Privacy Policy

Effective Date: September 12, 2025

Last Updated Date: March 23, 2026

Shenzhen Honglu Mingyuan Technology Co., Ltd. (hereinafter referred to as "we", "the Company" or "Honglu Mingyuan") is committed to protecting your privacy and personal information.

This Privacy Policy applies to the AI watch supporting application (hereinafter referred to as "this App") developed by us, and is intended to explain how we collect, use, store, share and protect your personal information.

Please carefully read this Policy before using this App. If you do not agree to any content of this Policy, please stop using this App immediately. Your continued use shall mean that you agree to our processing of your information in accordance with this Policy.

1. Information We Collect

1.1 Information Necessary for Providing Services

• Device Information: Device model, operating system version, device identifiers (such as UUID, Android ID, Advertising ID), Bluetooth address, hardware serial number, etc.
• Health and Sports Data: Heart rate, step count, sleep data, blood oxygen saturation, exercise trajectory and other data collected by the watch sensor.
• Recording Data: If you use the watch's recording function, we will collect and store the audio files you actively record.
• Account Information: If you register an account, we will collect your username, email address, password, etc.
• Usage Behavior Data: App usage logs, function click records, error reports, etc.

1.2 Information Collected with Your Explicit Consent

• Location Information: Used for exercise trajectory recording or weather services (if applicable).
• Media Permissions: Access to photo albums, microphones, cameras, etc. (e.g., for avatar upload or voice input).
• Third-Party Service Integration: If you choose to synchronize data using health platforms such as Apple Health and Google Fit.

1.3 Information Collected Automatically

We may automatically collect device information, IP address, browser type, access time, etc. through technologies such as Cookies, log files, and web beacons to improve service experience and security.

1.4 Categories of Personal Information We Collect

• Account and Identity Information: Information used for account creation, login, device binding, identity verification, customer support, and security management, which may include your name or nickname, mobile phone number, email address, date of birth or age range, country, region, province, or time zone, account ID, user identifier, device identifier, third-party login account information (if applicable), and the name and contact details of an emergency contact that you voluntarily set.
• Health and Fitness Information: Information used for health monitoring, analysis, reminders, and personalized services, which may include profile information such as height, weight, age, and gender; heart rate, resting heart rate, blood oxygen, sleep, stress, body temperature trends (if supported by the device), steps, distance, calories, activity duration, workout records, exercise goals, training plans, completion status, and health-related information that you actively enter or record, such as bodily feelings, health goals, lifestyle habits, medication reminders, or notes.
• Recording, Transcription, and AI Interaction Information: When you use AI recording and transcription, meeting notes, voice memos, or smart summary features, we may collect audio files, text transcripts corresponding to voice content, AI-generated summaries, labels, to-do items, question-and-answer results, or structured content, text you submit to AI, edit history, instructions, and operation logs, error logs, and processing status information related to the use of those features.
• Device and Connectivity Information: To enable normal watch operation, synchronization, and service optimization, we may also collect the watch model, phone model, operating system version, Bluetooth connection information, device pairing records, App version, firmware version, IP address, network type, crash logs, performance logs, push notification identifiers, and necessary application runtime information.

1.5 How We Collect Information

• Information You Provide: We collect information that you actively provide when you register an account, complete your profile, bind a device, set up a health profile, enable AI features, upload recordings, input text, contact customer service, or submit feedback.
• Automatically During Your Use of the Watch and App: When you use the Maxee.ai health watch and related App, we may automatically collect information related to device operation and service provision, such as health monitoring data, device status, connection logs, usage records, and error logs.
• Through Watch Sensors and System Functions: Subject to your authorization, the watch may collect relevant information through its sensors and system capabilities, such as heart rate, blood oxygen, sleep, and workout sensor data, audio collected by the microphone (only when you actively enable recording or voice features), and information generated under Bluetooth, notification synchronization, and location-related permissions depending on the specific feature.
• With Assistance from Third-Party Service Providers: Some information may be collected or processed with the assistance of third-party service providers, such as SMS verification, cloud storage, speech recognition, AI transcription, push notifications, payment services, or customer support. We require such third parties to process information within the agreed scope and to implement corresponding data protection measures.

