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Privacy Policy – Vision Function Training

Our privacy policy was last updated on November 10, 2022.

Please take a moment to familiarize yourself with our privacy practices, and if you have any questions, please contact us.

About Us

Simingtang Internet Hospital is invested and established by Chengdu Shuangliu Simingtang Internet Hospital Co., Ltd. (hereinafter referred to as the "Company"). The Company was founded in December 2010 and is registered in Zhangjiang High‑Tech Park & China (Shanghai) Pilot Free Trade Zone, Pudong New Area, Shanghai. It is a high‑tech enterprise and software enterprise recognized by the Shanghai municipal government. The Company holds 4 invention patents and 38 computer software copyright registration certificates, and is a Class II medical device manufacturer. (Hereafter "Vision Function Training" or "we") attaches great importance to your privacy. This privacy policy is developed with your needs fully in mind. You will gain a comprehensive understanding of our personal information collection and use practices, while ensuring that you ultimately retain control over the personal information you provide to Vision Function Training – which is of paramount importance.

About This Privacy Policy

Except for specific Vision Function Training products or services that provide a separate privacy policy, this privacy policy applies to all Simingtang devices, websites, or applications that reference or link to this privacy policy. This privacy policy sets forth how Vision Function Training collects, uses, discloses, processes, and protects the information you provide to us or that we collect when you use our products or services through our website (http://www.simingtang.com/) and our mobile applications. If a particular Vision Function Training product or service has a separate privacy policy, that separate privacy policy shall prevail. Any matters not covered by that separate privacy policy shall be governed by this privacy policy. At the same time, depending on factors such as the device model you use, service version, or geographic location, the way a specific product or service collects and processes your personal information may differ. You should refer to the separate privacy policy for detailed information.

Except as otherwise provided by applicable law in your jurisdiction, "personal information" under this privacy policy means information that can identify a specific individual either by itself or when combined with other information. We will strictly adhere to this privacy policy in using such information. When required, based on applicable legal classifications, personal information may also include sensitive personal data or information.

How We Can Help You

Finally, we want to bring you the best experience. If you have any questions about the data processing practices described in this privacy policy, please contact us by sending an email to info@simingtang.com so that we can address your specific needs. We are happy to hear from you.

1. What Information We Collect and How We Use It

1.1 What Information We Collect

To provide our services to you, we need you to provide the information necessary for the use of those services. We only collect information that is necessary for specific, explicit, and legitimate purposes, and we ensure that such information is not further processed in a manner incompatible with those purposes. You have the right to choose whether to provide the information we request, but in most cases, if you refuse, we may not be able to provide you with the corresponding services or respond to your issues.

If you complete account registration, we may proactively contact you through the contact information you provide (such as mobile phone number, WeChat account, etc.) via phone or WeChat to provide registration confirmation, product introduction, service guidance, and follow‑up support.

Depending on the services you choose, we may collect one or more of the following types of information:

1.1.1 Personal Information You Actively Provide to Us

We collect the personal information you need to provide when using the corresponding services, based on the services you choose. For example, if you use the Vision Function Training shopping service, you may provide your name, contact information, email address, shipping address, order information, invoicing information, as well as bank account number, bank account holder name, credit card number, and other relevant information. If you participate in our events or win a prize, you may provide your name, phone number, and address.

1.1.2 Information We Collect During Your Use of Services

• Information related to your device or SIM card: For example, IMEI/OAID, GAID, IMSI, SN, MAC address, serial number, device version and type, ROM version, Android version, Android_ID, Space ID, SIM card operator and home location, screen display information, device input information, device activation time, device manufacturer and model name, network operator, connection type, hardware base configuration, sales channel, and usage‑related information (e.g., CPU, memory, battery usage, device resolution, device temperature, screen‑on count, and unlock count).

• Information related to your application usage: Including in‑app unique identifiers (e.g., VAID, OAID, AAID, Instance ID), application basic information such as installed APP information, application ID, SDK version, system update settings, application settings (region, language, time zone, font), app foreground/background timestamps, and application status records (e.g., download, installation, update, deletion).

