Privacy Policy

 

Overview

 

This policy will help you understand the following:

 

1. Definitions

2. How we collect personal information

3. How we store and protect personal information

4. How we use personal information

5. How we provide personal information to third parties

6. How you can access and manage your personal information

7. Use of Cookies and related technologies

8. Statement on third-party responsibilities

9. Special provisions for minors' privacy rights

10. Applicability and updates to this policy

11. Other

12. Contact Us

 

Xiaoyao and its associated products and website services (hereinafter referred to as "the Platform") are operated by Chinese Online Group and its affiliates (hereinafter referred to as "we"). We respect and protect your privacy. When you use the Platform, we will collect, store, use, disclose, and protect your personal information in accordance with this Privacy Policy (hereinafter referred to as "this Policy").

 

This Privacy Policy applies to the Platform's website (https://xiaoyao.col.com) and any other applications, mini-programs, web pages, H5 pages, etc., that we may develop from time to time and operate independently or jointly with other third parties, as well as multiple application versions including but not limited to [V0.1]. The personal information we may obtain depends on the specific version of the product you are using, the type/version of the terminal device you are using, and the functions you are using.

 

This Policy is closely related to your use of the Platform. It aims to help you understand which personal information we will collect, why we collect this information, what we will do with this information, and how we will protect it. We will follow this Privacy Policy to collect and use your personal information, but we will not adopt a mandatory bundling approach to collect all your personal information simply because you have authorized this Privacy Policy. We will strictly follow legal requirements and obtain your separate consent in specific circumstances. In addition to this Privacy Policy, we may also inform you of the rules for handling your personal information through product page notifications, pop-up prompts, information push, and other means. The specific use of personal information for specific business functions will be subject to specific rules, which will have the same effect as this Privacy Policy. Unless otherwise stipulated by law or administrative regulations, regarding how we handle your personal information, you have the right to be informed and to make decisions. You have the right to restrict or refuse us or any other party from processing your personal information. At the same time, you have the right to ask us to explain the rules for processing your personal information.

 

We suggest that you carefully read and understand the entire content of this Policy. When you click to accept this Policy, it means that you have understood this article and agree that we will collect and use your information within the scope of the law and as stipulated in this Policy. If you do not agree with any content of this Policy or cannot understand the relevant content of this Policy, you should immediately stop accessing and using the Platform. If you have any questions, opinions, or suggestions about the content of this Policy, you can send an email to [zhuangyy@col.com] for consultation.

 

If you are under 18 years old or do not have full civil capacity, please read this Policy with your guardian, especially the terms regarding minors' personal information, and obtain the consent of your parent or guardian in advance. If you are the guardian of a minor, when you have any questions about the personal information of the minor under your guardianship, please contact us by sending an email to [zhuangyy@col.com].

 

1. Definitions

 

Personal Information: Refers to various types of information recorded in electronic or other forms that can independently or in combination with other information identify a specific natural person's identity or reflect a specific natural person's activity status, including name, date of birth, ID card number, personal biometric information, address, communication contact information, communication records and content, account password, property information, credit information, travel trajectory, accommodation information, health physiological information, transaction information. (Quoted from GB/T35273-2020 Information Security Technology - Personal Information Security Specification)

 

Sensitive Personal Information: Refers to personal information that may endanger personal and property safety, easily lead to personal reputation, physical and mental health damage, or discriminatory treatment if leaked, illegally provided, or abused. This includes ID card numbers, personal biometric information, bank account numbers, communication records and content, credit information, travel trajectory, accommodation information, health physiological information, transaction information, personal information of children under 14 years old (inclusive), etc. (Quoted from GB/T35273-2020 Information Security Technology - Personal Information Security Specification)

 

2. How We Collect Personal Information

 

To enable you to use the Platform normally, we will collect your personal information in accordance with the scope of specific products and/or services and different functions, following the principles of legality, propriety, necessity, and transparency, and only collect the personal information necessary to implement the product functions.

 

If we wish to use your personal information for purposes not covered by this Policy, or if we intend to use information collected for specific purposes for other purposes, we will promptly inform you in a reasonable manner and obtain your consent again. We will provide you with detailed information on the personal information collected for each business function, as well as the methods and purposes of collection, and prompt you for the permissions required when you use specific functions. During your use of the Platform, we will collect the following information in the manner described below to provide you with services, optimize our services, and ensure the security of your account.

