This Privacy Policy ("Privacy Policy" or "Policy") outlines the information that Beijing Wentian Lanyue Technology Co., Ltd. and its affiliates ("Haivivi", "we", "us", or "our") collect and process from you. This Policy applies to all websites, mobile applications (Haivivi, 智子玩具, Giztoy), electronic toy products, and other services provided by Haivivi that link to this Policy, as well as our offline services (collectively, the "Services").

By using the Services, you agree to the practices described in this Policy. If you do not agree to these practices, please do not access or use the Services. Any capitalized terms not defined herein are defined in the Haivivi Terms of Service . You can review this Privacy Policy at any time at the bottom of the official website's homepage or in the "My - Settings - Version Number" section of the application.

We solemnly remind you to carefully read and thoroughly understand this Policy before using this product and submitting personal information. You may use the Services only after confirming your full understanding and agreement. This Policy will be presented for your reading and consent when you register for an account, and it will also be displayed or linked on platforms and applications related to the collection of personal information by this product. We will strictly follow the commitments of this Policy to collect and use your personal information and will obtain your separate consent as required by laws and regulations, without coercing you into a bundled collection of your personal information by agreeing to this Policy. Please be sure to read all terms of this Policy carefully and completely. We will highlight the categories of personal information collected and their usage scenarios with bolding/underlining, and clauses that exclude or limit liability will also be bolded for your attention. Please read these sections carefully.

This Privacy Policy will help you understand the following:

I. Scope of this Privacy Policy

II. How We Collect and Use Your Personal Information

III. How We Use Cookies and Similar Technologies

IV. Third Parties We Access and How We Share, Transfer, and Publicly Disclose Your Personal Information

V. How We Store and Protect Your Personal Information

VI. Your Rights Regarding Your Personal Information

VII. Terms of Use for Minors

VIII. How Your Personal Information Is Transferred Globally

IX. Changes to the Privacy Policy

X. Dispute Resolution

XI. Appendix

XII. Miscellaneous

I. Scope of this Privacy Policy

This Privacy Policy applies only to the products and services developed by Beijing Wentian Lanyue Technology Co., Ltd. and its affiliates, including functions/services that are entrusted to or integrated with legally owned and operated products by affiliates.

Affiliates here refer to companies, organizations, or individuals related to the company through common ownership or control. Third parties refer to companies, organizations, or individuals that are not related through common ownership or control (i.e., non-affiliated companies) or other unrelated individuals.

This Privacy Policy does not apply to the following situations:

(a) The collection and use of your personal information by third-party services (including any third-party applications and websites) accessed through our products and/or services;

(b) The collection and use of your personal information by other third parties that provide advertising services in our products and/or services;

(c) Our products and/or services may include or link to information or other services (including websites) provided by third parties. Such third-party services may be operated by the respective third parties. Your use of such third-party services (including any personal information you provide to such third parties) is subject to the service terms and privacy policies of those third parties (not this Privacy Policy), and you need to read their terms carefully. Please protect your personal information properly and provide it to others only when necessary. This Privacy Policy applies only to the information we collect, store, use, share, and disclose, and does not apply to the services provided by any third party or the information use rules of any third party. We are not responsible for any third party's use of information provided by you.

II. How We Collect and Use Your Personal Information

According to the "Personal Information Protection Law," personal information is any kind of information related to an identified or identifiable natural person, recorded electronically or otherwise, excluding anonymized information. Sensitive personal information is personal information that, once leaked or illegally used, could easily lead to the infringement of a natural person's personal dignity or harm to their personal or property safety, including biometric data, religious beliefs, specific identities, medical health, financial accounts, and location tracking, as well as the personal information of minors under the age of fourteen.

During the use of the application by users and other bound members, we will collect and use information that users and other bound members actively provide or that is generated from their use of the services. Users and other bound members are not required to provide personal information to us, but in some cases, if you choose not to provide it, Haivivi will not be able to provide you with the relevant products or services, nor will it be able to respond to or resolve issues you encounter while using our products/services. Haivivi will only collect and use your personal information for the purposes described in this statement and with your consent:

(1) Information We Collect

When you visit or use our Services, we collect various types of information based on your usage. It is important to note that some information is essential for us to provide the Services. If you choose not to share this necessary information, or request its deletion, you may lose access to some of our Services. The information we collect can be categorized as follows: data you provide directly to us, data collected automatically from your interaction with our Services, and data we obtain from other sources.

