Title

Togoo Privacy Policy

Updated date: May 12, 2023

Effective date: May 12, 2023

Update tips:

Dear Togoo users, in order to ensure your right to know and strengthen the protection of your personal information security, we recently updated "Youmeng+SDK" and "Jiguang SDK".

1. Our products are integrated with Umeng+SDK, Umeng+SDK needs to collect your device Mac address, unique device identification code (IMEI/androld ID/IDFA/OPENUDID, GUID/IP address/SIM card MSI information). Uniquely identify users for statistics such as new user additions. In special cases (such as when users use tablet devices or TV boxes), in order to provide statistical analysis services normally. The statistical analysis service has basic anti-cheating functions. By obtaining user location information and IP addresses, cheating devices are eliminated, and the geographical distribution data of users is corrected to improve the accuracy of report data. In order to provide you with a one-click sharing service, our product integrates Umeng+U-Share SDK, which will collect your device identification information (such as IMEI/androld ID/IDFA, etc.) and the public information of your social account that you need to share, In order to complete the one-click sharing service. For your information security, we have entered into data security and confidentiality agreements with third-party SDK service providers, and these companies will strictly abide by our data privacy and security requirements. We will not share your personally identifiable information with them unless we have your consent. In order for you to better understand the types and uses of data collected by [Youmeng+], and how to protect your personal information, you can visit https://www.umeng.com/policy to learn about [ Youmeng+] Privacy Policy .

2. Our products integrate Jiguang SDK, and Jiguang SDK needs to collect your personal information, including device information, network information, location information, and application information. And other personal information of your end users that you supplement based on the type of mobile application and your specific requirements for developer services, including phone numbers, user chat information, APP application page information, APP function event related information, user sharing information content etc. In order for you to better understand the purpose of [Jiguang SDK] and how to protect your personal information, you can log in to https://www.jiguang.cn/license/privacy to understand the privacy policy of [Jiguang SDK].

3. App installation and operation "Permission List" and its purpose

List of third-party SDKs

Jiguang one-click login SDK

Company: Shenzhen Hexun Huagu Information Technology Co., Ltd.

Purpose of use: one-click login, WIFI BSSID

Collect data: device identification (IMEI, IMSI, SIM card information), MAC address, local number, running process information, obtain Android_ID, read BSSID of WIFI

Sharing method: SDK native collection

QQ SDK

Company: Tencent Technology (Shenzhen) Co., Ltd.

Purpose of use: use QQ to log in or share content to QQ

Collected data: device identification (IMEI, ICCID, AndroidID), MAC address, application list, geographic location information

Sharing method: SDK native collection

WeChat SDK

Company: Shenzhen Tencent Computer System Co., Ltd.

Purpose of use: use WeChat to log in, share content to WeChat, or use WeChat to pay

Collected data: device identification (IMEI, ICCID, Android ID), MAC address

Sharing method: SDK native collection

Alipay SDK

Affiliated companies: Alipay (China) Network Technology Co., Ltd., Taobao (China) Software Co., Ltd.

Purpose of use: Pay with Alipay

Data collection: device identification (IMEI, IMSI, hardware serial number, Android ID, ICCID, SIM card serial number), MAC address, device screen density, network information (network type, wifi information, operator information, BSSID, SSID), application data

Sharing method: SDK native collection

SoundNet SDK

Company: Shenzhen Shengwang Information Technology Co., Ltd.

Purpose of use: Live streaming

Collect data: device information (AndroidID, sensors), camera, microphone

Sharing method: SDK native collection

Bugly SDK

Company: Shenzhen Tencent Computer System Co., Ltd.

Purpose of use: bug statistics, troubleshoot crashes, and help App improve

Collected data: mobile phone model, mobile phone brand, Android system version, Android system api level, manufacturer system version, cpu architecture type, whether the device is rooted, disk space occupied, sdcard space occupied, memory space occupied, network type, current application The name and PID of the running process

Sharing method: SDK native collection

Baidu Speech Recognition SDK

Affiliated company: Beijing Baidu Netcom Technology Co., Ltd.

