Important Notice: We understand the importance of your personal information and will do our utmost to protect it securely and reliably. We are committed to maintaining your trust and adhering to the following principles to protect your personal information: consistency ofrights and responsibilities, clarity of purpose, opt-in consent, minimum necessary, ensuring security, subject participation, and transparency. We also pledge to implement appropriate security measures in accordance with established industry standards toprotect your personal information.
Please note that this Personal Information Protection Policy ("Policy") applies only to the user-side H5 pages, mini-programs, and new forms of products and services currently available or under development (collectively, "Products") of STARTHING PTE.LTD. and its subsidiaries (please click here for details: https://docs.qq.com/doc/DQ0h5akZ4cUN6aEVs) ("Le Yaoyao" or "we"), including claw machines, coin exchange machines, massage chairs, capsule toy machines, charging stations, vending machines,washing machines, and other products and services currently available or under development (collectively, "Products"). This Policy does not apply to third-party pages you access through our products or to products or services provided by other thirdparties ("other third parties," including but not limited to your transaction counterparties, any third-party websites, and third-party service providers). If other third parties collect your personal information, please carefully review the personalinformation protection policies or similar statements of such third parties and consult with them. If you identify risks with these third-party services, we recommend that you terminate the relevant operations to protect your legal rights and interestsand contact us promptly.
This Policy is closely related to your use of our products. Please read and confirm that you fully understand its entirety before using our products and make any choices you deem appropriate. We strive to use clear and concise language. Terms andpersonal information that are material to your rights and interests are highlighted in bold and underlined for your attention. Our products and services are primarily intended for adults. We specifically caution minors under the age of 18 (especiallythose under the age of 14) and their guardians. If you are a minor, please ensure that your parent or guardian carefully reads this Policy and obtain your parent or guardian's consent before using our services or providing us with information. We haveincluded a dedicated section on the protection of minors' personal information. Please read it carefully.
By actively selecting or clicking "Agree" to this Policy during registration, login, or use of our products, you are deemed to have carefully read, fully understood, and fully agreed to all terms of this Policy, and consent to our processing of yourpersonal information and the protection of your personal information in accordance with this Policy. If you do not agree to any of the terms of this Policy, please immediately cease registration, login, and use of our products.
Once you have successfully registered a STARTHING account, you can use your STARTHING account to log in and use our claw machines, coin exchange machines, massage chairs, capsule machines, charging stations, vending machines, washing machines, and otherproducts and services, including user-friendly H5 pages and mini-programs, as well as any new product or service offerings that may emerge as technology evolves.
Please acknowledge and acknowledge that some of your personal information will be directly authorized to STARTHING's partner merchants. In this context, we act solely as a trustee of their personal information.
This policy will help you understand the following:
1. How we collect your personal information
2. How we use your personal information
3. How we entrust the processing, sharing, transfer, and public disclosure of personal information
4. How we store and protect personal information
5. Your rights regarding personal information
6. How we handle the personal information of minors
7. Revisions and Notices
8. How to Contact Us
Personal information is information about an identified or identifiable natural person recorded electronically or otherwise, excluding anonymized information. The personal information covered in this policy includes: basic personal information (includingbirthday, delivery address, gender, and mobile phone number); online identity information (including user ID, nickname, profile picture, and third-party platform account information); personal property information (including virtual property such ascoupons, membership cards, IC cards, account balances, gold coins, and order, transaction, and consumption records); personal online history and log information (including product usage and click history); personal location information (includinglocation information); and personal tag information. Sensitive personal information is personal information that, if leaked or used illegally, could easily lead to the infringement of a natural person's personal dignity or the endangerment of personal orproperty safety. The sensitive personal information covered in this policy includes personal property information such as coupons, membership cards, IC cards, account balances, gold coins and other virtual property information, orders, transactions andconsumption records. (I) Circumstances in which you authorize us to collect your personal information 1. User account management (1) Basic account services To become our user and enable us to provide platform-based membership services, you can registeran account by authorizing a third-party platform (including WeChat, etc., hereinafter the same) account. We will obtain your account information (including WeChat account nickname, avatar, OPENID) from the third-party platform to identify your identityand enable convenient login or registration. (2) Additional value-added services You can choose to fill in your birthday, region, and gender information so that we can provide you with better personalized services and experience. In addition, in order toverify the identity of large-scale top-ups or specific users (such as students), issue or bind welfare coupons, and handle user complaints, we also need to obtain your mobile phone number. If you do not provide this information, you may not be able touse certain features or services within certain products, but this will not affect your use of other basic features or services.