(a) Information You Provide Directly to Us

We collect information directly from you in various ways. This can happen when you interact with our Services, communicate with us, register for an account, subscribe to our newsletter, or participate in promotions. The information you provide may concern you and others and may include a range of data types, including but not limited to:

• Email address;
• Username;
• Payment information (e.g., information processed through our payment providers);
• Your User Content, as defined in the [ Terms of Service ](https://www.haivivi.cn/en/terms-of-service), including chat communications, posted images, and shared roles;
• WiFi information, to enable device networking functions;
• Content of communications with us.You are not obligated to provide this information to us, but please note that without it, certain features of some Services may not be accessible or usable.

(b) Information We Collect Automatically

Together with our third-party vendors, including advertising networks and analytics companies, we may use cookies, web beacons, and other tracking technologies to collect information about the computer or device (including mobile devices) you use to access the Services. The following are the types of information we may collect and analyze, including but not limited to:

• Browser type;
• ISP or operating system;
• Domain name;
• Access times;
• Referring or exit pages;
• Page views;
• IP address;
• The version of the service you are using;
• The type of device you are using;
• The MAC address of the device you are using.

We also track when and how often you visit or use the Services, including your interactions with and navigation of our website or mobile app. This information, including data collected by our third-party vendors, is used for analysis—to identify the most frequently used parts of our Services and to understand user preferences—to evaluate the success of our advertising campaigns, and for other purposes described in this Policy. When you visit the Services, we may collect general location information, which can be inferred from your IP address.

(c) Information Temporarily Used by the App or Device

To improve the user experience, we may use the following information on our visual and interactive pages. This information will only be used temporarily and will not be stored long-term. This information includes:

• Clipboard content;
• Accelerometer sensor;
• Magnetic field sensor;
• Orientation sensor;
• Gyroscope sensor;
• Light sensor;
• Proximity sensor;
• Gravity sensor;
• Linear acceleration sensor;
• Rotation vector sensor.We use this content to optimize the app's interactive experience, such as pasting content into a text box or displaying floating effects in the UI.

(d) Personal Information Required for Smart Device Connection

• Smart devices connected via Wi-Fi: Wi-Fi information (SSID, BSSID, Wi-Fi MAC address, Wi-Fi password), device MAC address, device ID;
• Smart devices connected via Wi-Fi after establishing a local connection via Bluetooth: Wi-Fi information (SSID, BSSID, Wi-Fi MAC address, Wi-Fi password), device MAC address, device Bluetooth MAC address;
• BSSID is used to connect to a network when the SSID is not broadcast, or to select a specific AP for connection among multiple APs;
• Smart devices connected via Bluetooth: device Bluetooth MAC address, device ID;
• Smart devices connected via Zigbee: device MAC address, device ID.
• If your device is equipped with temperature and humidity sensors or human body sensors, we will also collect information about the surrounding environment of the device, so that you can accurately view the environmental information detected by the device's sensors. For example: temperature, humidity, PM2.5, and whether someone has passed by, etc.;
• If your device is equipped with a microphone or camera, we will also collect real-time audio or video footage;
• If your device is equipped with a GPS positioning chip, we will also collect the real-time location of the device.
• Smart devices connected via Wi-Fi may scan the Wi-Fi information around you to determine if the network can be switched; at the same time, this information is also used to prompt you to select and switch Wi-Fi information. This information is only temporarily stored in the system and will be deleted when the device is reset. The scanned data includes: SSID, BSSID, security type, etc.

(e) Permissions Required for App Operation and Data Collected

• Internet access: The app needs to connect to Haivivi servers for login, data synchronization, and content retrieval.
• Wi-Fi status: Obtain and change the phone's Wi-Fi connection status, used for configuring smart devices connected via Wi-Fi.
• Bluetooth: Scan, discover, and connect to devices that use Bluetooth for configuration.
• Location information: Location permission is required to scan the Wi-Fi list for network configuration and to discover nearby smart devices connected via Wi-Fi.
• Local network: Connect to smart devices on the Wi-Fi network for configuration.
• Camera: Take photos to set personal or toy avatars.
• Photos and media library: Allow you to select pictures from your album to set your personal avatar, or to access/save media files.

