APUS Launcher Privacy Policy

1. Overview

APUS Launcher (this “Product”) is smart phone user system developed, operated and managed by Beijing Qilin Hesheng Network Technology Co.,ltd. (“APUS” “We” or “us”). We fully respect and protect users’ personal privacy. While providing you with quality services, we will collect, use, disclose, store and protect your personal data in accordance with this Privacy Policy (the “Policy”).

We will explain how we process your personal data in this Policy and how you may access and control your personal data.

Please completely read and fully understand this Policy before using this Product. If you have any questions about this Policy, or have any complaints or suggestions, please contact us via the methods as described in this Policy. This policy will help you understand the followings:

How We Collect and Use Your Personal Data

Process Your Personal Data Using Third Party Services

How We Process the Minor’s Data

How Your Personal Data Is Transferred Globally

2. How We Collect and Use Your Personal Data

We may collect your personal data as follows while we are providing services. These data is critical for us to realize various functions of this Product. We will use these data to help us develop and improve our products to provide better services. We will use your personal data in strict compliance with the purposes set forth in this Policy. We will inform you in advance and obtain your consent before we use these data for any other purposes than set forth in this Policy or we use the personal data collected for specific purposes for other purposes.

2.1. Category and purpose of your personal data we collect

This product is a smart phone user system product with full functionality with rich content and services. We will collect different categories of your personal data in different scenarios according to various product features, and will use these data to realize such product features.

2.1.1. Pre-activation service

In order to strictly comply with the laws and policies of the relevant countries or regions, we need to use pre-activation services to know your country or region. During pre-activation, we will send your IP address, country code (MCC), mobile phone language, system version and other information to our server. This information is only used to know your country or region, thus providing you with agreements and services that comply with that country or region. This information will be deleted within a short period of time after knowing your country or region, and will not be permanently saved.

2.1.2. Boost and Power Saving

In order to make it easier for you to experience APUS Launcher more quickly, we provide performance optimization feature to speed up the operation of your mobile phone, and provide power-saving optimization functions (Power Saver) to extend the life of your phone and save the power. Boost and power saving are the core functions of APUS Launcher. To make it easier for you to use the above functions, you can manage the performance with the shortcuts in left-screen performance center card, boost application on desktop, and notification bar shortcuts.

In order to achieve the functions above, we need to get the phone memory information to show the proportion of your phone’s memory usage, so that you have a real-time understanding of the current situation of phone’s performance. At the same time, we need to get the battery temperature to show the CPU temperature and expected battery life in the left-screen performance center card. And, we need to get the information of applications which are running, so that we can use the boost function to clear the running application to accelerate mobile phone. We need to obtain the battery power of the mobile phone for the APUS Power Saver application to display the remaining power of mobile phone so that you can quickly grasp and manage the power of mobile phone.

2.1.3. Desktop Application Arrangement

Arranging applications on the desktop is a necessary function for APUS Launcher. We need to obtain your application list information to organize applications on the desktop. We need to obtain application activity information and read the application’s state changes (uninstall, update, install) so that applications on the desktop can instantly update the status. For example, if you uninstall an app, the corresponding app icon will disappear on the desktop. When you install the app, the corresponding app icon will appear on the desktop instantly.

2.1.4. Smart Folders

To organize and manage applications conveniently on your mobile phone and enable you find applications quickly, we provide Smart Folders to classify applications intelligently. In order to realize this function, we need to obtain the application list information of the mobile phone and upload it to the server. The server will automatically classify the applications through the cloud classification strategy and create application folders automatically for you on APUS Launcher, to make you find applications faster through applications category.

