Privacy Policy

1. What Information We Collect About You

We collect your information based on the principles of lawfulness, reasonableness, and necessity. When providing you with a specific service, we will clearly inform you of the information we will collect and its purpose to respond to your specific service request. Depending on the service you choose, we may collect one or more of the following types of information in the following scenarios:

1.1 To help us understand the operation of this product, we use mobile analytics software such as the Umeng Data Statistics SDK. We may log information such as your frequency of use, crash data, overall usage, and performance data. We do not associate the information stored in the analytics software with any of your personal information.

1.2 When you download or use this product, we may access information related to your mobile device, such as hardware model, IMEI number or other unique device identifier, MAC address, IP address, operating system version, and device settings used to access the service.

1.3 When you use this product service, we will automatically receive and record information from your browser and computer, such as your IP address, browser type, language used, access date and time, software and hardware feature information, and web page records you access.

1.4 When you use the services of this product, we may access location-related information, such as your device’s GPS signal, nearby WLAN access points, cell phone signal transmission tower information, country code, city code, mobile network code, cell ID, latitude and longitude information, and language settings.

1.5 It is important to note that individual device information and service log information are non-identifiable (cannot identify a specific natural person). If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be considered personal information during the combined use. Unless authorized by you or otherwise provided by laws and regulations, we will anonymize and de-identify such information.

1.6 In addition, we may also collect other information, such as questionnaire responses you submit when participating in a survey, and information you provide when interacting with us.

1.7 To improve the security of your use of this product and services, protect your or the public’s personal and property safety, and better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, and network intrusions, we may use or integrate your device interaction information, web log information, and information obtained with your authorization or shared in accordance with the law to prevent security incidents and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

1.8 If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing such personal information to us. If we use the information for other purposes not specified in this Policy, or use information collected for a specific purpose for other purposes, or actively obtain your personal information from a third party, we will obtain your prior consent.

1.9 Exceptions to authorization and consent: You fully understand and agree that we do not need your authorization and consent to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, or information access:

• 1.9.1 Related to national security and national defense security;
• 1.9.2 Related to public safety, public health, and major public interests;
• 1.9.3 Related to judicial or administrative law enforcement (e.g., criminal investigation, prosecution, trial, and execution of judgments);
• 1.9.4 Necessary to protect your or another person’s life, property, or other major legitimate rights and interests, but it is difficult to obtain your consent;
• 1.9.5 Personal information you have disclosed to the public;
• 1.9.6 Personal information collected from legally publicly disclosed sources (e.g., legal news reports, government information disclosure channels);
• 1.9.7 Necessary to execute the agreement or other written documents signed with you;
• 1.9.8 Necessary to maintain the safe and stable operation of the products and/or services provided (e.g., identifying and resolving product/service malfunctions);
• 1.9.9 Necessary for legitimate news reporting;
• 1.9.10 Necessary for academic research institutions to conduct statistical or academic research based on public interests (provided that personal information in research results is de-identified);
• 1.9.11 Other circumstances stipulated by laws and regulations.

2. How We Use Your Information

2.1 We will keep your personal data up to date; store or destroy it securely; minimize the collection and retention of data needed to provide you with services; protect personal information from disclosure, misuse, unauthorized access, and disclosure; and take appropriate technical measures to protect the security of your personal information.

2.2 We use your information for the following purposes:

• 2.2.1 To provide other services you request (as described when we collect the information);
• 2.2.2 For internal management and back-office support, and to share your contact information with our global branches;
• 2.2.3 To maintain the integrity and security of the data technology systems where we store and process your personal information;
• 2.2.4 To enforce or protect our agreement or contract with you;
• 2.2.5 To detect and investigate information breaches, illegal activities, and fraud;
• 2.2.6 To contact you to resolve issues;
• 2.2.7 Other uses with your permission.

2.3 Please note that the above uses cover the main ways we use your information. From time to time, we may provide more diverse services by updating our website pages. When we intend to use your information for other purposes not specified in this Policy, or use information collected for a specific purpose for other purposes, we will seek your consent again by updating this Policy.

3. How We Share Your Information

We will not share your personal information with companies, organizations, or individuals outside KeyPlay, except in the following cases:

3.1 Statutory sharing: We may share your personal information externally in accordance with laws and regulations, litigation and dispute resolution needs, or as required by administrative and judicial authorities.

3.2 Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

3.3 Sharing with affiliated companies: To facilitate us in providing services to you and protect the public’s personal and property safety, your personal information may be shared with our affiliated companies and/or their designated service providers. We will only share necessary personal information and will be bound by the purposes stated in this Policy. If we share your sensitive personal information or our affiliated companies change the purpose of using and processing personal information, we will seek your authorization and consent again.

3.4 Sharing with authorized partners: We may entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share your information for the legal, legitimate, necessary, specific, and explicit purposes stated in this Policy. Authorized partners will only access the information needed to perform their duties and may not use this information for any other purpose.