 

2.1 Registration and Login

 

We will collect the information you provide when registering for a Platform account (including nickname, mobile phone number, and verification code match results), and we will also send service notifications to your mobile phone number. You should be aware that mobile phone numbers, ID card information, and verification code match results are your sensitive personal information. You can only successfully create and/or log in to an account and use the related functions of the product by providing the correct and accurate information above. If you refuse to provide it, it may lead to your inability to use this function, so please carefully consider providing it. When you choose the one-click login/registration function, based on our cooperation with telecommunications operators, we will collect your mobile phone number and mobile operator information to provide you with quick login services.

 

To maintain your basic information, you can choose to edit your personal profile, and we will obtain the information you provide and upload when editing your profile (including nickname, avatar, email address, location, birthday, gender). If you choose not to provide the above information, you may not be able to use a certain function or part of the service, but it will not affect your use of other services we provide.

 

You can choose to log in using your account (mobile phone number + verification code/login password) after creating an account. We will encrypt your password for automatic storage, transmission, and verification of your password. When you keep, enter, and use your password, you should carefully assess the physical and electronic environment to prevent password leakage. If you forget your password, you can retrieve it through SMS verification.

 

2.2 Real-name Authentication

 

Before using certain functions or services, according to relevant laws and regulations, you may need to provide your real name, ID number, mobile phone number to complete real-name authentication. ID numbers, phone numbers, and facial recognition information are your sensitive personal information. You can refuse to provide them, and at this time, you may not be able to obtain related services, but it will not affect the normal use of other functions and services.

 

2.3 Message Notifications

 

To provide you with services, we may use your contact information (e.g., phone number) that you provided during the use of products and/or services to send you various notifications, including identity verification, security verification, user experience surveys, dispute resolution, and other types of notifications. In addition, we may also provide you with commercial information about services, functions, or activities that you may be interested in through the contact information collected in the above process in the form of SMS or phone calls. If you do not wish to receive this information, you can unsubscribe through the unsubscribe method provided in the SMS, or you can contact us directly to unsubscribe.

 

2.4 Text Information

 

When you use the machine continuation function, the Software needs to obtain the text information you input to be continued and complete the machine continuation, so as to provide you with continuation services. When you use the machine dialogue function, the Software needs to obtain the text information you input and complete the dialogue content generation, so as to provide you with machine dialogue services. We will encrypt and upload the above information to the server and generate/return content for you based on generative artificial intelligence technology. This is to facilitate your viewing and management at any time.

 

2.5 Ensuring Service Security, Optimizing and Improving Services

 

When you use the Platform, to ensure that you can use our services normally, more accurately locate and resolve problems you encounter when using services, improve and optimize service experience, and ensure the security of your account, prevent, detect, investigate fraud, security hazards, illegal or non-compliant behavior with our agreements, policies, or rules, and protect the legitimate rights and interests of you, us, our affiliates, our partners, and the general public, we will collect your device information, log information, and other information related to the login environment.

 

Please understand that when you switch the Platform from the device screen to the device background, due to some device models and system reasons, the information collection behavior generated by your previous use of the Platform's related functions may not be able to stop immediately, resulting in a brief period of background information collection.

 

2.6 Other Functions

 

When you use other functions or services of the Platform (including after-sales service, customer support, feedback, etc.), we may collect your account information, device information, software information, IP address, geographical location, service logs, communication logs, communication information. To ensure your account and system security, when you use some functions or services of the Platform, we may also need you to provide your account information first and match it with your previous personal information to verify your user identity. If you do not agree to our collection of the above information, you can contact us through the feedback entry [Feedback] or send an email to [zhuangyy@col.com]. You will not be able to use the above functions, but it will not affect your use of other functions or services we provide for you.

 

To improve the security of your use of our products/services, prevent your account, funds, and personal information from being obtained by illegal elements, and prevent viruses, malware programs, or malicious websites, we need to record the service categories, methods, and related operation information that you use. The above information is necessary for us to maintain the stable operation of products/services. If you cannot provide the above information, you may not be able to complete the risk control verification of the products/services you use.

