to the installation list and IMEI personal information of the pangolin SDK integrated with this product. Sent to Beijing Youzhuju Network Technology Co., Ltd.

1.2.3 Our product integrates Guangdiantong Advertising SDK. In order to provide you with valuable advertising services that meet your needs, when you agree to this privacy policy, you are authorized to agree to the installation list of Guangdiantong SDK integrated with this product. , IMEI personal information is sent to Tencent Technology (Shenzhen) Co., Ltd.

1.2.4 Our product is integrated with the Alibaba Cloud Feedback SDK. In order to facilitate your feedback to us about problems in use, when you agree to this privacy policy, you also authorize the Alibaba Cloud Feedback SDK integrated with this product to fill in your feedback. Send us your text, pictures, audio and video content.

1.2.5 Our product integrates the SDK of Google Firebase. In order to facilitate our statistics on your usage, we will send your usage data to us for analysis so that we can improve APP functions and provide you with a better service experience.

1.2.6 Our product integrates Tencent Bugly's SDK, in order to facilitate us to collect data such as crashes, freezes, and abnormalities in your APP, so that we can fix APP bugs and provide you with a better service experience.

(3) Customer service and dispute handling

When you contact us to apply for dispute resolution, in order to protect your account and system security, we need you to provide the necessary personal information to verify your user identity.

In order to facilitate contact with you, help you solve the problem as soon as possible or record the solution and results of the related problem, we may save your account information, other information you provide to prove relevant facts, or the contact information you left.

In order to provide services and improve the quality of services, we may also use other information about you, including relevant information you provide when you contact customer service.

(4) Other

1. If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing this personal information to us.

2. If we use information for other purposes not specified in this policy, or use information collected for a specific purpose for other purposes, or we actively obtain your personal information from a third party, we will solicit in advance Your consent.

If we obtain your information indirectly from a third party, we will explicitly ask the third party in writing to collect personal information after obtaining your consent in accordance with the law, and inform you of the content of the shared information, which involves sensitive information. Before it is provided to us, it needs to be clearly confirmed by you, and requires the third party to make a commitment to the legality and compliance of the source of personal information. If the third party violates the behavior, we will explicitly require the other party to bear the corresponding legal responsibility; at the same time; , Our professional security team will strengthen the security of personal information (including sensitive information reporting, sensitive information encrypted storage, access control, etc.). We will use no less than the same protection measures and measures as our own users' personal information to protect personal information obtained indirectly.

3. Exceptions with authorization and consent

You fully understand and agree that, in accordance with relevant laws and regulations, we do not need your authorization and consent to collect and use your personal information in the following situations, and we may not respond to your corrections/modifications, deletions, cancellations, and withdrawals Request for consent and request for information:

1) Related to national security and national defense security;

2) Related to public safety, public health, and major public interests;

3) Related to criminal investigation, prosecution, trial, and execution of judgments;

4) In order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain your own consent;

5) The personal information collected is disclosed to the public by yourself;

6) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

7) Necessary for signing a contract according to your requirements;

8) It is necessary to maintain the safe and stable operation of the products or services provided, such as discovering and disposing of product or service failures;

9) Necessary for legal news reports;

10) When it is necessary for academic research institutions to conduct statistical or academic research based on public interests, and when they provide academic research or description results to the outside, they de-identify the personal information contained in the results;

11) Other circumstances stipulated by laws and regulations.

4. If we stop operating this product or service, we will promptly stop the activities of continuing to collect your personal information, will notify you of the suspension of operations in the form of one-by-one delivery or announcement, and deal with what we hold and have been closed. Business-related personal information is deleted or anonymized.

5. When you actively cancel your account, we will make it anonymous or delete your personal information as soon as possible in accordance with the requirements of applicable laws and regulations.

2. Information storage

2.1 Where to store information

We will store the personal information of users collected in China in China in accordance with laws and regulations.

We currently do not transfer or store your personal information across borders. If cross-border transmission or storage is required in the future, we will inform you of the purpose of the information going abroad, recipients, security assurance measures and security risks, and obtain your consent.