Purpose of use: Speech recognition conversion

Data collection: device identification (IMEI or OAID, SN, IMSI, Android ID, GAID), application information (APP registration and version number, running status), network information (IP or domain name connection results, current network type)

Sharing method: SDK native collection

Xunfei Speech Recognition SDK

Affiliated Company: HKUST Xunfei Co., Ltd.

Purpose of use: Speech recognition conversion

Sharing method: SDK native collection

Google Speech Recognition SDK

Affiliated Company: Google Inc.

Purpose of use: Speech recognition conversion

Sharing method: SDK native collection

Microsoft Speech Recognition SDK

Company Affiliation: Microsoft

Purpose of use: Speech recognition conversion

Sharing method: SDK native collection

Rongyun SDK

Affiliated company: Beijing Yunzhong Rongxin Network Technology Co., Ltd.

Purpose of use: use IM message transmission

Sharing method: SDK native collection

Umeng share SDK

Affiliated company: Youmeng Tongxin (Beijing) Technology Co., Ltd.

Purpose of use: use and share

Youmeng Statistics SDK

Affiliated company: Youmeng Tongxin (Beijing) Technology Co., Ltd.

Purpose of use: usage statistics

Sharing method: SDK native collection

Telecom extreme test SDK

Affiliated company: China Telecom Group Co., Ltd.

Purpose of use: use one-click login

Sharing method: SDK native collection

China Unicom Extreme Test SDK

Affiliated company: China Unicom Network Communications Group Co., Ltd.

Purpose of use: use one-click login

Sharing method: SDK native collection

Mobile Extreme Experience SDK

Affiliated company: China Mobile Communications Group Co., Ltd.

Purpose of use: use one-click login

Sharing method: SDK native collection

Weibo SDK

Affiliated company: Beijing Weimeng Chuangke Network Technology Co., Ltd.

Purpose of use: use Weibo to share, share content to Weibo

Collected data: device identification (IMEI, ICCID, Android ID), MAC address

Sharing method: SDK native collection

Xiaomi Push SDK

Company: Beijing Xiaomi Technology Co., Ltd.

Purpose of use: message push

Collected data: device identification (IMEI, ICCID, Android ID), MAC address

Sharing method: SDK native collection

OPPO Push SDK

Affiliated company: Guangdong Mobile Communication Co., Ltd.

Purpose of use: message push

Collected data: device identification (IMEI, ICCID, Android ID), MAC address

Shanghai Lingfen Technology Co., Ltd. (hereinafter referred to as "we") is well aware of the importance of personal information to you, and will do our best to protect your personal information safe and reliable. We are committed to maintaining your trust in us, adhering to the following principles, and protecting you Personal information: the principle of consistent rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of least enough, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we promise that we will take corresponding security protection measures to protect your personal information according to mature security solutions in the industry. In view of this, we formulate this "Togoo Privacy Policy" (hereinafter referred to as "this policy/this privacy policy") and remind you:

This policy applies to Togoo products or services.

It should be noted that this policy does not apply to services provided to you by other third parties, nor does it apply to products or services that have separately set privacy policies.

Before using Togoo's products or services, please be sure to carefully read and thoroughly understand this policy, especially the terms marked in bold/bold underline. You should read them carefully and use related products or services after confirming your full understanding and agreement. Serve. Once you start using Togoo's products or services, it means that you have fully understood and agreed to this policy. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the various contact methods provided by Togoo.

This Privacy Policy will help you understand the following:

1. How do we collect and use your personal information
2. How do we use cookies and similar technologies
3. How do we share, transfer and publicly disclose your personal information
4. How do we protect your personal information
5. How do you manage your personal information Personal information
6. How do we handle personal information of minors
7. How do we store your personal information
8. How to update this privacy policy
9. How to contact us

1. How we collect and use your personal information

Personal information refers to all kinds of information recorded electronically or in other ways that can identify a specific natural person or reflect the activities of a specific natural person alone or in combination with other information, including name, date of birth, ID number, personal biometric information, address, Communication contact information, communication records and content, account passwords, property information, credit information, whereabouts, accommodation information, health and physiological information, transaction information, etc.

