Privacy Policy

Update Date: May 15, 2023

Introduction

SnapAction (hereinafter also referred to as “we”) deeply understands the importance of your personal information to you. Therefore, we place great emphasis on protecting your privacy and personal information. We treat and handle the content of this “SnapAction Privacy Policy” (including Appendix 1, hereinafter also referred to as “this Policy”) with a high degree of care and responsibility. This Policy is closely related to the products and/or services you use. When you download, install, start, browse, register, log in, use, uninstall, or exit our products and/or services (hereinafter collectively referred to as “use our products and/or services” or “use products and/or services”), we will process and protect your personal information in accordance with the provisions of this Policy. Therefore, we hope that you can carefully read and fully understand the full text of this Policy, and make the appropriate choices according to the guidance of this Policy when necessary. The technical terms involved in this Policy are explained in a simple and understandable manner to facilitate your understanding.

You should carefully read and fully understand the “SnapAction Privacy Policy” and decide whether to agree to the content of this Policy and whether to use our products and/or services. If you do not agree with the content of this Policy, it may result in our products and/or services not functioning properly, or failing to achieve the service effect we expect, or failing to achieve the level of personal information protection you expect. In this case, you should immediately stop accessing/using our products and/or services. Your use or continued use of the products and/or services we provide, or your failure to express any objection to us in a clear manner before using or continuing to use the products and/or services we provide, indicates that you fully understand and agree to the full content of this “SnapAction Privacy Policy” (including updated versions).

SnapAction has highlighted key clauses in this Policy that may have a significant impact on your rights (possibly) by using bold fonts or other reasonable means, so please pay attention to the key points. You should use our products and/or services only after fully reading and clearly understanding the aforementioned bold clauses in this Policy and agreeing to the validity of all clauses in this Policy. You will not claim that the clauses in this Policy are illegal or invalid on the grounds that SnapAction has not fulfilled its reasonable notice obligations.

This privacy policy is an integral part of the service agreement for using this application. This privacy policy will help you understand the following:

Scope of Application
How We Collect and Use Your Personal Information
How We Use Cookies and Similar Technologies
How We Share, Transfer, and Disclose Your Personal Information
How You Manage Your Information and Account Cancellation
How We Store Your Personal Information
How We Protect Your Personal Information
How Your Personal Information is Transferred Globally
Amendments to This Policy
Jurisdiction of Disputes
Contact Us

1. Scope of Application

1.1

(1) When you register an account for this application, you provide personal registration information (including but not limited to phone number, name, age, phone verification code, etc.) as required by this application;

(2) When you use the network services of this application or access the platform webpage of this application, this application automatically receives and records information on your browser and computer, including but not limited to your IP address, browser type, language used, date and time of access, hardware and software feature information, and web page records you request;

(3) This application obtains user personal data through legal means from business partners.

You understand and agree that the following information does not apply to this privacy policy:

(1) Keyword information you enter when using the search service provided by this application platform;

(2) Information data collected by this application about the information you publish on this application, including but not limited to participation in activities, transaction information, and evaluation details;

(3) Violations of laws or regulations or the rules of this application and the measures taken by this application against you.

1.2. Information Use

(1) This application will not provide, sell, rent, share, or trade your personal information to any unrelated third party, unless prior permission is obtained from you, or the third party and this application (including affiliated companies of this application) provide services to you individually or jointly, and after the service is terminated, it will be prohibited from accessing all the materials that it was previously able to access.

(2) This application also does not allow any third party to collect, edit, sell, or disseminate your personal information by any means. Any user of this application platform who engages in the above activities will be immediately terminated from the service agreement with this application upon discovery.

(3) For the purpose of serving users, this application may use your personal information to provide you with information of interest, including but not limited to sending you product and service information, or sharing information with partners of this application so that they can send you information about their products and services (the latter requires your prior consent).

(4) Our APP or the third-party plugins (SDKs) used may collect user information (including but not limited to IMEI, IMSI, device MAC address, software list, device serial number, the above permissions are mainly used for the realization of product security assurance functions, service content push, maintenance/improvement of our products and/or services, and data statistics for active or crash issues. If it exceeds this reasonable scope, we will apply for authorization from you again and inform you of the purpose of exceeding the scope. You can choose to refuse, and refusal will not affect other functions).