2. How We Use Your Information

We only use your information for the following purposes:

• Provide, maintain, and optimize this App, watch features, and AI features, including recording, transcription, summarization, intelligent Q&A, health data analysis, reminders, recommendations, and device feature optimization;
• Process your account registration, login, identity verification, account recovery, after-sales services, customer support, and service notifications;
• Display, analyze, and manage health monitoring data, workout records, trend analysis, personalized reminders, and related service configurations;
• Enable data synchronization, backup, restore, cross-device management, and any cloud services that you activate;
• Analyze user behavior, diagnose failures, record error logs, and improve product quality, performance, security, and user experience;
• Fulfill legal obligations, or respond to regulatory, compliance, audit, or security needs;
• Other purposes with your consent.

3. How We Share Your Information

We do not sell your personal information. We will only share your information to the extent necessary to provide relevant features, where you authorize us to do so, or where permitted or required by law.

3.1 Controls and Restrictions on Direct Identifiers

Maxee.ai takes reasonable measures to limit, to the extent practicable, the disclosure of information that can directly identify you to third-party AI service providers. To the extent reasonably feasible:

• Your name, mobile phone number, email address, account identifiers, and other direct identifiers will not be proactively transmitted as part of AI model input unless such processing is truly necessary to implement a feature.
• Information provided to AI systems will, where possible, be processed in a de-identified, masked, or pseudonymized manner.
• Information that you actively provide during recording, voice input, text input, notes, questions, or other AI feature usage may contain your name, contact details, health status, location, schedule, or other personal information. Content that you actively submit, speak, upload, or synchronize to AI features may be processed by third-party AI service providers to enable transcription, summaries, Q&A, classification, reminders, or other intelligent services.
• If you use the recording function to capture conversations with others, you are responsible for obtaining any necessary authorization or consent and for complying with applicable laws and regulations. Maxee.ai cannot control the specific information contained in content that you actively input or record, so please provide information carefully when using AI recording, transcription, and related features.

3.2 Third-Party Communication and Platform Services

• Audio/Video and Voice Processing Services: To enable voice recording, speech recognition, speech-to-text conversion, content understanding, summary generation, or related AI capabilities, Maxee.ai may integrate third-party technology service providers. When you use relevant features, your voice data, audio files, transcripts, and related session data may be processed through such third-party technical services. We conduct reasonable review and management of integrated third-party services, but we cannot fully control third-party infrastructure, network environments, or service continuity, nor can we guarantee absolute security in every transmission process.
• SMS Verification and Notification Services: When you use a mobile phone number to register, log in, verify your identity, recover your account, or receive service notifications, your mobile phone number and necessary verification information may be transmitted to third-party SMS service providers to send verification codes or service notifications. Other than information necessary to complete the SMS transmission, we do not transmit complete health monitoring data, recording content, or transcription content through SMS service providers.
• Cloud Storage and Synchronization Services: To enable synchronization, backup, and recovery between the watch and mobile App or across different devices, part of your data may be stored in the cloud, including basic account information, device binding relationships, health monitoring records, audio files, transcripts, summary results (if you enable synchronization), preference settings, reminder settings, and related service configurations. If you do not enable the relevant synchronization feature, some data may remain stored only on the watch locally or on your phone locally.

3.3 Specific AI and Speech Service Providers We Currently Use

To avoid ambiguity, we may currently use the following specific service providers in connection with relevant AI features. Depending on the feature scenario, we may not call all providers at the same time; we select one or more of them only to the extent necessary based on the relevant function, model capability, stability, regional availability, and cost.