(f) Information Collected Through Third-Party Accounts

Whenever you use a third-party account, such as a social media account ("Third-Party Account"), to connect to our account, we may collect certain information. This collection is based on the permissions you grant and may include data from your Third-Party Account. For example, by using a third-party account like Facebook or Google to connect to our Services, we receive information that helps us identify your account on those services. We securely collect and store this information to simplify the process of connecting you to our Services.

Choosing to link your account with a Third-Party Account is entirely your choice. When you begin the connection, you will have the opportunity to provide your consent. If you decide to revoke this permission, you can easily do so by logging into the Third-Party Account and disconnecting our Services from there, or through the native application on your smartphone. It is important to note that we may retain the information we have previously collected from you.

(2) When you use the following services, features, and settings, we will collect and use your personal information in the following ways:

(a) Account Registration, Login, and Password Recovery

When you first use the Haivivi application and services, we will collect your mobile phone number to register an account. After successful registration, you can log in using your registered mobile number or account password. If you forget your account password, you can retrieve it using your mobile number. To change the mobile number associated with your account, we require you to provide the old mobile number to receive a verification code. After the change is successful, we will delete the old mobile number information and collect and use your new mobile number to comply with identity authentication requirements of laws and regulations such as the "Cybersecurity Law" and the "Provisions on the Administration of Internet User Account Information." You can optionally provide a nickname for subsequent use of the account; not providing a nickname will not affect your normal use of other functions.

(b) Completing User Information

After binding a device, you can voluntarily fill in your nickname, real name, gender, birthday, wireless network, and geographic location information in the application. Providing the above information is not mandatory; users can choose whether to fill it in or not. Unless required by relevant laws and regulations, refusing to provide corresponding information will only affect the user experience of some services. We will also collect the points and level data of the bound device and display it on the corresponding page in the application. This data is only used for the user's personal page display and will not be used for other purposes.

(c) Conversation

When you use the application's features for sessions/text/voice/image/video/location information sending and receiving, or file transfer, we will collect voice/video/image/text/location information to ensure the stable operation of the service. Please be assured that voice and text data are only used for immediate processing, and we will not save the relevant voice and text data. Due to differences in device models, some services may be limited to specific products. Please understand the specific support situation based on the device used. At the same time, we will conduct a legality and compliance review of the relevant content in accordance with applicable laws and regulations.

(d) Ensuring Normal and Secure Service Operation, System Failure Analysis

To ensure you can use the service normally and to protect your account security, as well as to prevent viruses, Trojan horses, or other malicious programs and websites, we will record your service usage log information (operation logs, service failure information) and collect your device's hardware model, operating system version number, and network connection status (SIM card/WIFI) to achieve abnormal account monitoring, customer service, fault recording, fraud monitoring, archiving, and backup. If you do not agree to provide this type of information, it may affect the normal use of the service.

(e) Location-based Services

We will obtain your consent through a separate pop-up window to call your real-time GPS precise location information so that you can use functions such as finding a device in the application. If you do not agree to provide your GPS location information, you will not be able to use the above functions or services, but it will not affect your normal use of other functions of the service. You can turn off the authorization for location at any time in the permission management of your mobile terminal.

(f) Communication Services

In some devices, Haivivi provides users with an emergency contact function, which requires users to voluntarily fill in the mobile phone number and nickname of the emergency contact. We will not force you to fill in this type of information. If you do not agree to provide this type of information, you will not be able to use the communication-related services, but it will not affect the normal operation of other services.

(g) Sports Services

When the device you are using supports the sports/health monitoring module service, we will collect the basic user information you voluntarily fill in the application (birthday, gender, height, weight), the set training plan, and daily goals. Failure to fill in or truthfully fill in will result in our inability to evaluate and generate more accurate data or realize related functions, but it will not affect the other basic business functions of the device.