Service Content Display/Browsing

In the process of displaying and browsing service content through our products and/or services, we will collect some of your information based on your specific operations using our products and/or services, including the following personal information:

Device information: including unique device identifiers, login IP address, device MAC address, IMEI, device model, device name, device identification, browser type and settings, language settings, operating system and application version, network connection method, network quality data, mobile network information (including operator name), product version number, location-related information of the device (including location information you authorize us to obtain). Our APP will not actively collect any of your information without your consent, including but not limited to IMEI, IMSI, device MAC address, software list, device serial number, Android ID. With your consent, our APP or the third-party SDK plugins used may collect user information (including but not limited to IMEI, IMSI, device MAC address, software list, device serial number, Android ID, mainly used for 【Umeng+】Statistical analysis service collects unique device identifiers (IMEI/Mac/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) to provide statistical analysis services, and calibrates report data accuracy through geolocation, providing basic anti-cheating capabilities;

1.3. Information Disclosure

Under the following circumstances, this application will disclose your personal information in whole or in part based on your personal will or legal provisions:

(1) Disclosure with your prior consent;

(2) Sharing your personal information with third parties is necessary to provide the products and services you request;

(3) Disclosure to third parties or administrative or judicial institutions in accordance with relevant legal provisions or the requirements of administrative or judicial institutions;

(4) Disclosure to third parties if you violate Chinese laws, regulations, or the service agreement or related rules of this application;

(5) Disclosure to the complainant if you are a qualified intellectual property complainant and have filed a complaint, at the request of the complainant, so that both parties can handle possible rights disputes;

(6) In a transaction created on this application platform, if any party to the transaction has fulfilled or partially fulfilled the transaction obligations and requested information disclosure, this application has the right to decide to provide the user with the contact information of the other party to the transaction and other necessary information to facilitate the completion of the transaction or the resolution of disputes.

1.4 Third-Party SDK Information Explanation

To ensure the realization of relevant functions of the APP and the safe and stable operation of the application, we may integrate software development kits (SDKs) provided by third parties for relevant purposes. Our product may include all or part of the following SDKs:

(1) Umeng SDK

Our product integrates the Umeng+ SDK, which requires the collection of your device information such as device MAC address, unique device identifier (IMEI/android ID), IDFA, OPenUDID, GUID, SIM card IMSI, and geolocation to provide statistical analysis, download, activation, installation, and other services, and calibrates report data accuracy through geolocation, providing basic anti-cheating capabilities. Specifically:

1) 【Umeng+】Terminal Statistical Analysis Service (U-App/U-Web) 【Umeng+】Statistical analysis service helps you understand how your end users use your products (including services, including but not limited to mobile application clients, mobile websites, application platforms, PC websites, sites, and other terminals confirmed by 【Umeng+】to provide services, hereinafter the same), and helps you analyze the performance of your products on different terminal devices. When you integrate the 【Umeng+】statistical analysis tool in your product, your product collects and transmits data to our servers through the 【Umeng+】statistical analysis tool. We collect unique device identifiers (IMEI/Mac/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) to provide statistical analysis services and calibrate report data accuracy through geolocation, providing basic anti-cheating capabilities.

In addition to the aforementioned personal information, statistical analysis services will collect the following information based on different statistical dimensions: SDK/API/JS code version, browser, internet service provider, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, device model, sensor parameters, terminal manufacturer, terminal device operating system version, session start/stop time, language location, time zone, and network status (WiFi, etc.), hard disk, CPU, and battery usage.

1.5 Personal Information Permissions Explanation

To ensure the normal operation and function improvement of the APP, we may need the following all or part of the device permissions:

(1) Read phone status

Obtain device IMEI/Mac and other identifiers to identify user uniqueness. Umeng mobile statistics, Alipay payment, WeChat payment, and other third-party SDKs may require this permission.

(2) Read/write external storage

Cache necessary data generated by the application, such as application information, image cache, etc. Umeng mobile statistics, Alipay payment, WeChat payment, advertising components, fresco image library SDK may require this permission.

(3) Access approximate location/obtain precise location

Based on location information, provide user portraits and location-based advertising services. Umeng mobile statistics, advertising components, and other third-party SDKs may require this permission.