 

2.7 Other Additional Services Based on System Permissions

 

To provide you with more convenient, high-quality, and personalized products/services and strive to improve your experience, we may collect and use your personal information through enabling system permissions in the additional services we provide to you. If you do not agree to enable relevant permissions, it will not affect your use of our other services, but you may not be able to obtain these additional services that bring you a better user experience.

 

Device Permission

Business Function

Authorization Method

Telephone (Device Info)

Used for security risk control

Asked when you first open the Platform

Contacts

Read contacts to populate the Platform's system address book friend list

Asked when you first use the corresponding function

Storage

Read photos in system album for editing avatar; export Platform images/data; app update downloads

Asked when you first use the corresponding function

Camera

Take photos for editing avatar

Asked when you first use the corresponding function

Microphone

Voice instant communication and voice smart assistant

Asked when you first use the corresponding function

Album

Read photos in system album for editing avatar

Asked when you first use the corresponding function

 

2.8 Please understand and be aware that, in accordance with relevant laws and regulations and national standards, in the following circumstances, we may collect and use your personal information without obtaining your authorization:

 

2.8.1 Related to our fulfillment of obligations stipulated by laws and regulations;

 

2.8.2 Related to national interests such as national security and defense;

 

2.8.3 Related to major public interests such as public safety, public health, and public awareness;

 

2.8.4 Related to criminal investigation, prosecution, trial, and judgment execution;

 

2.8.5 To protect your or another person's significant legitimate interests in life and property when it is difficult to obtain your consent;

 

6. Personal information that you have publicly disclosed to the general public;

 

7. Necessary for the conclusion and performance of contracts as required by you;

 

8. Collected from legally disclosed information, such as legitimate news reports and government information disclosure channels;

 

9. Necessary for maintaining the secure and stable operation of the provided products or services, such as discovering and dealing with product or service failures;

 

10. Other circumstances stipulated by laws and regulations.

 

2.9 Function and Service Updates

 

Please understand that the products and/or services we provide are continuously updated and developed. If you choose to use other services that are not covered in the above explanation, we will inform you of the scope and purpose of information collection through page prompts, interactive processes, website announcements, or contractual agreements. We will collect, use, store, disclose, and protect your information in accordance with this Policy and the relevant user agreements. If you choose not to provide the above information, you may not be able to use certain services or parts of the services, but it will not affect your use of other services we provide. In addition, third-party entities may provide services to you through [API interfaces or other means]. When you enter a service page operated by a third-party entity, please note that the relevant services are provided by the third-party entity. When it comes to the collection of personal information by third-party entities, it is recommended that you carefully review their privacy policies or contractual agreements.

 

3. How We Store and Protect Personal Information

 

(1) Information Storage

 

When you register for an account or use our services, some necessary information may need to be collected and used (see "How We Collect Personal Information"). If the real information you fill in is incomplete, you may be restricted in using the corresponding services. Generally speaking, we will only keep your personal information for the shortest time necessary to achieve the purpose. When our products and/or services cease operations, we will notify you in the form of a push notification or announcement and delete or anonymize your personal information within a reasonable period.

 

Ways to store and handle personal information after the expiration period:

 

1. Personal information collected and generated in the operation of our services within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. However, to handle cross-border business and with your authorization, your personal information, as part of transaction information, may be transferred overseas. In such cases, we will follow the relevant laws and regulations to carry out personal information security export declaration and assessment procedures and take effective measures to protect your information security, such as implementing data de-identification before cross-border data transfer, or through agreements, verification, and other measures to require overseas entities to keep your information confidential.

 

2. According to relevant laws and regulations, the storage period of network operation logs shall be no less than 6 months; the storage period of transaction information shall be no less than 3 years from the date of transaction completion; the storage period of record backups shall be no less than 60 days.

 

3. Unless otherwise stipulated by law, when your personal information exceeds the storage period or you actively cancel your account, we will delete your personal information in accordance with applicable laws and regulations, or anonymize it.