• Microsoft Azure AI / Azure OpenAI Service (Microsoft Corporation): When you use AI Q&A, text understanding, content summarization, health data analysis, reminder recommendations, or other large-model-based text generation features, your text inputs, transcript text, structured context, necessary health-related context, and model request/output data may be transmitted to Microsoft Azure servers located in the United States or another Microsoft Azure North America region selected by us. According to Microsoft's official Azure OpenAI documentation, prompts, completions, embeddings, and training data are not used to improve OpenAI models, Microsoft products, or third-party products without our explicit permission or instruction.
• Deepgram (Deepgram, Inc.): When you use speech recognition, speech-to-text, speaker diarization, timestamps, or related audio understanding features, your audio files, audio streams, voice segments, transcription request parameters, and related technical metadata may be transmitted to Deepgram servers located in the United States. According to Deepgram's official materials, Deepgram offers model improvement programs, private cloud, and self-hosted deployment and data-use options. Unless we separately participate in a relevant model improvement program, separately authorize such use, or permit such use under an applicable contract, we do not intend to authorize the use of end-user audio or transcript content for model training or improvement unrelated to providing the service to you.
• AssemblyAI (AssemblyAI, Inc.): When you use speech transcription, meeting note organization, voice summaries, or AI functions related to audio understanding, your audio files, transcription requests, transcript text, summary requests, and related technical metadata may be transmitted to AssemblyAI servers located in the United States. If we configure an AssemblyAI European endpoint for a specific feature, the relevant data will instead be transmitted to AssemblyAI servers located in the European Union. According to AssemblyAI's official materials, certain submitted content may be used for model improvement under specific contracts or settings, but customers can restrict such use through opt-out settings, European servers, or specific contractual arrangements. For its LLM Gateway provider scenarios, AssemblyAI states that it has opted all LLM Gateway providers out of training on that data.
• Google Gemini / Google Cloud Vertex AI (Google LLC): When you use AI Q&A, text generation, summaries, label extraction, or other Gemini-based features, your text inputs, transcript text, prompts, structured context, necessary file content, and model request/output data may be transmitted to Google servers located in the United States multi-region, Canada region, European Union region, or another specific region selected by us in Google Cloud. According to Google Cloud Vertex AI documentation, customer data is not used to train or fine-tune Google's foundation models without prior permission or instruction in the Vertex AI managed model context. For the Gemini Developer API, Google's official documentation states that free-tier content may be used to improve Google products, while paid-tier content is not used to improve Google products by default. In addition, if we affirmatively enable logging, dataset sharing, feedback sharing, or a similar feature in a particular Gemini API configuration, shared logs, prompts, responses, and metadata may also be used for product improvement or model development under Google's applicable policies. Unless we separately enable such sharing or use a configuration that permits such use and separately notify you, we do not intend to authorize the use of your content for model training unrelated to providing the service to you.

We review the service providers listed above and require them, through contracts, data processing agreements, or other compliance measures, to provide privacy, security, confidentiality, and data protection measures that are the same as or equivalent to those required by this Policy, applicable law, and Apple App Store review requirements.

In addition to the scenarios above, we may also share your information in the following circumstances:

• With your explicit consent;
• Service Providers: Third-party service providers for AI services, cloud storage, SMS verification, push notifications, data analysis, payment services, customer support, and health platforms (all subject to confidentiality obligations and contractual restrictions);
• Legal Requirements: In response to requests from law enforcement agencies, courts, or government authorities;
• Business Transfers: In the event of corporate mergers, acquisitions, or asset sales, your information may be transferred as part of the transaction.

We require all third-party service providers to comply with applicable data protection laws and only allow them to process your information for purposes necessary to provide services. We also require third parties that receive your information to provide the same or an equivalent level of protection for personal information as we do.

4. Data Storage and Security

• Storage Location: Your data will be stored on servers in North America (such as the United States or Canada), and may also be stored in other regions (such as the European Union) due to the distribution of service providers. We will ensure compliance with local data protection regulations.
• Storage Period: We will only retain your information for the period necessary to achieve the purposes stated in this Policy, or for the period required by law.
• Security Measures: We adopt encryption technology, access control, security auditing and other measures to protect the security of your data.

5. Your Rights

In accordance with applicable laws (such as CCPA, GDPR, etc.), you may have the following rights:

• Access, correct or delete your personal information;
• Restrict or object to our processing of your information;
• Right to data portability;
• Withdraw consent (without affecting the legality of processing before withdrawal);
• Lodge a complaint with a regulatory authority.

You can contact us through the following methods to exercise the above rights:

• Email: SZhonglumy@yeah.net
• Mailing Address: Data Protection Office, B310, Qingchuangyuan · Donghuanhui, Donghuan 1st Road, Longhua District, Shenzhen City, Guangdong Province, China

6. Explanation of Registration Information Differences Across Different Apps

Maxee.ai may provide two or more mobile applications related to its health watch. Because different applications may serve different feature scenarios, account systems, and service content, the scope of information collected during registration, login, or first use may also differ.