2.2 Method and period of information storage

Mobile phone number or other third-party account: If you need to use this product service and use your mobile phone number or third-party account to authorize login, we need to keep your account to ensure that you use the service normally. When you log out of this product account , We will delete the corresponding information;

Picture or video: When our products or services cease to operate, we will notify you in the form of push notifications, announcements, etc., and delete your personal information or make anonymization within a reasonable period of time.

Three information security

3.1 Safety protection measures

We strive to provide protection for users' information security to prevent information leakage, loss, improper use, unauthorized access and disclosure, etc. We use multi-faceted security protection measures to ensure that the protection of users' personal information is at a reasonable level of security, including technical protection means, management system control, security system protection and many other aspects.

We adopt industry-leading technological protection measures. The technical means we use include but are not limited to firewalls, encryption (such as SSL), de-identification or anonymization, access control measures, etc. In addition, we will continue to strengthen the security capabilities of the software installed on your device. For example, we will complete part of the information encryption work locally on your device to consolidate secure transmission; we will learn about the application information installed on your device and the running process information to prevent malicious programs such as viruses and Trojan horses.

We have established a special management system, process and organization to ensure the safety of personal information. For example, we strictly limit the scope of people who can access information, require them to observe confidentiality obligations and conduct audits, and those who violate their obligations will be punished in accordance with regulations. We will also review the management system, process and organization to prevent unauthorized persons from accessing, using or disclosing user information.

3.2 Security incident handling measures

In the event of personal information leakage, damage, loss and other security incidents, we will activate emergency plans to prevent the expansion of security incidents. After a security incident occurs, we will promptly inform you of the basic situation of the security incident, the disposal measures and remedial measures we are about to or have taken, and our response suggestions to you in the form of push notifications, emails, etc. If it is difficult to inform one by one, we will issue warnings through announcements and other methods.

Four how we use information

We strictly abide by laws and regulations and agreements with users, and use the collected information as described in this privacy protection guide to provide you with better services.

4.1 Information Use Rules

We will use the collected information in accordance with the following rules:

1) Third-party advertising SDKs (Pangolin SDK, Guangdiantong SDK, Youmeng SDK) will use cookies and related technologies to collect your account number, search history, browsing history, location information and other characteristics to provide you with personalized services, including Corresponding to the characteristic tag of the account number to carry out indirect population portraits and provide you with more accurate and personalized services and content, etc., to show you more relevant advertisements or other promotional content, to optimize the personalized service experience, and to evaluate and improve The effectiveness of our advertising and other promotional activities;

2) We will analyze the operation of our products based on the frequency of your use of this product, fault information, performance information, etc., to ensure the safety of services, optimize our products, and improve our service quality. We will not combine the information we store in the analysis software with the personally identifiable information you provide.

4.2 Ways to obtain consent after informing the purpose of the change

We will use the collected information for the purposes covered by this privacy protection guideline. If we use your personal information beyond the stated purpose at the time of collection and the scope of direct or reasonable connection, we will notify you again and obtain your express consent before using your personal information

4.3 This product currently uses all or part of the following third-party SDKs, as follows:

1. Youmeng + SDK (Youmeng Tongxin (Beijing) Technology Co., Ltd.)

Function: During your use of our products, in order to reduce the impact of bugs (unknown errors that may be generated by the software) on your use, our products integrate Umeng+SDK, Umeng+SDK needs to collect your device Mac address and unique device Identification code (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) to provide statistical analysis services, and to calibrate the accuracy of report data through geographic location to provide basic anti-cheating capabilities.

The type of personal information collected: installation list, device Mac address, unique device identification code IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information

2. Alibaba Cloud Feedback (Alibaba Cloud Computing Co., Ltd.)

Function: During your use of our products, if you encounter any problems, in order to allow you to contact us more quickly.

Types of personal information collected: pictures and audios uploaded by users.

Pangolin (Beijing Youzhuju Network Technology Co., Ltd.)

Function: advertising cooperation, attribution, anti-cheating monitoring

Types of personal information collected: operator, device time zone, compliant device identification, device Mac address, unique device identification code (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information)

3. Guangdiantong (Tencent Technology (Shenzhen) Co., Ltd.)

Function: advertising cooperation, attribution, anti-cheating monitoring

4. Google Firebase (Google Inc.)

Function: Collect your device Mac address, unique device identification code (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) to provide statistical analysis services, and calibrate report data accuracy through geographic location.