 

In the following circumstances, we may change the storage period of personal information due to the need to comply with legal requirements:

 

1. To comply with relevant laws and regulations;

 

2. To comply with the provisions of court judgments, rulings, or other legal procedures;

 

3. To comply with the requirements of relevant government agencies or legally authorized organizations.

 

When our products or services cease operations, we will notify you in the form of push notifications, announcements, etc., and delete or anonymize your personal information within a reasonable period.

 

(2) Information Protection

 

To ensure the security of your personal information, we are committed to using various security technologies and supporting management systems to ensure the security of your information at a reasonable level. We strive to reduce the risks of your information being leaked, damaged, misused, accessed without authorization, disclosed without authorization, and altered. For example: through the use of Secure Sockets Layer (SSL) for encrypted transmission, encrypted storage of information, strict restrictions on data center access, the use of dedicated network channels and network proxies. At the same time, we have established a personal information protection department and relevant internal control systems. In addition, we hire external independent third parties to conduct information security assessments annually.

 

We have established a personal information security incident emergency response plan and regularly organize internal personnel for emergency response training and emergency drills to master the relevant response strategies and procedures. In the unfortunate event of a personal information security incident, we will notify you in accordance with the requirements of the laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions for you to prevent and reduce risks on your own, and the remedial measures for you. We will promptly inform you of the relevant situation through push notifications, sending emails/short messages, and other means. If it is difficult to notify each personal information subject individually, we will take reasonable and effective measures to make an announcement. At the same time, we will also report the handling of personal information security incidents to the regulatory authorities in accordance with the requirements.

 

Please be sure to properly keep your login name and other identity elements. When you use the Platform services, we will identify your identity through your login name and other identity elements. Once you leak the above information, you may suffer losses and may face adverse legal consequences. If you find that your login name and/or other identity elements may or have been leaked, please contact us immediately so that we can take corresponding measures in a timely manner to avoid or reduce related losses. At the same time, please properly keep your mobile phone, tablet computer, and other mobile terminal devices to prevent others from using your trusted devices to log in to your account.

 

4. How We Use Personal Information

 

To comply with national laws and regulations and regulatory requirements, and to provide you with services and improve service quality, or to ensure the security of your account, we will use your information in the following circumstances:

 

1. During the period when we provide you with services, we will collect and use your relevant personal information in accordance with this Privacy Policy and your separate authorization. When you cancel the service or authorization, we will stop collecting and using your relevant personal information. However, we may continue to use your personal information previously collected in accordance with laws, regulations, and the requirements of national competent authorities for auditing, national competent authorities' investigation, and other purposes.

 

2. We will use the collected information for big data analysis. For example, we will use the collected information to analyze and form industry insight reports that do not contain any personal information. We may disclose and share with our partners the information that has been processed statistically and does not contain identity-identifying content. We may use the information to understand how users use our services or to let the public know the overall usage trends of our services. Without your consent, we will not disclose your personal information to any company, organization, or individual outside of us, except as otherwise stipulated by laws and regulations or this Policy.

 

3. You understand and agree that, without disclosing the personal information of individual users, we have the right to use the entire user database for technical analysis and to commercially utilize the user database that has been anonymized.

 

4. You understand and agree that certain functions of the Platform may allow third parties to know your information. For example: when you share relevant content to third-party products/platforms on your own, third parties may know some of your information, including but not limited to nickname, avatar, shared content, etc. Moreover, after sharing, the information you share will be displayed on the product/platform (including but not limited to WeChat and other platforms) you share. On these platforms, third parties can view your information according to the settings of their respective products/platforms, including but not limited to nickname, avatar, shared content. If you do not want third parties to know your information, please do not use these functions of the Platform. Your use of these functions of the Platform means that you agree that third parties know these pieces of information.

 

You understand and agree that we have the right to associate the data records of your account on this Platform with the account on our other websites and clients. Similarly, we may also associate the data records of your account on this Platform with the account on our other websites and clients.

 

To provide you with a more convenient and enjoyable experience, when you access or use our products/services, we may use small data files to identify your identity, which can help you avoid the trouble of repeatedly entering registration information and also help us determine the security status of your account.