• Basic Device Management Apps: If an App is mainly used for watch binding, device connection, firmware upgrades, and the display and synchronization of basic health data, it will typically collect only your mobile phone number or email address, verification code, account identifier, device binding information, and basic user profile and necessary permission information during registration and use.
• AI-Enhanced Apps: If an App mainly provides advanced features such as AI recording and transcription, content summarization, intelligent Q&A, cloud synchronization, cross-device management, or membership services, then in addition to basic registration information, it may also collect audio files and transcripts, AI interaction inputs, cloud storage information, membership purchase and order information, and richer preference settings and usage logs depending on the feature needs.

Each App will explain the specific collection scope, purposes of use, and processing methods according to its actual functions and applicable scenarios in its privacy policy, user agreement, or feature activation page. We only collect information to the extent necessary to provide the relevant features.

7. Special Notice Regarding Recording Features

When you use the watch or App for recording, voice memos, meeting notes, call record organization, or AI transcription, please note:

• The recording feature may involve your own voice, the voices or speech of third parties, and other personal information.
• Before recording, transcription, summarization, storage, or synchronization, you should ensure that any necessary authorization or consent has been obtained for the relevant processing and that you comply with applicable laws and regulations.
• You must not use the relevant features to unlawfully collect, store, or disseminate other people's personal information, or for any purpose that violates laws or regulations.
• If your use of the recording feature gives rise to any dispute, complaint, or legal liability, you shall bear the corresponding responsibility in accordance with law.

8. Limitations of Health Data and AI Recommendations

The health monitoring, trend analysis, reminder recommendations, and AI outputs provided by the Maxee.ai health watch are intended only for health management, lifestyle reference, and device functionality services, and do not constitute medical diagnosis, treatment advice, or medical opinions.

If you experience physical discomfort, an emergency, or require professional medical judgment, please consult a doctor or qualified medical institution promptly.

9. Third-Party Services and SDKs

We may integrate the following types of third-party services (see the appendix for the specific list):

• Payment Services (e.g., Apple Pay, Google Pay);
• Data Analysis (e.g., Google Analytics, Firebase);
• Advertising Platforms (if applicable);
• Map Services (e.g., Google Maps);
• Health Platforms (e.g., Apple HealthKit, Google Fit).

These services may collect and use your information, and their actions are subject to their own privacy policies.

10. Policy Updates

We may update this Policy from time to time. The updated Policy will be published in the App and take effect. If the changes substantially affect your rights, we will notify you through a prominent method.

11. Contact Us

If you have any questions, suggestions, or complaints about this Policy, please contact us through the following methods:

• Company Name: Shenzhen Honglu Mingyuan Technology Co., Ltd.
• Address: B310, Qingchuangyuan · Donghuanhui, Donghuan 1st Road, Longhua District, Shenzhen City, Guangdong Province, China
• Email: SZhonglumy@yeah.net

12. AI Recording, Transcription & Insights Consent

This Section explains how Maxee.AI uses artificial intelligence ("AI") tools in connection with its smart wearable device and related services, including AI-enabled audio recording, speech-to-text transcription, summaries, and other AI-assisted insights or outputs (collectively, the "AI-assisted Features"), the associated risks and limitations, and how your personal information will be handled. Please read carefully before using the AI-assisted Features.

After successfully registering with the Maxee.AI platform, you may use the relevant features only after you have read and agreed to this Privacy Policy and have provided any necessary permissions or consent for recording, microphone access, health data, cloud synchronization, and AI-assisted features through the feature activation page, system permission prompts, or agreement confirmation page.

1. Nature of AI-Assisted Features
   Maxee.AI Corporation ("Maxee.AI") is a technology company that provides smart wearable devices, software, and related digital services. Maxee.AI may use AI tools to support certain product functions, including but not limited to audio recording, speech recognition, speech-to-text transcription, summaries, keyword extraction, reminders, recommendations, and other AI-generated outputs.
   
   These AI-assisted Features are provided for convenience, productivity, informational, personal organization, and supportive purposes only. AI-generated transcriptions, summaries, and other outputs may not always be accurate, complete, or contextually correct. They are not a substitute for professional advice, legal advice, medical advice, emergency services, or any other regulated professional service.
   
