Sky Brid CAM Privacy Policy

Preface

This product is a hardware and software integrated product provided by Dongguan Zhihuitianfeng Technology Co., Ltd. (hereinafter referred to as "we", "us" or "the Company"). The smart hardware devices include but are not limited to the smart hardware devices of this product (hereinafter referred to as "Cameras") and smart doorbell hardware devices (hereinafter referred to as "Doorbells"). After binding with the mobile client application "Sky Bird CAM" (hereinafter referred to as the "APP"), you may control the smart hardware devices through the APP and view real-time captured and historical recorded videos of the smart hardware devices on the APP. Meanwhile, we also provide image and video event alerts, sound event alerts, and two-way audio intercom functions via the APP. Thank you very much for your trust in us. We fully recognize the importance of personal information to users and understand that effective protection of users' personal information is the cornerstone of the sustainable and healthy development of our business. Thank you for your use of and trust in our products and services! We deeply appreciate this hard-earned trust and will adopt corresponding security protection measures in accordance with industry-leading security standards to safeguard your personal information and consolidate this trust.

This Privacy Policy is designed to help you understand the following contents:

1. How we collect and use your personal information

2. How we store your personal information

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

4. How we protect your personal information

5. How we use Cookies and similar technologies

6. Your rights to manage personal information

7. Protection of minors' personal information

8. Scope of application of this Privacy Policy

9. Amendment and revision of this Privacy Policy

10. How to contact us

11. Entry into force of this Privacy Policy

Through this Privacy Policy, we aim to explain how we collect, use, store, share and transfer your personal information and smart hardware device information when you use the APP to manage and control smart hardware devices, as well as the ways for you to access, update, delete and protect such information. Please carefully read and fully understand this Privacy Policy before using the APP, and start using our products or services only after full understanding and consent. Your continued use of the products and services of this product shall constitute your full understanding and acceptance of this Policy, as well as your consent to our collection, use, storage and sharing of your relevant information in accordance with this Privacy Policy. If you have any questions, comments or suggestions regarding the content of this Policy, you may contact us through the contact methods specified in this Privacy Policy.

I. How We Collect and Use Your Personal Information

Purposes

In compliance with laws and regulations, we adhere to the principles of legality, legitimacy, necessity and integrity, and collect and use your personal information solely for the purpose of providing the functions and services of the 【Sky Bird CAM】 product you choose to use.

Please note:

Due to differences in technical implementation (different mobile operating systems), the scope or collection methods of personal information involved in different application forms may vary. If the actual software form or functions you use are inconsistent with the description herein, the actual usage shall prevail.

We will collect and use your personal information in accordance with this Privacy Policy, including your sensitive information such as facial recognition features of you and your family, voiceprint information, location information, and purchase and consumption records of this product. Please refer to the functional descriptions below for the purposes and usage of collecting and using such sensitive information. Once leaked, illegally provided or misused, personal sensitive information may endanger personal and property safety and easily cause damage to personal reputation and physical and mental health. Therefore, we will adopt compliant technologies to encrypt and store sensitive information that you explicitly consent to and actively provide, so as to protect the security of your personal information.

We do not indirectly obtain your personal information through other channels such as sharing, transferring or collecting public information. Should we need to indirectly obtain your personal information through other channels in the future, we will only collect the minimum information necessary to realize the business functions of our products and services, and clearly inform you and obtain your explicit consent before collection and use. Meanwhile, we will ensure the legality of information sources before collecting information, and verify the scope of authorized consent for personal information processing obtained from information providers, including usage purposes, authorized transfer, sharing and public disclosure. If our personal information processing activities carried out for business needs exceed the scope of the aforesaid authorized consent, we will obtain your explicit consent within a reasonable period after obtaining the personal information or before processing it.

The detailed purposes and usage of our collection and use of your information are as follows:

(I) Core Functions of This Product

Core functions refer to the basic functions that support the normal operation and service provision of the APP. If you refuse to provide the personal information necessary for us to deliver services, you will not be able to use this product.