 

5. How We Provide Personal Information to Third Parties

 

5.1 Sharing

 

We commit to keeping your information confidential in accordance with relevant laws and regulations and regulatory provisions. We will not share your personal information with any third-party services or institutions to provide you with the services of this Platform. Unless there is one or more of the following circumstances:

 

5.1.1 Sharing with explicit consent or authorization from you or your active choice

 

Please note that any personal information you actively disclose during the use of the Platform (including posts, comments you make in platform interactions, as well as text, images, audio, and video you upload when contributing to the platform) can be read, collected, and used by any third party and may be independently copied and stored by third parties with no affiliation to us. Please be cautious about disclosing your relevant sensitive personal information. The personal information you voluntarily disclose may contain your personal identity information, personal financial information, and other sensitive information. You should obtain the legal consent of others before disclosing any personal information of others in your disclosed information to avoid the illegal disclosure of their personal information. You can control the scope of the information you share and can contact us through the feedback entry [Feedback] or send an email to [zhuangyy@col.com] to delete the information you publicly share. However, please note that these pieces of information may still be independently saved by other users or non-affiliated third parties.

 

5.1.2 Sharing in statutory circumstances

 

Please understand and agree that we may share your personal information with administrative and judicial authorities in accordance with legal requirements, litigation dispute resolution needs, or as required by law.

 

5.1.3 Sharing personal information with affiliated companies

 

Please understand and agree that, in order to better provide you with services, achieve unified management, personalized recommendations, ensure system and account security, and protect the personal and property safety of our affiliated companies, other users, or the general public from infringement, your personal information may be shared with our affiliated companies. We will only share necessary personal information and will be bound by the purposes stated in this Policy. Affiliated companies will also take the same security measures as stated in this Policy to protect your personal information security. If affiliated companies wish to change the purpose of personal information processing, they will seek your authorization again.

 

5.1.4 Sharing for the necessity of realizing our products and/or services

 

Please understand and agree that in certain cases, in order to provide you with our services or achieve the core functions of our products and/or services, or to provide you with the services you need, we must share your personal information with third parties. We will only share the personal information necessary to provide the services. At the same time, we will enter into strict confidentiality agreements with our partners, requiring them to process your personal information in accordance with our instructions, this Privacy Policy, and other relevant confidentiality and security measures. Our partners are not allowed to use the shared personal information for other purposes. If the shared personal information is used for other purposes, they will be required to obtain your separate consent again.

 

5.1.5 Necessary sharing with authorized business partners

 

Please understand and agree that in order to carry out necessary/reasonable business smoothly and meet your requirements, our products may contain third-party SDKs or similar applications, and we need to share some of your information with some business partners. We will conduct a security assessment of the data collection capabilities of third-party SDKs or similar applications before data sharing and will only collect and use information through agreements that require them to process your personal information for the purposes we specify and not for any other purposes. If the use of your personal information exceeds or changes the purpose of sharing, we will require them to obtain your separate consent again.

 

To ensure the smooth operation of related functions of the Platform and the stable and secure operation of applications, we may integrate third-party SDKs or similar applications to achieve relevant purposes. We will conduct strict security assessments of third-party SDK or similar application service providers to protect the security of your personal information. The third-party SDK or similar application service providers will collect and process information in accordance with their own privacy policies, which are not covered by this Policy. We strongly recommend that you review their privacy policies or relevant statements before using any third-party SDK services. When you use these products or services provided by third-party SDKs, third-party SDKs may call your device permissions and obtain some of your information so that you can normally use the corresponding functions on different mobile devices or third-party platforms. We list the names, functions/services provided, permissions applied for, types of personal information collected, and official website links of third-party SDKs or similar applications with personal information collection functions.

 

5.2 Transfer

 

In principle, we will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

 

(1) At your own request;

 

(2) With your prior explicit consent;

 

(3) In accordance with legal requirements or mandatory administrative and judicial requirements;

 

(4) In the event of a merger, acquisition, asset transfer, consolidation, reorganization, or bankruptcy liquidation, etc., if the transfer of personal information is involved, we will require the new holder of your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require that company or organization to obtain your separate consent again.

 

(5) With the development of our business, we and our affiliates may engage in mergers, acquisitions, asset transfers, consolidations, reorganizations, or similar transactions, and your personal information may be transferred as part of such transactions. We will notify you in advance of the transfer.