   Where applicable, AI-generated outputs may be reviewed, edited, supplemented, or acted upon by you based on your own judgment. You are solely responsible for reviewing any AI-generated output before relying on, sharing, storing, or using it.
2. Categories of Information Processed for AI Features
   To provide AI features in the Maxee.ai health watch and related services, including but not limited to voice recording, voice transcription, content summarization, intelligent Q&A, health data analysis, reminder recommendations, and device feature optimization, we may process the following categories of information:
   (a) recording content, voice commands, and transcript text generated in the watch or App;
   (b) text content, questions, notes, tags, or instructions that you actively input;
   (c) information related to health management, such as heart rate, blood oxygen, sleep, stress, activity, steps, calories, and other monitoring data, as well as your recorded bodily feelings, symptoms, medication reminders, health goals, or lifestyle information;
   (d) operation records, error logs, interaction timestamps, and device status information related to AI feature invocation; and
   (e) other contextual information necessary to generate AI outputs.
   
   The information above may include personal information, and in certain circumstances may include sensitive personal information. We follow the principle of minimum necessity and process only the data needed to provide the relevant AI features.
3. Controls and Restrictions on Direct Identifiers
   Maxee.ai takes reasonable measures to limit the disclosure of information that can directly identify users to third-party AI service providers. To the extent reasonably feasible, your name, mobile phone number, email address, account identifiers, and other direct identifiers will not be proactively transmitted as part of AI model input unless such processing is necessary to implement the relevant feature. Information provided to AI systems will, where possible, be processed in a de-identified, masked, or pseudonymized manner.
   
   However, you understand and agree that information you actively provide during recording, voice input, text input, notes, questions, or other AI feature usage may contain your name, contact details, health status, location, schedule, or other personal information. Content that you actively submit, speak, upload, or synchronize to AI features may be processed by third-party AI service providers to enable transcription, summaries, Q&A, classification, reminders, or other intelligent services. If you use the recording feature to capture conversations with others, you are responsible for obtaining any necessary authorization or consent and for complying with applicable laws and regulations. We cannot control the specific information contained in content that you actively input or record, so please provide information carefully.
4. Third-Party Communication and Platform Services
   To enable voice recording, speech recognition, speech-to-text conversion, content understanding, summary generation, AI Q&A, and other intelligent services, Maxee.ai may currently use specific services from Microsoft Azure AI / Azure OpenAI Service, Deepgram, AssemblyAI, and Google Gemini / Google Cloud Vertex AI. When you use relevant features, your voice data, audio files, transcripts, text inputs, prompts, structured context, and related session data may, depending on the relevant feature, be transmitted to service provider servers located in the United States, Canada, the European Union, or another specific region selected by us in the relevant cloud service.
   
   When you use a mobile phone number to register, log in, verify your identity, recover your account, or receive service notifications, your mobile phone number and necessary verification information may be transmitted to third-party SMS service providers to send verification codes or service notifications. Other than information necessary to complete the SMS transmission, we do not transmit complete health monitoring data, recording content, or transcription content through SMS service providers.
   
   To enable synchronization, backup, and recovery between the watch and mobile App or across different devices, part of your data may be stored in the cloud, including basic account information, device binding relationships, health monitoring records, audio files, transcripts, summary results (if you enable synchronization), preference settings, reminder settings, and related service configurations. If you do not enable the relevant synchronization feature, some data may remain stored only on the watch locally or on your phone locally. We use the applicable provider policies and contractual arrangements to restrict the use of relevant data for model training or product improvement unrelated to providing the service to you. If a particular service configuration allows such sharing or training, we will provide additional notice and obtain your authorization where required.
5. Collection, Use, and Disclosure of Personal Information
   Your personal information, audio data, voice data, device data, usage data, transcripts, and related information may be collected to:
   (a) enable the AI-assisted Features to function, including recording, transcription, summarization, and related outputs;
   (b) improve product functionality, quality, performance, safety, and user experience;
   (c) maintain accurate records of services provided through the Maxee.AI platform;
   (d) support secure communication, synchronization, storage, and account management; and
   (e) comply with legal, regulatory, operational, or security obligations.
   
   Your information will only be used or disclosed:
   (a) to Maxee.AI and its service providers, contractors, subprocessors, and affiliated technology partners who support the operation of the AI-assisted Features and related services;
   (b) to third-party communication, cloud storage, push notification, payment, customer support, or health platform service providers at your direction or with your authorization; and
   (c) as otherwise required or permitted by law.
   
