**Leitingzhiyan Privacy Policy**

**Special Reminder**
Before using our software and related services, please read the "Leitingzhiyan Privacy Policy" carefully to understand our rules for processing your personal information. If you have any questions during the reading process, you can contact us through the contact information at the end of the "Leitingzhiyan Privacy Policy" document. If you disagree with any terms of the agreement, you should immediately stop accessing Leitingzhiyan.

**Introduction**
The "Leitingzhiyan" app software service is developed and published by Fujian Chenfeng Network Technology Co., Ltd. (hereinafter referred to as "the company," "we"). We highly value user privacy and personal information protection. When you use our software and related services, we may collect and use your related information. Through this "Leitingzhiyan Privacy Policy," we aim to explain how we collect, use, store, share, and transfer this information when you use our software and related services, as well as the ways we provide for accessing, updating, deleting, and protecting this information.

**This Privacy Policy will help you understand the following:**
1. How we collect and use your personal information
2. How we use cookies and similar technologies
3. How we share, transfer, and publicly disclose your personal information
4. How we protect and store your personal information
5. Your rights regarding personal information
6. Protection of minors' information
7. Policy updates and notifications
8. How to contact us

**I. How We Collect and Use Your Personal Information**

Personal information refers to various types of information recorded electronically or through other means that can identify a specific natural person alone or in combination with other information, or reflect the activities of a specific natural person. Personal information involved in this privacy policy includes: basic information (including personal name, birth date, gender, address, personal phone number, email); personal identity information (including ID card, military officer card, passport, driver's license, etc.); personal image, voice and picture; online identity markers (including system account, IP address, email address and associated passwords, password protection answers); personal property information (transaction and consumption records, balance and other virtual property information); contact list; personal Internet records (including website browsing records, software usage records, click records); information on commonly used personal devices (including hardware model, device MAC address, operating system type, software list unique device identifiers such as IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information, etc.); and personal location information (including travel information, precise positioning information, accommodation information, latitude and longitude, etc.).

According to the principles of legality, properness, and necessity, we collect and use your personal information for implementing the functions mentioned in this policy: In the process of using "Leitingzhiyan" and its services, we will collect information based on the principles of legality, properness, and necessity. The information we collect or you provide will be used for:

1. Ensuring the normal basic operation of the product;
2. Implementing various functions and services;
3. Optimizing and improving products and services;
4. Ensuring the safety of products, services, and user use;
5. Complying with the provisions of laws, regulations, and national standards.


**(A) Personal Information You Provide Directly and Authorize Us to Collect**

1. **Commonly Used Device Information**
- Please be aware that we must collect basic information necessary for providing services and ensuring normal operation of the product, such as your device's hardware model, operating system version, International Mobile Equipment Identity (IMEI), network device hardware address (MAC), IP address, software version, network access method and type, operation log.

2. **Personal Registration, Login Information**
- When you register or log in, you can create a Leitingzhiyan account using your mobile number. We will send a text message verification code to confirm the validity of your identity.
- You may also log in using a third-party account (like WeChat). In this case, you authorize us to obtain your public information (avatar, nickname) registered on the third-party platform. After agreeing to this privacy policy, your third-party account will be linked to your Leitingzhiyan account, allowing you to log in and use our products and services directly through the third-party account.
- For a better service and experience, you may provide additional information according to your needs, such as avatar, nickname, gender, location, personal signature. However, not providing these will not affect the basic business functions of the service.
- When setting or changing a user avatar that requires the "photography" function, we will request your authorization for camera and album permissions. If you refuse to provide authorization, this feature cannot be used, but it will not affect the use of other basic functions of Leitingzhiyan.
- When you use the upload, publish pictures, and audio-video functions, we will request your authorization for camera, album, and microphone permissions. If you refuse to provide authorization, these functions cannot be used.
- When you post information and choose to display location, we will request your authorization for geographical location permissions and collect location information related to the service. If you refuse to provide precise geographical location information, you cannot use this feature, but it will not affect the use of other basic functions of Leitingzhiyan.
- When you post comments, ask questions, or answer, we will collect the information you publish and display your nickname, avatar, and published content.