 

5.3 Public Disclosure

 

We will only publicly disclose your personal information in the following circumstances:

 

(1) When it is necessary to disclose relevant information in the list of penalties for non-compliant accounts, fraudulent behavior, etc., in a de-identified manner;

 

(2) With your explicit consent or authorization;

 

(3) When required by government, regulatory, or judicial authorities in accordance with laws and regulations.

 

5.4 Exceptions to Consent

 

In accordance with relevant laws and regulations and national standards, we may legally share, transfer, and publicly disclose your personal information without obtaining your consent in the following circumstances:

 

(1) Related to fulfilling obligations stipulated by laws and regulations and industry authorities;

 

(2) Directly related to national security and defense;

 

(3) Directly related to public safety, public health, and major public interests;

 

(4) Directly related to criminal investigation, prosecution, trial, and judgment execution;

 

(5) Necessary to protect your or another person's significant legitimate interests in life and property when it is difficult to obtain your consent; personal information that you have publicly disclosed to the general public;

 

(6) Collected from legally disclosed information, such as legitimate news reports and government information disclosure channels;

 

(7) Other circumstances stipulated by laws and regulations.

 

6. How You Can Access and Manage Your Personal Information

 

During your use of the Platform, to make it more convenient for you to access and manage your personal information, we have provided corresponding operational settings in the product design, and you can refer to the following guidance for operation.

 

6.1 Managing Your Personal Information

 

(1) You can log in to your account and view your account information on the "My" page, including: avatar, nickname, etc.

 

(2) If you find that your information is incorrect, you can modify your information according to the prompts on the page;

 

(3) You can access, modify, and delete your registration information and other personal information during the use of our services. You can also contact us through the notification guidance. The scope and manner of your access, modification, and deletion of personal information will depend on the specific services you use.

 

6.2 If you find that our use of your personal information violates laws and regulations or the agreements with you, you can send an email to [zhuangyy@col.com] to request the deletion of the relevant information.

 

Under the following circumstances, users may request us to delete their relevant information:

 

(1) If our processing of user information violates laws and regulations;

 

(2) If we collect and use user information without obtaining the user's consent;

 

(3) If our processing of user information violates the agreement with the user;

 

(4) If the user no longer uses our products or services, or the user cancels the account;

 

(5) If we no longer provide products or services to users.

 

If we decide to respond to the user's deletion request, we will also notify the entities that have obtained the user's relevant information from us and require them to delete the information in a timely manner, unless otherwise stipulated by laws and regulations, or these entities have obtained the user's independent authorization. When you delete information from our services, we may not immediately delete the corresponding information in the backup system, but we will delete this information when the backup is updated.

 

6.3 Account Cancellation

 

You can submit the cancellation application in the form of an email to [zhuangyy@col.com]. We will assist you in canceling your account and deleting all information related to your account in accordance with your request after completing reasonable and necessary verification of personal identity, security status, device information, infringement complaints, etc. Please note that once the account is successfully canceled, it cannot be restored. Even if you register an account with the same mobile phone number on the Platform after cancellation, the account will be considered a new user account. The data and services in your original canceled account cannot be recovered. Please be cautious when operating. Please dispose of the content in the account before initiating the account cancellation application. Otherwise, it is considered that you voluntarily give up all rights to the above content.

 

6.4 Managing Authorization Scope

 

You can modify the authorization scope through the device system permissions. After you cancel the authorization for information collection, we will no longer collect that information. However, your decision to revoke consent or authorization will not affect the personal information processing that has been carried out previously. After you cancel the authorization to share information with third parties, we will no longer provide information to that third party in the relevant business scenario. Similarly, your account cancellation is considered as your withdrawal of the relevant consent or authorization under this Policy.

 

6.5 Despite the above agreements, in the following circumstances, we may not be able to respond to your request:

 

(1) Directly related to national security and defense;

 

(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 that you have subjective malice or abuse of rights;

 

(5) The response to your request will cause serious damage to the legitimate rights and interests of other individuals or organizations;

 

(6) Involving trade secrets.