   Maxee.AI will not sell, rent, or trade your personal information for unrelated third-party commercial marketing purposes. We require any third party that processes your information to do so in accordance with contractual arrangements, applicable law, and the same or an equivalent level of protection as described in this Policy.
6. Privacy Safeguards
   Maxee.AI implements reasonable administrative, technical, and physical safeguards designed to protect your personal information, including, where appropriate, encryption, secure servers, access controls, authentication measures, and internal privacy and security policies.
   
   While reasonable steps are taken to protect your data, no electronic system, network transmission, cloud storage environment, or AI processing workflow is entirely risk-free. By using the AI-assisted Features, you acknowledge and accept that there is always some risk associated with the electronic collection, transmission, storage, and processing of data.
7. Risks and Limitations of AI-Assisted Recording and Transcription
   AI-assisted recording, transcription, summarization, and related outputs may be inaccurate, incomplete, delayed, misinterpreted, or unsuitable for your intended purpose. Accuracy may be affected by factors including background noise, speaker accents, multiple speakers, technical issues, poor audio quality, interruptions, overlapping speech, unsupported languages, and limitations of AI models.
   
   AI-generated outputs may fail to capture nuance, tone, context, intent, names, dates, technical terms, confidential information, or legally significant wording. You should not rely solely on AI-generated content for important personal, business, legal, medical, regulatory, employment, financial, or safety-related decisions. The health monitoring, trend analysis, reminder recommendations, and AI outputs provided by the Maxee.ai health watch are intended only for health management, lifestyle reference, and device functionality services, and do not constitute medical diagnosis, treatment advice, or medical opinions. If you experience physical discomfort, an emergency, or require professional medical judgment, please consult a doctor or qualified medical institution promptly.
   
   You are responsible for ensuring that your use of the recording and transcription features complies with all applicable laws, regulations, workplace rules, confidentiality obligations, and consent requirements in your jurisdiction, including any requirement to notify or obtain consent from other individuals before recording them. Maxee.AI does not guarantee that the AI-assisted Features will be uninterrupted, error-free, fully secure, or suitable for every use case.
8. Sensitive Information and User Responsibility
   You should avoid using the AI-assisted Features to record, upload, store, or process highly sensitive information unless you have carefully considered the risks and are legally authorized to do so. Sensitive information may include, without limitation, health information, financial account information, passwords, government-issued identification numbers, confidential business information, trade secrets, legal communications, or information relating to children or third parties.
   
   You are solely responsible for:
   (a) determining whether you are permitted to record any conversation, meeting, or audio;
   (b) obtaining any legally required consent or authorization from other individuals;
   (c) reviewing the accuracy and appropriateness of any transcription or AI-generated output; and
   (d) deciding whether to store, share, delete, or act upon any such output.
9. Consent
   By signing below (or clicking "I Consent" on the Maxee.AI platform, device interface, mobile application, website, or related Terms of Use), you confirm that:
   (a) you understand the role of AI in the recording, transcription, summarization, and other AI-assisted Features provided by Maxee.AI;
   (b) you understand the risks and limitations associated with AI-generated outputs;
   (c) you understand that AI-generated outputs may be inaccurate, incomplete, or unsuitable for your intended purpose;
   (d) before any recording, transcription, summarization, cloud synchronization, or related data is sent to third-party AI, communication, or platform service providers, we will request any necessary permission or consent from you based on applicable law and the specific feature scenario through the feature activation page, system permission prompts, or agreement confirmation page;
   (e) you consent to the collection, use, processing, storage, and disclosure of your personal information, audio data, transcripts, and related information as described in this Section;
   (f) you acknowledge that you are responsible for complying with applicable laws and obtaining any necessary consent before recording others; and
   (g) you consent to receive and use AI-assisted outputs through the Maxee.AI platform and smart wearable device.

13. Account Cancellation

To cancel your account, the following conditions must be met simultaneously:

1. No abnormal login has occurred for the account in the recent 1 month.
2. The account is not involved in any complaints or reports.
3. There are no unused benefits in the account. If you still have unused benefits, your cancellation application will be deemed as your voluntary waiver of the corresponding benefits.
4. You fully waive the right to retain or retrieve such data.
5. The account cancellation is not involved in any ongoing complaints, disputes, lawsuits, investigations by competent authorities, etc., and there is no actual risk of the above-mentioned litigation or adjustment.
6. The account does not have other situations where obligations required by laws and regulations have not been fulfilled.