2.1.5. Application Smart Rank

In order to find applications more quickly on APUS Launcher, we provide the function of application smart rank. Smart rank is a special feature of APUS Launcher. In order to realize this function, we need to obtain your application list information and the application activity information through your manually opening usage permit to place your frequently used applications on the your first two screens, making you find common applications quickly on the desktop, and the applications in the folder will be ranked by usage frequency, allowing users to find applications quickly in the folder;

2.1.6. Allapps

Allapps is a necessary feature of APUS Launcher. It displays all your apps on the Allapps interface, sorted by first letter, to find applications quickly. In order to realize this function, we need to obtain your application list information to arrange applications in Allapps, and to obtain application activity information, ie reading the application state changes (unload, upgrade, install), so that the application in Allapps can update status instantly. If the application is uninstalled, the corresponding application icon will disappear in Allapps. When the user installs a new application, the corresponding application icon will instantly appear in Allapps. We obtain the application’s activity information (application usage history) to display the apps you recently used on Allapps interface to find recently used applications.

2.1.7. Widget List

The widget list can display the widget corresponding to each application in the mobile phone. You can add any widget to the desktop. To achieve this function, we obtain the widget information of the mobile phone so that the widget corresponding to each application in the mobile phone can be displayed in the widget list. We will get application list information so that each widget’s application information can be displayed in the widget list

2.1.8. Required Information

To show you the current time and date instantly, APUS Launcher will get the system time and date information to display the system time and date in the clock weather widget.

The commonly used switches of mobile phone are the most commonly used function of your mobile phone, including switching automatic brightness switch, vibration switch, data network switch, mobile phone mode switch, flashlight switch, screen rotation switch, ring switch, bluetooth switch, wifi hot-spot switch, wifi switch And GPS switch. To facilitate the user to operate these switches in the most convenient way, APUS Launcher will set shortcut switch entries in the notification bar, settings center, Free Swipe and lock screen interface. In order to realize this function, we need to obtain the switch status and wifi name information of the mobile phone so that you can quickly operate and manage the common system switch of the mobile phone.

2.1.9. Unread Messages

Showing your number of unread messages and missed calls is a necessary feature of your mobile phone desktop, making it easier for you to get unread messages the first time. In order to realize this function, we will display the number of unread messages on the phone and SMS icon in APUS Launcher Dock bar. Therefore, you need to enable the call permit to obtain the unread quantity of call records so that we can display your missed calls number. We need you enable SMS permit to get the number of unread text messages to display your missed calls on the SMS icon.

2.1.10. The beautification of mobile phone

The beautification of mobile phone is the core function of APUS Launcher. APUS Launcher will recommend beautiful mobile wallpaper for you when the application is initialized. In addition, you also have the option to continue to use the default wallpaper used by your previous mobile desktop. In order to realize this function, APUS Launcher needs to read the default mobile wallpaper of the original desktop of mobile phone, so that you can choose to use the original mobile wallpaper and wallpaper recommended by APUS Launcher.
APUS Launcher will provide theme & wallpaper store where you can choose to download and apply your favorite theme or wallpaper in order to beautify your mobile phone. In order to realize this function, APUS Launcher need to get your browsing record of theme and wallpaper to recommend themes and wallpapers you may like; Need to get local info of your theme and wallpaper to display the theme and wallpaper you used in “My” feature, and you can directly apply downloaded themes and wallpapers; Need to get the status of phone network to remind you to download the HD wallpaper in wifi status.

2.1.11. Sharing

When you use APUS Launcher, you may use sharing function in multiple functions such as theme wallpaper, news, and APUS Know. In order to experience the sharing of this core function better, you need to obtain the application list information of the mobile phone, which is used to prompt to share the corresponding apps according to sharing types (text, pictures, links, etc.) of different functions.

2.1.12. Preventing Crash

In order to use APUS Launcher normally, we need to prevent the program from crashing due to full memory space and forced writes. APUS Launcher needs to obtain the storage information of the mobile phone in order to monitor the state of the remaining storage space and avoid forcing write to the storage space to prevent the program from crashing.

2.1.13. HD Icon

The beautification of the mobile phone is the core function of APUS Launcher. APUS Launcher will recommend more uniform and exquisite HD application icons for you. You also have the right to continue to use the default icon of the previous mobile phone desktop. To achieve this function, APUS Launcher needs to read the application list information to display the HD icon and the default display icon of the installed application in the setting center, so that you can select one icon styles to display on the desktop.