• Information generated when you use Vision Function Training: For example, information generated during vision training, including region, Internet Protocol (IP) address, content provider, wallpaper change frequency, image view count, image browsing mode, image view duration, clicks, article exposure, and subscription information.

• Location information (only for specific services/features): If you use location‑related services, we may collect various types of information related to your device's approximate or precise location. For example, region, country code, city code, mobile network code, mobile country code, cell ID, latitude/longitude, time zone, and language settings.

• Log information: Information related to your use of certain features, applications, and websites. For example, cookies and other identifier technologies, IP address, network request information, temporary message history, standard system logs, error/crash information, and service log information (e.g., registration time, access time, activity time).

• Other information: Environmental characteristic values (ECV), i.e., information derived from your Vision Function Training account, device identifiers, Wi‑Fi connection information, and geolocation.

1.1.3 Information from Third Parties

In some cases permitted by law, we may obtain your personal information from third parties. For example:

• For security and anti‑fraud purposes, with your authorization, we may verify your information (e.g., phone number) through legitimate sources for specific accounts and financial transaction services.

• We may also obtain certain information from third‑party social networking services, such as account, nickname, avatar, and email (e.g., when you log in to Vision Function Training services using a social network account).

• Information about you provided by others, such as the shipping address provided to us by other users when they purchase products for you on the Vision Function Training mall.

1.1.4 Non‑Personal Information

We may also collect other information that cannot directly or indirectly identify a specific individual and that is not considered personal information under applicable local law. This type of information is called non‑personal information. We may collect, use, transfer, and disclose non‑personal information. Below are examples of how we collect and use non‑personal information in aggregate form.

• We may include statistical data generated from your use of specific services (e.g., anonymized device‑related information, daily active events, page view events, page view duration events, session events).

• Network monitoring data such as request duration, request and error counts.

• Application crash events (e.g., automatically generated logs after an app crash).

The purpose of collecting such information is to improve the services we provide to you. The type and amount of information we collect will depend on how you use our products or services.

We will aggregate this information to help us provide more useful information to you and understand which parts of our website, products, or services are of most interest to you. For example, we may only need to know the number of active users in a day, without knowing who they are, so aggregate data is sufficient for our statistical analysis. We will, to the extent possible, separate your personal information from non‑personal information and ensure that these two categories are used separately. If we combine non‑personal information with personal information, the combined information will be treated as personal information during the period of combination.

1.2 How We Use This Personal Information

We collect personal information to provide you with products and/or services and to ensure compliance with applicable laws, regulations, and other normative documents. This includes:

• Security purposes such as loss prevention and fraud prevention, assisting in user identification and identity verification. We use your information for anti‑fraud purposes only when both conditions are met: it is absolutely necessary, and it is used to evaluate a legitimate interest of Vision Function Training in protecting users and services.

• Handling your questions or requests regarding devices and services, such as answering customer inquiries, sending system and application notifications, and managing your participation in sweepstakes and other activities.

• Conducting related promotional activities, such as providing promotional and marketing materials and updates. Unless otherwise required by applicable law, if you no longer wish to receive certain categories of marketing communications, you can opt out using the method provided in such communications (e.g., the unsubscribe link at the bottom of emails). Please refer to "Your Rights" below.

• Internal purposes, such as data analysis, research, and development of statistical information related to the use of our products or services, to better improve our offerings. For example, machine learning or model training after de‑identification.

• Optimizing device performance, such as analyzing application memory usage or CPU utilization.

• Storing and maintaining information related to you for our business operations (e.g., business statistics) or fulfilling legal obligations.

• Processing data based on Vision Function Training's legitimate interests (in applicable jurisdictions, e.g., under the GDPR). Legitimate interests include enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our business, systems, products, services, and customers (including for loss prevention and anti‑fraud purposes); internal management; compliance with internal rules and procedures; and other legitimate interests described in this privacy policy. For example, to ensure the security of our services and to better understand application performance, we may record information such as your usage frequency, crash logs, overall usage, performance data, and application source. To prevent unauthorized unlocking of devices, we may collect Vision Function Training account information, the serial number and IP address of the operating computer, and the serial number and device information of your phone.