You acknowledge and understand that account cancellation is an irreversible action. You acknowledge and agree to the consequences of account cancellation.

After the account cancellation process is completed, the following consequences will occur, including but not limited to:

1. You will no longer be able to perform any permission operations relying on this account.
2. You will no longer be able to log in to the App account using this account.
3. After cancellation, we will clear your data, and you will not be able to retrieve all the information and data you have stored and used under this account.

Appendix I: Supplementary Clauses for Specific Jurisdictions

These supplementary clauses apply to the processing of personal information of users located in the following jurisdictions and are supplements to the main Privacy Policy.

In case of any conflict between these supplementary clauses and the main Policy, these supplementary clauses shall prevail.

A. Supplementary Clauses for Canadian Users (in accordance with PIPEDA)

Shenzhen Honglu Mingyuan Technology Co., Ltd. (hereinafter referred to as "we") complies with the principles of Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), including accountability, identification of purposes, consent, limitation of collection, use, disclosure and retention, accuracy, security safeguards, openness and individual access.

Legal Basis for Processing: We only collect, use and disclose your personal information for clear and legitimate purposes with your meaningful consent. You have the right to withdraw your consent at any time, but this will not affect the legality of processing based on the consent before withdrawal.

Data Retention and Accuracy: We are committed to ensuring that your personal information is as accurate, complete and up-to-date as possible. We will only retain your personal information for the time necessary to achieve the stated purposes.

Right of Access and Correction: You have the right to access the personal information we hold about you and to request correction of any inaccurate or incomplete information. You may submit a written request to us through the contact information provided in the main Policy. We will respond within 30 days.

Challenging Our Compliance: If you have any questions or complaints about our compliance with PIPEDA, please first contact us via SZhonglumy@yeah.net. If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPCC).

Cross-Border Data Transfers: Your personal information may be processed and stored outside Canada. When conducting such transfers, we will ensure that your information is protected at a level equivalent to that required by PIPEDA through contracts or other legal means.

B. Supplementary Clauses for California Residents (in accordance with CCPA/CPRA)

These clauses apply to consumers who are California residents ("you") and supplement the information we provided in the main Privacy Policy regarding the collection, use and sharing of your personal information.

Definition of "Sale" or "Sharing": We will not sell your personal information for money or other valuable consideration. We may "share" your device identifiers and internet activity information with third-party partners in the context of providing personalized advertising, which may be defined as "sale" or "sharing" under CCPA/CPRA. You have the right to opt out of such "sale" or "sharing" through the following methods.

Your California Privacy Rights: In accordance with CCPA/CPRA, you have the following rights:

• Right to Know: You have the right to know the categories and specific content of personal information we collect, use, disclose and sell about you.
• Right to Delete: You have the right to request the deletion of personal information we have collected from you (except as otherwise provided by applicable exceptions).
• Right to Correct: You have the right to request correction of inaccurate personal information we hold about you.
• Right to Opt Out: You have the right to opt out of the "sale" or "sharing" of your personal information for the purpose of cross-context behavioral advertising (personalized advertising).
• Right to Restrict: You have the right to restrict the use and disclosure of sensitive personal information.
• Right Against Retaliation: You will not be subject to any discriminatory treatment when exercising these rights.

How to Exercise Your Rights:

You may submit a verifiable consumer request to us by sending an email to SZhonglumy@yeah.net to exercise your rights to know, delete, correct and restrict.

To exercise your right to opt out, you may take the following actions:

• When you launch the App for the first time, reject the option of "sharing data for personalized advertising purposes" in the pop-up consent management platform.
• Switch the relevant options at any time through the "Privacy Settings" menu in the App.
• Or send a signal through Global Privacy Control (GPC). Please note that we are working to identify and implement GPC signals from browsers.

Categories of Information We Collected (in the past 12 months):

Data Retention: We determine the retention period of personal information based on the purposes stated in the main Policy and comply with the relevant requirements of CCPA/CPRA.

Authorized Agents: You may submit requests through an authorized agent. The agent must provide a copy of the signed power of attorney. We may contact you directly to verify your identity.

Contact Information: If you have any questions about your California rights, please contact us via email at SZhonglumy@yeah.net or the mailing address provided in the main Policy.