(4) Obtain task information

Umeng mobile statistics require this permission to track the task stack and obtain detailed crash and exception information.

(5) Album permission: When you use customer service, issue feedback, and other services or functions in SnapAction, you can enable the album permission to upload images or videos from your device. If you do not enable this permission, you will not be able to use the related functions of uploading images or videos, but it will not affect the use of other services.

(6) Camera permission: When you use customer service, issue feedback, and other services or functions in SnapAction, you can enable the camera permission to take photos or videos in real-time and upload them. If you do not enable this permission, you will not be able to use the related functions of taking photos or videos, but it will not affect the use of other services.

(7) Microphone permission: When you use customer service and other services or functions in SnapAction, you can enable the microphone permission to click the voice button to record, so that the platform can collect your voice content for necessary processing. If you do not enable this permission, you will not be able to use the related functions of voice input, but it will not affect the use of other services.

(8) Network connection: When you use this app, you can enable this permission to use related functions that require network connection, which may generate GPRS traffic. If you do not enable this permission, you will not be able to use the related functions of network connection, but it will not affect the use of other functions.

(9) Obtain network information status: When you use SnapAction, you can enable this permission to use related functions that require network connection, which can determine whether the current network connection is effective. If you do not enable this permission, the program will not be able to distinguish your network status, and you will not be able to use the related functions of network connection, but it will not affect the use of other functions.

(10) Allow the program to read or write system settings: When you use network functions and message push in SnapAction, you can enable this permission to set the network environment and push permissions. If you do not enable this permission, you will not be able to use the related functions, but it will not affect the use of other functions.

(11) Allow the program to obtain the current WIFI connection status and WLAN hotspot information: When you use the WIFI connection function, you can enable this permission to set the network environment. If you do not enable this permission, you will not be able to use the function, but it will not affect the use of other functions.

1.6 Information Storage and Exchange

The information and data about you collected by this application will be stored on the servers of this application and/or its affiliated companies, and may be transmitted to the country, region, or location where this application collects information and data, and accessed, stored, and displayed abroad.

1.7 Use of Cookies

(1) If you do not refuse to accept cookies, this application will set or retrieve cookies on your computer so that you can log in or use the platform services or functions that rely on cookies.

(2) You have the right to choose to accept or refuse cookies. You can refuse to accept cookies by modifying your browser settings. However, if you choose to refuse to accept cookies, you may not be able to log in or use the network services or functions of this application that rely on cookies.

(3) The information obtained through the cookies set by this application will apply to this policy.

2. How We Collect and Use Your Personal Information

2.1 Types and Purposes of Information Collection

We collect and use your personal information for the following purposes as described in this Policy:

2.1.1 To provide you with SnapAction corresponding functions, we need to collect information including:

Account information:

Help you become our user. The registration information you fill in, including your phone number, is used for registration, login, and use of the SnapAction account to use SnapAction products and services, as well as for customer service and after-sales support, and to ensure your account security. Personal profile and service project information:

During the registration and login process for some single services, if you provide additional information (such as region, nickname, gender, date of birth, avatar, interests, etc.), it will help us provide you with a better service experience. However, if you do not provide this information, it will not affect your use of SnapAction’s basic functions. At the same time, in accordance with the requirements of relevant laws and regulations or specific functions and services, you may need to provide other information (such as name, ID card, and other identification information) before using specific functions and services. If you do not provide this information, we will not be able to provide you with related functions and services.

2.1.2 To provide you with services that better meet your needs, you will provide information and associate it, including these functions and information:

Product reservation/purchase:

You need to provide contact information (such as name, gender, phone number, etc.) to SnapAction.

Information release:

When you actively evaluate or publish other content (such as comments, etc.) on SnapAction, we will collect and publish information after your authorization, showing your nickname, avatar, and published content, etc. You can authorize access to your camera, photos, and microphone by actively uploading pictures to publish content. When you need to turn off this function, most mobile devices support your demand. For specific methods, please refer to or contact the service provider or manufacturer of your mobile device.

Payment:

When you pay on SnapAction, you can choose payment services provided by third-party payment institutions cooperating with SnapAction (such as WeChat Pay, Alipay, etc.). The payment function itself does not collect your personal information, but we need to share your SnapAction order information and reconciliation information with these payment institutions to confirm your payment instructions and complete the payment.