2. Payment and Purchase/Coin Order Management
To display your account transaction information and ensure transaction security, we will generate an order for the purchase of the product and/or service through the system. We will collect information about your virtual assets, such as coupons,membership cards, IC cards, account balances, gold coins, and other virtual assets, as well as the specific order number, order creation time, and transaction amount, for display purposes and to facilitate transaction management of your orders andaccount assets.
3. Remote Order Fraud Risk Control
To mitigate financial risks and prevent users from engaging in remote order fraud, we will collect your location information after you enable location permissions.
4. Customer Service and After-Sales Services
When you contact our customer service or use other user response features (such as personal information protection complaints or suggestions, other customer after-sales services, dispute resolution, complaints, or requests), we will require you toprovide necessary personal information to verify your identity and ensure the security of your account and the system. To process your request, our customer service representatives will need to query or verify your relevant information within the scopeof your authorization and use it only as necessary. If you refuse to provide this information or provide incorrect information, we will be unable to provide you with support. After confirming your user identity, we will also store your contactinformation (the information you use when contacting us or other information you proactively provide to us), your correspondence/call history and content, and other necessary information related to your request, so that we can contact you, assist youwith your issue, or record the resolution and results of your request.
5. Personalized Recommendations
Based on your personal information (your past transaction records, region), we will combine one or more of these pieces of information to extract relevant characteristics of your consumption preferences, behavior patterns, and location, and create tagsto provide you with personalized content, such as page displays, nearby merchant discount recommendations, and customized packages, that better suit your needs.
Certain features or services of our products may require you to provide specific personal information. When you select such features or services, we will notify you of this through pop-ups and obtain your consent. By providing this information, youconsent to our processing of your personal information for the purposes and in the manner described in this Policy. If you choose not to provide this information, you may not be able to use such features or services properly, but this will not affectyour use of other features or services of the product.
(2) Circumstances Where You Directly Authorize STARTHING Merchants to Collect Your Personal Information
You acknowledge and confirm that, in order to facilitate your purchase of relevant products or services, STARTHING's partner merchants specifically authorize and entrust us to provide SaaS system technical support to obtain your order information andnecessary transaction-related information (including mobile phone number, delivery address, purchase history, etc.) to facilitate transactions between you and the merchant and for the merchant to provide subsequent after-sales service. In this case, someof your personal information is provided directly to the STARTHING partner merchants, who will fulfill their obligations regarding personal information protection. We merely act as a trustee of the merchant's personal information. The specificcircumstances are as follows:
1. Delivery of Products and/or Services
After you use payment, purchase/coin deposit, or coupon services and complete payment/receipt/redemption, STARTHING's partner merchants will provide you with the corresponding products and/or services. These merchants will need to use your mobile phonenumber, order information (specific order number, order creation time, order status, order content, order quantity, notes), online identity information (user ID, nickname, profile picture), transaction and spending records, coupons, membership cards, ICcards, account balance, and gold coins) to facilitate the delivery of physical gifts.
Some products/services offer a points mall feature. If you want to redeem points for physical gifts, you will need to provide the merchant with the recipient's name, address, and mobile phone number to facilitate delivery of the physical gift.
2. Customer Service and After-Sales Services
When you contact a merchant's customer service or use other user response features (such as personal information protection complaints or suggestions, other customer after-sales services, dispute resolution, complaints, or requests), the merchant willneed to provide necessary personal information to match and verify your user identity, including your account information (user ID, nickname, profile picture) and mobile phone number, to ensure the security of your account and the system. To process yourrequest, the merchant's customer service will need to query or verify your relevant information within the scope of your authorization and use it only as necessary. If you refuse to provide this information or provide incorrect information, the merchantwill be unable to provide you with support. After confirming your user identity, the merchant will also store your contact information (the information you use when contacting us or other contact information you proactively provide to us), locationinformation (for locating device failures), your correspondence/call history and content with the merchant, and other necessary information related to your request, so that they can contact you, assist you with your issue, or record the resolution andresults of the issue.
