一、Application scope

This policy applies to all products and services offered to you by SocialSmartly service providers in the form of websites, software clients, cell phones, and new forms that emerge as technology evolves.

In addition to the information collection and use activities described in this Policy, this Policy does not apply to other services provided to you by SocialSmartly's partners and other third parties, which are subject to the personal information collection and use rules that they have separately stated to you.

二、Information collection and use

The personal information we need/may need to collect and use about you in connection with your use of our products/services includes either.

1. In order to achieve the basic function of providing our products and/or services to you, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services properly.

2. In order to provide you with additional features of our products and/or services, you may choose to individually consent or not to consent to the information we collect and use. If you refuse to provide it, you will not be able to use the additional features properly or to achieve the functional effect we intend to achieve, and it will not affect your use of our basic features.

We would like to remind you that we are committed to creating a wide range of products and services to meet your needs. Due to the variety of product modules and services we provide to you, and the difference in the scope of specific products/services selected by different users, the basic/additional features and the type and scope of personal information collected and used may vary.

We will provide you with various specific functional scenarios including but not limited to.

1. Basic, Professional and Business versions of SocialSmartly products

We provide you with services based on the packages or functional modules you create an account with SocialSmartly and order from SocialSmartly. In order to create a SocialSmartly account you will need to provide us with at least your cell phone number or email address. If you refuse to provide such information, you will not be able to register for a SocialSmartly account.

When you use SocialSmartly products and services, SocialSmartly automatically receives and records information on your browser and computer, including, but not limited to, your IP address, browser type, language used, date and time of access, hardware and software characteristics and the pages you visit, and your service logs and operation logs.

To ensure that we are providing services to you personally, we may verify your identity based on the information you provide above. If there are scenarios where we are required by law to determine your necessary identity (including protecting the rights and interests of minors, combating telecommunications network fraud, withholding taxes for you, and identifying relevant subjects in administrative law enforcement or judicial proceedings), you may authorize the face recognition verification channel we provide to verify the information for the above purposes.

2. Additional services

You can choose to further improve the account information of this product, you can provide us with your nickname, cell phone number, etc. to obtain additional services that better meet your needs. You can also choose not to provide, but you will not be able to access the relevant services, but does not affect the normal use of other features and services.

From time to time, SocialSmartly may launch campaigns for new services and features. If you participate in a campaign, we may collect information including, but not limited to, your identity and contact information through the campaign interface in order to contact you, verify your eligibility for rewards, and issue rewards to you. If you do not participate in the relevant operational activities, you do not need to provide the aforementioned information, if you participate in the operational activities but refuse to provide, you will not be able to obtain the relevant rewards.

SocialSmartly collects store information (only on standalone platforms that support this feature) for the user's own marketing scenarios, if the user actively authorizes it. You may not be able to use the marketing-related features without authorization.

3. Customer service and dispute handling

When you contact us or submit an application for in-sale, after-sale or dispute handling, we need you to provide the necessary personal information to verify your membership in order to protect the security of your account and system.

In order to contact you and help you resolve your problem as quickly as possible or to record the solution and outcome of the problem, we may keep a record of your communications, correspondence/calls and related content (including account information, address, email address, other information you provide to prove relevant facts, or contact information you leave) with us. We may use your account information and order information if you make inquiries, complaints or suggestions regarding a specific order.

We may also use other information about you that is reasonably necessary to provide the Services and improve the quality of the Services, including information you provide when you contact Customer Service and information you send to us in response to a survey.

三、Provide information externally

(i) Sharing

We do not share your personal information with companies, organizations and individuals outside of SocialSmartly service providers, except for the following.

1. Sharing necessary to fulfill legal obligations: We may share your personal information as required by laws and regulations, as necessary for litigation or dispute resolution, or as requested by administrative or judicial authorities in accordance with the law, and as necessary to fulfill other legal obligations.