(h) Marketing Activities, Surveys

We will send you satisfaction/market research questionnaires through the application or website backend, or invite you to participate in marketing activities. If you agree to participate in the corresponding questionnaire survey activities, we may collect the personal information you actively provide and generate during the process of completing the questionnaire (such as name, contact information), which you can provide selectively. If you agree to participate in the corresponding marketing activities, we will collect your name, mailing address, and contact information according to the needs of the activity, in order to carry out further marketing questionnaire visits with you or to send you gifts.

(i) Problem Feedback

When you use our products, you can provide feedback on problems encountered during use. We may collect your phone number or other contact information you provide in order to contact you and answer your feedback questions.

(3) We may process personal information based on other legal grounds stipulated by laws and regulations:

• (a) Directly related to national security, defense security, criminal investigation, prosecution, trial, and judgment execution;
• (b) Necessary to perform statutory duties or legal obligations;
• (c) Necessary for the conclusion and performance of a contract to which the individual is a party;
• (d) Necessary to respond to public health emergencies, or to protect the life, health, and property safety of natural persons in emergencies;
• (e) To carry out news reporting, public opinion supervision, and other acts for the public interest, and to process personal information within a reasonable scope;
• (f) To process personal information that has been disclosed by the individual or that has been legally disclosed by other means within a reasonable scope in accordance with the provisions of the Personal Information Protection Law;
• (g) Other circumstances stipulated by laws and regulations.

(4) Other situations:

• (a) In circumstances other than the above, if we want to use your personal information for other purposes not specified in this Privacy Policy, we will ask for your prior consent.
• (b) Unless you withdraw your consent or refuse our collection and use through system settings, all personal information you provide while using our products and/or services will continue to be authorized for our use within the scope of this Privacy Policy during your use of our products and/or services.
• (c) When you use related services on interfaces such as "Mall" and "Customer Service and After-sales" in the application or website, Haivivi will jump to mini-programs like "Haivivi Official Mall" and "Haivivi Customer Service" after obtaining your consent. The specific services will be provided by the corresponding mini-programs. Please read and be aware of the privacy policies displayed on their interfaces. Haivivi will not collect your personal information through these functions.
• (d) Anonymized data and statistical data: After collecting your personal information, we will de-identify or/and anonymize the data in a timely manner through technical means. Among them, the anonymized data cannot identify you and does not belong to personal information. We have the right to mine, analyze, and utilize the anonymized data (including for commercial use). In addition, we will compile statistics on the use of products and/or services by users, and may share these statistics with the public or third parties to show the overall usage trends of our software and related services. However, these statistics will not contain any of your personal information.
• (e) Application permission calls: To provide you with the above services, we will call some of your device permissions when collecting and processing your personal information. You can choose to close some or all permissions in your device's settings to refuse our collection of corresponding personal information. In different devices, the permission display and closing methods may be different. Please refer to the instructions or guidelines of the device and system developer for details.

III. How We Use Cookies and Similar Technologies

You understand and agree that when you use our products and/or services, to provide you with an easier access experience, we may use various technologies to collect and store information, and in this process, we may send one or more Cookies or anonymous identifiers to your device.

When you use our products and/or services, we may use Cookies and similar technologies to collect your information to understand your preferences and usage habits, save you the step of entering repetitive information, conduct consulting or data analysis, and promptly discover and prevent security risks. Cookies can also help us count traffic information and analyze the effectiveness of page design and advertising.

We will not use Cookies for any other purposes than those described in this Privacy Policy. You can retain or delete Cookies according to your own preferences, and you can also clear all Cookies saved in the software or webpage.