3. Personalized Recommendations
Based on your personal information (your past transaction history, region, gender, birthday), some merchants may combine one or more of these information to extract relevant characteristics of your consumption preferences, behavioral habits, and locationinformation and create tags to provide you with more tailored page displays and personalized content recommendations. (3) Circumstances in which we indirectly obtain your personal information from third parties
We may indirectly obtain user identification information (such as profile pictures, nicknames, and OpenID) from third parties that you authorize them to share. After you agree to this Policy, we will link your third-party platform account with yourSTARTHING product account, allowing you to log in and use our products directly through your third-party platform account.
(4) Scenarios in which you may choose to provide your personal information
To provide you with more convenient and high-quality products and/or services and strive to enhance your experience, we may enable system permissions to collect and use your personal information in the services we provide you. If you do not consent toenabling these permissions, your use of other basic product features or services will not be affected, but you may not be able to enjoy the user experience provided by these additional services.
1. Location Permission
Permission Description: Access Location Information
Usage Scenarios and Purposes:
Ÿ Use your location information to locate specific devices to promptly resolve device issues;
Ÿ To meet financial risk management regulatory requirements, we need to obtain location information to detect users engaging in remote order fraud and determine whether users are actually using the device;
Ÿ Display nearby devices and offers to provide personalized recommendations.
2. Bluetooth Permissions
Permission Description: Allows the product to connect to Bluetooth devices.
Usage Scenario and Purpose: Some devices require Bluetooth connectivity. Enabling Bluetooth permissions will allow these devices to connect and activate the hardware via Bluetooth.
3. Camera Permissions
Permission Description: Allows you to scan QR codes, take photos, communicate with customer service, and provide verification.
4. Album/Photo and Storage Permissions
Permission Description: Access your albums/photos.
Permission Description: Read and upload images and files in your device's storage, upload/edit/modify avatars, etc.
5. Clipboard
Permission Description: Write to your clipboard.
Usage Scenario and Purpose: Allows you to write a referral code so you can receive new user benefits on our partner platforms. Please note that, aside from writing the referral code to your clipboard, we will not read, copy, access, or upload yourclipboard information.
Note on Specific Functional Permissions: Because our product is web-based and relies on third-party platforms such as WeChat and browsers, if you need to enable or disable the functional permissions required to use these specific features, you mustenable or disable authorization for WeChat, browsers, and other third-party platforms. Most mobile devices support this requirement. For specific instructions, please refer to or contact your mobile device service provider or manufacturer. You can alsocontact us. Please note that by enabling any permission, you authorize us to collect and use relevant personal information to provide you with the corresponding services. Once you disable any permission, you revoke your authorization. We will no longercollect and use the relevant personal information based on the corresponding permission, and we will no longer be able to provide you with the corresponding services. Your decision to disable a permission does not affect the collection and use ofinformation previously authorized by you. (V) In accordance with relevant laws and regulations, we may collect your personal information without your authorization or consent in the following circumstances:
Ÿ Necessary for the conclusion and performance of a contract to which you are a party;
Ÿ Necessary for the performance of statutory duties or obligations;
Ÿ Necessary for responding to public health emergencies, or in emergency situations, to protect the life, health, and property safety of you or others;
Ÿ Processing your personal information within a reasonable scope for news reporting, public opinion supervision, and other activities in the public interest;
Ÿ Processing personal information that you have disclosed voluntarily or that has otherwise been legally disclosed, within a reasonable scope;
Ÿ Other circumstances prescribed by laws and administrative regulations.
(I) We will use the collected personal information in accordance with this Policy to enable the functions of our products and/or services.
(II) You understand and agree that we will anonymize your personal information so that it cannot be re-identified or linked to you, and we reserve the right to analyze and commercially exploit the processed data without disclosing your personalinformation.