2.1.14. Account Information

We need you to provide email, mobile phone number and password to create your account. You can use the email or mobile phone number to receive the verification code to verify the authenticity and validity of the account. At the same time, the email or mobile phone number information provided by you will also be used. We will contact with you to get in touch with the communication method. When you create an account, you can share the theme wallpaper, upload wallpaper;

We provide you with the point mall function, you can get points rewards (including signing in, inviting friends, etc.) in the product by completing tasks, and use the points you get to exchange virtual prizes or physical goods. In order to realize the permanent preservation and redemption of points, you need to register and log in. For detailed policies on the use of accounts and points, please refer to account privacy policy details
When you’re not signed in to a APUS Account, we store the information we collect with unique identifiers tied to the device you’re using.
When you’re signed in, we also collect information that we store with your APUS Account, which we treat as personal information.

2.1.15. Search History

In order to facilitate you to view and use past search keywords, we provide search records. To do this, we need to save the keywords that you have searched for, to display them on the search page, so that you can click directly from the search page to finish searching without entering keywords again.

On mobile phones that support speech recognition, we provide you with voice search capabilities. We support speech recognition programs that evoke the system. The system’s speech recognition program recognizes your speech and converts it into text and returns it to us. We search for this text through the search function. We will not apply for permission throughout the entire process and will not collect and store any data related to your voice.

To make it easier for you to search for the applications and games you need, this product provides you with search functions for applications and games. With your search keywords, you can quickly find applications and games that interest you. At the same time, we will also identify the installation of the application and game for you, so that you can understand the use of information faster. In order to satisfy the above functions, we need to use the search keywords you entered so that our servers can handle your needs more directly. At the same time, we need your application list to compare the application or game in the search results and complete your judgment on whether to install.

2.1.18. Remember Search Engines and Search Categories

In order to use the search engine and search categories you previously set up during the search, we help you save your previous settings so that you do not need to repeat settings. To do this, we need to remember your search engine and search category settings.

In order to facilitate your quicker search or visit the website, we provide you with a quick search function. On the input page, we will check if your clipboard has new content. If the clipboard has new content, we will get it and display it so that you can click directly on the search or visit.

2.1.20. Hot Words Ranking

The hot word leaderboard feature shows you the search content that most users click on in some countries. The content is sorted by user clicks so that you can understand the local search hot words. In order to facilitate the real-time updating of hot words, we need to collect hot news information that you need to click for statistics.

2.1.21. Download Management

The download management function allows you to download multiple files at the same time, manage the download progress of each file, quickly find or delete already downloaded files, and can automatically start a download task that has not been completed due to network anomalies. In order to achieve these functions, we will save the download status information, such as: wait for download, pause download, network interruption, etc.; perform status display, and use this information to determine whether to continue downloading.We also save download file information and when the download started and completed so that you can quickly find or delete downloaded files by name and time. We provide the ability to delete download tasks. You can delete the download tasks one by one or delete them all at one time according to your needs.

2.1.22. News & Content

Providing high-quality news content for the most of users is the core feature of APUS Launcher, in order to grasp your favorite news content the first time. APUS Launcher need to get your city information so as to recommend local content for you through the news; Need to get news browsing record info to recommend news you may like.

2.1.23. Privacy & Safety

To protect your data and privacy, APUS Launcher provides feature of Applock, which can encrypt your privacy application, and you can only open locked applications with a password. In order to realize this function, APUS Launcher need to get application list information for which applications you can choose to lock; Need to get the status of your application, so password page can appear instantly when you open the locked application; Need to get the password you set (the password will be encrypted) and secret question, used to unlock or recover the password.
APUS Launcher also provides feature of hide apps to protect user privacy, you can hide privacy applications to prevent others from seeing. To experience hide apps normally, APUS Launcher need to get your application list info so that you can select to add hidden applications from application list; Need to get the password you set (the password will be encrypted) to open hidden applications and need to get secret question to recover password.