IV. Third Parties We Access and How We Share, Transfer, and Publicly Disclose Your Personal Information

(1) Third Parties We Cooperate With to Process Your Personal Information

• (a) Entrusted Processing of Personal Information: To achieve the data processing purposes required for providing services, we will cooperate with third-party partners (third-party service providers, contractors, agents, application developers, etc.) and entrust them to process or share with them the personal information we collect. If we entrust a third party to process personal information, we will conduct a security assessment of the entrusted party and the entrustment behavior, sign an entrustment agreement, and require that the processing behavior of the entrusted party does not exceed our authorized scope. We entrust third parties to process your personal information only for the purpose of providing our services to you, achieving the purposes described in the "How We Collect and Use Your Personal Information" section, or fulfilling our obligations and exercising our rights in this policy. A typical scenario where we entrust a third party to process your personal information is entrusting software service providers, smart device providers, or system service providers to process your personal information. We will entrust third-party service providers to provide services such as location navigation, data storage, and content and image compliance review. Based on your authorization and settings for the corresponding services, we will entrust the above service providers to process your device information, location information, and image information to realize our services. We will require the above service providers to take necessary technical and management measures to protect your personal information and to delete, destroy, or anonymize the relevant information after the purpose of the entrusted processing is achieved. The above-mentioned entrusted processing scenarios are all necessary for providing services to you. If you refuse to allow our service providers to collect the necessary personal information in the above scenarios, it may result in you being unable to enjoy the services provided by that provider or affect our ability to provide you with related products or services normally.
• (b) Sharing: Sharing refers to Haivivi providing personal information to other personal information processors, where both parties independently determine the processing purpose and method in the personal information processing activities. Generally, Haivivi will not share your personal information externally, except in the following cases:
  • Sharing under legal circumstances: When required by applicable laws and regulations, or by mandatory administrative and judicial requirements, we will share your personal information externally in accordance with the requirements of administrative and judicial authorities.
  • Sharing with Haivivi's affiliated companies: Your personal information may be shared with our affiliated companies. We will only share necessary personal information, and it will be bound by this Privacy Policy. If an affiliated company wants to change the purpose of processing personal information, it will seek your authorization and consent again.
  • Other circumstances stipulated by laws and regulations.

(2) Transfer of Your Personal Information

We will not transfer your personal information to any company, organization, or individual other than us and our affiliated companies, except in the following cases:

• (a) With your explicit prior authorization and consent;
• (b) To meet the requirements of laws, regulations, legal procedures, or mandatory government requests or judicial rulings;
• (c) If we or our affiliated companies are involved in transactions such as mergers, divisions, liquidations, or the acquisition or sale of assets or businesses, your personal information may be transferred as part of such transactions. We will ensure the confidentiality of such information at the time of transfer and will do our utmost to ensure that the new company or organization holding your personal information continues to be bound by this Privacy Policy. Otherwise, we will require the company or organization to re-seek your authorization and consent.
• (d) Directly related to public safety, public health, and major public interests;
• (e) Directly related to criminal investigation, prosecution, trial, and judgment execution;
• (f) Other circumstances stipulated by laws and regulations.

(3) Public Disclosure of Your Personal Information

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

• (a) With your explicit consent;
• (b) Based on laws, regulations, legal procedures, litigation, or mandatory requirements from government authorities;
• (c) Directly related to national security and national defense;
• (d) Directly related to public safety, public health, and major public interests;
• (e) Directly related to criminal investigation, prosecution, trial, and judgment execution;
• (f) Other circumstances stipulated by laws and regulations.

(4) Disclosure by Accessed Third Parties

Aurora Security Authentication SDK

Third-Party Entity	Shenzhen Hexun Huagu Information Technology Co., Ltd.
Purpose of Cooperation	To provide one-click login service based on the native phone number for App users.
Types and Purposes of Personal Information Processed	Device identifiers (Android ID and MAC address), device hardware information (including device model, device screen resolution, device hardware manufacturer, device product name, device storage space), operating system information (including OS version, system name, system language), network information (including network type, carrier name, IP address, DHCP, WIFI status information, MAC address), phone number: used to effectively identify the device, quickly respond to verification requests to provide efficient, stable, and smooth one-click authentication services, and generate a unique Aurora device identifier.
Data Processing Method	Through de-identification, encrypted transmission, and other security measures.
Official Website	https://www.jiguang.cn
Privacy Policy	https://www.jiguang.cn/license/privacy

V. How We Store and Protect Your Personal Information

(1) Location of Information Storage

In accordance with laws and regulations, we will store your personal information collected and generated during our operations within the territory of the People's Republic of China. If cross-border transmission is required, we will separately obtain your authorized consent.

