MsgCenter Privacy Policy

1.Overview

MsgCenter (this “Product”) is a smart phone information management software developed, operated and managed by Beijing Qilin Hesheng Network Technology Co.,ltd. Limited (“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
- How We Use Cookie and Similar Technologies
- How We Share, Transfer and Disclose Your Personal Data
- Process Your Personal Data Using Third Party Services
- How We Protect Your Personal Data
- How You Access and Control Your Personal Data
- How We Process the Minor’s Data
- How Your Personal Data Is Transferred Globally
- Contact Us
- Update of Privacy Policy

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 full functionality browser product 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. Sms function

In order to allow you to see messages received in the message center and send, reply, and forward messages to the contacts, we provide you with SMS related functions, such as a list of messages displayed on the front page of a message center, sending or replying messages at the message center, putting a contact message session on top of the display, etc. . In order to achieve this function, we need to read and record your contact information and message information in the local, including short message content, contact name, telephone number, contact head image. We provide the function of deleting text messages in the message center.

2.1.3.Third-party message management

In order to facilitate your timely view and management of the message notifications received from third party applications, we provide you with the functions of third-party message aggregation, message grouping, and notification bar management. For example, we display messages in a list in the form of a list of third-party social applications that you receive, and you can divide the same message into a set of displays. In order to achieve the above function, we need to get the read permissions of the notification bar and record your notification column local, including the notification source and the notification content, so that you can manage the notification message. You can control what application information is received in settings.

2.1.4.Contact manager

In order to help you quickly find the social way of contacts, we provide you with contact management functions. For example, we display a contact in the form of a list in the message center, and on the right side of the interface show the possible social way of the contacts, phone, SMS, mail, social applications, and you can drag a contact to the desired open icon and jump directly into the chat interface between you and the contact. In order to achieve this function, we need to get your contact information, including contact name, head image, phone number, mailbox address, and we will also get installed application information so that you can quickly locate a contact for a contact application.

2.1.5.Call record and dialing

MsgCenter provides you with the function of call recording and dial-up keyboard. We display all the phone calls in the phone list in the form of lists, and you can dial the phone directly in the message center. In order to make you use this function normally, we need to get call record information to implement the display and edit management of the call record list, including the telephone number, the way to call (the incoming calls, the unanswered calls, the dialed and rejected calls), and the time of the call. Meanwhile, in order to help you quickly select contacts in dialing, we need to read your address book contact information.

2.1.6.Message remind

In order to facilitate your timely viewing of important messages received, we provide you with the function of message reminders. When the message center detects that you have received a new unread message from SMS, phone, mail, and third party applications, the reminder bubble on the desktop message center displays the corresponding application icon to prompt you to have new messages. In order to achieve the above functions, we need to get your SMS, call records and notification bar messages, including the source and content of the notification message. At the same time, in order for you to use this function normally, we need to open the permissions of the suspension window to ensure that you can receive the reminder of the message in time. You can turn off the function at any time in settings.

2.1.7.Search

MsgCenter provides you with the function of searching all information contents in application, including summary information, third party messages, contacts and call records. We will read short message information to implement the corresponding message content of the specified search; read the contact information of the address book to find the corresponding contact quickly; read the information of the notification bar to search the content of the third-party message; read the call record quickly to find the call record.

2.1.8.Integral mall

Through a registered account, you can obtain integral rewards (including signing in, inviting friends) in the product by completing the task (including signing in, inviting friends) to exchange virtual prizes and physical goods. Please refer to the [account privacy policy details] for detailed policies on account and integral usage.

2.2.Your personal data we obtain from a third-party

For now, we do not obtain your personal data from any third-party. If certain services may require your personal data from a third-party, we will notify you in advance and obtain your 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 webpage 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.

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. installation channel attribution

In order to provide a better service for the installation of channels, we use the services of third party providers. The service needs to get your information included: application package name, application version, application installation time, system version, Android ID, national information, language information, brand, model. The information obtained is used only for this purpose.

4.3.2. 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.

4.4 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.
Browsing history, bookmarks, web page data, cookie, downloading file information, and search history are all stored locally and are available throughout the application lifecycle. You can manually clear this data at any time.
The link address of the user’s visiting webpage collected by the secure browsing function is stored anonymously on the server for data analysis.

After you cancel your account, we may not be able to delete your personal data immediately due to technical reasons; however, we will delete it during the next system update, and we undertake not to process your personal data during the period between cancellation of your account and the next system update.

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 interest-based 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 interest-based 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 interest-based 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 on this policy, or you need to exercise your data management power and manage your privacy data, please contact us at any time. The contact way is: msgcenter-privacy@apusapps.com.

If you find any violation of this policy, please contact our DPO at any time. Contact is: 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.

The content of this Privacy Policy shall be adjusted according to the local legal or statutory requirements.

Last updated: [May 15, 2018]