2.1.24. Smart Center

Smart Center is the core feature provided by APUS Launcher to users, which allows you to quickly browse and operate some common functions. Recent card can display your recent clipboards, and APUS Launcher need to get your clipboard content to display in recent card; To display the notes you input on the Note Card, APUS Launcher need to get the text info you manually enter to display the notes you entered on the note card; To display your most frequently used applications, Need to get application list to show application icon, name, etc, and need to get application activity info to show your most frequently used application.

Local App Search: We provide local app search function to help you quickly search for installed apps. To do this, we need to use your app list data, including app package name, app icon, app name, to match the app you want to search for and to display on the search page;
Contact Search: Our search function supports searching contacts in the address book to help you quickly find the phone number of your family member or friends. Once found, you can call directly. This requires the use of your address book information, including contact names, avatars, and numbers;
SMS Search: In order to help you quickly search for historical messages sent and received, we provide SMS search function. This needs to use your SMS information, including: SMS content, SMS time, SMS contact information;
Music & Video Search: Our search function supports searching for local music and videos to help you quickly find songs and videos in your phone. This requires the use of your multimedia file information, including: file name, title, artist, path, topic;
Schedule search: Our search function provides schedule search function to help you search for your added schedule. For example, you can search for information on train tickets that you have added, your friends’ birthdays, and so on. This requires the use of your calendar information, including: title, location, description, start time;
Settings Search: Our search function supports searching for system settings and APUS settings to help you quickly set up your mobile phone, saving time and operating cost. For example, you can search for WLAN, Bluetooth, GPS, and more. This needs to use your system info to match the name of the setting item you are searching for.

2.2. Your personal data we obtain from a third party

We may obtain your personal data types and their uses from third parties as follows:

a) We can obtain your data from third parties through the application interface. We will get your Facebook account data (Facebook account’s gender, avatar, nickname, account ID, account email), which will be used to quickly log in to the Facebook account in the function of Circle in Discovery, and can show the user the basics of the people nearby. We do not use this account information in other places;

b) We will obtain the number of your unread messages through APUS Message Center application to facilitate unobtained messages the first time.

We will give you special tips when you initiate the above-mentioned features concerning special types of personal data, inform you once again about the special types of personal data that may be collected, and obtain your express consent

Cookie is a small piece of text sent to a browser by a website visited by a user. It helps the browser to record user access information, such as preferred language and other settings. In this way, users will have an easier and more practical experience when they visit the same website the next time. Cookie play a vital role. Without cookie, the user’s experience of Internet will be greatly reduced, and some website features or services may not even work properly. We use cookies to provide you with a complete web browsing service. We do not collect cookie information ourselves. Please note that the websites you visit may use cookie to store your preferences, settings, login status, etc. For example, when you visit a web page that has a login function for the first time, you need to enter a user name and password to log in. After logging in, the website will record your login status, When you switch different pages under the site, you do not need to re-enter the user name and password, you can directly browse the content of the web page. Websites may use cookie to recommend advertisements. For example, some websites use cookie to record websites that you click on to prevent you from seeing duplicate advertisements. We provide the ability to disable and delete cookies. You can disable or delete cookies.

To make it easier for you to open web pages, we provide web page caching. We allow websites you visit to store some web page data, such as web page pictures and other information. When you visit the site next time, the site will directly read the saved data for display, thereby to open the web page fast. The cache will expire due to expiration or manual removal. We will not upload any cached content.

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

We will share with or transfer or disclose your personal data to a third party with your consent or explicit instructions. In addition, to improve the quality of our service, we may also share with or transfer or disclose your personal data to a third party under the following circumstances.

4.1. Subsidiary Products

We may share your personal data with our subsidiary products to provide a more consistent experience and better service. We guarantee that our subsidiary products will treat your personal data in accordance with the purposes and requirements shown in this Policy. We will obtain your prior consent again if our subsidiary products wish to use your personal data for purposes other than those set forth in this Policy.

4.2. Affiliated Company

We may share your personal data with our affiliated companies and will ensure their processing of your personal data is in compliance with the purposes and requirements of this Policy. We will obtain your prior consent again if affiliated companies intend to use your personal data for other purposes than set forth in this Policy.