• Other purposes with your consent.

More detailed examples of how we use your information (which may include personal information) are provided below:

• Activating and registering the Vision Function Training products or services you purchase.

• Creating and maintaining your Vision Function Training account. The personal information you provide when creating a Vision Function Training account through the website or mobile device may be used to establish your personal Vision Function Training account and profile page.

• Processing your orders. Information related to e‑commerce orders may be used to process orders and related after‑sales services, including customer support and reshipment. In addition, the order number will be used to verify the delivery of orders and packages with logistics partners. Recipient information, including name, address, phone number, and postal code, will be used for delivery. The email address will be used to send you package tracking information. The list of purchased items will be used to print invoices and allow you to identify the contents of the package.

• Providing push services. Vision Function Training account, GAID, FCM token, Android ID, and Space ID (only applicable to the spare space function on Vision Function Training devices) may be used to provide Vision Function Training push notifications and service notifications, to evaluate advertising effectiveness, and to send you software updates or new product release notifications, including sales and promotional information. To provide these services, we will collect information about your applications (application version ID, package name) and device‑related information (model, brand).

• Verifying user identity. Vision Function Training uses ECV values to help verify user identity and prevent unauthorized logins.

• Collecting user feedback. The feedback you choose to provide is very important to help Vision Function Training improve its services. To promptly process your feedback, Vision Function Training may use the personal information you provide to contact you and keep records for problem‑solving and service improvement.

• Sending notifications. We may use your personal information to send important notifications, such as those regarding orders and changes to our terms, conditions, and policies. Because such information is crucial to communication between you and Vision Function Training, we do not recommend that you refuse to receive such notifications.

• Conducting promotional activities. If you participate in sweepstakes, contests, or similar promotions through Vision Function Training's social media platforms, we may use the personal information you provide to deliver such rewards to you.

In accordance with the reasons for combining information described above and applicable legal requirements, we will provide you with specific control mechanisms for such integration. You have the right to object to the processing of personal information for direct marketing purposes and to automated decision‑making. You can contact us by sending an email to info@simingtang.com, or refer to the control mechanisms described in the separate privacy policies of each product or service. Please see "Your Rights" below.

2. How We Use Cookies and Similar Technologies

Vision Function Training and third‑party service providers and business partners use cookies, tags, and scripts (for more details, see "How We Share, Transfer, and Publicly Disclose Your Personal Information" below). These technologies are used to analyze trends, administer the website, track your activities on the website, and collect aggregate statistical information about the entire user base. We receive individual or aggregate analysis reports collected through these technologies. These technologies help us better understand your behavior, allowing us to see which parts of our website you visit, measure and improve the effectiveness of advertising and web searches.

• Log files: Like most websites, we collect certain information and store it in log files. This information may include IP address, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamps, and/or clickstream data. We do not link automatically collected log data with other information we collect.

• Local Storage – HTML5/Flash: We use Local Storage Objects (LSOs), such as HTML5 or Flash, to store content and preferences. Third parties that partner with us to provide certain features on our website, or to display ads based on your web browsing behavior, may also collect and store information via HTML5 or Flash cookies. Various browsers provide their own management tools to delete HTML5 local storage objects.

• Mobile analytics: In some mobile applications, we use analytics cookies to collect information about how visitors use our website. This cookie‑collected information includes how often you use the application, events occurring within the application, cumulative usage, performance data, and application crashes. We do not link information stored within analytics software with any personal information you submit within the mobile application.

3. How We Share, Transfer, and Publicly Disclose Your Personal Information

3.1 Sharing

We do not sell any personal information to third parties.

We may share your personal information with third parties (as defined below) from time to time to provide or improve our products or services, including providing products or services at your request. Specific details regarding data sharing are provided below.