Please note that the processed data Information that cannot identify a specific natural person. If we combine this information with other information that can identify a specific natural person, such information will be considered personal informationduring the period of combined use. Unless we obtain your authorization or otherwise require by law or regulation, we will de-identify this information to protect the security of your personal information.
(3) When we display your personal information, we will desensitize it through methods including content replacement and anonymization to protect your information security.
(4) If we intend to use your personal information for other purposes not specified in this Policy, or if we intend to use information collected for a specific purpose for other purposes, we will explain this to you again and obtain your consent.
(5) To help you discover more products or services that meet your personal needs, we and STARTHING merchants will generate indirect demographic profiles based on your historical spending amount, frequency, and region to recommend personalized content toyou. If you do not wish to receive personalized recommendations from us or merchants, you can contact the merchant through the contact information provided in this Policy to opt out. (VI) We or our third-party partners may obtain and use your informationthrough cookies or similar technologies and store such information as log information.
We use cookies to provide users with a simple and easy-to-use online experience. A cookie is a small amount of data that is sent from a web server to your browser and stored on your device. We use cookies to benefit users. For example, to speed up thelogin process for this product, you can choose to store your username in a cookie, which will make it easier and faster the next time you log in to our services. Cookies can help us identify the pages and content you connect to, the time you spend on ourspecific services, and the services you choose.
We may have cookies or similar technologies placed by other partners. These cookies and/or similar technologies may collect non-personally identifiable information about you to analyze how users use these services. The collection and use of suchinformation by these third-party cookies or similar technologies is not governed by this Policy but by their own data protection statements. We are not responsible for third-party cookies or similar technologies.
(I) Outsourced Processing
Certain specific modules within our product features or services are provided by external vendors. Examples include the WeChat Official Account and WeChat Mini-Program services, mobile payment services (including WeChat Pay, Alipay, JD Pay, and CloudQuickPass), and location-based positioning and dynamic image recognition service providers.
We sign strict confidentiality agreements with companies, organizations, and individuals to whom we outsource the processing of your personal information, requiring them to handle your personal information in accordance with our requirements, thisPolicy, and any other relevant confidentiality and security measures.
In addition, as a technical service provider, we accept the entrustment of our partner merchants and provide services as a personal information trustee. Therefore, some of your personal information is collected and used by these merchants. We willprocess it in accordance with their requirements and ensure that they fulfill their obligations to protect your personal information. For more details, please refer to the "Circumstances Where You Directly Authorize Leyao Merchants to Collect YourPersonal Information" section.
(II) Sharing
We take the protection of your personal information very seriously. We will only provide your personal information to third parties for legitimate, proper, necessary, specific, and explicit purposes. We will sign strict confidentiality agreements withcompanies, organizations, and individuals receiving personal information, requiring them to handle the information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures. Currently, we sharepersonal information with third parties in the following circumstances:
1. When you register, log in, or use any of our products and services, including claw machines, coin exchange machines, massage chairs, gashapon machines, charging stations, vending machines, washing machines, and other products and services currentlyavailable or under development, and upon your consent to this Policy, we will synchronize your Le Yao Yao account information, as well as your basic personal information, transaction and spending records collected by the service operator when you use anyproduct or service, to our "Le Yao Yao Life" official account to provide you with transaction information reminders and to the operators of other products and services (please click here for details. https://docs.qq.com/doc/DQ0h5akZ4cUN6aEVs). We will only share necessary personal information for the purposes stated in this Policy. If an affiliated company wishes to change the purpose for processing your personal information, we will re-request yourauthorization and consent. 2. When you choose to participate in marketing activities hosted by us, our affiliates, or third parties on our products, you may be asked to provide your mobile phone number. We will only share this information with affiliatesor third parties with your consent to ensure you receive a consistent service experience during the activities or to enable third parties to promptly redeem rewards.