4.3. Third party service provider

We may engage third party service providers to provide specific services. Third party service providers may collect data when providing services, and we will ensure that they follow our instructions, follow the purposes and requirements set out in this policy to process your personal data, and take appropriate confidentiality and security measures to safeguard data security.

4.3.1 Search Function

In order to provide you with comprehensive search results, we provide you with a variety of different search engines for your choice. The search engines we use include: Google, Bing, Yahoo, Aol, Ask, Baidu, Sogou, DuckDuckGo, Yandex, Naver, Daum and their corresponding contracting agencies. You can choose your favorite search engine. When you search, we will use your search keywords, go to the search engine server you selected or its corresponding contracting agency server, and finally display the query results to you.

4.3.2 Search Suggestion

In order to help you quickly find the content you want to search for, and provide more accurate search results, when you enter keywords, we recommend some search suggestions that you may need based on your language, your locale and what you entered. In this process, we go to the Google search suggestion server according to your language, your locale and the keywords you entered. We will show the results to you when the other party query the search suggestions that matches your language, your locale and the keywords you entered. You can directly select the search suggestions you want to search for. In the process, we will not collect any of your personal data.

4.3.3 Visiting a Web Page

In order to realize the function of browsing the webpage, we will request the content of the webpage according to the webpage link address you provided, and then display the content of the webpage returned by the server. In this process, website may collect your relevant data,such as user agent, cookies, browsing track and so on. In addition, to implement special functions in certain web pages, the website may use the browser to apply for the location of your address or mobile phone file information, for example: pictures that need to be uploaded to the avatar, and microphone information. After you authorize it, the website can display related functions.
In addition, when you use the search, news, and discovery features in APUS Launcher, you may directly visit third-party web sites, which may collect your data without APUS’s knowledge. When you visit these sites, we will use toast to alert you with data security.

4.3.4. Statistics

In order to analyze data and provide you with better services, we use the services of third-party. The service needs to obtain your information including: application package name, application version, application installation time, system version, Android ID, country information, mobile phone language information, mobile phone brand, mobile phone model. The information obtained is only used for this purpose.

4.3.5. Anti-fraud and Anti-Cheat

In order to prevent fraud and prevent cheating, and to provide you with better services and better ecological environment, we use Digital Union’s services. The service needs to obtain your information including: application package name, application time information, application version number, installation path, application size and other application information; CPU, screen resolution, total memory information and other hardware general information; country code, start-up time, system time and other system information; mobile phone brand, mobile phone model, memory, CPU and other equipment hardware information. The information obtained is only used for this purpose.

4.3.6. APUS Launcher Theme Application

In order to display whether the user is using the theme in a stand-alone theme application belonging to APUS Launcher, we will give APUS Launcher whether the application corresponding themes information is given to the themes application to which APUS Launcher belongs.

4.4 Share of your personal data as required by law

Subject to compliance with this Policy, we may be required to share or disclose your personal data under certain circumstances, such as in accordance with laws and regulations, and compulsory requirements of government orders; to safeguard the legitimate rights and interests of yours, ours, and third parties; and to prevent or deal with fraud, secure or technical problems.

4.5 Change of organization and existing status of our company

For any change of the organization or existing status of our company (such as restructuring, merger or bankruptcy), your personal data may be transferred to the company entity after change or our affiliated company (the “Data Transferee”). The Data Transferee will continue to be bound by this Policy.

5. Process Your Personal Data Using Third Party Services

The Product may contain a hyperlink directing to third party products or services, such as a hyperlink to another website. You may click the hyperlinks in this Product to access third party products or services. Meanwhile, we may also embed third party links in this Product and you may click these links to access or use third party products or services on the interface of this Product. We hereby remind you that when you access or use third party products or services via the above methods whereby your personal data will be obtained by such third party products or services, the privacy policies of such third party products or services will apply to such personal data.