3.1.1 Sharing You Actively Choose

With your explicit consent or active choice, we share information within the scope you authorize/request with third parties you designate. For example, when you use your Vision Function Training account to quickly log in to third‑party websites or apps.

3.1.2 Sharing with Our Affiliated Companies

To conduct business operations smoothly and to provide you with the full functionality of products and services, we may from time to time share your personal information with other Simingtang affiliated companies.

3.1.3 Sharing with Third‑Party Service Providers and Business Partners

To ensure that we provide you with the products and services described in this privacy policy, we may share your personal information with our third‑party service providers and business partners when necessary.

Vision Function Training may be required to disclose your personal information in response to laws, legal processes, litigation, and/or requests from public and governmental authorities. We may also disclose information about you if we believe that such disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance.

We may also disclose information about you if we determine that such disclosure is reasonably necessary to enforce our terms, protect our business, rights, assets, or products, or to protect users, or for the purpose of detecting, preventing, and addressing fraud, unauthorized use of our products, violations of our terms or policies, or other harmful or illegal activities. (In some cases, to the extent expressly permitted by local data protection laws, Vision Function Training may collect, use, or disclose your personal information without your consent.) This may include providing information to public or government agencies; communicating with third‑party partners regarding the reliability of your account to prevent fraud, abuse, or other harmful activities within and outside our products.

In addition, we may share your personal information with the following parties:

• Our accountants, auditors, lawyers, or similar advisors, when we request their professional advice.

• Investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction involving a Simingtang group entity.

• Other third parties detailed in this privacy policy or otherwise notified to you, such as when you authorize disclosure of specific information.

3.2 Transfer

Except in the following circumstances, Vision Function Training will not transfer your information to any party:

• With your explicit consent.

• If Chengdu Shuangliu Simingtang Internet Hospital Co., Ltd. participates in a merger, acquisition, or sale of all or part of its assets that may affect your personal information, we will notify you of any changes in ownership or use of your personal information, as well as any choices you may have regarding your personal information, via email and/or prominent notice on our website or other appropriate means.

• As explained in this privacy policy or otherwise notified to you.

3.3 Public Disclosure

Vision Function Training may publicly disclose your personal information in the following circumstances:

• When we need to announce winners of promotions, contests, or sweepstakes, we will only disclose limited information.

• When we have obtained your explicit consent, or when you have disclosed information through our services such as social media pages or public forums.

• Public disclosure based on legal or reasonable grounds, including laws, regulations, legal processes, litigation, or requests from government authorities.

4. How We Store and Protect Your Personal Information

4.1 Security Measures of Vision Function Training

We are committed to protecting the security of your personal information. To prevent unauthorized access, disclosure, or other similar risks, we have implemented all legally required physical, electronic, and managerial measures to safeguard the information we collect from your mobile devices and the Vision Function Training website. We will ensure the protection of your personal information in accordance with applicable laws.

For example, when you access your Vision Function Training account, you may choose our two‑step verification process to better ensure security, and we strongly encourage you to use this method. When you send or receive information from Vision Function Training devices to our servers, we ensure encryption using Transport Layer Security (TLS) and other appropriate algorithms.

Your personal information is stored on secure servers and protected in controlled facilities. We classify your information based on importance and sensitivity, ensuring that your personal information has an appropriate level of security. Similarly, we have special access control measures for cloud‑based data storage, and we regularly review our information collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access and use.

We will conduct due diligence on third‑party service providers and business partners to ensure they have the ability to protect your personal information. We will also check whether third parties adopt appropriate security standards through appropriate contractual restrictions and, when necessary, audits and assessments. In addition, employees, third‑party service providers, and business partners who access your personal information are bound by strict contractual confidentiality obligations.

We conduct security and privacy protection training and tests to enhance our employees' awareness of the importance of protecting personal information. We will take all feasible and legally required measures to protect your personal information. However, you should be aware that the use of the Internet is not completely secure, and therefore, we cannot guarantee the security or integrity of any personal information transmitted over the Internet.