1. Information Collected for Account Registration

After installing the APP of this product on your mobile phone, you need to register or log in to our account to use it. When registering an account, you are required to provide your mobile phone number, set an account password, or use one-click login for registration and login. Based on our cooperation with communication operators, when you use the "one-click login" function, with your explicit consent, the operator will send your mobile phone number to us to facilitate quick login services. Refusal to provide a mobile phone number will prevent you from using the one-click login method for account registration and login, but will not affect registration and login via other methods or the normal use of other functions. You may modify your avatar, nickname and password via "Mine -> Edit Personal Information".

Upon account cancellation, we will stop using and delete the aforesaid information or anonymize your personal information, unless otherwise required by laws and regulations.

2. Binding Smart Hardware Devices

After logging in to the APP, you may connect and bind the APP to smart hardware devices through acoustic wave induction. To complete device binding, we need to obtain your location information (for acquiring WiFi lists), WiFi network information, power-on/off and network connection status of smart hardware devices and mobile phones, smart hardware device models, mobile phone operators, mobile operating systems and versions, mobile phone models, and mobile local storage space. The above information will be uploaded to our company's servers to prevent unauthorized access and management of smart hardware devices by non-users and better protect your information security. You may unbind smart hardware devices and delete all your personal information associated with the devices via "Settings -> Unbind and Delete This Camera" or "Settings -> Unbind and Delete This Doorbell".

After binding smart hardware devices, you can view real-time video feeds and historical recorded videos captured by the devices through the APP. You may also save videos locally or share them with friends via third-party applications. When sharing videos to third-party applications, we will not obtain any information about your third-party applications (including relevant account information). When your mobile phone is connected to WiFi, logged in to the APP, and you have purchased cloud storage services or inserted a memory card into your mobile phone, you may view and manage historical video recordings captured by smart hardware devices via "Cloud Storage" and "TF Card Recording" in the APP. When using cloud storage services, with smart hardware devices powered on and connected to WiFi, all videos captured by the devices will be encrypted and uploaded to our company's servers for cross-device synchronization and file protection; such video files will only be retained for 7 days. If you use TF card recording services, videos captured by smart hardware devices will only be stored locally on your device and will not be uploaded to our servers.

Please note that videos captured by smart hardware devices may record facial features of you, your family members or third parties. To protect the privacy rights and interests of all parties, please read and understand the Disclaimer of This Product via "Mine -> General Settings -> About" during installation, use and management of smart hardware devices through the APP, so as to fully understand the rights, obligations and liabilities of both parties. Videos captured by smart hardware devices are critical privacy information for you and your family. Any uploaded videos will be strictly encrypted and stored on our servers, and will not be used for other purposes or shared with third parties.

3. Controlling Smart Hardware Devices

After binding smart hardware devices, you may control camera functions via "Camera -> Settings" in the APP, including camera naming, real-time preview, alarm activation, message push and album management. You may also control doorbell functions via "System Settings", including adjusting monitoring ranges, enabling stay alerts and forced removal alerts, and receiving doorbell-related push notifications. The information you set and provide will be uploaded to our servers as control commands to realize remote management of smart hardware devices.

4. Message Center Function

When the camera is powered on, this function supports playback of full-day camera videos for the past month. You may configure message center functions via "Mine -> Camera Settings -> Motion Detection Alarm", including detection time periods, sensitivity and message types. Meanwhile, you may set message notification methods via "Mine -> Motion Detection Alarm -> Notification Methods". To receive timely alerts, you need to enable system notification permissions and allow background operation on your mobile device. Your configuration information and relevant data will be uploaded to our servers to send control commands to the camera. Disabling this function will terminate alarm services and message reminders, without affecting the use of other APP functions.

Special Reminder

In accordance with Article 214-1 of the Criminal Law of the People's Republic of China and Article 1032 of the Civil Code of the People's Republic of China, we warmly remind you:

It is strictly prohibited to install any form of audio or video recording equipment in private spaces such as hotel rooms, changing rooms, bathrooms and bedrooms.

Acts of secretly photographing or peeping into others' privacy may constitute the crime of infringing upon citizens' personal information or the crime of illegal use of wiretapping and photographing special equipment, with a maximum criminal penalty of seven years of fixed-term imprisonment.