3. To complete order payment, deliver goods or services, confirm transaction status, and provide you with after-sales and dispute resolution services, we will share your order information, transaction amount, and other necessary information required byanti-money laundering laws with third-party payment institutions and banks through the transaction counterparties, payment institutions, and financial institutions you select based on the transaction (please click here for details: https://doc.weixin.qqcom/doc/w3_AQUAXQYQAHk3LMeKQFpRkea5pU0A1?scode=ANUAxQdYAA8FpvjUeuAQUAXQYQAHk). Processing this information is necessary to enable consumption functions; otherwise, the transaction cannot be completed. 4. We may share your personal information externallyas required by laws and regulations, or at the mandatory request of competent government authorities.
5. Third-party SDKs embedded in our products: Our products utilize the SDK of Umeng Tongxin (Beijing) Technology Co., Ltd., which compiles statistics about the use of our products to evaluate and analyze overall usage trends. In this context, we need toshare the following information with them: page visits and clickthrough records. The SDK link/privacy policy is: https://www.umeng.com/policy. Please acknowledge and confirm that we anonymize this statistical information before sharing it, ensuring thatthe recipient cannot recover and re-identify the subject of the personal information. This information does not contain any personal information that could identify you as a specific individual.
We sign strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to handle the information in accordance with our instructions, this policy, and any other relevantconfidentiality and security measures. (3) Transfer
If we need to transfer your personal information due to merger, division, dissolution, bankruptcy, or other reasons, we will inform you of the name and contact information of the recipient and require the new recipient to continue to protect yourpersonal information in accordance with laws and regulations and at least in accordance with this Policy.
(4) Public Disclosure
We will only disclose your information in the following circumstances and after implementing security measures that meet industry standards:
1. With your explicit consent;
2. Legal Disclosure: We may disclose your personal information publicly when required by law, judicial proceedings, or by mandatory government regulations. (V) Exceptions
Please note that, in accordance with relevant laws and regulations, we do not need to obtain your prior consent for the processing, sharing, transfer, or public disclosure of your personal information in the following circumstances:
Ÿ Necessary for the conclusion and performance of a contract to which you are a party;
Ÿ Necessary for the performance of statutory duties or obligations;
Ÿ Necessary for responding to public health emergencies, or for protecting the life, health, and property safety of you or others in an emergency;
Ÿ Processing your personal information within a reasonable scope for news reporting, public opinion supervision, and other activities in the public interest;
Ÿ Processing personal information that you have disclosed voluntarily or that has otherwise been lawfully disclosed, within a reasonable scope;
Ÿ Other circumstances prescribed by laws and administrative regulations.
(I) We comply with laws and regulations and store user personal information collected within China. (2) We will only store your personal information for the period necessary to fulfill the purposes outlined in this Policy. If applicable laws andregulations require a storage period, we will do so within the prescribed period. Our criteria for determining such periods include:
Ÿ Fulfilling transactions with you, maintaining relevant transaction and business records, and responding to potential inquiries or complaints;
Ÿ Ensuring the security and quality of our services;
Ÿ Whether you consent to a longer retention period;
Ÿ Required by the statute of limitations;
Ÿ Whether there are other special agreements or legal provisions regarding retention periods. For example, the "E-Commerce Law of the People's Republic of China" requires that product and service information and transaction information be retained for atleast three years from the date of transaction completion.
After the expiration of the retention period, we will delete or anonymize your personal information in accordance with applicable law. If we terminate our services or operations, we will notify you in advance and delete or anonymize your personalinformation after termination.
Please note that due to applicable laws and security technology limitations, we are unable to immediately delete the relevant information from our backup systems. We will securely store your personal information and limit any further processing until thebackups can be deleted or anonymized. (3) We will take the following measures to protect the security of your personal information: We will adopt security measures that meet industry standards, including establishing reasonable systems and securitytechnologies to prevent your information from unauthorized access, use, public disclosure, modification, damage, or loss. For example, we will use encryption technology to ensure data confidentiality; we will deploy access control mechanisms to ensurethat only authorized personnel can access personal information; we will strictly limit the scope of personnel who may access your personal information and require all personnel who may have access to your personal information to comply withconfidentiality obligations. Failure to fulfill these obligations may result in legal liability.