Sensitive personal information refers to personal information that, if leaked, illegally provided or abused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment, including ID number, personal biometric information, bank account number , communication records and content, property information, credit information, whereabouts, accommodation information, health and physiological information, transaction information, personal information of children under the age of 14 (including) etc. (we will be sensitive to specific individuals in this Privacy Policy Information is highlighted in bold ).

The contents of personal information and personal sensitive information come from GB/T35273 "Personal Information Security Specification".

You understand and agree that:

1. We are committed to creating a variety of products and services to meet your needs. Because we provide you with a wide variety of products and services, and the range of specific products/services chosen by different users is different, accordingly, the type and scope of personal information collected and used will be different. Please refer to the specific product/service Function shall prevail;

2. In order to bring you a better product and service experience, we continue to work hard to improve our technology, and we may launch new or optimized functions from time to time, which may require the collection and use of new personal information or changes Purpose or method of using personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with a way to choose your own consent, and after obtaining your express consent Collect, use. During this process, if you have any questions, comments or suggestions, you can contact us through the various contact methods we provide, and we will answer you as soon as possible.

The types of personal information collected by the functions of the products or services we provide, as well as the rules for collecting and using personal information (such as the purpose and method of collecting and using personal information) are as follows:

1. When you register for Togoo services, we will collect your nickname, profile picture, gender, date of birth, mobile phone number, username and password to be used to create a Togoo account. If you agree and authorize us to authorize your account information (avatar, nickname and other information prompted on the page) to a third party so that you can easily register or log in to a third-party account, we will Account information is shared with third parties. In addition, we may obtain information related to your registered account on the third-party platform (avatar, nickname, and other information authorized by you) from a third party according to your authorization, and bind it to your Togoo account so that you can use it through A third-party account directly logs in and uses our products and/or services. We will use your relevant information within the scope of your authorization and consent. The above information you provide will continue to authorize us to use it during your use of the service. When you voluntarily cancel your account, we will anonymize or delete your personal information as soon as possible in accordance with the requirements of applicable laws and regulations.

2. When you register and start using various services of Togoo, in order to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize our service experience and protect your account security, we will collect information about your use The service and usage information and correlate these information, including: Device information: We will receive and record the relevant information of the device you use (including the device model) according to the specific permissions you grant during software installation and use. , operating system version, setting parameters, device configuration, device identification, device network information, device environment, software list and other software and hardware feature information). Service log information: When you use our website or the products or services provided by clients, we will automatically collect your detailed usage of our services and save them as relevant service logs. Including your browsing, clicking to view and search query content, following and sharing information, posting information, as well as IP address, browser type, operator information, language used, access date and time. Please note that individual device information, log information, etc. are information that cannot identify a specific natural person. If we combine this type of information with other information to identify a specific natural person, or use it in combination with personal information, during the combined use, such information will be regarded as personal information, unless otherwise authorized by you or laws and regulations Unless otherwise specified, we will anonymize and de-identify such personal information. We will collect information about your installed apps or running processes.

3. When you use dynamic, video chat/voice chat, and other information release functions to publicly release information, including posting pictures/videos, posting comments, and Q&A content, you need to enable the photo album, camera, and microphone permissions to take photos Or video or voice interaction. Please note that the information you post publicly may involve personal information or even sensitive personal information of you or others, for example, you choose to upload a picture containing personal information when posting an update. Please consider more carefully whether to share or even publicly share relevant information when using our services. We will store it in an encrypted manner, and you can delete this information at any time. Unless you choose independently or comply with relevant laws and regulations, we will not provide the above dynamic information to the outside world, or use it for purposes other than this function.

record your geographic location information after obtaining your consent to enable location permissions . This information is sensitive information, and refusing to provide this information will make you unable to use the above functions, but it will not affect your normal use of other functions of Togoo. In addition, you can also turn off related functions at any time. If you are not our registered user but have turned on the location permission , after confirming that you authorize us to extract, disclose and use your geographic location information, you can browse nearby people and nearby updates.

5. When you use game services, in order to better provide you with game services, improve your game experience, ensure your normal use of our services, maintain the normal operation of basic game functions, optimize the performance of game products and protect your account security, We will collect and use your account information, device information, game log information and transaction record information . If you interact with nearby players through text, pictures, voice, video and other methods in the game, after your authorization and consent, we will access your microphone, photo album, camera, and geographic location information to provide you with voice chat, live broadcast To interact and find nearby gamers, we may collect and save the above information sent by you to filter inappropriate content such as pornography, violence, politics, insults, malicious advertisements, etc., so as to purify the game environment and maintain a healthy online environment.