(II) Additional Functions of This Product

Additional functions refer to optional services excluding core functions and third-party functions, which require your voluntary activation. We will not collect your personal information for unactivated additional functions. You may disable additional functions via the specified paths below; disabling such functions will terminate our collection and use of corresponding personal information and will not affect the core functions of the APP.

1. Screenshot and Video Recording

This function allows you to take screenshots and record clips while viewing camera videos. You may view captured screenshots and recordings in "Mine -> Album". Screenshots and recorded clips will be uploaded to our servers for cross-device synchronization and will not be used for other purposes or shared with third parties.

2. Human Body Detection

We conduct facial feature recognition on footage captured by smart hardware devices to provide stranger movement alerts and protect family safety. You may view a list of individuals captured by smart hardware devices (especially doorbells) and related recordings from the past two days. You may also label frequent visitors such as family members and friends to enhance stranger movement monitoring accuracy.

3. Smart Hardware Device Sharing

You may invite friends to share smart hardware devices via shared QR codes. We will not obtain any of your account information when you share device QR codes with others.

Invited contacts can only view real-time device footage and all alarm records. You may manage shared family member lists via "Settings -> Device Sharing".

4. Cloud Storage Purchase

Cloud storage enables you to view and save historical videos captured by smart hardware devices at any time via the APP. To use this service, you need to purchase cloud storage packages. When purchasing and paying for cloud storage services via third-party payment channels (WeChat Pay, Alipay), we only collect information about your purchased package type, selected smart hardware device and payment status to provide corresponding cloud storage services. We will not obtain any information related to your third-party payment accounts.

(III) Third-Party Functions of This Product

Third-party functions refer to services provided by independent third-party software and service providers. We will only share necessary user data with third parties for legitimate, proper, necessary, specific and clear purposes and with your explicit authorization and consent to deliver relevant services. We ensure that third parties will not use shared information for unauthorized purposes. When you activate third-party functions and services, you need to provide personal information as required by third parties, which will be directly uploaded to third-party servers. We will not obtain or share any personal information with third parties. Before using third-party products, please carefully read their relevant agreements and privacy policies and abide by their service terms during use.

(IV) Mobile Device Permission Access

In the provision of services, the APP will request access to certain mobile device permissions. The corresponding business functions, access purposes and pop-up reminder settings for each permission are detailed below. You may disable partial or all permissions in your device settings to refuse the collection of corresponding personal information. Permission display and disabling methods may vary by device brand and system; please refer to the official guidelines of your device manufacturer for specific operations. Please note that enabling any permission constitutes your authorization for us to collect and use relevant personal information to provide corresponding services, while disabling any permission revokes such authorization and terminates our corresponding data processing and service provision. Disabling permissions will not affect data collection and processing conducted under your prior authorization.

- Permission: Phone Permission

Corresponding Function: Core Function

Access Purpose: Risk control and operational security assurance

Pop-up Reminder: Yes

Disabled by User: Yes

- Permission: Location Permission

Corresponding Function: Core Function

Access Purpose: Obtain local WiFi network lists to complete smart hardware device WiFi connection configuration

Pop-up Reminder: Yes

Disabled by User: Yes

- Permission: Storage Permission

Corresponding Function: Core Function

Access Purpose: Local storage of videos and images captured by smart hardware devices

Pop-up Reminder: Yes

Disabled by User: Yes

- Permission: Camera Permission

Corresponding Function: Additional Function

Access Purpose: Scan QR codes for smart hardware device addition and sharing

Pop-up Reminder: Yes

Disabled by User: Yes

- Permission: Microphone Permission

Corresponding Function: Additional Function

Access Purpose: Two-way audio intercom

Pop-up Reminder: Yes

Disabled by User: Yes

(V) Product and Service Optimization

To continuously improve our products, resolve and reduce application crashes, and deliver optimized functional services, we collect the following information about your mobile devices and bound smart hardware devices through public system interfaces: International Mobile Equipment Identity (IMEI), Media Access Control (MAC) address, mobile operator, mobile phone model, system version, system serial number, system ID, screen resolution, network access type, installed APP names, versions, package names, provincial and urban location data, APP usage duration and frequency, and crash logs. Such data is used for user statistics, product usage analysis, crash troubleshooting and functional optimization, and does not involve personally identifiable information.