(4) We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected.
(5) The Internet environment is not 100% secure. We will do our best to ensure the security of any information you send to us, but we recommend that you do not send personal information via email, instant messaging, or other communication methods. If ourphysical, technical, or management protection facilities are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information, which in turn harms your legal rights and interests, we will notify you promptly inaccordance with legal requirements.
(VI) In the unfortunate event of a personal information security incident, we will promptly inform you, in accordance with laws and regulations, of the following: the basic circumstances and potential impact of the incident, the measures we have taken orwill take, suggestions for your own risk prevention and mitigation, and any remedial measures available to you. We will promptly inform you of the incident by email, letter, phone call, push notification, or other means. If it is difficult to inform eachindividual subject of personal information individually, we will issue an announcement using reasonable and effective means. Furthermore, we will proactively report the handling of the personal information security incident to regulatory authorities asrequired.
In accordance with relevant Chinese laws, regulations, and standards, as well as common practices in other countries and regions, we guarantee that you and your immediate family members may exercise the following rights:
(I) Access, Correction, and Supplementation of Your Personal Information
You may access your personal information by visiting "My - User Information" and, in accordance with the corresponding information management procedures, correct or supplement your personal information yourself or by contacting customer service. We willensure that you are able to access, correct, and supplement your personal information to the greatest extent possible in accordance with common standards. If you believe that some of your personal information cannot be accessed, corrected, orsupplemented through the Product, please contact customer service through the contact information provided in Section 8 of this Policy.
(II) Deleting Your Personal Information
You may request deletion of your personal information in the following circumstances:
Ÿ If our processing of personal information violates laws and regulations;
Ÿ If our processing of personal information violates the agreement with you;
Ÿ If you cancel your Product account or withdraw your consent;
Ÿ If your Product account is deleted in accordance with relevant national laws and regulations;
Ÿ If the purpose for processing the personal information has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose;
Ÿ If we terminate our services and operations.
You may delete your personal information by contacting customer service. If we decide to comply with your deletion request, we will also notify the entities that obtained your personal information from us and request that they delete it promptly, unlessotherwise provided by laws and regulations or such entities have obtained your independent authorization.
After you delete your information from our services, if your personal information has not expired under the retention period prescribed by laws and administrative regulations, or if deletion of your personal information is technically difficult, we willcease processing it beyond storage and implementing necessary security measures. (3) Changing the Scope of Your Authorization and Withdrawing Your Consent
You have the right to change or withdraw your consent for us to process your personal information. You can do so by contacting customer service. However, your change or withdrawal of consent will not affect the processing of your personal informationthat was already conducted based on your consent before the change or withdrawal. We will not refuse to provide product features or services based on this grounds, unless the processing of your personal information is necessary for providing the productfeatures or services.
(4) Account Cancellation
You may cancel your previously registered product account at any time. You can do so by clicking on your profile picture, accessing your profile page, and selecting "Account Cancellation." After account cancellation, we will cease providing you withproducts and related services and, upon your request, delete your personal information, unless otherwise required by law or regulations. Please exercise caution. For cancellation considerations, please refer to the "Tips" on the cancellation page. Tooptimize your user experience, we may provide you with an account recovery function within a certain period of time after account deactivation. You can scan the QR code using the same WeChat account to access the STARTHING product and follow theon-screen prompts to apply for account recovery. After your account is restored, you can continue to use your original account to experience the STARTHING services and enjoy the remaining assets and virtual property rights (if any) within your account.
(V) Obtaining a Copy of Personal Information and Transferring Personal Information to a Third Party
You have the right to obtain a copy of your personal information. You can do so by contacting customer service. Where technically feasible and in compliance with the conditions specified by the national cyberspace administration, and if the datainterface is compatible, we may also, upon your request, directly transfer a copy of your personal information to a third party designated by you.
(VI) Submitting Personal Information Security Complaints, Reports, Feedback, or Requesting an Explanation of Personal Information Processing Rules
If you encounter suspected violations of your personal information security while using our services, or discover that your personal information security has been compromised, we may also provide you with a copy of your personal information.If you haveany questions about personal information security incidents, or have any comments or suggestions about our personal information security practices, you may file a personal information security complaint, report a violation, or leave your comments orsuggestions through the contact information provided in Article 8 of this Policy.
