Cuebao Privacy Policy

Cuebao is operated by Linghe Fangcheng (Beijing) Technology Co., Ltd. We take the protection of your personal information and privacy seriously, and we have prepared this Policy in accordance with the Personal Information Protection Law of the People's Republic of China, the Cybersecurity Law of the People's Republic of China, the Data Security Law of the People's Republic of China and other applicable laws and regulations.

This Policy explains how we handle personal information when you use the Cuebao application, websites and related services, and how you can manage your own personal information. Please read and understand this Policy carefully before using the Service.

1. How we collect and use personal information

We process personal information only to the extent necessary to deliver clearly identified functions. Different functions require different information, and you may choose whether to use each function based on your own needs.

• Account registration, sign-in and security verification: we process account identifiers, display names, phone numbers, email addresses, password hashes, one-time passcode verification records and sign-in method status, in order to create accounts, verify sign-in, recover accounts, safeguard account security and process account deletion.
• Device and service security: we process device identifiers, device models, system environment, app environment, language and region settings, IP addresses, request timestamps, verification tokens and necessary logs, in order to prevent fraud, automated abuse, credential-stuffing, malicious requests and other conduct that endangers the security of the Service.
• Core companion and pet-care services: we process pet names, pet state, interaction records, activity progress and content that you actively enter or generate within the Service, in order to provide companion, pet-care, interaction and related functions.
• Customer service and dispute handling: we process your contact details, account information, feedback content, communication records and necessary service logs, in order to respond to enquiries, complaints, rights requests and disputes.
• Service stability and troubleshooting: we process crash information, API errors, request identifiers, timestamps, app environment, and device and system summaries, in order to locate problems, repair faults and maintain stable operation of the Service.
• Compliance records: we process the names and versions of the agreements you have confirmed, the time of confirmation, and records of authorisation or withdrawal, in order to evidence that you have seen and confirmed the relevant agreements and to perform our legal obligations.

Sensitive personal information. Phone numbers, account security verification records, personal information of children under the age of fourteen, and inferred information that may reflect personal characteristics may constitute sensitive personal information. We process sensitive personal information only where there is a specific purpose and sufficient necessity, and only with strict protective measures in place. Where separate consent is required by law, we will obtain that separate consent in accordance with the law.

Device permissions. We request necessary permissions only when you use the related function, and we explain the purpose on the system authorisation page or within the relevant feature page. You may manage authorisations in your device system settings. Turning off a permission may prevent the corresponding function from working, but it does not affect other functions that do not depend on that permission.

Cookies and similar technologies. We may use necessary technologies such as local storage, cache and tokens in order to maintain your sign-in state, safeguard security, record your privacy choices and improve service stability. We do not use these technologies for third-party advertising tracking.

2. Entrusted processing, sharing, transfer and public disclosure

We do not sell your personal information. In order to provide verification codes, human verification, fault diagnosis, cloud resources, security protection and customer service, we may entrust service providers to process necessary information. We require entrusted parties to process information in accordance with our instructions, this Policy and applicable laws and regulations.

Except in the following circumstances, we will not share, transfer or publicly disclose your personal information to third parties:

• where we have obtained your separate consent;
• where necessary to perform statutory obligations or to respond to lawful requests from competent authorities;
• where necessary to protect the personal or property safety of you, other users or the public, or the security of the Service;
• where personal information must be transferred due to a merger, division, dissolution or declaration of bankruptcy, in which case we will require the recipient to remain bound by this Policy.

Third-party services. The third-party services we use, the purposes of processing and the scope of information involved are set out in the Cuebao Third-Party Information Sharing List. We will update that list whenever the third-party services change.

3. Storage of personal information

Personal information collected and generated during our operations in the Chinese mainland is stored within the Chinese mainland. We will not transfer such personal information 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.

We retain personal information only for the shortest period necessary to achieve the purposes of processing. After an account is deleted, we will delete or anonymise the personal information. 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 retention period expires.

4. How we protect personal information

We protect personal information using encrypted transmission, password hashing, access control, least-privilege principles, log auditing, identity verification, risk detection and security incident response mechanisms. The internet environment is not absolutely secure. If a personal information security incident occurs, we will perform our notification and reporting obligations in accordance with the law.

5. Your rights

You may lawfully access, copy, correct, supplement and delete your personal information, withdraw consent, delete your account, request an explanation of our personal information processing rules, or make a complaint or report. You may act through the relevant entry points within the application, or contact us at privacy@cuebao.com. To safeguard account security, we may need to verify your identity.

Withdrawing consent does not affect processing of personal information already carried out on the basis of consent before the withdrawal. Deleting or withdrawing certain necessary information may prevent the corresponding functions from continuing to operate.

6. Protection of minors

Minors should read and use this Service under the guidance of a guardian. Before a child under the age of fourteen uses functions that involve personal information, a guardian should read and agree to the Cuebao Children's Personal Information Protection Rules. Guardians may contact us to exercise rights of access, correction, deletion and account cancellation.

7. Updates to this Policy

We may update this Policy in light of laws and regulations, regulatory requirements or changes to the Service. Where a material change occurs, we will notify you through in-app prompts, website announcements or other prominent means, and we will obtain your consent again where required by law.

8. Contact us

Contact for the person responsible for personal information protection: privacy@cuebao.com. Customer service contact: support@cuebao.com. Postal address: Rm 35 Unit A03, No.17 Guangshun North St, Wangjing, Chaoyang Dist, Beijing, China.

Relationship between documents and interpretation. This Policy, together with the Cuebao Terms of Service, the Cuebao Personal Information Collection List, the Cuebao Third-Party Information Sharing List, the Cuebao System Permission Notice, the Cuebao Children's Personal Information Protection Rules and the Cuebao Data Compliance Notice, explains your rights and obligations when using the Service. Where these documents describe the same matter inconsistently, the description that is more protective of users' personal information rights and interests prevails to the extent permitted by law.

Request handling and feedback. After receiving your rights request, we will verify your identity and handle the request in accordance with the law. To safeguard account and information security, you may need to provide the necessary supporting materials relating to your request. Where a request cannot be met in whole or in part, we will explain the reason to the extent required by law.

Language versions. We may provide Chinese, English and Arabic versions. The different language versions are intended to help users understand the same rules; they do not change the legal requirements applicable to this Service in the Chinese mainland.