(2) Storage Period

To enable you to use our products and/or services and to effectively handle potential disputes, unless otherwise required by laws and regulations, the storage period for your personal information will be limited to the minimum time necessary to achieve the purposes for which you have authorized its use. After this period, we will delete or anonymize your personal information (i.e., process your personal information so that your identity cannot be identified by any third party). After you deregister your account, we will stop providing you with products and services and, at your request, delete your personal information or anonymize it. However, data retained due to other requirements of national laws, regulations, rules, normative documents, or government policies, orders, etc., or to fulfill our compliance obligations, is excluded. For example, the "Cybersecurity Law of the People's Republic of China" requires technical measures to monitor and record network operation status and cybersecurity incidents, and to retain relevant network logs for no less than six months.

(3) Cessation of Operation

If we terminate services or operations, we will notify you at least thirty days in advance through individual delivery or public announcement, and promptly stop collecting your personal information. After terminating services or operations, we will delete or anonymize your personal information in our possession, and will require third parties entrusted with processing personal information to terminate cooperation and delete or anonymize your personal information according to the agreement. To better protect your rights, we will provide you with channels to download, copy, and destroy your personal information. For security purposes, you may need to provide a written request or otherwise prove your identity.

(4) Security Measures

• (a) We take the security of your personal information very seriously and will strive to adopt various reasonable security measures that comply with industry standards (including technical and management aspects) to protect your personal information, to prevent the personal information you provide from being improperly used or from unauthorized access, public disclosure, use, modification, damage, loss, or leakage.
• (b) We will use encryption technology, anonymization, and other reasonably feasible means to protect your personal information, and use trusted protection mechanisms to prevent your personal information from being maliciously attacked.
• (c) We will establish a dedicated security department, security management system, and data security process to ensure the security of your personal information. We adopt a strict data use and access system to ensure that only authorized personnel can access your personal information, and we conduct security audits of data and technology in a timely manner.
• (d) Despite the reasonable and effective measures taken above and compliance with the standards required by relevant laws and regulations, please understand that due to technical limitations and various possible malicious means, in the Internet industry, even with our best efforts to strengthen security measures, it is impossible to always guarantee 100% security of information. We will do our best to ensure the security of the personal information you provide to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, leading to damage to your legitimate rights and interests, we will bear the corresponding legal responsibility. You acknowledge and understand that the systems and communication networks you use to access our services may have problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of your personal information, including but not limited to using complex passwords, regularly changing passwords, and not disclosing your account password and other personal information to others.
• (e) We will formulate an emergency response plan and immediately activate it in the event of a user information security incident, striving to prevent the impact and consequences of such security incidents from expanding. Once a user information security incident (leakage, loss, etc.) occurs, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the incident through push notifications, emails, letters, text messages, etc. When it is difficult to inform you one by one, we will adopt a reasonable and effective way to issue an announcement. At the same time, we will also report the disposal of user information security incidents in accordance with the requirements of relevant regulatory authorities.

We hereby specifically remind you that the personal information protection measures provided in this Privacy Policy only apply to our products and/or services. Once you leave "Haivivi" and related services to browse or use other websites, services, and content resources, we have no ability or obligation to protect any personal information you submit in applications and websites outside of our products and/or services, regardless of whether you log in or browse the above software or websites based on links or guidance from "Haivivi". We do not assume any legal responsibility for this.

VI. Your Rights Regarding Your Personal Information

Haivivi highly respects your rights regarding your personal information. The following lists the rights you have by law and how we will protect them. Please note that for security reasons, we may verify your identity before processing your request. In principle, we do not charge a fee for your reasonable requests. If processing your request requires a high cost or presents other significant difficulties, we will provide you with alternative methods to protect your legitimate rights and interests with your consent. We may refuse requests that are unreasonably repetitive, require excessive technical means (for example, requiring the development of new systems or fundamentally changing current practices), pose a risk to the legitimate rights and interests of others, or are very impractical. In addition, if your request is directly related to matters of national security, national defense, public health, criminal investigation, and other public interests, or may cause serious damage to the legitimate rights and interests of you or other individuals or organizations, we may not be able to respond to your request. Generally, we will complete the processing of your request and reply within fifteen working days.