**3. Other Personal Information You Actively Provide or Authorize Us to Collect**
- When participating in our marketing activities, you may provide your name, address, contact information, and bank account information as required by the activity. These might include sensitive personal information (like phone number, bank account) necessary for transfers or gifts. If you refuse to provide this information, we may not be able to transfer funds or provide gifts.
- When using the "invite friends" feature, you need to authorize Leitingzhiyan to access and read your contact list (including reading contact names). We will recommend the service to your contacts by sending messages. If you do not use this specific service, you do not need to authorize the provision of related information.
- Certain other personal information (such as your marital history, race, religion, etc.) may be considered sensitive. Be cautious when providing, uploading, or publishing content and information in our products and/or services (such as photos of your social activities) as it may reveal sensitive personal information.
- For personalized information services, we collect and use the following information:
1) Operations and usage behavior information related to your interests (such as videos you are interested in);
2) Feedback, posts, likes, comments you actively provide;
3) Geolocation information after obtaining your explicit consent.
- We will statistically analyze the above information and use algorithms for characteristic and preference analysis to provide you with personalized recommendations, display specific information of interest to you, or promote specific functions or services more suited to you.


**(B) Handling Changes in the Purposes of Collecting and Using Personal Information**

Please be aware that with the development of our business, there might be adjustments in the functions and services of "Leitingzhiyan." In principle, when new functions or services are related to the listed scenarios, the collection and use of personal information will have a direct or reasonable connection to the original processing purposes. In scenarios where there is no direct or reasonable connection to the original processing purposes, we will inform you again and obtain your consent for collecting and using your personal information.

**(C) Personal Information Collected and Used Without Consent Under Law**

Please understand that in the following circumstances, according to laws, regulations, and related national standards, we collect and use your personal information without needing your authorized consent:

1. Directly related to national security and public safety;
2. Directly related to crime investigation, prosecution, trial, and judgment execution;
3. Necessary for protecting the significant legal rights and interests of you or other individuals in situations difficult to obtain consent;
4. The personal information collected is disclosed by you to the public;
5. Collecting your personal information from legally publicly disclosed information, such as legal news reporting, government information disclosure channels;
6. Necessary for signing or fulfilling contracts as per your request;
7. Necessary for maintaining the safe and stable operation of our software and related services, such as discovering and handling software and service malfunctions;
8. Necessary for legal news reporting;
9. Necessary for academic research institutions conducting statistical or academic research in the public interest, and de-identifying personal information contained in the results when providing academic research or descriptions to the public;
10. Other situations stipulated by laws and regulations.

**II. How We Use Cookies and Similar Technologies**

Cookies and similar technologies are commonly used on the Internet. When you use "Leitingzhiyan" and related services, we might send one or more cookies or anonymous identifiers to your device to collect and store information about your visit and use of our product. We use cookies and similar technologies primarily for the following purposes:

(A) Ensuring the Secure and Efficient Operation of Products and Services
- We may set authentication cookies or anonymous identifiers to ensure you are securely logged in to our services and to detect and prevent illegal activities like fraud.

(B) Helping You Obtain a More Convenient Access Experience
- These technologies can save you the trouble of repeatedly entering personal information or searching (e.g., recording search history).

(C) Recommending, Displaying, and Pushing Content or Accounts That May Interest You
- We may use cookies and similar technologies to understand your preferences and usage habits, conduct consultations or data analysis to improve our products and services, and optimize your choices regarding advertisements.

(D) Providing You with Interactive Services
- When you use Leitingzhiyan products or services, cookies are sent to your device. When you interact with services provided to our partners (e.g., advertising and/or promotional services, services provided by Leitingzhiyan displayed on other websites), we allow cookies or anonymous identifiers to be sent to Leitingzhiyan's servers.


(E) Clearing Cookies
- Most browsers offer the function to clear browser cache data. You can perform such data clearing operations in your browser settings. If you choose to clear, you might be unable to use services or features dependent on cookies provided by us.

We promise not to use cookies for any purposes other than those described in this privacy policy. You can choose to refuse cookies by modifying your browser settings, but this may prevent you from logging in or using services or features provided by Leitingzhiyan that rely on cookies.

If you do not wish to receive personalized promotional information based on cookies when visiting Leitingzhiyan or affiliated websites, you can restrict the use of cookies by Leitingzhiyan through personalized settings.


