Privacy Policy — Tsattine application

Tsattine (hereinafter referred to as "we" or "this application"). This statement applies only to this product. If you have any questions, comments or suggestions, please contact us by email at: 493588565@qq.com.

Shenzhen Xinglian Technology R&D Co., Ltd. (hereinafter referred to as "we") operates this application. We fully recognize the importance of your personal information and will make every effort to protect it. Thank you for downloading, using and trusting our software! We are committed to protecting your personal information through the following principles to earn and maintain your trust: responsibility consistency, clear purpose, choice consent, minimum necessity, security assurance, subject participation, and transparency. We solemnly promise to protect your personal information and privacy in accordance with applicable laws and regulations.

Before using this application and its related services, please read carefully and fully understand all terms of this policy, especially clauses that limit or exempt our liability, and choose whether to accept them. Limitation and disclaimer clauses may be highlighted in bold and underlined to draw your attention.

Your use or continued use of our products indicates that you agree that we may collect, store and share your relevant information in accordance with this policy. If you violate any provisions of this agreement, we reserve the right to unilaterally restrict, suspend or terminate services to you at any time according to the severity of the violation, and pursue corresponding legal responsibilities. If you do not agree to any part or all of this policy, or have any questions about its content, you should immediately stop using our services and contact us promptly.

1. How We Collect and Use Personal Information

We collect and use your personal information in accordance with the principles of legality, fairness and necessity. We collect information you actively provide and data generated during your use of services through the following methods:

Product Security Features

To identify your device ID, ensure normal product operation, guarantee system security and improve service quality and efficiency, we need to obtain your MAC address, device serial number, IMSI, Android ID, IP address, hardware model, operating system version, unique device identifier (IMEI, etc.), network hardware address (MAC), software version, installed application list, network access method, WiFi_SSID, WiFi_BSSID, network type, network status, network quality indicators, operation logs, hardware serial number, service logs and WiFi scan results.

After you launch the APP and agree to this privacy policy, we collect your Android ID, IMEI and OAID as your unique user identifier for service access. All such data is transmitted and stored through MD5 encryption, and anonymized without disclosing your personal identity. Please note that collected device information cannot be used to identify any specific natural person. Unless you separately authorize or the law requires otherwise, device information collected by this application is only used to identify you as a user of this application.

All the above permissions are necessary conditions for corresponding product and service functions. If you refuse specific permissions, you will not be able to use related functions, but other functions and core basic services remain accessible. If you agree to provide your sensitive personal information, you agree that we may process such data for the purposes and methods described herein. Sensitive personal information refers to personal information that, once leaked, illegally provided or abused, may endanger personal and property safety, or easily lead to damage to reputation, physical and mental health, or discriminatory treatment. Examples include identity document numbers, biometric data, bank account details, communication records, and health and physiological information. The definitions of "personal information" and "sensitive personal information" here are consistent with GB/T 35273 "Information Security Technology - Personal Information Security Specification".

Permissions Requested by This Application

When you use the functions of this application, we may request the following permissions from your terminal device:

• Precise location access: Allows the application to receive satellite positioning data through GPS
• Coarse location access: Obtain latitude and longitude through wireless networks or cellular base stations

Unless you separately authorize or the law requires otherwise, location data collected by this application is only used to identify you as a user of this application.

Personal Information Usage Rules

1. This application will not provide, sell, rent or share your personal information with unrelated third parties, unless we obtain your prior consent, or these third parties (including Tsattine's affiliated companies) jointly or individually provide services to you, and are prohibited from accessing all such data upon service termination.
2. This application prohibits any third party from collecting, editing, selling or distributing your personal information in any way. If any platform user engages in such activities, we reserve the right to immediately terminate the service agreement with that user.
3. To serve users, you acknowledge and agree that we may conduct technical analysis on the entire user database, and commercially utilize de-identified aggregate user data without disclosing individual user privacy. If we intend to use your personal information beyond the scope stated at collection or its directly reasonably related purposes, we will notify you again and obtain your explicit consent before such use.

Special Reminder

Data that cannot identify you alone or in combination with other information does not constitute personal information in the legal sense. When we combine non-identifiable data with your personal data to identify you, during such combined use, the combined dataset shall be treated and protected as your personal information in accordance with this statement.

Situations Where Consent Is Not Required for Collection and Use

Please note that in the following circumstances, we may collect and use your personal information without your authorization in accordance with applicable laws, regulations and national standards:

1. Directly related to national security and defense security;
2. Directly related to public safety, public health or major public interests;
3. Directly related to criminal investigation, prosecution, trial and judgment execution;
4. Necessary to protect the vital personal or property interests of the data subject or other individuals, and consent cannot be obtained in time;
5. Personal information voluntarily disclosed to the public by you;
6. Personal information legally disclosed through public channels such as official news reports and government disclosures;
7. Necessary to sign or perform contracts at your request;
8. Necessary to maintain the stable operation of this application and related services, such as troubleshooting software failures;
9. Necessary for legitimate news reporting;
10. Statistical or academic research conducted by research institutions for public interest, provided that all personal information in published results has been de-identified;
11. Other circumstances stipulated by applicable laws and regulations.

