Privacy Policy

(i) Information we collect

1. Collect information necessary to realize product functions based on the principles of legality, legitimacy and necessity

• The updates you upload when using Manage Pro (including but not limited to the text messages, photos, videos, etc. that you share).
• When you use the album and album-related functions, we will ask you to authorize the album and photo permissions. If you refuse to provide authorization, you will not be able to use the relevant functions, but it will not affect your correct use of other functions of Manage Pro.
• When you use mood and mood-related functions, we will ask you to authorize location permissions to match weather conditions. If you refuse to authorize, you will not be able to use the relevant functions, but it will not affect your correct use of other functions of Manage Pro.
• When you use activities and activity-related functions, we will collect your gender, age, height, weight and other information, and we will ask you to authorize Manage Pro to obtain information from "Apple Health", including but not limited to steps, walking + running distance, activity energy, height, physical training, weight and other information, and display it to you in the corresponding function. If you refuse to authorize, you will not be able to use the relevant functions, but it will not affect your correct use of other functions of Manage Pro.
• When you use Manage Pro, if you need to file a complaint, make an inquiry or appeal to us, we may need to collect your name, mobile phone number, email address and other valid contact information in order to facilitate contact with you or help you solve the problem. If you refuse to provide the above information, we may not be able to provide you with timely feedback on the relevant processing results.
• If you share the content in Manage Pro to a third-party platform, we will read your application list information to determine whether the third-party platform exists in order to achieve the purpose of sharing.

2. Information we obtain when you use our services

• Network environment optimization. We may also collect your network operator and type, network type, and WIFI name to help you save network traffic during the advertising push process.
• In order to maintain the normal operation of our services, protect your account security, troubleshoot product failures, and improve and optimize our services, we will collect your IMEI, device model information, login IP address, and operation log information. This type of information is necessary to provide services and will be de-identified after collection and will not be used to identify any specific user.
• To protect your account, network, operation and system security, and to prevent phishing fraud and Trojan viruses, we may collect your device information, including the unchangeable unique device identifier (such as IMEI number, MAC, SIM card IMSI information), hardware serial number, etc. during your use of this product.

3. Exceptions to consent

Please be fully aware that in the following circumstances, we do not need to obtain your authorization and consent (again) to collect and use personal information:

• Those related to national security or national defense security;
• Related to public safety, public health, or major public interests;
• Related to criminal investigation, prosecution, trial and execution of judgment;
• For the purpose of protecting the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the consent of the individual;
• The personal information collected is disclosed to the public by the subject of personal information on his/her own accord;
• Your personal information is collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;
• Necessary for signing and performing a contract according to your requirements;
• Necessary for maintaining the safe and stable operation of the services provided, such as discovering and handling service failures;
• Other circumstances prescribed by laws and regulations.

4. In the process of providing services, in order to ensure that you can use the product functions normally, we will apply to the system for the following permissions for your device. Before applying, we will follow your consent. If you do not agree to enable this permission, please click "Do not allow". Rejecting the application for this permission will only affect your use of specific product functions. The call of system privacy permissions by various business functions is as follows:

(ii) How we use the collected information

• We strictly abide by the provisions of laws and regulations and the agreements with users, and use the collected information for the following purposes. If we use your information beyond the following purposes, we will explain it to you again and obtain your consent:
  • Providing services to you.
  • Meeting your personalized needs: language settings, location settings, and personalized help services.
  • Product development and service optimization: When our system fails, we will record and analyze the information generated by the system failure to optimize our services.
  • Security. For example, we will use your information for identity verification, security prevention, anti-fraud monitoring, archive backup, customer security services, etc.
• In order to provide you with a better experience, improve our services or for other purposes with your consent, we may use the information collected through certain services for our other services, subject to compliance with relevant laws and regulations. For example, we may use your information when you use one of our services to display personalized content or advertisements to you in another service, or to conduct user research, analysis and statistics.
• To ensure the security of the service and help us better understand the operation of our applications, we may record relevant information. For example, the frequency of your use of the application, failure information, overall usage, performance data, and the source of the application. We will not combine the information we store in the analysis software with the personally identifiable information you provide in the application.

(i) COOKIES

COOKIES is a neutral technology that allows website servers to store data on or read data from clients. COOKIES files are files that store some information related to the user's visit to the website. COOKIES content is usually encrypted, and secure COOKIES technology will provide users with more convenient services when surfing the Internet.

(ii) Use of Cookies

To ensure the normal operation of the website, we or our third-party partners may place secure COOKIES and related technologies on your computer or mobile device to collect your information in order to provide you with a more personalized user experience and services. COOKIES usually contain identifiers, site names, and some numbers and characters. We will strictly require third-party partners to comply with the relevant provisions of this policy.

We will not use COOKIES for any purpose other than those described in this policy. You can manage COOKIES through browser settings, including whether to enable and choose to close them. However, if you disable COOKIES, you may not be able to use certain services. For more information on how to change browser settings, please visit the relevant settings page of the browser you are using.

(iii) Do Not Track

Some web browsers have a Do Not Track feature that sends a Do Not Track request to the website. If your browser has Do Not Track enabled, we will respect your choice.