6. When you purchase Togoo in-app purchase products and services, we will collect the payment information you provide.

7. When you contact us or apply for dispute resolution, in order to protect your account and system security, we need you to provide necessary personal information to verify your user identity . We may save your communication/call records and content (including account information, other information you provide to prove relevant facts, or contact information you left) in order to contact you or help you solve problems, or to record related Solutions to problems and results. In order to provide services and improve the reasonable needs of service quality, we may also use other information about you, including relevant information you provide when you contact customer service, and questionnaire response information you send to us when you participate in questionnaire surveys.

8. In order to improve the security of your use of the services provided by us, our affiliates and partners, protect the personal and property safety of you or other users or the public from infringement, and better prevent phishing websites, fraud, network vulnerabilities, computer viruses, Network attacks, network intrusion and other security risks, to more accurately identify violations of laws and regulations or Togoo related agreement rules, we may use or integrate your user information, transaction information, device information, related network logs and our affiliated companies, partners Obtain the information you authorize or share with us in accordance with the law to comprehensively judge your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

location information (geographic location), camera (camera), photo album (picture library), microphone (voice) and address book in your device , in order to realize the collection and use of the information involved in these permissions. When you use related services, we will pop up a window to prompt you whether to enable the corresponding permissions. You can check the status of the above permissions one by one in your device settings or the client "More-Settings-Privacy-System Permission Management", and you can decide whether to turn these permissions on or off at any time. Please note that if you enable any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you close any permission, it means that you cancel the authorization, and we will no longer continue to collect based on the corresponding permission And use relevant personal information, and cannot provide you with the services corresponding to this permission. However, your decision to close the permission will not affect the previous collection and use of information based on your authorization.

10. You understand and agree that the services we provide may require you to enable your sensors, gyroscope sensors, gravity sensors, acceleration sensors, and clipboards in your device. To realize the collection and use of information involved in these permissions. We will pop up to prompt you whether you want to enable the corresponding permission during the related service. You can check the status of the above permissions one by one in your device settings or the client "More-Settings-Privacy-System Permission Management", and you can decide whether to turn these permissions on or off at any time. Please note that if you enable any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you close any permission, it means that you cancel the authorization, and we will no longer continue to collect based on the corresponding permission And use relevant personal information, and cannot provide you with the services corresponding to this permission. However, your decision to close the permission will not affect the previous collection and use of information based on your authorization.

11. If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing such personal information to Togoo.

12. If we use information for other purposes not specified in this policy, or use information collected based on specific purposes for other purposes, or we actively obtain your personal information from third parties, we will obtain your personal information in advance. agreed.

13. If we obtain your information indirectly from a third party, we will explicitly request the third party to collect personal information after obtaining your consent in accordance with the law before collecting it, and inform you of the content of the shared information, and it involves Sensitive information needs to be clearly confirmed by you before it is provided to us, and the third party is required to make a commitment to the legality and compliance of the source of personal information. If the third party violates the law, we will clearly require the other party to bear the corresponding legal responsibility ;At the same time, our professional security team will carry out security protection for personal information (including classification of sensitive information, access control of sensitive information use, encrypted storage of sensitive information, etc.). We will use no less than the same protection means and measures as we use for our own users' personal information to protect indirectly obtained personal information.