2. How We Store Personal Information

We highly value the security of your personal information and take reasonable technical and management protection measures to prevent improper access, unauthorized disclosure, unauthorized use, alteration, damage or loss of personal information you submit.

2.1 Storage Location

In accordance with laws and regulations, all personal information collected within mainland China will be stored within the People's Republic of China. Currently, we do not transfer such data overseas. If cross-border transfer is required in the future, we will comply with national regulatory requirements and obtain your consent.

2.2 Storage Period

Generally, we retain your personal information only for the shortest period necessary to fulfill the stated purposes:

• Account information: We retain your account data while you use this application to ensure normal service access. After you cancel your account, we will delete or anonymize all corresponding information. (If this software does not support account login, please ignore this clause.)

We may extend the retention period to comply with:

1. Applicable laws, rules and regulations;
2. Court judgments, rulings or other legal proceedings;
3. Requirements from government agencies with statutory authority;
4. Where we have reason to believe compliance with laws and regulations is necessary;
5. Service agreements or this privacy policy, and legitimate interests to protect our customers, ourselves, affiliates, other users or employees from personal or property damage;
6. In product or service closure scenarios, we will notify you through push notifications, official announcements and other means, and delete or anonymize your personal information within a reasonable time.

2.3 Disposal of Expired Personal Information

We retain personal information only for the duration necessary for the purposes outlined in this policy, unless the law permits extension. Once the statutory retention period expires, we will delete or anonymize your personal information. If we cease operating any product or service, we will notify you at least fifteen (15) days in advance and delete or anonymize your personal information after closure.

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

3.1 Sharing of Personal Information

Except under the following conditions, we will not share your personal information with other companies, organizations or individuals:

We may share your personal information in accordance with laws and regulations or mandatory orders issued by competent government authorities.

Third-Party SDK List

3.2 Transfer of Personal Information

Except under the following conditions, we will not transfer your personal information to any company, organization or individual:

1. Transfer with your explicit prior consent;
2. In the case of merger, acquisition, asset sale or bankruptcy liquidation, your personal information may be transferred. In such transfers, we will continue to protect your data in accordance with security standards no lower than those specified herein, or require the transferee to obtain your renewed consent if the transferee intends to change the processing purpose or method.

3.3 Public Disclosure of Personal Information

Under normal circumstances, we will not publicly disclose collected personal information. If disclosure is necessary, we will inform you of the purpose of disclosure and the types of data to be disclosed, and obtain your explicit consent before authorizing public release.

1. Disclosure necessary to deliver products or services to third parties you requested;
2. Disclosure ordered by legal, administrative or judicial authorities;
3. If you violate Chinese laws and regulations or the service agreement and related rules of this application, disclosure is necessary;
4. Disclosure to the respondent at the request of qualified intellectual property complainants to resolve potential rights disputes;
5. Disclosure of contact information to transaction counterparties to complete transactions or resolve disputes, where either party fulfills part or all of transaction obligations and submits a disclosure request;
6. Other disclosures we believe comply with applicable laws, regulations or platform policies.

4. Use of Cookies and Related Technologies

1. If you do not disable Cookies, the Tsattine application may set or access Cookies on your device to enable login and access to platform functions that depend on Cookies. Cookies allow us to provide more personalized services, including promotional content.
2. You can choose to accept or reject Cookies by modifying browser settings. Rejecting Cookies may prevent you from logging in or accessing core platform functions that depend on Cookies.
3. All information obtained by Cookies deployed in the Tsattine application is subject to this privacy policy.

5. How We Protect Personal Information

We implement comprehensive safeguards to prevent data loss, abuse, unauthorized access and disclosure.

5.1 Security Measures Adopted

We employ certified protection controls to block unauthorized access, disclosure, alteration, damage or loss of your personal data, including:

1. SSL encryption for all data transmission between browser and server;
2. HTTPS secure browsing for all application web pages;
3. Encryption technologies to ensure data confidentiality;
4. Trusted defense mechanisms against malicious attacks;
5. Access control systems that restrict personal data access to authorized employees only;
6. Regular privacy and security training for all employees.

5.2 Minimization of Irrelevant Data Collection

We take all reasonable steps to avoid collecting irrelevant personal information and retain data only for the shortest necessary period permitted by law.

5.3 User Security Reminders

You acknowledge that systems and communication networks beyond our control may have security risks. We strongly recommend that you take protective measures, including complex passwords, regular password updates and not disclosing account credentials to third parties. (If the application does not have account login functionality, please ignore this paragraph.)