(VI) Security Assurance

To enhance the security of your use of products and services provided by us, our affiliates and partners, protect personal and property safety, and prevent phishing, fraud, network vulnerabilities, computer viruses, cyber attacks and unauthorized intrusion, we may integrate account information, smart hardware data, APP usage records and authorized information shared by affiliates and partners for identity verification, security threat detection and response, and take documented audit, analysis and disposal measures in accordance with laws and regulations.

(VII) Exceptions to Authorization and Consent

In accordance with applicable laws and regulations, collection of personal information without your authorization and consent is permitted under the following circumstances:

1. Related to national security and national defense security;

2. Related to public safety, public health and major public interests;

3. Required for criminal investigation, prosecution, trial and judicial proceedings;

4. Necessary to safeguard the legitimate life, property and other major rights and interests of you or other individuals where obtaining personal consent is difficult;

5. Personal information voluntarily disclosed to the public by you;

6. Personal information collected from legally disclosed public channels such as official news reports and government announcements;

7. Necessary for contract performance at your request;

8. Essential to maintain the stable and secure operation of provided products and services, such as equipment failure detection and troubleshooting;

9. Required for legitimate news reporting;

10. Statistical and academic research conducted by research institutions for public interest with processed and de-identified research results;

11. Other circumstances stipulated by laws and regulations.

(VIII) Clipboard Access

Usage Purpose: We need to access your clipboard to read shared passwords, invitation codes and links for information sharing, event participation and function linkage such as page redirection.

Special Note: Mobile system clipboard access prompts cannot distinguish legitimate data reading from false alarms. If you receive abnormal clipboard access reminders, please contact us for problem investigation and resolution.

(IX) Gravity Sensor Access

Usage Purpose: The gravity sensor is used to detect mobile phone rotation status, enabling automatic vertical-to-horizontal screen switching during real-time video viewing, local playback and cloud storage playback.

(X) Self-Startup and Associated Startup Instructions

1. To ensure timely push message reception and custom ringtone playback when the APP is closed or running in the background, the APP requires self-startup permission and may wake up periodically through system broadcasts to ensure core service availability, which is functionally necessary.

2. Redirection to third-party applications via push message content will only be performed with your explicit consent; no unauthorized self-startup will occur without consent.

3. Opening files downloaded within the APP may trigger associated startup of third-party applications.

Personal Information Collection List

- Account Registration & Login

Collected Information: Registration region, mobile phone number, email address, verification code, account password

Usage Purpose: Account creation, login identity verification and password retrieval

- Personal Profile

Collected Information: Avatar, nickname, account ID

Usage Purpose: Online identity improvement, community interaction including likes and comments

- Device Binding & Network Connection

Collected Information: Account ID, device name, device model, device MAC address, device UID, network information of connected devices (IP address, WiFi MAC address, WiFi SSID, WiFi password, signal strength), Bluetooth MAC address

Usage Purpose: Secure connection, management and normal use of smart devices

- Smart Device Information Viewing

Collected Information: Device UID, device name, time zone, local network information, indicator status, TF card status, SIM card status

Usage Purpose: Real-time and basic information query of smart devices

- Smart Device Configuration

Collected Information: Indicator settings, TF card recording settings, fill light settings, motion detection configurations, video parameters, operation mode settings, audio modes, device restart commands, network settings, volume adjustment, PTZ control, two-way intercom and display settings

Usage Purpose: Remote configuration and functional management of smart hardware devices

- Smart Device Real-Time Monitoring

Collected Information: Audio switch status, real-time video data with timestamps, device power level, signal strength