Exceptions to Authorized Consent

You fully understand and agree that we do not need your authorization to collect and use your personal information under the following circumstances, and we may not agree to your request for correction/modification, deletion, cancellation, withdrawal of consent, or information request:

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

2. Related to national security and national defense security;

3. Related to public security, public health, or major public interests;

4. Related to criminal investigation, prosecution, trial and execution of judgments;

5. For the purpose of safeguarding the major legal rights and interests of the personal information subject or other individuals such as life and property, but it is difficult to obtain your consent;

6. The collected personal information is disclosed to the public by you;

7. Collect personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;

8. It is necessary to sign a contract according to your request;

9. It is necessary to maintain the safe and stable operation of the products or services provided, such as discovering and handling product or service failures;

10. Necessary for legitimate news reports;

11. It is necessary for academic research institutions to carry out statistical or academic research based on public interests, and when providing academic research or description results to the outside world, de-identify the personal information contained in the results;

12. Other circumstances stipulated by laws and regulations.

Please be informed that, according to applicable laws, if we take technical measures and other necessary measures to process personal information, so that the data recipient cannot re-identify a specific individual and cannot recover, or we may conduct de-identification research on the collected information , statistical analysis and prediction, used to improve the content and layout of Togoo, provide product or service support for business decisions, and improve our products and services (including using anonymous data for machine learning or model algorithm training), then such processing The data is used without further notice and consent to you.

If we stop operating Togoo products or services, we will stop collecting your personal information in a timely manner, notify you of the notice of cessation of operation by delivery or announcement one by one, and delete or anonymize the personal information we hold .

2. How do we use cookies and similar technologies

(1) Cookies

To ensure the normal functioning of the website and provide you with an easier visiting experience, we store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names and some numbers and characters. With the help of cookies, websites can store your data. You can perform corresponding data clearing operations in your browser. If you clear it, you may not be able to use the services or corresponding functions provided by us that rely on cookies.

(2) Cookie similar technology

In addition to cookies, we also use other similar technologies on our website. For example, the on-site notice we send to you may contain an address link to the content of our website. If you click on the link, we will track this click to help us understand your product or service preferences so that we can proactively improve customer service experience. If you do not want your activities to be tracked down in this way, you can unsubscribe from our mail list at any time.

3. How do we share, transfer and publicly disclose your personal information

We are aware of the corresponding legal responsibilities for external sharing, transfer, and public disclosure of personal information, and we will only share, transfer, and publicly disclose your personal information within the scope of this Privacy Policy:

(1) Sharing

We will not share your personal information with companies, organizations and individuals other than Togoo service providers, except in the following cases:

1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

2. Sharing under statutory circumstances: We may share your personal information externally in accordance with the provisions of laws and regulations, the needs of litigation dispute resolution, or the legal requirements of administrative and judicial authorities.

3. Sharing with authorized partners: We may entrust authorized partners to provide you with certain services or perform functions on our behalf, and we will only share your information for the legal, legitimate, necessary, specific, and clear purposes stated in this privacy policy statement. Authorized partners can only access the information needed to perform their duties, and shall not use this information for any other purpose.

Currently, our authorized partners include the following types:

(1) Authorized partners of advertising and analysis services. Unless we have your permission, we will not share your personally identifiable information with partners who provide advertising and analysis services. We will commission these partners to process information related to the coverage and effectiveness of advertising, but will not provide your personally identifiable information, or we will de-identify this information so that it does not personally identify you. Such partners may combine the above information with other data obtained legally by them to carry out advertising services or decision-making recommendations entrusted by us.

(2) Suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business, including providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertisements and services, providing customer service, payment facilitation Or conduct academic research and surveys.

We will conduct strict security inspections on the application program interface (API) and software tool development kit (SDK) for authorized partners to obtain relevant information, and agree with authorized partners on strict data protection measures to make them comply with our entrusted purpose, Service Description, this Privacy Policy and any other relevant confidentiality and security measures to process personal information.

(2) Transfer

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

1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

2. In cases involving mergers, acquisitions or bankruptcy liquidation, or other situations involving mergers, acquisitions or bankruptcy liquidation, if the transfer of personal information is involved, we will require new companies and organizations that hold your personal information to continue to be bound by this policy. Otherwise, we will require the company, organization and individual to seek your authorization and consent again.

(3) Public disclosure

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

1. With your explicit consent or based on your active choice, we may publicly disclose your personal information;

2. If we determine that you have violated laws and regulations or seriously violated Togoo's relevant agreement rules, or in order to protect the personal and property safety of Togoo and its affiliated company users or the public from infringement, we may levy according to laws and regulations or Togoo's relevant agreement rules. Disclose your personal information with your consent, including relevant violations and the measures Togoo has taken against you.