We will handle personal information breaches in accordance with applicable data protection laws, and, when necessary, promptly notify relevant supervisory authorities and data subjects of data breach incidents.

4.2 What You Can Do

You can protect your personal information by not disclosing your login password or account information to anyone (unless that person is formally authorized by you). You can set a unique password for Vision Function Training software to prevent password leaks from other websites from compromising your Vision Function Training account security. At all times, do not disclose the verification code you receive to anyone (including those claiming to be Vision Function Training customer service representatives). Whenever you log in to Vision Function Training software as a Vision Function Training account user, especially on another person's computer or a public Internet terminal, you should always log out after the session ends.

Vision Function Training software is not responsible for any security breaches resulting from your failure to maintain the confidentiality of your personal information, which may allow third parties to access your personal information. Notwithstanding the foregoing, if any other Internet user gains unauthorized access to your account or there is any other security breach, you should notify us immediately. Your assistance will help us protect the confidentiality of your personal information.

4.3 Accessing Other Features on Your Device

Our applications may access certain features on your device, such as enabling email to launch contacts, SMS storage, and Wi‑Fi network status. This information is used to allow these applications to run on your device and to enable you to interact with them. You can revoke permission by contacting us at info@simingtang.com.

4.4 Retention Policy

We retain personal information for the period necessary to fulfill the purposes described in this privacy policy and in the separate privacy policies of specific products or services, or as required to comply with applicable laws. Specific retention periods may be found in the relevant service or product pages. After personal information has fulfilled its collection purpose, or after we confirm your deletion or account cancellation request, or after we terminate the corresponding product or service, we will cease retention and delete or anonymize the information. Where possible, we will indicate the retention period for the categories, types, or fields of personal information we have identified. In determining the retention period, we consider the following factors:

• The volume, nature, and sensitivity of the personal information

• The risk of harm from unauthorized use or disclosure

• The purposes for which we process personal information, and how long we need that specific information to achieve those purposes

• How long we need the personal information to remain as accurate and up‑to‑date as possible

• How long the personal information may be relevant to future legal claims

• Other applicable legal, accounting, reporting, or regulatory requirements that specify retention periods for certain records

Depending on your jurisdiction, there may be exceptions for personal information we process for public interest, scientific, historical research, or statistical purposes. If required by applicable law or your request, and to the extent necessary and permitted, Vision Function Training may continue to retain such information beyond its standard retention period, even if the further processing is unrelated to the original purpose of collection.

5. Your Rights

You have control over your personal information.

5.1 Control Settings

Vision Function Training understands that everyone's privacy concerns differ. Therefore, we provide examples of the various ways Vision Function Training offers you to choose how to limit the collection, use, disclosure, and processing of your personal information, and to control your privacy settings:

• Log in or log out of your Vision Function Training account.

If you have previously given consent for us to use your personal information for the purposes described above, you can change your decision by contacting us at info@simingtang.com.

5.2 Rights You Have Regarding Your Personal Information

Under the laws and regulations of your country or region, you have the right to request access to, correction of, or deletion of any personal information we hold about you (hereinafter "Request"). These rights are subject to specific exclusions and exceptions provided by applicable law.

For more details regarding the personal information in your Vision Function Training account, you can contact us at info@simingtang.com to make changes.

We will process your request effectively if the following conditions are met:

(1) The request is submitted through the dedicated request channel provided by Vision Function Training software, and for the protection of your information, your request should be made in writing (unless local law explicitly recognizes oral requests).

(2) You provide sufficient information to enable Vision Function Training software to verify your identity, ensuring that the requester is the data subject or a duly authorized person.

Once we have obtained sufficient information to confirm that we can process your request, we will respond to your request within the time limits set by applicable data protection laws.

Specifically:

• You have the right to receive clear, transparent, and easily understandable information about how we use your personal information and what rights you have. This is the purpose of this privacy policy.

• Upon your request and in accordance with applicable law, we may provide a record of the personal information we have collected and processed about you. We may charge a reasonable fee based on the relevant legal permissions and actual administrative costs.