(1) Right to Know

You have the right to know the rules for processing your personal information, and we inform you of how we process your personal information by publishing this Privacy Policy. We are committed to the transparency of the use of your information. You can request an explanation of the processing rules of this Privacy Policy by contacting our data protection and legal team at [legal@haivivi.com](mailto:legal@haivivi.com).

(2) Right of Access and Copy

You can directly access your personal information in the interface of our products or services. If you are unable to query or access your personal information on your own, or if you encounter any problems in exercising your right of data access, you can request access by contacting our data protection and legal team at [legal@haivivi.com](mailto:legal@haivivi.com). You can also request a copy of your personal information.

(3) Right to Rectification

When you find that the personal information we process about you is incorrect or incomplete, you have the right to ask us to make corrections or additions. For some of your personal information, you can directly correct or modify it on the relevant function page of the product or service. You can directly correct your personal information through the "click on the avatar in the upper left corner - personal information" path on the personal settings page. For personal information for which a self-modification channel is not yet provided, you can request correction or supplementation of your personal information by contacting our data protection and legal team at [legal@haivivi.com](mailto:legal@haivivi.com).

(4) Right to Erasure

When you find that we have collected or used your personal information in violation of laws, administrative regulations, or the provisions of this Privacy Policy, you have the right to request us to delete the relevant personal information. You can request us to delete or anonymize the personal data you have submitted by contacting our data protection and legal team at [legal@haivivi.com](mailto:legal@haivivi.com).

(5) Right to Withdraw Consent

You can withdraw your consent to the processing of your personal information at any time, unless the personal information is necessary for the corresponding business function (the personal information necessary for each business function is detailed in the "How We Collect and Use Your Personal Information" section of this Privacy Policy). When you withdraw your consent, we will no longer process the corresponding personal information, but your decision to withdraw your consent will not affect the personal information processing that was previously carried out based on your authorization. You can change the scope of your authorization for us to continue collecting personal information by deleting information, closing permissions, etc. If you encounter any problems in exercising your right to withdraw consent, you can contact our data protection and legal team at [legal@haivivi.com](mailto:legal@haivivi.com).

(6) Right to Deregister

You can apply to deregister your account through the "Personal - upper left corner avatar - Personal Information - Deregister Account" path in the application. Before you deregister your account, we will verify your personal identity, security status, and device information. You acknowledge and understand that the act of deregistering an account is irreversible. Once you deregister your account, we will stop providing you with related services and will delete all information about your account or anonymize it within 15 working days at your request, unless otherwise provided by laws and regulations.

(7) Right to Complain

You have the right to complain by calling 400-081-7878 to contact online customer service. We will respond to your request in a timely manner within 15 working days. If you are not satisfied with our response, especially if our personal information processing behavior has harmed your legitimate rights and interests, you can also complain or report to regulatory authorities such as the Cyberspace Administration, public security, and market supervision departments, or file a lawsuit in a court with jurisdiction.

(8) In any of the following circumstances, we may not be able to respond to your request for correction, deletion, or deregistration of information as required by laws and regulations:

• (a) Related to national security and national defense;
• (b) Related to public safety, public health, major public interests, etc.;
• (c) Related to criminal investigation, prosecution, trial, and execution of judgments, etc.;
• (d) There is sufficient evidence to show that you have subjective malice or abuse of rights;
• (e) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
• (f) Involving commercial secrets;
• (g) Other circumstances stipulated by laws and regulations.

VII. Terms of Use for Minors

Protecting the personal information of children and minors is a fundamental principle of Haivivi. We will collect, use, or disclose personal information of children or minors only when permitted by laws and regulations, with explicit consent from guardians, or when necessary to protect their rights and interests. We will protect the personal information of children and minors with the assistance and supervision of their guardians:

For data that can be identified as personal information of children or minors, we will strictly collect, use, or disclose the personal information of children or minors in accordance with the requirements of laws and regulations such as the "Law of the People's Republic of China on the Protection of Minors" and the "Regulations on the Network Protection of Children's Personal Information." We have established a special internal system for the protection of children's personal information and will use various security technologies and procedures to establish a complete management system to protect the personal information of minors from unauthorized access, use, or disclosure. If you are a minor, you should obtain the consent of your guardian before using related services or providing related information, and use the product services together under the guardianship and guidance of your guardian.