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

3. Sharing with Affiliates: In order for us to work with our affiliates to provide some of our services to you, to provide you with products and services based on your SocialSmartly platform account, to recommend information that may be of interest to you, to identify member account anomalies, and to protect the personal and property safety of SocialSmartly affiliates or other users or the public from abuse, your personal information may be shared with Our affiliates and/or their designated service providers. We will only share personal information that is necessary and subject to the purposes stated in this policy, and will seek your authorized consent again if we share your sensitive personal information or if our affiliates change the purposes for which the personal information is used and processed.

Please note that the information you voluntarily share or even publicly share when using our services may involve personal or even sensitive personal information about you or others. Please consider and make your decision more carefully.

(ii) Entrusted Processing

We may entrust the processing of your personal information to authorized partners in order to authorize them to provide certain services or perform functions for you on our behalf. We will only entrust them with your information for the lawful, legitimate, necessary, specific and defined purposes stated in this policy, and the authorized partner will only have access to the information necessary to perform its duties, and we will require by agreement that it not use the information for any other purpose beyond the scope of the entrustment. If an Authorized Partner uses your information for a purpose that we have not delegated, it will obtain your consent separately.

Currently, we commission the following types of licensing partners.

1. Authorized partners in the advertising and analytics services category. We will entrust these partners with the processing of information related to advertising placement, reach and effectiveness, subject to the use of security technologies common to the industry. We will not entrust your personally identifiable information to our partners.

2. Vendors, Service Providers and Other Partners. We entrust the processing of information to vendors, service providers and other partners who support our business with technical infrastructure services commissioned by us, analyze how our services are used, provide customer service, facilitate payments or conduct academic research and surveys.

(iii) Assignment

If we need to transfer personal information due to merger, separation, dissolution, or being declared bankrupt, we will inform you of the name or name and contact information of the recipient. The recipient will continue to fulfill this policy and other legal obligations. If the recipient changes the original purpose or method of processing, we will obtain your consent again.

(iv) Public Disclosure

We will only publicly disclose your personal information when.

1. we may publicly disclose your personal information based on your active choice and other individual consent.

2. If we determine that you have violated laws or regulations or seriously violated the relevant agreements and rules of the SocialSmartly Platform, or to protect the personal and property safety of SocialSmartly Platform users or the public from harm, we may disclose personal information about you, including the relevant violations and the measures the Platform has taken against you.

四、Your rights

You can access and manage your information and we will respond to your request, subject to legal and regulatory requirements, by.

(i) Access, corrections and supplements

You have the right to consult to correct and supplement your information through the official website customer service or through services@socialsmartly.com request.

(ii) Deletion

You can delete some of your information or request to cancel your account to delete all of your information by following the paths listed under '(a) Accessing, correcting and supplementing your information.

In the following cases, you can request us to delete personal information by contacting [Customer Service].

1、If we handle personal information in violation of laws and regulations.

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

3、If our handling of personal information is in serious violation of the agreement with you.

4, if our processing purposes have been achieved, cannot be achieved, or are no longer necessary to achieve the processing purposes.

5、If we stop providing products or services, or if the retention period has expired.

If we decide to respond to your request for deletion, we will also notify the subjects who received your personal information from us, if possible, and ask them to delete it promptly (unless otherwise required by law or regulation, or unless these subjects have independently obtained your authorization).

Once you or we have assisted you in deleting the relevant information, we may not be able to immediately remove the corresponding information from the backup system because of applicable legal and security technical restrictions, and we will securely store your personal information and restrict any further processing of it until the backup can be erased or anonymization is achieved.

(iii) Change the scope of authorization

You can change or withdraw the scope of your authorization to collect and process your personal information in the following ways: You can manage the authorization of the binding relationship through 'My-Account and Security'.