• If you believe that any information we hold about you is incorrect or incomplete, you may request that we correct or supplement it for the purposes of use.

• Under applicable laws and regulations, when we no longer have grounds to continue using your personal information, you have the right to request that we delete your personal information. We will evaluate your deletion request and, if it meets the relevant requirements, take corresponding steps, including technical measures. Please note that due to applicable laws and security technology limitations, we may not be able to immediately delete the information from backup systems. In such cases, we will securely store your personal information and isolate it from any further processing until the backup can be cleared or anonymized.

• You have the right to object to certain types of processing, including processing for direct marketing purposes (including profiling), and, in certain circumstances, processing based on our legitimate interests (including profiling).

In particular, under the laws of certain jurisdictions:

• You have the right to request that we restrict the processing of your personal information. We will evaluate your restriction request. If it meets the requirements of the General Data Protection Regulation (GDPR), we will process your information in accordance with the specific circumstances of the regulation and will notify you before lifting the restriction.

• You have the right to object to automated decision‑making, including profiling, that produces legal effects or similarly significant effects on you.

• You have the right to request that your personal information be transferred in a structured, commonly used format to another data controller (data portability).

We have the right to refuse to process, or to only partially respond to, your request in cases of exemptions provided by applicable law, or where other rights granted to us by applicable law apply, such as where the request is manifestly unfounded or excessive, or where it would require disclosing third‑party information. In some cases, we may charge a fee as permitted by applicable law. If we believe that a deletion request would, in some respects, prevent us from lawfully using the information for establishing, exercising, or defending legal claims permitted by applicable law, the request may also be refused.

5.3 Withdrawing Consent

You may withdraw consent previously granted to us for specific purposes, including the collection, use, and/or disclosure of personal information we hold or control. Depending on the specific service you use, you may do so by contacting us at info@simingtang.com. We will process your request within a reasonable time after you make it, and in accordance with your request, we will no longer collect, use, and/or disclose your personal information thereafter.

Depending on the scope of your withdrawal, you may no longer be able to continue using Vision Function Training products or services. However, your decision to withdraw consent or authorization does not affect the validity of personal information processing activities carried out based on your consent prior to such withdrawal.

5.4 Cancelling Services or Account

If you wish to cancel a specific product or service, you may contact us at info@simingtang.com.

If you wish to cancel your Vision Function Training account, please be aware that this action will prevent you from using Vision Function Training products or services, so please proceed with caution. In certain specific cases, cancellation may be prevented or delayed.

When you authorize login to Vision Function Training through a third‑party account, you need to request account cancellation from that third party.

6. How Your Personal Information Is Transferred Globally

Vision Function Training processes and backs up personal information through global operations and control facilities. For the purposes described in this privacy policy, your information may be transferred to these data centers in accordance with applicable laws.

We may also transfer your personal information to third‑party service providers and business partners, so your information may also be transferred to other countries or regions. The jurisdictions in which these global facilities are located may not protect personal information to the same standard as your jurisdiction, and there may be different risks under different data protection laws. However, this does not change our commitment to complying with this privacy policy and protecting your personal information.

In particular,

• Personal information collected and generated during our operations within mainland China will be stored in data centers in mainland China, except where cross‑border transfer is permitted under applicable law.

• Personal information collected and generated during our operations in Russia will be processed and stored in data centers in Russia, except as permitted under Russian law.

• Personal information collected and generated during our operations in India will be stored in data centers in India.

If we need to transfer personal information outside your jurisdiction, whether to our affiliates or third‑party service providers, we will comply with all applicable laws. We implement uniform security safeguards to ensure that all such transfers meet local applicable data protection requirements. You have the right to contact us at info@simingtang.com to learn about the security safeguards we have in place.

7. Protection of Minors' Information

We believe that it is the responsibility of parents or guardians to supervise their children's use of our products or services. However, we do not directly provide services to children, nor do we use children's personal information for marketing purposes.

If you are a parent or guardian and you believe that a minor has submitted personal information to Vision Function Training, please contact us at info@simingtang.com to ensure that such personal information is promptly deleted.