(4) Exceptions to obtaining prior authorization and consent when sharing, transferring, and publicly disclosing personal information

In the following situations, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

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

2. Related to national security and national defense security;

3. Related to public security, public health, or major public interests;

4. Related to criminal investigation, prosecution, trial and execution of judgments;

5. For the protection of your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain the consent of the person;

6. Personal information that you disclose to the public by yourself;

7. Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.

According to the law, if we take technical measures and other necessary measures to process personal information, so that the data recipient cannot re-identify specific individuals and cannot recover, the sharing, transfer, and public disclosure of such processed data do not need to notify you separately And get your consent.

4. How do we protect your personal information

(1) We strive to provide security for users' personal information to prevent illegal use, unauthorized access and disclosure, leakage, damage and loss of users' personal information. We will use various security protection measures within a reasonable level of security to ensure the security of information. For example, we will use encryption technology (such as SSL), anonymization processing, encrypted storage and other means to protect your personal information; establish a trusted protection mechanism to prevent personal information from being maliciously attacked; establish an access control mechanism and abide by the least privilege Principles to ensure that only authorized personnel can access personal information; conduct security and personal information protection training courses to strengthen employees' awareness of personal information protection.

(2) We have an industry-leading data security management system centered on data and centered around the data life cycle, which improves the security of the entire system from multiple dimensions such as management organization, organizational construction, system, and product technology. We have established special management systems, processes and organizations to ensure the security of personal information. For example, we strictly limit who can access information, require them to abide by confidentiality obligations, and conduct audits. In the event of a security incident such as personal information leakage, we will activate an emergency plan to prevent the expansion of the security incident, and notify you in the form of push notifications, announcements, etc.

(3) We will take reasonable and feasible measures to avoid collecting irrelevant personal information.

(4) The Internet is not an absolutely safe environment, and we strongly recommend that you do not use communication methods not recommended by Togoo to send personal information . You can connect and share with each other through our services. When you create a communication, transaction or sharing through our services, you can independently choose the object of communication, transaction or sharing, as a third party who can see your transaction content, contact information, communication information or sharing content and other related information.

If you find that your personal information, especially your account or password, has been leaked, please contact Togoo customer service immediately so that we can take corresponding measures according to your application.

Please note that the information you share voluntarily or even publicly when using our services may involve personal information or even sensitive personal information of you or others, such as when you post news or choose to upload personal information in public places such as group chats and circles picture of. Please consider more carefully whether to share or even publicly share relevant information when using our services.

Please use a complex password to help us ensure the security of your account. We will do our best to keep any information you send us secure.

At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

V. How do you manage your personal information

You can access and manage your personal information in the following ways:

(1) Query, correct and supplement your personal information, and obtain a copy of your personal information

You have the right to access your personal information, except for exceptions provided by laws and regulations. You can access your personal information yourself by:

Account Information - If you want to access or edit your personal ID information in your account, bind your phone, change your password, add security information or close your account, etc., you can log in to your account through "My"-" Settings" to do this.

Personal data—If you want to access or edit your nickname, avatar, hometown, date of birth, height, occupation, school, personal signature, location and other information in your personal data, you can log in to your account through "My"-" View or Edit Profile" to do so.

Dynamic information - you can log in to your account and access or clear your dynamic posting history through "My Dynamic".

If you are unable to access such personal information through the above path, you can contact us through Togoo customer service at any time. We will respond to your access request within 15 days.

For other personal information generated during your use of our products or services, we will provide you with the relevant arrangements in "(6) Responding to your above request" in this article.

(2) Delete your personal information

You can delete some of your personal information through the methods listed in "(1) Query, Correct or Supplement Your Personal Information and Obtain a Copy of Your Personal Information" in this article.

You can request us to delete your personal information under the following circumstances:

1. If our handling of personal information violates laws and regulations;

2. If we collect and use your personal information without your explicit consent;

3. If our handling of personal information seriously violates the agreement with you;

4. If you no longer use our products or services, or you voluntarily cancel your account;

5. If we no longer provide you with products or services permanently.

If we decide to respond to your deletion request, we will also notify the subjects who obtained your personal information from us as much as possible and request them to delete them in a timely manner, unless laws and regulations provide otherwise, or these subjects have obtained your independent authorization.