Types of personal information collected: IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information

5. Tencent Bugly (Shenzhen Tencent Computer System Co., Ltd.)

Function: In order to reduce bugs (unknown errors that may be generated by the software) affecting your use, our product integrates Tencent Bugly??s SDK to collect your device??s Mac address and unique device identification code (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) in order to provide statistical analysis services, and calibrate the accuracy of report data through geographic location.

Collection of personal information types: installation list, APP crashes, abnormalities, freezes, etc., IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information

6. Pangolin (Beijing Giant Engine Network Technology Co., Ltd.)

Function: advertising cooperation, attribution, anti-cheating monitoring

Types of personal information collected: installation list, operator, device time zone, compliant device identification, device Mac address, unique device identification code (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information)

4.4 Device permission call

In the process of providing services, in order to ensure that you can use the product functions normally, this product applies to the system for some or all of your permissions. We will ask for your consent before applying. You can choose "allow" or "prohibit" to apply for permission. After your authorization, we will open the relevant permissions. You can cancel the authorization in the system at any time. After you cancel the authorization, you will not be able to use the relevant business functions, but will not prevent you from using other functions.

The invocation of system privacy permissions by various business functions is as follows (this product does not necessarily use the following permissions, only to ensure that you can use the product functions normally, apply for some or all of the following permissions, if you do not use the functions, then Will not apply for permission):

Device permissions

Business functions

Authorization method

Can be closed

Read and write sd card

Save pictures or audio files, read album pictures or audio, video files

Authorize when users need it

Yes

recording

User feedback for recording voice or recording audio editing

Authorize when users need it

Yes

camera

Take a custom avatar

Authorize when users need it

Yes

Read the unique identification code of the device

Read IMSI to determine the type of operator

Authorize when users need it

Yes

Five external provision

At present, we will share information with our product partners so that they can send users information about their products and services. When we share your information, we will urge alliance members, partners or other trusted third-party suppliers and services Businesses and agents abide by the privacy policy and require them to take relevant confidentiality and security measures to handle the above-mentioned information. We will use relevant technologies to locate your location. These technologies include IP address, GPS, and sensor technologies such as WLAN access points, Bluetooth, and base stations that can provide relevant information. We only collect your geographic location at the time, but will not associate your location information at various times to determine your whereabouts.

We will not publicly disclose the personal information it collects. If public disclosure is necessary, we will inform you of the purpose of the public disclosure, the type of information disclosed, and the sensitive information that may be involved, and obtain your express consent.

With the continuous development of our business, we may conduct mergers, acquisitions, asset transfers and other transactions. We will inform you of the relevant circumstances and continue to protect or require new controllers in accordance with laws and regulations and standards not lower than those required by this guide. Continue to protect your personal information.

In addition, in accordance with relevant laws, regulations and national standards, in the following situations, we may share, transfer, and publicly disclose personal information without prior authorization and consent from the subject of personal information:

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 execution of judgments;

4) In order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the consent of the person;

5) Personal information that the subject of personal information discloses to the public by himself;

6) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

6. Your rights

During your use of this product, in order for you to access, correct, and delete your personal information more conveniently, while protecting your right to withdraw your consent to the use of personal information and cancel your account, we have provided you with corresponding information in the product design. For operation settings, you can refer to the following guidelines for operation. In addition, we have also set up complaints and reporting channels, and your comments will be dealt with in a timely manner.

Seven, change

We may revise this guideline in due course. When the terms of the guidelines change, we will show you the changed guidelines in the form of push notifications and pop-up windows when you log in and update the version. Please note that we will collect, use, and store your personal information in accordance with the updated guidelines only after you click the consent button in the pop-up window.

8. Protection of minors

We attach great importance to the protection of the personal information of minors. According to relevant laws and regulations, if you are a minor under the age of 18, you should obtain the written consent of your parent or legal guardian before using this service. If you are the guardian of a minor, if you have any questions about the personal information of the minor under your supervision, please contact us through the contact information in Section 9.

Nine, contact us

When you have other complaints, suggestions, and minor personal information related issues, please contact us through the APP internal feedback channel or send an email to haloappteam@outlook.com

We will review the issue as soon as possible and respond within fifteen days after verifying your user identity.