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

(A) Sharing
- We do not share your personal information with any company, organization, or individuals outside of Leitingzhiyan, except in the following cases:
1) Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
2) Sharing under legal requirements: We may share your personal information externally according to legal regulations or mandatory government requirements.
3) Sharing for providing specific functions or services: To ensure the consistency of services provided to you within our products and affiliated services, and to facilitate unified management of your information, we will share your de-identified personal information with these affiliates.
4) Helping you use Leitingzhiyan account to log into third-party products: With your consent, we will share your nickname, avatar, and ID information with the third-party product you log into.
5) For programmatic advertising: We might share de-identified or anonymized information with advertising partners. We do not share information that identifies you personally, such as your name or ID number, but provide user portrait tags and de-identified or anonymized information to help them improve advertising effectiveness without identifying you personally.

- Sharing to help you participate in marketing activities: When you choose to participate in marketing activities we organize, you provide information like name, communication address, contact information, and bank account details. With your explicit consent, we will share this information with third parties to ensure timely delivery of prizes to you.
- Careful assessment and responsibility constraints on third-party entities sharing personal information: We will only share the necessary information with third parties with your consent. If the third party needs to use personal information beyond the scope of authorization for business needs, they must seek your consent again.

(B) Transfer
- We will not transfer your personal information to any company, organization, or individual, except under the following circumstances:
1) With your explicit consent or authorization;
2) Required by applicable laws, legal processes, or mandatory administrative or judicial demands;
3) As stipulated in related agreements signed with you (including electronic agreements and corresponding platform rules) or other legal documents;
4) In transactions involving mergers, acquisitions, asset transfers, or similar, if personal information transfer is involved, we will require the new entity holding your personal information to continue to be subject to this privacy policy or seek your authorization again.

(C) Public Disclosure
- We will only publicly disclose your personal information in the following circumstances:
1) With your explicit consent;
2) Legal disclosure: We might publicly disclose your personal information under legal, legal procedure, litigation, or mandatory government authority requirements.

(D) Exceptions in Sharing, Transferring, or Publicly Disclosing Personal Information:
- In the following circumstances, sharing, transferring, and publicly disclosing your personal information by the Leitingzhiyan software and related services does not require your prior authorization or consent:
1. Related to national security or defense security;
2. Related to public safety, public health, or major public interests;
3. Related to criminal investigations, prosecutions, trials, and judgments;
4. Necessary to protect the significant lawful rights and interests of personal information subjects or other individuals in situations difficult to obtain consent;
5. When the personal information subject publicly discloses personal information;
6. Collecting personal information from legally publicly disclosed sources, such as legal news reports, government information disclosure, etc.


**IV. How We Protect and Save Your Personal Information**

(A) Storage of User Personal Information
- **Storage Location:** In accordance with legal and regulatory requirements, we store your personal information within the territory of the People's Republic of China. Currently, we do not store your personal information across borders or provide it to entities outside.
- **Storage Duration:** Unless required by laws and regulations or agreed upon by both parties, we will only retain your relevant personal information for the minimum time necessary to achieve the purposes. We will delete your personal information as soon as possible after you actively cancel your account.

(B) Security Measures for User Personal Information
- We highly prioritize the security of your personal information and take all reasonably practicable measures to minimize the risk of your information being disclosed, damaged, misused, accessed without authorization, disclosed without authorization, altered, or lost:
1. Data Security Measures: We adopt security measures that meet industry standards, including establishing reasonable system specifications and security technologies to protect your personal information.
2. Other Security Measures: We have established a comprehensive information confidentiality system for managing and standardizing the storage and use of personal information.

3. Security Event Handling: We have established a comprehensive personal information security incident emergency response mechanism to further ensure your information security.

**V. Your Rights to Personal Information**
- You have the right to access, correct, delete, and withdraw consent to your personal information. We provide clear channels for you to exercise these rights.

**VI. Protection of Minors' Information**
- We take extra precautions to protect the personal information of minors. If a minor's personal information is collected with parental consent, we only use or disclose this information as permitted by law, explicitly consented to by the guardian, or necessary to protect the minor.

**VII. Updates and Notifications**
- This policy may be updated. We will notify you of significant changes and provide the updated policy in an accessible manner.

**VIII. How to Contact Us**
- For any questions, feedback, or concerns about this policy or your personal information, please contact us through the provided channels.