After you or we assist you to delete information from our services, we may not immediately delete the corresponding information from the backup system in accordance with relevant laws and regulations, and we will safely store your personal information and share it with any Quarantine is further processed until backups can be purged or anonymized.

(3) Change the scope of your authorization and consent

Each business function requires some basic personal information to be completed (see "Article 1" of this Privacy Policy). In addition, for the collection and use of additional personal information, you can give or withdraw your authorization in My-Settings or contact Togoo customer service.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.

(4) Cancellation of account by the subject of personal information

You can submit an account cancellation application on the "Account Cancellation" page (for example, TogooAPP "Settings-Account Cancellation").

After you voluntarily cancel your account, we will stop providing you with products or services, and delete or anonymize your personal information in accordance with the requirements of applicable laws.

(5) Automatic decision-making of constraint information system

In some business functions, we may only make decisions based on non-human automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide methods of appeal without infringing on Togoo's trade secrets or other user rights and social public interests.

(6) Responding to your above request

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will reply within 15 days. If you are not satisfied, you can also file a complaint through Togoo customer service.

For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. We may deny requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical.

In the following situations, we will not be able to respond to your request in accordance with the requirements of laws and regulations:

1. Related to national security and national defense security;

2. Related to public security, public health, or major public interests;

3. Related to criminal investigation, prosecution, trial and execution of judgments;

4. There is sufficient evidence that the personal information subject has subjective malice or abuse of rights;

5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6. Those involving commercial secrets.

6. How do we handle personal information of minors

Minors may not create their own user accounts without the consent of their parents or guardians. If you are a minor, we recommend that you ask your parents or guardians to read this Privacy Policy carefully, and use our services or provide us with information with the consent of your parents or guardians.

We will only use or disclose the personal information of minors as permitted by laws and regulations, with the explicit consent of parents or guardians, or as necessary to protect the minors.

7. How do we store your personal information

Your personal information collected and generated during our operations in the People's Republic of China will be stored in China.

Generally speaking, we will store and retain your personal information within 6 months from the date when you use the service to obtain your personal information to after you cancel your account.

After your personal information exceeds the retention period, we will delete your personal information or make it anonymized in accordance with the requirements of applicable laws.

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

8. How to update this Privacy Policy

Our Privacy Policy is subject to change.

We will not limit your rights under this Privacy Policy without your explicit consent. For major changes, we will provide prominent notices (including we will notify you through Togoo publicity and even provide you with pop-up prompts).

Major changes referred to in this policy include, but are not limited to:

1. Major changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

2. We have undergone major changes in aspects such as control rights. Such as changes in owners caused by mergers and acquisitions, etc.;

3. The main object of personal information sharing, transfer or public disclosure changes;

4. There are major changes in your right to participate in the processing of personal information and how to exercise it;

5. When our responsible department, contact information and complaint channels for handling personal information security change;

6. When the personal information security impact assessment report indicates that there is a high risk.

We will also archive previous versions of this Privacy Policy for your review.

9. How to contact us

You can contact us in the following ways, we will respond to your request within 15 days:

1. If you have any questions, comments or suggestions about the content of this policy, you can contact us through Togoo customer service and the online customer service in the Togoo mobile APP;

2. If you find that your personal information may be leaked, you can contact Togoo customer service to complain and report;

3. We have also set up a dedicated department for personal information protection, which you can contact through;

4. If you find that your personal information may be leaked, you can send an email to zero@zerophil to complain and report.

If you are not satisfied with our response, especially if you believe that our personal information processing behavior has damaged your legal rights, you can also seek a solution by filing a lawsuit with the court with jurisdiction in the place where the defendant is domiciled.

5. Shanghai Lingfen Technology Co., Ltd. affiliated to Togoo, registered address: Room 803, Building 5, No. 559 Zhuyuan Road, Minhang District, Shanghai, common office address: Room 803, Building 5, No. 559 Zhuyuan Road, Minhang District, Shanghai, person in charge of information protection Contact number: 13914155922、Facebook：xuezhonggeng、WhatsApp：008613914155922

Shanghai Lingfen Technology Co., Ltd.