6. How We Store and Protect Your Personal Data

6.1. Security protection of personal data

We are committed to protecting your personal data. We have adopted all possible security technologies and procedures to protect your personal data against unauthorized access, use, revision, damage, destruction or disclosure. These security measures mainly include the following:

a) Your personal data is stored in the computer systems located in a controlled site with security measures such as encryption.

b) Only APUS employees who have the necessity to process relevant data for the purpose of product operation are authorized to access your personal data and such employees are required to comply with strict confidentiality obligations.

c) We are constantly striving to ensure the security of your personal data, and we adopt encryption technologies during data transmission to prevent your information against unauthorized access, use, revision, damage, destruction or disclosure.

d) We are more prudential when we transmit and store special categories of your personal data and adopt encryption technologies and other security measures to ensure data security.

In case of personal data security incident, according to the requirements of relevant laws and regulations, we will promptly inform you via push notification, announcement, etc. the basic situations and possible influence of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc. We will timely deal with system vulnerabilities, cyber-attacks, virus intrusion, and other security risks.

6.2. Personal data storage term

We will store your personal data for the necessary period for data collection and processing purposes. Beyond the above-mentioned period, we will delete or anonymize personal data.

6.2.1 Data that need to be uploaded to the server

Application List: For the above-mentioned smart folder function of APUS Launcher, the application list data will be saved in the server for data analysis and improvement functions. For example, if we find that the cloud classification is irrational through data analysis, we need to re-enumerate and formulate the application list, making new cloud classification strategy to improve user experience;

Users browse data: The data of users’ browsing themes & wallpapers, news, and application will be uploaded to the server for personalized recommendation of related content. We only provide corresponding services after users’ data authorization, and these data will be saved on the server at most 30 Days, then delete processing will be performed. Users can also turn off personalized content recommendations in settings center. After turning off, we will not provide personalized recommendations.

The location information, application list information, and browsing information through users’ using APUS Launcher discovery are stored anonymously on the server to recommend data nearby to users so that the functions can be used normally.

Feedback content submitted by the user in APUS help is uploaded to the server. Users can manually clear the feedback on the feedback page.

The image information uploaded by the user in the UGC function of the theme & wallpaper application will be uploaded to the server, and users can delete it through the Dashboard;

The keywords used in the game and application search will be uploaded to the server, and users can delete it through the Dashboard;

Other location information will be uploaded to the server. These data will be stored on the server for up to 30 days and will be deleted later.

6.2.2 Data Not Saved

Memory information, running application information, hardware information, application activity information, system information, call information, text message information, multimedia file information, storage information, address book information, clipboard content, schedule information, input information, and the collected clipboard contents, URLs accessed, application list, message information, contact information, multimedia file information, calendar information, and mobile phone system settings When using the search function, are not stored in the mobile phone. The temporary acquisition for data is done when the corresponding functions are used;

The password information of the user setting information, we use the hash algorithm to encrypt the password, and the algorithm can not be traced back to ensure the security of the data;

6.2.3 Saving Local Data

Application list, widget information, location information, theme and wallpaper information, these data information will be stored locally, will only be used for the functional purposes above, in order to be able to call the data at any time to achieve the corresponding function, these data will be available in the application life cycle, Users can go to the system settings to manually clear the data;

Your search history, bookmarks, web page data, cookies, downloaded file information, search engines, and the settings of search categories are stored locally during the application life cycle and can be manually cleared in settings.

6.2.4 Account Information

Your account information (including gender, nickname, name, phone number, email address, birthday, personalized signature, city or region, address, educational history, interests, career information) will be used to display in your profile and Edit (including modification and deletion). Before you cancel your account information, we will save this information and use it strictly in accordance with the purpose above. When you cancel your account or delete your account information from your profile, we will delete or anonymize this data;

After you delete your account, for technical reasons, we may not be able to delete your personal data immediately; however, we will delete it at the next system update, and we guarantee that we will not continue to process your personal account during your time when you log off the account until we update the system.

7. How You Access and Control Your Personal Data

7.1. Access and revise your personal data

You may access and edit your personal data online through APUS User Information Center.