5.4 Regular Security Risk Assessments

We regularly conduct information security risk and personal information compliance impact assessments. You can submit inquiries and supervision requests through the contact channels listed in this statement.

5.5 Legal Liability for Data Breaches

The Internet cannot guarantee absolute security. If our physical, technical or management safeguards are compromised, resulting in unauthorized access, disclosure, tampering or destruction of your data and causing damage to your legitimate interests, we will bear corresponding legal responsibilities.

5.6 Remedial Measures After Security Incidents

In the event of a personal information security breach, we will promptly notify you in accordance with applicable legal requirements, including an overview of the incident, potential impacts, remedial measures we have implemented or will implement, self-protection recommendations and compensation solutions. Notifications will be sent via email, letter, telephone or in-app push notifications; if individual notification is not feasible, a mass public announcement will be issued.

5.7 Emergency Response Plan

We maintain formal emergency response protocols and activate them immediately upon detecting data breaches or losses to contain adverse effects. We will report all security events to relevant regulatory authorities in accordance with legal requirements.

5.8 Third-Party Platform Disclaimer

Once you exit this application to browse external websites or third-party services, whether or not you access them through links embedded in the Tsattine application, we have no ability or obligation to protect any personal information you submit to external platforms.

6. Your Rights

In accordance with the Personal Information Protection Law of the People's Republic of China, relevant national standards and global industry practices, we fully guarantee your rights to access, correct, delete and withdraw consent to your personal information to protect your privacy and data security.

6.1 Right to Access Personal Information

You can access your personal information unless restricted by law. Saved media files (audio and video) can be found, viewed, modified or deleted in the device album.

6.2 Right to Correct Personal Information

If you find that the personal information we hold is inaccurate, you can submit a correction request through the access channels listed in Section 6.1.

6.3 Right to Delete Personal Information

You can submit a deletion request in the following circumstances:

1. We process personal information in violation of applicable laws;
2. We collect or use your data without obtaining your consent;
3. Our processing violates our agreement with you;
4. You wish to remove content you publicly posted from public view;
5. We cease providing products or services to you.

If we approve your deletion request, we will notify all third parties who have received your data and request timely deletion, unless exempted by law or you have independently authorized such parties. Deletion within the application takes effect immediately, although residual copies may remain in backup systems until the next backup refresh cycle. To delete media files, enter the album page, click "Select", mark the target video and confirm deletion.

6.4 Right to Modify or Withdraw Consent

You can adjust or withdraw consent by deleting local files, disabling device permissions or updating privacy settings through "Privacy Policy and User Agreement" within the application. Please note that withdrawing consent will disable corresponding functions that depend on such data, but will not invalidate previously authorized data processing.

6.5 Right to Obtain Copies of Personal Information

You can request a complete copy of your personal data by sending an email to 493588565@qq.com. We will respond to your request within 10 calendar days. Where technically feasible, we may directly transmit a copy of your data to a third party you designate at your request.

6.6 Right to Complain and Report

If you believe your personal information rights have been violated or discover related violations, please submit feedback through Settings > Contact Us. We will review and respond to your complaint within 10 calendar days.

6.7 Right to View This Privacy Statement

You can access the full text of this privacy policy through Settings > Privacy Policy within the application.

6.8 Right to Explanation of Automated Decision-Making

Certain functions rely on algorithmic automated decision-making without human intervention. If such decisions have a significant impact on your legitimate interests, you have the right to request a full explanation and appropriate remedies from us.

6.9 Right to Service Termination Notification

If we cease operations, we will immediately stop new data collection, notify you through individual or public announcements, and delete or anonymize all stored personal information.

6.10 Response Standards for All User Requests

For security purposes, we may require written identity verification to process your requests. All valid requests will be responded to within 10 calendar days. If you are dissatisfied with our solution, disputes shall be submitted to the Beijing Arbitration Commission in accordance with its effective arbitration rules; the arbitration award shall be final and binding on all parties. We do not charge fees for reasonable, infrequent requests, but may charge reasonable administrative fees for excessive, repeatedly submitted requests. We reserve the right to reject unreasonable requests that require extensive system reconstruction, pose risks to third parties or involve archived backup data.

According to applicable laws, we cannot fulfill requests in the following circumstances:

1. Matters directly related to national security and defense security;
2. Matters directly related to public safety, public health and major public interests;
3. Matters directly related to criminal investigation, prosecution, trial and judgment execution;
4. Requests with clear evidence of malicious abuse of rights;
5. Requests that would seriously harm the legitimate interests of you or other individuals/organizations;
6. Requests involving our trade secrets.

7. How to Contact Us

This software is operated by Shenzhen Xinglian Technology R&D Co., Ltd. If you have any questions, comments, suggestions or complaints regarding this policy or the protection of your personal information, please contact us through the following information:

We typically respond to your inquiries within 15 business days.