(i) Use and provision of personal information

Without your consent, we will not share your personal information with any company, organization or individual other than ourselves, except in the following circumstances:

• Sharing with explicit authorization and consent: The authorization or consent of you or your guardian has been obtained. This is provided to you to handle disputes or controversies between you and others, or in accordance with the relevant agreements signed with you, or other legal documents;
• Sharing under legal circumstances: According to relevant laws and regulations, for the needs of litigation activities, or to meet the requirements of judicial or administrative agencies based on legal procedures. For example: within the scope permitted by laws and regulations, it is necessary to provide information to protect the interests, property, and safety of Manage Pro or Manage Pro's partners, you, other Manage Pro users, or the general public from damage;
• Sharing with our affiliates: We may share your personal information with our affiliates in order to provide you with services, recommend information that may be of interest to you, or protect the personal and property safety of you, our affiliates, or other users from infringement;
• Sharing with our authorized partners: We may entrust authorized partners to provide you with certain services or perform certain functions on our behalf. To protect the security of your personal information, we will sign a corresponding personal information use or confidentiality agreement with our partners before sharing your personal information with them, requiring them to process personal information in accordance with our instructions, this policy and any other relevant confidentiality and security measures.

Currently, our authorized partners include the following types:

• Authorized partners for advertising and analysis services. We will not share your personally identifiable information with partners that provide advertising and analysis services unless we obtain your permission or de-identify or anonymize the data in accordance with regulations. We may provide these partners with information about the coverage and effectiveness of their planning reports, but we will not provide your personally identifiable information, or we will aggregate this information after anonymization to ensure that it does not identify you personally. Such partners may combine the above information with other data they legally obtain to make advertising or decision-making recommendations.
• Suppliers, service providers and other partners. Based on business needs, we may send information to suppliers, service providers and other partners who support our business. Such support includes providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, payment convenience or conducting academic research and surveys. In particular, when it comes to storage services, we will take strict confidentiality measures for the content of storage services performed in accordance with regulations. If it involves renting third-party storage space, we will strictly require the third party to have minimal access to the data and keep it strictly confidential.

Manage Pro third-party SDK service providers is as follows (Note: The data processing type of third-party SDK may change due to version upgrades, policy adjustments, etc., please refer to its official announcement .):

(ii) Transfer

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

• With your explicit consent;
• In the event of a merger, acquisition or bankruptcy liquidation, if personal information is transferred, we will require the new company or organization holding your personal information to continue to be bound by this Policy. Otherwise, we will require the company or organization to obtain your authorization and consent again;
• Comply with the relevant agreements signed with you (including electronic agreements signed online) or other legal documents;
• Provide information as required by applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements.

(iii) Public Disclosure

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

• Obtain your explicit consent or based on your active choice;
• Disclosure based on laws and regulations: We may disclose your personal information publicly when required by laws, legal procedures, litigation or government authorities.

(iv) Sharing, transfer and public disclosure without prior authorization

Based on the provisions of relevant laws and regulations, in the following circumstances, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

• Related to national security and national defense security;
• Related to public safety, public health, and major public interests;
• Related to criminal investigation, prosecution, trial and execution of judgment;
• To protect your or other individuals’ life, property and other major legal rights and interests, but it is difficult to obtain their consent;
• Personal information that you disclose to the public on your own initiative;
• Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.

According to laws and regulations, sharing and transferring de-identified personal information, while ensuring that the data recipient cannot restore and re-identify the subject of the personal information, does not constitute external sharing, transfer or public disclosure of personal information, and the storage and processing of such data will not require additional notification to you and your consent.

(i) Protection of Personal Information

• conduct a rating and safety assessment on Manage Pro in accordance with relevant regulations.
• We will take reasonable and feasible measures to try our best to avoid collecting irrelevant personal information. The personal information we collect and generate within the territory of the People's Republic of China is stored within the territory of the People's Republic of China.
• We have strict data protection and management measures in place. We will take security measures to protect your personal information from unauthorized access, use, disclosure, modification, damage or loss and other forms of illegal processing.
• If the security of the data we obtain and store is unfortunately compromised, or if the user's non-public information is disclosed to unrelated third parties due to external behavior (such as hacker attacks), we will activate the emergency plan, form an emergency response team, start the process, conduct an internal investigation, report and notify the regulatory authorities, and cooperate with the regulatory authorities to reduce the impact of the accident on users. At the same time, we will inform relevant users in the form of push notifications, emails, announcements, etc.
• If our products or services cease to operate, we will promptly stop collecting your personal information and inform you of the cessation of operations through push notifications, announcements, etc. In any case, we will delete or anonymize your personal information after terminating the service or operation.

(ii) Storage of Personal Information

We will take appropriate security measures and technical means to store and protect your personal information to prevent loss, misuse, unauthorized access or leakage, tampering or destruction. We will only store personal information for the period necessary to achieve the purposes of this Privacy Policy and in accordance with the storage period corresponding to the different levels of personal information. The storage period is strictly in accordance with the laws and regulations. In accordance with the provisions of this clause, we only allow third parties such as employees who need to know this information to access personal information and require them to fulfill the corresponding confidentiality obligations.

(i) Personal information management

We solemnly promise that we will not save your personal information locally. If you wish to delete your personal information, you can do so by uninstalling this app.

(ii) Change or withdraw your authorization information

the Manage Pro client is allowed to access through the device's own permission settings. After the relevant settings and modifications take effect, we will not be able to provide you with the corresponding services. Your withdrawal or change of your authorization will not affect the collection and use of personal information based on your authorization.

(iii) Cancel your account

You can contact us through "Settings-Feedback" or send an email (luokaiguike@163.com) to apply for account cancellation. Before you cancel your account, we will verify your personal identity, security status, and device information. You know and understand that account cancellation is irreversible. Once you cancel your account, we will stop providing you with related services.

(iv) Complaints and reports

In certain business functions of Manage Pro and related services, we may make decisions based on non-human automatic decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legal rights and interests, you have the right to ask us for an explanation and we will provide appropriate relief.

for your reasonable requests above. However, for repeated requests that exceed reasonable limits, we will charge a certain cost based on the actual situation. We may reject requests that are unreasonably repetitive, require excessive technical means (such as developing a new system or fundamentally changing the current management), pose risks to the legitimate rights and interests of others, or are extremely impractical.