Usage Purpose: Real-time video monitoring and device status viewing

- Order Records

Collected Information: Order details, payment records

Usage Purpose: Cloud storage service transaction recording and order management

- Two-Way Audio Intercom

Collected Information: Voice audio data

Usage Purpose: Real-time voice communication with smart hardware devices

- Device Recording & Playback

Collected Information: Video files, recording timestamps, alarm event types

Usage Purpose: Video storage and historical playback

- Device Sharing

Collected Information: Shared account data, device access permissions

Usage Purpose: Cross-user shared management and access control of smart devices

- Monitoring Management

Collected Information: Video content, event logs, alarm types, detection area and time settings, detection sensitivity

Usage Purpose: Intelligent video analysis and event recording based on user configurations

- Motion Detection & AI Intelligent Recognition

Collected Information: Alarm video footage, AI event recognition results

Usage Purpose: Stranger alert identification, event tagging and AI model training

- Phone Alarm Notification

Collected Information: Phone numbers, scheduled reminder time, device information

Usage Purpose: Voice call alerts triggered by abnormal events

- 4G Data Service

Collected Information: Data card ICCID, order information, payment records

Usage Purpose: 4G data traffic service activation and management

- Help Center, User Feedback & Online Customer Service

Collected Information: Device information, problem descriptions, account data, device configuration status, operation logs

Usage Purpose: Product defect analysis, service improvement and user experience optimization

Other Rules for Personal Information Usage

1. To improve products and services, we may invite you to participate in customer surveys and promotional activities via in-app notifications, SMS, emails or phone calls.

2. After collection, personal information will be processed through technical anonymization. Anonymized data that cannot identify individual users may be independently analyzed and commercially utilized by us without additional user consent.

II. How We Store Your Personal Information

All personal information collected and generated within the territory of the People's Republic of China will be stored domestically without cross-border transmission. Should cross-border data transmission be required in the future, we will comply with national laws, administrative regulations and regulatory requirements, and obtain your additional explicit consent before overseas data transmission. We will disclose the storage location and usage of cross-border data in detail in this Privacy Policy and adopt encryption and anonymization technologies to ensure data security during transmission.

We only store your personal information for the shortest period necessary to fulfill the stated purposes and as required by laws and regulations. The retention period of cloud storage videos on our servers is subject to the validity period of your purchased cloud storage packages; videos will no longer be stored on servers upon cloud storage service expiration. If you stop using the APP or unbind smart hardware devices, we will immediately suspend personal information collection, anonymize your existing personal data and permanently delete all relevant information within 3 years. Any personal information exceeding the statutory retention period of 3 years will be directly deleted or anonymized.

In the event of product or service suspension, we will promptly terminate personal information collection, notify users via individual notifications or public announcements, and delete or anonymize all stored personal information.

III. How We Share, Transfer, Suspend Accounts and Publicly Disclose Your Personal Information

(I) Information Sharing

We will not share your personal information with any third-party companies, organizations or individuals, except under the following circumstances:

1. Sharing with your explicit consent;

2. Sharing required by laws and regulations, judicial proceedings or administrative law enforcement requests;

3. Sharing necessary information to prevent threats to personal and property safety and safeguard the legitimate interests of us, our affiliates, partners and the public within the scope permitted by law;

4. Intra-group sharing with affiliated companies to deliver integrated services; only necessary personal information will be shared, and affiliates shall be bound by this Privacy Policy. Any change of personal information processing purposes by affiliates will require your re-authorization and consent;

5. Limited sharing with qualified suppliers, service providers, consultants and partners for legitimate and necessary business purposes including technical operation, data analysis, advertising effect evaluation, customer service, payment processing and professional consulting. Only aggregated, anonymized or non-identifiable data may be shared for industry statistical analysis.

We sign strict data protection agreements with all third-party recipients to bind them to process shared information in compliance with this Privacy Policy and confidential protection requirements.

(II) Information Transfer

We will not transfer your personal information to any third-party companies, organizations or individuals, except under the following circumstances:

1. In the event of corporate merger, acquisition, asset transfer or similar business transactions involving personal information transfer, the new data controller will be required to comply with this Privacy Policy; re-authorization will be requested if the new controller intends to change data processing rules;

2. Transfer required by laws, legal procedures or mandatory government orders;

3. Information transfer conducted with your explicit consent.

(III) Information Disclosure

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

1. Public disclosure with your explicit consent;

2. Mandatory disclosure required by laws, judicial proceedings or government regulatory authorities;

3. Necessary public disclosure to safeguard legitimate public interests and property safety within the scope permitted by law;

4. Other disclosure circumstances stipulated by laws and regulations.

Data sharing, transfer and public disclosure of de-identified personal information that cannot be restored for individual identification will not require separate user notification and consent in accordance with legal provisions.