7.2. Change of your authorization scope

You may select on the page of APUS User Information Center to change your authorization scope for us to process your personal data. Please be minded that since all functions of the Product need certain basic personal data for normal operation, certain functions of the Product may not operate normally when you withdraw your consent to processing of some personal data.

When we receive your withdrawal of consent, we will no longer process your corresponding personal data.

7.3. Rejection of personalized advertising

You may always choose whether to receive promotional emails, messages, calls, and mails from us or third parties. You may also choose to no longer receive personalized advertisements through APUS User Information Center.

We will no longer use your personal data for the above-mentioned commercial promotion purposes when you refuse to receive personalized advertisements.

7.4. Delete your personal data

You may submit a request to us to delete your personal data when:

a) Your personal data is no longer necessary for data collection or processing;

b) You have withdrawn your consent to our processing of your personal data ;

c) Your personal data has been processed illegally;

d) We are obligated to delete your personal data in accordance with the laws of EU members.

We may not be able to delete your personal data immediately due to technical reasons. We will delete it during the next system update. We will not process your personal data in any way during the period between your request of deleting your personal data and the next system update.

7.5. Respond to your requests

We may first verify your identity upon receipt of your request, and may request you to provide the necessary information for authentication.

We will respond to your request on the 30th day after we receive your request and communicate with you in an appropriate way. If necessary, we may extend it (by an additional 30-day at most), and will inform you of the reason for the extension of the deadline on the 30th day after receiving your request. If we have reasonable reasons to believe that no measures are needed to respond your request, we will inform you of our decision 30 days from the date of receipt of your request and provide you with appropriate explanation.

We will use best efforts to help you resolve relevant problems. If you are not satisfied with the response you received, you may refer the complaint to the relevant regulatory authority, or file a lawsuit before a competent judicial authority.

8. How We Process the Minor’s Data

This Product is not intended for a minor under 16 years old (or equivalent minimum age set by the laws of EU members). We will only process the information of these minors to the extent permitted by law and with the consent of their guardians.

We will implement relevant technical measures and make our best efforts to verify whether the processing of minors’ information has been approved by their guardians. We will try to delete relevant data as soon as possible if we are aware that we have collected the personal data of a minor without the prior consent of their certified guardians.

9. Contact Us

If you have any questions or suggestions about this policy, or you need to exercise your data management power to manage your private data, please feel free to contact us at:launcher_privacy@apusapps.com . If you find any violation of the Policy, please feel free to contact our DPO at: dpo@apusapps.com

10. Update of Privacy Policy

We reserve the right to revise or modify this Policy. For any update of this Policy, we will send you notice on the interface of this Product to remind you of relevant updates and indicate the updated provisions for your ease of reading. Please do completely read and fully understand the updated Privacy Policy. By continuing to use this Product, you will be deemed to have accepted the updated version of this Policy. We will not reduce your rights under this Policy without your explicit consent.

11. How Your Personal Data Is Transferred Globally

We provide APUS products and services around the world, which means to conduct business globally, your personal data might be transmitted to a jurisdiction or accessed from such jurisdiction outside of the country/region where you use this Product. These jurisdictions include but are not limited to Singapore, United States, and China.

Please note that we only return demographic information to China and we do not include information on individual user identities. At the same time, in order to provide you with better services, our third party partners may transmit your data to other countries. For example, in order to detect robots or cheating, we have purchased a Chinese supplier’s traffic monitoring service. The merchant may return the user information to China in order to assist us in analyzing whether there is cheating in the user.

Personal data protection legislation in such jurisdiction might be different or even absent. Under such circumstance, we will adopt various measures to ensure security of your personal data. For instance, we will ask you for your explicit consent before transmission of your personal data, or implement security measures such as encryption and pseudonymisation during data transmission; when your personal data is transferred to such jurisdictions, we will apply the same protection of your personal data in accordance with the Policy. We will endeavor to protect your personal data with the measures stipulated in Article 46 and Article 47 of the EU General Data Protection Regulation.

Last updated: [June 22,2018]