8. Third‑Party Websites and Services

Our privacy policy does not apply to products or services provided by third parties. Depending on the Vision Function Training products or services you use, they may include third‑party products or services, covering voice support, camera processing, video playback, system cleaning and security‑related services, games, statistics, social, payment, map navigation, sharing, push, information filtering, input methods, and other types. Some of these will be provided in the form of links to third‑party websites, while others will be integrated as SDKs, APIs, etc. When you use these products or services, they may also collect your information. Therefore, we strongly encourage you to take the time to read the privacy policies of those third parties, just as you read ours. We are not responsible for, and cannot control, how third parties use the personal information they collect from you. Our privacy policy does not apply to other websites linked through our services.

Below are examples of third‑party terms and privacy policies that apply when you use the specific products or services mentioned above:

When using third‑party payment services to complete and pay for orders, the personal information you provide during payment will be processed in accordance with the privacy policies of the third‑party payment service providers.

• Partner: Alipay (Hangzhou) Information Technology Co., Ltd.

SDK Name: APP Payment Client SDK

Personal Information Collected: Device MAC address, unique device identifier, location information, application list, phone number, Wi‑Fi address

• Partner: Shenzhen Tencent Computer Systems Co., Ltd.

SDK Name: WeChat OpenSDK Android

Personal Information Collected: Device MAC address, unique device identifier, location information, application list

• Partner: Beijing Ruixun Lingtong Technology Co., Ltd.

SDK Name: Umeng SDK

Personal Information Collected: Device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI/ICCID/geolocation, etc.)

• Partner: Huiliangyun (Beijing) Technology Co., Ltd. / CloudMax Limited

SDK Name: Thermal Engine Harmony SDK

Personal Information Collected: Event time / login account / UA / device language / device time zone / manufacturer / OS version / screen height / screen width / device model / device name / device model identifier / network status / app version / app version code / package name / app name / channel name / browser / browser version / current page title / current page URL / previous page title / previous page URL / device unique ID / device current time / device boot time / advertising tracking enabled flag / ADServiceToken / device screen density / first installed app version / whether the app trial experience was released within the last 7 days.

Purpose: To understand the performance and usage of mobile applications across different terminal devices, platforms, or distribution channels; to optimize advertising strategies and anti‑fraud identification; to provide user profiling services; to conduct group analysis at the app installation level for targeted internet advertising and user ROI analysis; and to support A/B testing services.

9. How This Policy Is Updated

We will periodically review our privacy policy in accordance with business and technological changes, applicable laws, and good practices, and we may update this privacy policy. If we make material changes to this privacy policy, we will notify you through your registered contact information (such as email to the address associated with your account) or through Vision Function Training or mobile devices, so that you can learn about the information we collect and how we use it. Such privacy policy changes will take effect from the date of notification or as specified on the website. We recommend that you regularly check this page for the latest information on our privacy practices. Your continued use of products, websites, mobile, and/or any other devices will be deemed acceptance of the updated privacy policy. When we collect additional personal information from you, or when we use or disclose your personal information for new purposes, we will, in accordance with applicable legal requirements, obtain your consent again.

10. Contact Us

If you have any comments or questions about this privacy policy, or if you have any concerns about our collection, use, or disclosure of your personal information, please contact us by sending an email to info@simingtang.com. When we receive requests regarding your personal information rights, inquiries, etc., we have a professional team to resolve your issues. If your issue is of a significant nature, we may ask you to provide more information.

If you are not satisfied with the response you receive, you may refer the complaint to the relevant supervisory authority in your jurisdiction. If you consult us, we will provide information on possible complaint channels based on your actual circumstances.

If any handling of sensitive personal information is inconsistent with this privacy policy, or if you are dissatisfied, you must notify the designated complaint handler.

Contact number: 021-50120029; Office hours: Monday to Saturday, 9:00 AM – 6:00 PM

Email: info@simingtang.com

Thank you for taking the time to understand our privacy policy!