Cuebao Data Compliance Notice

This notice is written for Cuebao users. It summarises the data compliance arrangements that apply when we provide the Service in the Chinese mainland. It does not replace the Cuebao Privacy Policy; where the two are inconsistent, the statement that is more protective of users' rights and interests prevails.

1. Scope

This notice applies to the Cuebao application, websites and related services provided in the Chinese mainland. The operator of the Service is Linghe Fangcheng (Beijing) Technology Co., Ltd.

Compliance principles.

• Lawfulness, legitimacy, necessity and good faith: we process personal information only where there is a clear purpose and reasonable necessity.
• Openness and transparency: we explain our processing rules through the Privacy Policy, the Personal Information Collection List, the System Permission Notice and the Third-Party Information Sharing List.
• Minimum necessity: different functions process different information according to actual need, and non-essential information is never a precondition for using basic services.
• Security safeguards: we adopt technical and management measures to protect personal information and reduce the risk of leakage, tampering, loss and misuse.
• Protection of rights: we provide channels for you to access, copy, correct and delete information, withdraw consent, delete your account, and submit complaints and feedback.

2. Where data is stored

Personal information collected and generated during our operations in the Chinese mainland is stored within the Chinese mainland. We require entrusted processors and infrastructure service providers to process the relevant information in accordance with the contract, applicable laws and regulations and security requirements.

3. Cross-border transfer of personal information

We will not transfer personal information collected and generated during our operations in the Chinese mainland outside the Chinese mainland, unless laws and regulations provide otherwise, unless we have obtained your separate consent and completed the required statutory procedures, or unless the information has been anonymised so that it can no longer identify a specific individual.

4. Account deletion and rights requests

You may apply through the in-app entry points or at privacy@cuebao.com to access, copy, correct, supplement or delete your personal information, withdraw consent, delete your account, or request an explanation of our personal information processing rules. We will handle your request in accordance with the law after verifying your identity.

Once account deletion is complete, we will stop providing the Service for that account and will delete or anonymise the personal information associated with it. Information that laws and regulations require us to retain, or that is necessary for security, audit or dispute handling, will be deleted or anonymised once the necessary retention period expires.

5. Protection of minors

Minors should use the Service under the guidance of a guardian. The personal information of children under the age of fourteen is governed by the Cuebao Children's Personal Information Protection Rules. Guardians may contact us to handle requests relating to children's personal information.

Third-party services and permissions. We set out the names of third-party services, the purposes for which they are used and the types of information they may process in the Cuebao Third-Party Information Sharing List. When the application requests a device permission, it explains the purpose through the system authorisation page or the relevant feature page.

Automated decision-making and personalisation choices. Where we use algorithms or automated means to provide ranking, recommendation, risk identification or security protection, we follow the principles of lawfulness, legitimacy, necessity and transparency, and we do not use automated decision-making to apply unreasonable differential treatment to you. Where the law requires us to provide an entry point to turn off or manage such processing, we will provide it within the relevant function.

6. Complaints and dispute handling

If you consider that our processing of personal information has harmed your lawful rights and interests, you may submit a complaint through the privacy contact channel. We will handle it in accordance with the law after verifying your identity, and will provide feedback on the outcome within a reasonable period.

Consistency of public statements. The information we present to you in the Privacy Policy, the Terms of Service, the Third-Party Information Sharing List, the account deletion entry point, the customer service entry point and the permission notice should be consistent with the functions actually provided by the Service and with our actual personal information processing activities.

7. Contact details

For privacy matters, please contact privacy@cuebao.com. For customer service matters, please contact support@cuebao.com.

Relationship between documents. This notice, together with the Cuebao Privacy Policy, the Cuebao Personal Information Collection List, the Cuebao Third-Party Information Sharing List, the Cuebao System Permission Notice and the Cuebao Children's Personal Information Protection Rules, explains the data compliance arrangements for the Service. Where the same matter is described inconsistently, the statement that is more protective of users' rights and interests prevails.

Update mechanism. We may update this notice when laws and regulations, regulatory requirements, service functions or data processing methods change. Where a material change occurs, we will notify you through in-app prompts, website announcements or other prominent means, and we will obtain consent again where required by law.

Ongoing verification. We continuously verify the consistency of our public statements, actual functions, permission requests, third-party services and account deletion entry points. Where an inconsistency is identified, the statement documents should be updated before any release or submission for review.