If you have any questions about our personal information handling practices while reading this Policy or using our products, you may contact us through the contact information provided in Article 8 of this Policy.
(VII) Enforcement of User Rights for the Deceased
If a product user passes away, we will protect the rights and interests of their next of kin in accordance with the law. The next of kin of the deceased user may exercise the rights to access, copy, correct, and delete the deceased user's personalinformation through the contact information provided in Article 8 of this Policy, unless the deceased user made other arrangements during his or her lifetime.
(VIII) Responding to Your Requests
To ensure your safety, we may require verification of the user's identity before processing your request.
In principle, we do not charge fees for reasonable requests. However, for repeated requests that exceed reasonable limits, we may charge a fee based on the circumstances. We may reject requests that are unreasonably repetitive, require excessivetechnical effort (for example, developing new systems or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are extremely impractical.
In the following circumstances, we will be unable to respond to your request in accordance with laws and regulations:
Ÿ Related to fulfilling our obligations under laws and regulations;
Ÿ Directly related to national security or national defense;
Ÿ Directly related to public safety, public health, or major public interests;
Ÿ Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
Ÿ We have sufficient evidence to demonstrate subjective malice or abuse of rights;
Ÿ To protect the life, property, or other major legitimate rights and interests of you or another individual, but obtaining your consent is difficult;
Ÿ Responding to your request will result in serious damage to the legitimate rights and interests of you, another individual, or an organization;
Ÿ Involving trade secrets.
Ÿ Other circumstances specified by laws and regulations.
(I) If you are a minor under the age of 18, you must obtain the prior consent of your parent or legal guardian before using our products. We will protect the personal information of minors in accordance with relevant national laws and regulations.
(2) When collecting personal information of minors with the consent of their parents or legal guardians, we will only use or disclose this information when permitted by law, with the explicit consent of their parents or legal guardians, or when necessaryto protect the minors.
(3) If we discover that we have collected personal information of minors without prior, verifiable parental or legal guardian consent, we will endeavor to delete the relevant information as soon as possible.
(4) If you are a guardian of a minor, please contact us if you have any questions regarding the personal information of the minor you are responsible for.
To provide you with better service, we may modify the terms of this Policy from time to time based on updates to our services and relevant legal requirements. Such modifications shall constitute part of this Policy. We will post any changes to thisPolicy on this page. For significant changes, we will also provide more prominent notice (website announcements, push notifications, pop-up notifications, or other means). Significant changes referred to in this Policy include, but are not limited to:
1. Significant changes to our service model. This includes the purpose of processing personal information, the types of personal information processed, and how personal information is used;
2. Significant changes in our ownership structure, including changes in ownership due to business adjustments, bankruptcy, or mergers and acquisitions;
3. Significant changes in the primary recipients of personal information sharing, transfer, or disclosure;
4. Significant changes in your rights regarding personal information processing and how they are exercised;
5. Significant changes in the department responsible for handling personal information security, contact information, and complaint channels;
6. Other circumstances that are significant or may significantly impact your personal rights.
Any changes we make will prioritize your satisfaction.
We will provide you with service-related notifications when necessary. If you no longer wish to receive push notifications from us, you may request that we stop sending you text messages by following our SMS unsubscribe guidelines or by configuring yourmobile device to no longer receive push notifications, except where we are required to send you messages as required by law.
We have established a Personal Information Protection Department and appointed a responsible person for personal information protection. For questions, comments, or suggestions regarding your personal information, you may contact us through the followingchannels:
We will promptly review the issue and respond promptly after verifying your user identity. Generally, we will respond to your request within 15 business days. If we are unable to respond to your request, we will notify you within the legally prescribedtimeframe and explain the reasons.
If you are dissatisfied with our response, especially if our handling of your personal information has infringed upon your legal rights, you may also seek a solution through the following external channels: File a lawsuit with the People's Court withjurisdiction over STARTHING's place of residence.