(IV) Account Suspension

Accounts will be permanently suspended for serious violations including illegal content publication, fraud, malicious marketing and bulk account registration.

Official suspension notice: "We regret to inform you that your account has been permanently restricted due to violations of cybersecurity regulations and platform security requirements. Please strictly abide by national laws and regulations and use network services in a civilized manner. Thank you for your understanding and cooperation."

Suspended accounts cannot log in through conventional channels and are non-revocable.

IV. How We Protect Your Personal Information

We adopt industry-standard security protection measures to prevent unauthorized access, disclosure, modification, damage and loss of your personal information, and implement all reasonable and feasible safeguards for data security.

We attach great importance to personal information protection and have obtained national and international security certifications, including the Class III Cybersecurity Grade Protection Certification issued by national public security authorities and ISO 27001 Information Security Management System Certification.

We adopt encrypted transmission and storage technologies for personally identifiable information. Device identifiers such as IMEI and MAC addresses are anonymized and encrypted via the MD5 algorithm on mobile terminals before upload. We conduct real-time risk control through login time, IP address and login frequency monitoring, and send SMS alerts for abnormal login activities to prevent unauthorized account access. All data transmission between mobile terminals and our servers adopts customized encryption solutions combined with HTTPS dual encryption protocols to ensure transmission security.

For applications adopting WebView technology, strict URL verification and private data access restrictions are implemented for all file protocol requests to prevent unauthorized leakage of local private files and sensitive data.

Access control mechanisms are deployed on server terminals, with minimum privilege authorization for internal staff involved in data management and regular access log audits. Servers run on security-hardened operating systems with comprehensive account auditing and real-time security monitoring; emergency security upgrades will be implemented promptly upon system vulnerability detection.

Regular personal information protection and legal compliance training are provided for internal employees to strengthen privacy protection awareness.

In the event of security protection failure, we will activate emergency response plans in a timely manner to contain risk expansion, report incidents to competent authorities in accordance with legal requirements, and notify users of incident details, potential impacts and remedial measures via official announcements and in-app notifications.

V. How We Use Cookies and Similar Technologies

The Sky Bird CAM APP does not currently use Cookies or similar tracking technologies.

VI. Your Rights to Manage Personal Information

During your use of the APP, you may access, modify and manage your personal information through the following methods:

(I) Access and Correction of Personal Information

You may modify your account information and submitted personal data including account passwords, nicknames and avatars via "Mine -> Edit Personal Information".

(II) Deletion of Personal Information

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

1. Personal information collected without your explicit consent;

2. Personal information processing in violation of laws and regulations;

3. Improper personal information usage in breach of our service agreements;

4. Account cancellation, application uninstallation or discontinued product and service use;

5. Permanent termination of our service provision.

You may submit a deletion request via the contact methods specified in Section IX of this Privacy Policy, and we will respond within 15 working days. Server-side personal data will be permanently deleted upon request; backup system data will be deleted gradually during regular backup updates.

(III) Account Cancellation

You may cancel your account at any time via "Mine -> Account & Security". Please note that account cancellation is irreversible; cancelled accounts cannot be restored, and all related account information will be cleared, resulting in permanent loss of APP functional access. Upon cancellation, we will stop all personal information processing and delete or anonymize your account data within 10 working days, except for data required for legal retention.

Cancellation Process: Log in to the account – Home Page – Mine – Account & Security – Cancel Account

Special Reminder: Account cancellation for Sky Bird CAM is irreversible. Please exercise caution before submitting a cancellation application. You may terminate the cancellation process at any time by logging in to your pending cancellation account and selecting "Resume Login". No recovery is available once cancellation is completed, and you may only reuse our services through new account registration.