Customer service:

When you contact our customer service, our system may record the communication records between you and the customer service, and use your account information to verify your identity. When you need customer service related to your order, we may query your relevant order information to provide you with appropriate assistance and processing. You may also need to provide other information besides the aforementioned information to complete the modification.

Purchasing on behalf:

Purchasing SnapAction services on behalf: You can purchase various products/services on SnapAction for others and provide relevant information about the actual service recipient. You agree and ensure that you have obtained the authorization of the relevant person in advance.

Bill management:

To display your account order information, we will collect order information generated during your use of our services for display and management of your orders. In the orders generated by SnapAction, there may be your identity information, contact information, address information, payment information, which are sensitive information. Please be cautious about displaying or providing them to others. When SnapAction needs to provide order information externally, it will obtain your authorization and take reasonable commercial precautions to de-identify your information to maximize the protection of your personal information while ensuring the availability of the information.

2.1.3 To provide you with services that better meet your needs, we will collect and associate information about your use of products, services, and usage methods, including:

Device information:

We will receive and record the device information you use (device MAC address, device model, operating system version, device settings, unique device identifier, hardware and software feature information) and location-related information of the device (IP address, GPS/Beidou location information, and Wi-Fi access points, Bluetooth, and base stations that canprovide relevant information) based on the specific permissions you grant during software installation and use.

Log information:

When you use our services, we may collect detailed usage of our services as network logs. For example, your login account, search query content, IP address, browser type, telecom operator, network environment, language used, access date and time, and your web browsing records, Push open records, duration, refresh records, release records, follow, subscribe, collect, and share.

Third-party account information:

We will obtain your relevant information from SnapAction’s affiliated companies and partners in accordance with laws and regulations and the agreements with third parties after obtaining your authorization reasonably, and use your information after confirming the legality of the information source. If you log in using a third-party account, we will obtain the account information you share from the third party (such as avatar, nickname) after you agree to this privacy policy and bind your third-party account with the SnapAction account when you use related functions.

2.1.4 For your security

To prevent, detect, and investigate fraud, infringement, security threats, illegal activities, or violations of agreements, policies, or rules with us or our affiliated companies, we may collect or integrate your user information, service usage information, device information, log information, and information obtained from our affiliated companies and partners with your authorization or in accordance with laws.

2.1.5 Exceptions to obtaining authorization consent

According to relevant laws and regulations, the following circumstances do not require obtaining your authorization consent for collecting your information:

Related to national security and national defense security;
Related to public safety, public health, and major public interests;
Related to criminal investigation, prosecution, trial, and execution of judgments;
For the protection of the life, property, and other major legitimate rights and interests of information subjects or other individuals, but it is difficult to obtain the consent of the person;
Information that the information subject has disclosed to the public on their own;
Collecting information from legally publicly disclosed information, such as legitimate news reports and government information disclosure;
Necessary for signing contracts at your request;
Necessary for maintaining the security and stability of SnapAction services, such as discovering and handling product or service failures;
Necessary for legitimate news reporting;
Necessary for academic research institutions to conduct statistical or academic research based on public interests, and de-identify the information contained in the results when providing the results of academic research or description;
Other circumstances stipulated by laws and regulations.

2.2 Information Use

The collection of your information is for the purpose of providing services and improving service quality. For this purpose, your information will be used for the following purposes. If we need to use the collected relevant information for new purposes, scopes, or actual transmission methods that are inconsistent with the agreement, we will notify you through an in-app pop-up and obtain your explicit consent:

2.2.1 Service optimization

To provide you with the SnapAction products or services you use and maintain, improve, and optimize these services and service experiences;

2.2.2 Account security

To prevent, detect, and investigate fraud, infringement, security threats, illegal activities, or violations of agreements, policies, or rules with us or our affiliated companies, protect you, other users, or the public, and the legitimate rights and interests of our affiliated companies, we may use or integrate your user information, service usage information, device information, log information, and information obtained from our affiliated companies and partners with your authorization or in accordance with laws to comprehensively judge your account and transaction risks, verify your identity, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures;

2.2.3 Access to third-party SDKs (plugin details as explained in section 1.4 above)

To ensure the realization of relevant functions of SnapAction and the safe and stable operation of the application, we may integrate software development kits (SDKs) provided by third parties for relevant purposes. We will strictly monitor the software tool development kits (SDKs) obtained from partners to protect data security. Please note that third-party SDKs may change the types of data processing due to version upgrades, policy adjustments, etc. Please refer to the official explanation of the SDK for details.