• 3.4.1 Advertising and analytics service partners: We will not share your personally identifiable information with partners providing advertising and analytics services unless we have your permission. We entrust these partners with information related to ad reach and effectiveness, but we do not provide your personally identifiable information, or we de-identify this information so that it does not personally identify you. Such partners may combine the above information with other data they have legally obtained to provide the advertising services or decision-making recommendations we commission.
• 3.4.2 Suppliers, service providers, and other partners: We share information with suppliers, service providers, and other partners who support our business, including those entrusted with technical infrastructure services, analyzing how our services are used, measuring service effectiveness, providing customer service, facilitating payments, or conducting academic research and surveys.

3.5 We will not transfer your personal information to any company, organization, or individual, except in the following cases:

• 3.5.1 Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
• 3.5.2 In the event of a merger, acquisition, or bankruptcy liquidation of the KeyPlay service provider, or other situations involving merger, acquisition, or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to be bound by this Policy. Otherwise, we will require the company, organization, or individual to seek your authorization again.

4. How We Store Your Information

Unless otherwise required by law, this website will keep your information for the following periods:

• 4.1 During your use of the KeyPlay service, we will continue to store your information;
• 4.2 When you stop using the KeyPlay service, we will stop using your personal information and delete it within a certain period;
• 4.3 After your personal information is anonymized and desensitized, it will form usable circulating data. We do not need your consent for the storage and use of this data.

5. Protection of Personal Information

On the premise of prioritizing information security, we make every effort to take reasonable technical and management measures to protect your personal information, to maximize the protection of your personal information.

For information security purposes, your personal information will be encrypted, anonymized, or processed using industry-common technical methods that are reasonable and compliant with laws and regulations.

The company has a comprehensive information security supervision mechanism, including strict authorization requirements for data use, access, and sharing.

Although we have taken the above reasonable and effective measures and complied with the standards required by relevant laws and regulations, please understand that due to technical limitations and potential malicious means, in the Internet industry, even if we do our best to strengthen security measures, we cannot always ensure 100% information security.

You acknowledge and understand that unexpected and uncontrollable information security issues may occur during your use of the company’s applications. We also recommend that you take active measures to protect the security of your personal information (e.g., using complex passwords, changing passwords regularly, and not disclosing personal information to third parties).

Based on the above reasonable and effective measures, we have further established an information security response plan to activate emergency procedures when information security issues occur, and strive to prevent the expansion of the impact and consequences of these security incidents.

Information security issues caused by your personal reasons (especially issues caused by the environment in which you use this application) are not within the scope of the company’s personal information security protection.

6. How We Protect Your Information

6.1 We have taken reasonable and feasible security protection measures in line with industry standards to protect your information and prevent personal information from unauthorized access, public disclosure, use, modification, damage or loss. For example, the exchange of data between your browser and the server is protected by SSL protocol encryption; we will also use encryption technology to improve the security of personal information; we will use trusted protection mechanisms to prevent malicious attacks on personal information; we We will deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will conduct security and privacy protection training courses to enhance employees’ awareness of the importance of protecting personal information.

6.2 The Internet is not an absolutely safe environment. When using the products or services of this website, we strongly recommend that you do not send your information by means of communication other than those recommended by this website. You can connect and share with each other through our services.

6.3 In the event of an unfortunate personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and your suggestions for self-prevention and risk reduction , remedies for you, etc. We will inform you of the relevant circumstances of the event by email, letter, telephone, push notification, etc. When it is difficult to inform the personal information subjects one by one, we will publish announcements in a reasonable and effective way. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

7. Your Rights

7.1 You own your personal information in full. The company fully protects your authority to manage the personal information you submit to us. You can modify your personal information in this application at any time. When modifying your personal information, you should comply with the requirements of national laws and regulations.

7.2 During your use of the company’s application, we will clearly disclose the necessary permissions we need to apply for, and will also clearly inform you of the full content of this Privacy Policy. These permissions will not be enabled unless authorized by you. At the same time, you can also disable these permissions in your device’s operating system (e.g., GPS location, address book, camera, microphone, photo album). If the permissions are not necessary for the application, disabling or denying authorization will not affect the use of the application.

Please note that necessary permissions will affect the core functionality of the application. If you refuse to authorize necessary permissions or disable necessary authorizations in the device’s operating system, it will affect your use of the application.

When using this application, we will explicitly request your authorization for necessary permissions and will only enable these permissions after you agree and authorize.

7.3 We provide a complete account deletion function. To prevent account theft, we need to verify your account ownership, and you may need to provide supporting materials (e.g., personal information, account status, historical records).

Please note that account deletion is an irreversible process. After you cancel your account, we will delete your relevant information or anonymize it, unless otherwise required by laws and regulations.

8. Our Policy Regarding Children

Our platforms are not intended for use by children (under the age of 13 or higher as required by applicable law). We do not knowingly collect or solicit any personal data from children, serve interest-based advertising to children, or allow children to register or use the platform. Children should not use our platform or send us any personal data about themselves at any time. If we learn that we have inadvertently collected personal data from a child, we will take reasonable steps to delete this information from our records immediately. If you believe we may have information about a child, please contact us at: [email protected]

9. Amendments and Notices of This Privacy Policy

For business and technological development and to provide better services, we may revise this Privacy Policy from time to time. After the newly revised Privacy Policy is released, it will completely replace the previous version. Please check the relevant content in a timely manner.