For authorizations that you cannot set up directly by the above means, you may contact Customer Service to make changes, but please note that we may not be able to respond to your request to change the scope of your authorization for some types of personal information, such as information necessary to implement the basic functions of SocialSmartly or information necessary for us to fulfill our obligations under laws and regulations. When you withdraw your authorization, we will no longer process the corresponding personal information. However, your decision to withdraw your authorization will not affect the processing of personal information that we have previously performed based on your authorization.

(iv) Cancellation of Account

If you are sure that you will no longer use our products or services and you want to cancel your account, you can submit a request for cancellation of your account through the official website customer service or contact us through services@socialsmartly.com. After you make a cancellation request, we will stop providing you with products or services, and delete or anonymize your personal information in accordance with the requirements of applicable laws.

(v) Constraint on automatic decision making in information systems

In some business functions, we may make decisions based solely on automated, non-human decision-making mechanisms, including algorithms. If these decisions affect your legal rights, you may contact us through Customer Service.

(vi) Responding to your requests as described above

For the above requests made to us by you or possibly your guardians, close relatives and other entitled subjects, as well as your relevant personal information rights under the laws of the People's Republic of China and other applicable laws, you may contact us through customer service or initiate a complaint directly to our dedicated personal information protection department. We will respond within 15 days.

To protect the security of your account and the security of your personal information, when you make a request to us as described above, we may verify your identity (such as by adding account verification, requiring you to provide a written request or other reasonable means) before processing your request.

In principle, we do not charge a fee for your reasonable requests, but we will charge a fee at our discretion for repeated requests that exceed reasonable limits. We may refuse requests for information that is not directly related to your identity, repeated requests without reasonable justification, or requests that require excessive technical means (such as requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are impractical.

五、Storage of Information

We will only retain your personal information for as long as necessary to achieve the purposes described in this policy, unless there are mandatory retention requirements by law, such as the E-Commerce Law of the People's Republic of China, which requires that information about goods and services and transactions be kept for at least three years from the date of completion of the transaction.

We judge the storage period of personal information mainly based on the following criteria.

1、Completing the purpose of transactions related to you, maintaining the corresponding transaction and business records to respond to your possible inquiries or complaints.

2, to ensure the safety and quality of the services we provide to you.

3. whether you agree to a longer retention period

4. whether there are any other special agreements or legal or regulatory requirements regarding the retention period.

After the retention period is exceeded, we will delete or anonymize your personal information as required by applicable law.

We have taken reasonable and practicable security measures, consistent with industry standards, to protect your information from unauthorized access, public disclosure, use, modification, damage or loss of personal information.

六、Policy Updates

We are continually working to improve our products, services and technology in order to bring you a better experience with our products and services. As new services and business processes change, we may update our Privacy Policy to inform you of specific changes. We will not, however, limit your rights under this policy without your express consent.

We will also provide more prominent notice of significant changes (including when we notify you through public postings on the SocialSmartly website or provide you with a pop-up alert).

七、Protection of minors

SocialSmartly's services are primarily intended for adults. If you are a minor under applicable law, please be sure to read the developer's or advertiser's application's privacy policy and this Privacy Policy carefully together under the supervision and guidance of a parent or other guardian before using the SocialSmartly products and services, and use the application or provide personal information with the consent of your guardian.

We protect the personal information of minors in accordance with the provisions of applicable relevant laws and regulations, and unless otherwise required by law, we will only collect, use, store, share, transfer or publicly disclose personal information of minors when we receive legal permission, the express consent of a parent or other guardian, or when necessary to protect the minor. If we discover that we have collected personal information from a minor without prior verifiable parental consent, we will take steps to delete the information as soon as possible.

If you are a parent or other guardian of a minor, please contact us at the contact information listed in this Privacy Policy if you have questions about the personal information of a minor in your care.

八、Contacting Us

If you have any questions, comments or suggestions about the content of this Policy, you may contact us through SocialSmartly's online customer service; it is important to note that we may not respond to questions that are not related to this Policy or your personal information rights.