2.2.4 Other purposes with your consent.

2.2.5 SnapAction Permissions Use and Use Situation Explanation

To ensure the realization and security of SnapAction, we may apply for or use relevant operating system permissions; to ensure your right to know, we list the operating system permissions that the product may apply for and use through the following list, and you can manage the relevant permissions based on actual needs;

Due to product upgrades, the types and purposes of applying for and using permissions may change. We will adjust the list in a timely manner to ensure that you are informed of the application and use of permissions. Please note that we may also use third-party SDKs for business and product security needs, and these third parties may also apply for or use relevant operating system permissions (device identification information);

During the use of the product, you may use H5 pages or mini-programs developed by third parties, and these third-party plugins or mini-programs may also apply for or use relevant operating system permissions due to business functions.

3. How We Use Cookies and Similar Technologies

To provide you with a more relaxed access experience, when you use SnapAction products or services, we may collect and store relevant data about your access to SnapAction services through various technologies to identify your identity when you access or re-access SnapAction services, and analyze the data to provide you with better and more services. This includes using small data files to identify your identity, which helps to understand your usage habits, save you the steps of repeatedly entering account information, or help determine your account security. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively referred to as “cookies”)

Please understand that some of our services can only be realized through the use of cookies. If your browser or browser add-on services allow, you can modify your acceptance of cookies or reject SnapAction’s cookies, but rejecting SnapAction’s cookies in some cases may prevent you from using some of the functions of SnapAction services that rely on cookies.

Web pages often contain some electronic images, called “single-pixel GIF files” or “web beacons,” which help websites count the number of users browsing web pages or access certain cookies.

We will collect your web browsing activity information through web beacons, including the address of the page you visited, the address of the page you previously visited, the time you stayed on the page, your browsing environment, and display settings.

4. How We Share, Transfer, and Disclose Your Personal Information

4.1 Sharing

We will not share your personal information with companies, organizations, and individuals outside of SnapAction service providers, except in the following cases:

Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties;
Sharing with affiliated companies: To facilitate our provision of services based on affiliated accounts to you, recommend information of interest to you, or protect the legitimate rights and interests of SnapAction affiliated companies or other users or the public from infringement, your personal information may be shared with our affiliated companies. We will only share necessary personal information (such as to facilitate your use of the SnapAction account to use the products or services of affiliated companies, we will share your necessary account information with affiliated companies). If our affiliated companies change the purpose and processing of personal information, they will again seek your authorization and consent. You agree that affiliated companies and SnapAction will share necessary relevant information. SnapAction will accurately record and save the sharing and transfer of personal information, including the date, scale, purpose of sharing and transfer, and the basic situation of data recipients.
Sharing with authorized partners: Only for the purposes stated in this privacy policy, some of our services will be provided jointly by us and authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. When you purchase products on the website, we must share your personal information with logistics service providers to arrange delivery or arrange partner services. We will only share your personal information for legitimate, necessary, specific, and clear purposes and will only share the personal information necessary to provide the service. Our partners are not allowed to use the shared personal information for any other purposes unrelated to the product or service.

SnapAction services contain links to other websites. Except as required by law, SnapAction is not responsible for the privacy protection measures of other websites. We may add commercial partner or co-branded websites at any time when needed, but the information provided to them will only be basic information without privacy, and we will not disclose your identity.

Sharing under legal circumstances: We may share your personal information externally in accordance with laws and regulations, litigation dispute resolution needs, or the requirements of administrative or judicial authorities.

4.2 Transfer

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

Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
In the case of a merger, acquisition, or bankruptcy liquidation of SnapAction service providers, or other circumstances involving a merger, acquisition, or bankruptcy liquidation, if personal information transfer 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 re-seek your authorization and consent.