(IV) Revocation of Consent and Authorization

You may revoke authorized permissions at any time through the following methods:

1. Disable corresponding system permissions via mobile device settings: Settings -> Permission Management; or disable in-app permissions via "Mine -> System Permissions";

2. Disable optional functions or unbind smart hardware devices through the function closing paths specified in Section I of this Privacy Policy to revoke corresponding service authorization.

Please note that core service functions require basic personal information support. Revoking authorization for specific services will terminate our corresponding data processing and service provision, but will not affect data processing conducted under prior valid authorization.

VII. Protection of Minors' Personal Information

Minors must obtain guardian consent and authorization before using our products and services. We recommend guardians to guide minors in reading this Privacy Policy and advise minors to consult guardians before submitting personal information. If you are a minor guardian and have questions about minor personal information processing, please contact us through the specified channels.

VIII. Scope of Application of This Privacy Policy

This Privacy Policy applies exclusively to this product. Our other products and services are governed by independent privacy policies. This Privacy Policy does not apply to:

1. Third-party data collection in embedded third-party products and services;

2. Personal information collected by independent third-party services, SDKs and advertising platforms integrated within our APP.

We remind you to carefully read the privacy policies of third-party services before use and properly protect your personal information when interacting with third-party platforms.

IX. Amendment and Revision of This Privacy Policy

We reserve the right to update and revise this Privacy Policy as needed. We will not arbitrarily restrict your legitimate rights under this Privacy Policy without your explicit consent. Major policy revisions will be notified prominently via in-app pop-up reminders during APP upgrades and user re-login. Major changes include but are not limited to:

1. Fundamental adjustments to service models, including changes to personal information processing purposes and data types;

2. Ownership and control changes caused by corporate mergers and restructuring;

3. Major adjustments to third-party information sharing and disclosure scope;

4. Changes to user rights and remedy mechanisms for personal information management;

5. Adjustments to personal information security management departments and complaint channels;

6. High-risk adjustments identified through privacy impact assessments.

X. How to Contact Us

If you have any questions, comments, suggestions or complaints regarding this Privacy Policy and our personal information processing activities, please contact us through the following methods:

- Contact Phone: 0086 188 1682 7503

- Email: sales@skyphoenixs.com

We will respond to all valid inquiries within 15 working days under normal circumstances.

XI. Entry into Force of This Privacy Policy

This Privacy Policy is updated on April 28, 2026, and shall come into force on December 15, 2025.

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Appendix 1: Glossary of Terms

1. Personal Information: Refers to various electronic or other recorded information that can individually or in combination identify natural person identities or reflect personal activities, including basic personal data, identity documents, biometric information, property information, network account data, location tracking information, internet browsing records and mobile device unique identifiers.

2. Sensitive Personal Information: Refers to high-risk personal information that may endanger personal and property safety and cause personal rights infringement upon leakage or abuse, including biometric data, identity documents, property information, communication records and precise location information.

3. De-identification: Technical processing of personal information to prevent individual identification without additional auxiliary data.

4. Anonymization: Irreversible technical processing of personal information to completely eliminate individual identifiability.

5. Personal Information Deletion: Permanent removal of personal data from operational systems to make data irretrievable.

6. Minor: Individuals under the age of 14.

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Appendix 2: Third-Party SDK Partners and Information Sharing Statement

To ensure functional realization and stable operation of this product, we integrate third-party Software Development Kits (SDKs). All third-party SDKs undergo strict security audits to protect user data privacy. Detailed information of integrated third-party SDKs is listed below; we recommend you to review the official privacy policies of third-party service providers.

Partner Type: Third-party Payment Service Partner

Partner Name: Alipay Open Platform

Cooperation Purpose: To provide third-party payment services

Cooperation Method: Embedding third-party SDK

Shared Personal Information Fields: None

Partner Type: Social Service Partner, Third-party Payment Service Partner

Partner Name: WeChat Open Platform

Cooperation Purpose: To provide third-party login and sharing services as well as third-party payment services

Cooperation Method: Embedding third-party SDK

Shared Personal Information Fields: None