Privacy Agreement

1. Company and Contact Information

Legal Entity: Xuzhou Jiexiaokui Network Technology Co., Ltd

Office Address: No. 1-127 Fuda Road, Zhangzhai Town, Pei County, Xuzhou, 221000, CN

Website: https://jiexiaokui.com

Business Support: support@jiexiaokui.com

Key Account Contact: yuhualong@jiexiaokui.com

2. Scope of Services Covered

This policy covers our network technology development, technical consulting, technical services, digital content production services (excluding publishing and distribution), internet sales operations (excluding goods requiring licenses), wholesale and retail operations for daily necessities and related categories, self-media content operations, market marketing planning, enterprise management consulting, graphic design, advertising design, and advertising agency services.

It also covers mobile management applications published to app marketplaces, including tools used for workflow management, reporting, campaign operation, and business collaboration.

3. Data We Collect

We may collect the following categories of data depending on product features and local law requirements:

1. Account and identity data: email, profile name, account identifier, authentication token.

2. Device and technical data: device model, operating system, app version, language, time zone, IP address, mobile advertising identifiers, network type, crash logs, diagnostics.

3. Usage and interaction data: feature usage, event logs, in-app navigation, ad interaction events, performance metrics.

4. Business and communication data: support tickets, contact form content, commercial correspondence.

5. Commerce and operational data: order references, non-sensitive transaction metadata, category interaction trends.

6. Security data: anti-fraud signals, abnormal login or abuse detection indicators.

4. Purposes of Processing

We process personal data to provide, maintain, and improve services; support account management; secure platforms; communicate service notices; perform analytics; comply with legal obligations; manage advertising monetization where permitted; and respond to user requests.

5. Legal Bases by Region

Where required, we rely on one or more legal bases: consent, contract necessity, legitimate interests, legal obligation, and protection of vital interests.

For EEA and UK users, processing aligns with GDPR and UK GDPR legal basis requirements.

For US users, we follow applicable state privacy laws and sectoral rules; no sale of personal information is performed in violation of law.

6. App Marketplace Compliance Mapping

Google Play: Data safety declarations, prominent disclosure and consent when required, age and family policy alignment, ad ID disclosures, user data deletion request handling.

Apple App Store: App Privacy nutrition labels, ATT permission flow for tracking where applicable, child-directed disclosure controls, account deletion support where required by platform rules.

Other App Stores: Equivalent user disclosure, lawful basis controls, and in-app privacy notices consistent with this policy.

7. Advertising and Monetization Compliance

Our apps may integrate one or more advertising monetization SDKs and mediation partners according to product requirements and region-specific legal permissions.

Ad formats may include app open ads, rewarded video ads, interstitial ads, banner ads, and native ads.

Potential advertising and monetization platforms include but are not limited to: Google AdMob, Google Ad Manager, Google AdSense (where applicable), Meta Audience Network, AppLovin MAX, Unity Ads, ironSource, Mintegral, Pangle, Vungle, Chartboost, InMobi, Liftoff Monetize, Moloco Ads, Start.io, Smaato, DT Exchange (Fyber), Tapjoy, Yandex Ads, BidMachine, PubMatic, OpenX, Index Exchange, Magnite, and Amazon Publisher Services.

These platforms may process identifiers and technical data for ad delivery, frequency capping, anti-fraud, attribution, and campaign performance analysis, subject to local legal restrictions and platform terms.

Where legally required, we provide consent collection interfaces and preference management. For EEA/UK, we support consent signaling aligned with IAB TCF where implemented by partners. For US states, we support applicable opt-out signals and rights where required.

8. Cookies, SDKs, and Similar Technologies

Our website and applications use cookies, local storage, pixels, and SDK technologies for authentication, analytics, personalization, and service reliability.

Users may manage cookie preferences in browser settings and app permissions in device settings. Disabling some technologies may reduce functionality.

9. Country and Region Policy Adaptation

European Economic Area and Switzerland: GDPR-compliant transparency, lawful basis, data minimization, transfer safeguards, and user rights execution.

United Kingdom: UK GDPR and Data Protection Act aligned user rights and supervisory complaint access.

United States: CCPA/CPRA and applicable state law handling for access, deletion, correction, and opt-out requests; no unlawful discrimination for rights exercise.

Canada: PIPEDA-oriented notice and accountability standards.

Brazil: LGPD alignment including legal basis and rights management.

Australia and New Zealand: APP and equivalent privacy principle adaptation where applicable.

Other jurisdictions: We apply local mandatory privacy rules, mandatory notice language, and regulator-required controls where services are offered.

10. Data Sharing and Recipients

We may share data with service providers, cloud infrastructure partners, analytics providers, advertising partners, customer support tools, payment-related service providers (if applicable), legal advisors, and regulators when required by law.

Data sharing is limited to legitimate business needs and contractual controls, including confidentiality, security obligations, and processor terms.

11. International Data Transfers

Where cross-border data transfer occurs, we implement safeguards such as standard contractual clauses, transfer impact assessments, and additional technical and organizational measures when required by law.

12. Data Retention

We retain data only as long as necessary for service delivery, legal compliance, dispute resolution, fraud prevention, and contractual enforcement. Retention periods vary by data type and legal requirement.

13. Security Measures

We implement administrative, technical, and physical safeguards, including access controls, logging, encryption in transit where applicable, secure development practices, and incident response procedures. No security system is absolute, but we continuously improve controls.

14. Age and Child Privacy Policy

Our general services are intended for users who meet the minimum digital consent age under local law. We do not knowingly collect personal information from children where prohibited.

EEA: minimum age is generally 16, with local member-state variations that may lower to 13.

United States: for child-directed processing, COPPA requirements apply for under 13 users where applicable.

United Kingdom and Canada: youth protections apply under local law and platform policy.

If we become aware of unauthorized child data collection, we will take steps to delete data and restrict processing.

15. User Rights

Depending on location, users may have rights to access, correct, delete, port, restrict, object, and withdraw consent for personal data processing. Users may also request information on categories of data processed and third-party disclosures where required by law.

Requests can be sent to support@jiexiaokui.com. We will verify identity and respond within applicable legal timelines.

16. Do Not Track and Opt-Out Signals

Where required, we honor legally recognized browser and device-level privacy signals, including applicable global privacy control mechanisms and partner-supported ad opt-out frameworks.

17. Data Breach Notification

In the event of a personal data breach, we will investigate, mitigate, and notify relevant regulators and affected individuals where required by law and platform rules.

18. Third-Party Services

Third-party services embedded in our products have their own privacy policies. We encourage users to review provider-specific terms for analytics, attribution, cloud hosting, and advertising services.

19. Changes to This Policy

We may update this Privacy Agreement to reflect product changes, legal requirements, and platform policy updates. Material changes will be announced through website notices, in-app notices, or other reasonable channels.

20. Contact and Complaints

For privacy requests, policy questions, or complaints, contact support@jiexiaokui.com. Key account privacy coordination is available through yuhualong@jiexiaokui.com for enterprise projects.