4.3 Public Disclosure

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

Public disclosure with explicit consent: After obtaining your explicit consent, we may publicly disclose your personal information;
If we determine that you have violated laws and regulations or seriously violated the relevant agreement rules of SnapAction, or to protect the legitimate rights and interests of SnapAction and its affiliated companies, users, or the public from infringement, we may disclose your personal information, including the relevant violations and the measures taken by SnapAction against you, in accordance with laws and regulations or the relevant agreement rules of SnapAction after obtaining your consent.

4.4 Exceptions to obtaining authorization consent for sharing, transferring, and publicly disclosing personal information

The following circumstances do not require obtaining your authorization consent for sharing, transferring, and publicly disclosing your information:

Related to national security and national defense security;
Related to public safety, public health, and major public interests;
Related to criminal investigation, prosecution, trial, and execution of judgments;
For the protection of the life, property, and other major legitimate rights and interests of information subjects or other individuals, but it is difficult to obtain the consent of the person;
Information that the information subject has disclosed to the public on their own;
Collecting information from legally publicly disclosed information, such as legitimate news reports and government information disclosure;
Necessary for signing contracts at your request;
Necessary for maintaining the security and stability of SnapAction services, such as discovering and handling product or service failures;
Necessary for legitimate news reporting;
Necessary for academic research institutions to conduct statistical or academic research based on public interests, and de-identify the information contained in the results when providing the results of academic research or description;
Other circumstances stipulated by laws and regulations.

5. How You Manage Your Information and Account Cancellation

In accordance with relevant Chinese laws, regulations, standards, and other practices in countries and regions, we guarantee that you have the following rights to exercise over your personal information:

5.1 Account Information:

If you wish to access or edit the personal profile information in your account, change your password, add security information, etc., you can perform such operations in the product you use. You can choose (enter the “Me” menu item, click “User Avatar”) to view the information of your current registration and other information provided.

5.2 User Information Change:

You can change your personal information (including phone number, name, avatar, gender, etc.) on the APP. If you have any questions, you can contact us through SnapAction’s online service or phone service channels to help you solve the problem.

5.3 User Information Deletion

You can contact us through the contact information (zangqilong@gmail.com) announced on SnapAction’s official website, provide relevant information, and we will help you delete user information. If we stop operating or stop providing related services, we will stop the activity of continuing to collect your personal information in time, notify you of the stop of operation through a one-by-one delivery or announcement, and delete or anonymize the personal information we hold.

We need some basic personal information to complete each business function (see this privacy policy). In addition: You can withdraw some authorization by unbinding, modifying personal settings, deleting relevant information, etc., or revoke authorization by closing functions.

After you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawn consent or authorization, nor will we process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect the personal information processing that has been carried out based on your consent or authorization.

5.5 User Account Cancellation:

If you decide to stop using SnapAction, you can cancel your account. Account cancellation can be achieved in “SnapAction My Edit Personal Profile Cancel Account”. You can also contact us at zangqilong@gmail.com, provide relevant information, and we will help you cancel your account within 24 hours. Before you cancel your account, we will require you to perform necessary identity verification, including personal identity, security status, device information, etc. For the process and content of cancellation, please refer to the guidance on the account cancellation page. You understand and acknowledge that the act of canceling the account is irreversible. After you cancel your account, we will stop providing you with services and delete all information about your account or anonymize the relevant information, except as required by laws and regulations.

6. How We Store Your Personal Information

We will store the collected relevant personal information in the following forms: structured data storage, server placement within the People’s Republic of China. At the same time, we will only retain your personal information within the period necessary to achieve the purposes stated in this policy, unless there is a mandatory retention requirement by law. For example, the “E-commerce Law of the People’s Republic of China” requires that commodity and service information and transaction information be retained for no less than three years from the date of completion of the transaction; the “Implementation Opinions of the Ministry of Education and Other Six Departments on Regulating Off-campus Online Training” stipulates that user behavior logs must be retained for more than one year. For user behavior logs involved in our services, we will anonymize the processing. Our judgment criteria for the aforementioned retention period include:

Completion of transaction purposes related to you, maintenance of corresponding transaction and business records, response to your possible inquiries or complaints;
Ensuring the security and quality of services provided to you;
Whether you agree to a longer retention period;
Whether there are other special agreements for the retention period.

After your personal information exceeds the retention period, we will delete your personal information in accordance with the requirements of applicable laws or anonymize it (if you are a minor, after your personal information exceeds the retention period, we will process your personal information in accordance with relevant laws and regulations). If it is not possible to delete due to special circumstances.