 

7. Use of Cookies and Related Technologies

 

When you use our products and/or services, we or our third-party partners may collect your information (including login information and browsing records) through the placement of secure cookies and similar technologies to provide you with more personalized content that meets your needs, protect your information and account security, and improve our products and services. You can also manage cookies. You understand and acknowledge that some of our products/services can only be realized through the use of cookies or similar technologies. However, if you refuse us to use cookies and similar technologies to collect and use your relevant information, you may not be able to use our related products/services normally, or you may not be able to enjoy the best service experience on our products/services, and some services may not be available for use.

 

8. Statement on Third-Party Liability

 

For the integration of third-party products and services, we will establish a strict management mechanism and working procedures and enter into contracts with third-party product or service providers to clarify our respective security responsibilities and the personal information security measures to be implemented. When the product or service you use is provided by a third party, we will clearly identify and explain to you. If a third party needs to collect your information for service purposes, it will obtain your separate authorization.

 

9. Special Provisions for Minors' Privacy Rights

 

We expect parents or guardians to guide minors in using our services. We will protect the confidentiality and security of minors' personal information in accordance with relevant national laws and regulations.

 

If you are a minor, we suggest that you read this Policy with your parents or guardians and obtain their consent before using our services. If you are a guardian of a minor and have any questions about the minor's personal information, please contact us by sending an email to [zhuangyy@col.com].

 

10. Applicability and Updates to This Policy

 

This Privacy Policy applies to all services provided by the Platform. You confirm that by agreeing to this Policy and using the related services, you also agree to all the terms of the member services, including but not limited to the modifications and changes mentioned above. It should be specifically noted that this Privacy Policy does not apply to third-party cooperation institutions providing services to you. The Platform may contain links to other websites, and we will take necessary measures to review these websites in accordance with laws and regulations (including reviewing the qualifications of website operators, conducting reasonable and preliminary identification of the security situation of the websites through technical means, and urging the website operators to protect your personal information in accordance with the law). However, we cannot guarantee that the third party will take protective measures as required. We suggest that you review the privacy policy of that website to understand how they process your information and make prudent decisions.

 

Any other terms and conditions concluded between us and you regarding personal information and privacy will be considered as supplements to this Policy. If this Policy does not cover any content, the relevant terms and conditions will apply. If there are any changes in the following major circumstances that may lead to a substantial reduction in your rights under this Policy or have a significant impact on you, we will update this Policy in a timely manner:

 

(1) Changes in our basic situation, such as mergers, acquisitions, reorganizations;

 

(2) Changes in the scope, purpose, and rules for collecting, storing, and using personal information;

 

(3) Changes in the scope, purpose, and objects for providing personal information externally;

 

(4) Changes in the way you access and manage personal information;

 

(5) Changes in data security capabilities and information security risks;

 

(6) Changes in the channels and mechanisms for users to inquire, complain, external dispute resolution institutions, and contact information;

 

(7) Other changes that may have a significant impact on your personal information rights.

 

If this Policy is updated, we will notify you through page announcements, push notifications, sending emails, or sending short messages. To ensure that you can receive notifications in a timely manner, we recommend that you update your contact information in a timely manner. If you continue to use the Platform after the updated Policy takes effect, it means that you have read and accepted the modified agreement and are willing to be bound by the updated Policy.

 

You can view this Policy on the [Login Page - Privacy Policy]. We encourage you to review our Privacy Policy each time you use the Platform.

 

11. Other

 

Your use of the Platform is deemed to be your acceptance of this Policy. We have the right to modify the terms of this Policy when necessary. You can view the relevant agreement terms on the latest version of the Platform, and we will also display them in a prominent place on the Platform. This Policy will be updated on December 27, 2024.

 

All terms of this Policy are for your convenience in reading and do not have any actual meaning in themselves and cannot be used as a basis for interpreting this Policy.

 

If any part of the terms of this Policy is invalid or unenforceable for any reason, the remaining terms shall still be valid and binding on the parties.

 

12. Contact Us

 

If you have any questions, opinions, or complaints about this Privacy Policy or related matters, you can send an email to [zhuangyy@col.com] for consultation.

 

Chinese Online Group Co., Ltd.

 

Update Date: December 24, 2025