If you are the guardian of a minor and have any questions about the personal information of the minor under your guardianship, please call the official customer service hotline: 400-081-7878 or contact our data security team at [legal@haivivi.com](mailto:legal@haivivi.com). We will have dedicated personnel to handle matters related to the protection of children's personal information.

VIII. How Your Personal Information Is Transferred Globally

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.

With the globalization of our business, we also provide products or services through resources and servers around the world. If the services we provide to you involve transferring your personal information outside of China, we will separately inform you and obtain your authorized consent. This means that after obtaining your authorized consent, your personal information may be transferred to or accessed from jurisdictions outside the country/region where you use the product or service.

Such jurisdictions may have different data protection laws or may not have established relevant laws. In such cases, we will ensure that your personal information receives adequate equivalent protection as it would within the territory of the People's Republic of China. For example, we will request your consent for cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfer.

IX. Changes to the Privacy Policy

To provide you with better services, our products and/or services will be updated and changed from time to time. We will revise this Privacy Policy in a timely manner, and such revisions will form part of this Privacy Policy and have the same effect as this Privacy Policy. However, without your explicit consent, we will not reduce your rights under the currently effective Privacy Policy.

After this Privacy Policy is updated, we will issue an updated version on the mobile application client so that you can stay informed of the latest version of this Privacy Policy. For major changes, we will also provide a more prominent notice and re-obtain your consent (we will explain the specific changes to the Privacy Policy through methods including but not limited to email, text message, private message, or special prompts on the browsing page).

The major changes referred to in this Privacy Policy include but are not limited to:

(a) Major changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way personal information is used, etc.;

(b) Major changes in our ownership structure, organizational structure, etc. Such as changes in ownership caused by business adjustments, bankruptcy, mergers and acquisitions, etc.;

(c) Changes in the main objects of personal information sharing, transfer, or public disclosure;

(d) Major changes in your rights to participate in the processing of personal information and the way you exercise them;

(e) When our responsible department for handling personal information security, contact information, and complaint channels change;

(f) When the personal information security impact assessment report indicates a high risk.

X. Dispute Resolution

If you have any questions, opinions, or suggestions about this Privacy Policy or matters related to personal information, please contact us by sending an email to [legal@haivivi.com](mailto:legal@haivivi.com) or by calling the customer service hotline at 400-081-7878.

Generally, we will reply within fifteen working days. If we are unable to respond to your request, we will send you a notice and explain the reason within the maximum time limit required by law. If you are not satisfied with our reply, or if our handling of your personal information has infringed upon your legitimate rights and interests, and we are unable to provide a satisfactory reply and refuse to improve after you have provided feedback to us, you may file a complaint or report to the relevant regulatory authorities.

XI. Appendix

The interpretation and dispute resolution of this policy shall be governed by the laws of the People's Republic of China. Any dispute related to this policy shall be resolved by the parties through friendly negotiation; if negotiation fails, you may submit the dispute to the People's Court of Chaoyang District, Beijing.

If any court with jurisdiction rules or judges any provision of this policy to be invalid, that provision will be removed from this policy, but the invalidity of that provision will not affect the validity of the remaining provisions of this policy. The remaining provisions of this policy will continue to be enforced.

XII. Miscellaneous

The headings of this Privacy Policy are for convenience and reading only and do not affect the meaning or interpretation of any provisions in this Privacy Policy.

The copyright of this Privacy Policy belongs to the company, and the company reserves the right of final interpretation and modification to the extent permitted by law.

Owner Information:

Beijing Wentian Lanyue Technology Co., Ltd.

Office Address: Room 1306, 13th Floor, Building 1, No. 186 Beiyuan Road, Chaoyang District, Beijing

Contact Email: [legal@haivivi.com](mailto:legal@haivivi.com)

Contact Phone: 400-081-7878