7. How We Protect Your Personal Information

We will take various preventive measures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. To ensure the security of your personal information, we have strict information security regulations and processes, and a dedicated information security team within the company strictly enforces the aforementioned measures. SnapAction has an advanced data-centric data security management system throughout the data lifecycle, enhancing the security of the entire system from organizational construction, system design, personnel management, product technology, etc.

We will take reasonable and feasible measures to avoid collecting irrelevant personal information and retain your personal information only within the period necessary to achieve the purposes stated in this policy, unless an extended retention period is required or permitted by law.

After an information security incident occurs, we will inform you in accordance with the requirements of laws and regulations and no later than 30 natural days: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to prevent and reduce risks independently, and remedial measures for you. We will inform you of the event-related situation through email, letter, phone, push notification, etc. If it is difficult to inform each personal information subject one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also report the handling situation of personal information security incidents in accordance with the requirements of regulatory authorities.

Due to technical limitations and possible malicious means, in the internet industry, even with all-out efforts to strengthen security measures, it is impossible to always guarantee 100% information security. We will do our best to ensure the security of the personal information you provide to us. Please understand and acknowledge that the system and communication network you use to access our services may have problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of personal information, including but not limited to using complex passwords, regularly changing passwords, not disclosing your account password, and other personal information to others, etc.

8. How Your Personal Information is Transferred Globally

In principle, the personal information we collect and generate during the operation within the People’s Republic of China will be stored within the People’s Republic of China. For personal information generated by SnapAction users outside the People’s Republic of China during the use of SnapAction products and services, you agree to return and store it on servers within the People’s Republic of China, otherwise, you will not be able to use the existing SnapAction products and services. In such cases, we will ensure that your personal information is protected with a level of security equivalent to that within the People’s Republic of China.

9. Protection of Minors

We attach great importance to the protection of personal information of minors. If you are under the age of eighteen, please read this privacy policy carefully under the guidance of your guardian and obtain the consent of your guardian before using our services and providing your personal information. If your guardian does not agree to this privacy policy, you should immediately stop using SnapAction’s services and refuse to provide personal information. If you are a minor under the age of fourteen, please notify your guardian to read and accept our “User Privacy Policy” together and seek their consent and guidance before using our services and submitting your personal information. For personal information collected with the guardian’s consent, we will only use or disclose the information within the scope permitted by laws, obtaining the guardian’s explicit consent or protecting the child user. For personal information provided by minor users without the guardian’s consent, we will delete the relevant information upon receiving the guardian’s notice.

10. Amendments to This Policy

SnapAction reserves the right to modify this policy terms when necessary and notify you through an in-app pop-up. You can check the modified latest version policy at any time on this platform. If you do not agree with the modified policy, you have the right to terminate our authorization. If you continue to use the corresponding functions after this policy is updated, it is deemed that you have accepted the modified policy.

For significant changes, we will provide more prominent notices (including but not limited to in-app pop-ups, phone calls, text messages, and other methods to solicit opinions, announcements, and even pop-up prompts).

Significant changes referred to in this policy include but are not limited to:

Significant changes in our service mode, such as the purpose of processing user information and the way user information is used;
Significant changes in our control, organizational structure, etc., such as business adjustments, bankruptcy and acquisition, etc., causing owner changes;
Significant changes in the main objects of personal information sharing, transfer, or public disclosure;
Significant changes in the responsible department, contact methods, and complaint channels for user information security;
The security impact assessment report indicates a high risk.

11. Jurisdiction of Disputes

The conclusion, effectiveness, interpretation, amendment, supplement, termination, execution, and dispute resolution of this policy are governed by the laws of the People’s Republic of China. If there is no relevant legal provision, reference should be made to commercial practices and/or industry practices.

Any disputes arising from the use of SnapAction services and related to SnapAction services shall be resolved through consultation between SnapAction and you. If consultation fails, either party may file a lawsuit with the court.

12. Contact Us

When you have personal information-related issues or other complaints, suggestions, etc., you can contact us through the following methods. We will review the content involved as soon as possible and reply to your questions, complaints, and suggestions within 15 working days:

Email: zangqilong@gmail.com