Introduction

Welcome to the products and services provided by ZHANGHUI TECH LIMITED. When you use our products, we may collect and use your relevant information. We are committed to protecting the privacy of users (hereinafter referred to as "users" or "you") who use ZHANGHUI TECH LIMITED products and services.

We will update and review this Privacy Policy from time to time, and related measures will change accordingly. We kindly request that you periodically check this page to ensure you are always informed of our Privacy Policy.

This Privacy Policy mainly explains the following to you:

• What information we collect;
• The purposes for which we collect information;
• Your rights.

This Privacy Policy applies to all products and services under ZHANGHUI TECH LIMITED. When you use any of our products and services, you agree to the contents described in this policy.

I. Information We Collect

1. Non-Identifying Information

When you use ZHANGHUI TECH LIMITED products and services, we may collect information such as the user's source path and access sequence. For example, recording each user's source path, browser information, etc.

2. Registration Information

When you use ZHANGHUI TECH LIMITED registration services, we may collect your personal registration information, such as: personal identification (including ID card, passport, driver's license, etc.), place of origin, gender, personal mobile phone number, network identity identifier (including account, IP address, email address, and related passwords, password protection information, passcodes, passcode protection information, etc.).

3. Product Device Information

When you use ZHANGHUI TECH LIMITED products, we may collect your device information (including device model, device MAC address, operating system type, device settings, etc.), software list, unique device identifiers (such as IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information, and other information describing the basic situation of a user's commonly used devices).

4. Product-Related Information

When you use ZHANGHUI TECH LIMITED products, we may collect and summarize information such as your game virtual currency, game balance, game type, game records, etc.

II. How We Collect and Use Information

1. Information You Provide

a. Information you provide to us when you register for a ZHANGHUI TECH LIMITED product service account or use ZHANGHUI TECH LIMITED product services;

b. Shared information you provide to other parties through ZHANGHUI TECH LIMITED products, and information stored when you use ZHANGHUI TECH LIMITED products;

c. Your information shared by other parties;

d. Information we obtain when you use ZHANGHUI TECH LIMITED products or services, such as: log information, device information, network information, etc.

2. Cookies, Logs

We may obtain and use your information through cookies and store this information as log information. By using cookies we provide users with a better online experience. We use cookies to benefit users. For example, making the login process faster when using ZHANGHUI TECH LIMITED product services. Cookies help us determine which pages and content you connect to, enable us to serve you better and faster, and make your experience with ZHANGHUI TECH LIMITED richer.

You can control whether cookies are accepted by your device. Please consult the documentation accompanying your device for more information on this.

3. We use cookies for the following purposes

a. Remembering your identity. Cookies help us identify you as our registered user, or save information you have provided to us about your preferences or other information;

b. Analyzing your use of our services. We may use cookies to understand which activities or services you prefer when using ZHANGHUI TECH LIMITED products.

Non-personally identifiable information collected through cookies for the above purposes may be provided to other partners for analyzing how you and other users use ZHANGHUI TECH LIMITED product services.

Our products or services may place cookies, which may collect non-personally identifiable information related to you for analyzing how users use our products and services. You can control cookies through user selection mechanisms or user management. If you stop using cookies, we may not be able to provide you with the best service, and some services may not function properly.

III. We Collect and Use Your Information for the Following Purposes:

1. To Help You Quickly Complete Registration

To facilitate our provision of services to you, you need to provide basic registration information, such as personal identification, mobile phone number, etc., and create your username and password.

2. To Provide You with Prizes and Services

a. In some service projects, to provide you with prizes or services, you may need to provide personal identification information, name, shipping address, postal code, recipient, contact number, etc. If you refuse to provide such information, we will be unable to fulfill the prize provision or service;

b. When you contact us, we may save your communication/call records and the contact information you left, so that we can contact you or help you solve problems;

c. To provide you with prizes or services, we may collect information such as the logistics information and prize information you have selected, and may share this with the aforementioned service providers.

3. To Send You Notifications

We may send you service-related notices when necessary (e.g., suspension, maintenance, etc.), so that you can be better informed about the status of our services.

4. To Improve Our Services

We may use information collected through one ZHANGHUI TECH LIMITED product for our other products. We may invite you to participate in surveys concerning ZHANGHUI TECH LIMITED products to help us improve our existing products and services or design new ones.

5. To Provide You with Security

To verify your identity and provide you with better security, you may provide us with sensitive personal information such as identification documents to complete real-name authentication.

Apart from identity verification, we may use your information for customer service, security prevention, fraud monitoring, archiving, and backup purposes to ensure the security of the services we provide to you. We may use or integrate the information we collect about you, as well as information our partners obtain with your authorization or share according to law, to comprehensively assess your account, perform identity verification, detect and prevent security incidents, and take necessary records, audits, analysis, and disposal measures in accordance with the law.

IV. Sharing and Disclosure

1. Sharing

Without your explicit consent, we will not share your information with any third party outside of ZHANGHUI TECH LIMITED.

a. To provide services to you, we may share your information with partners or third parties, such as logistics services;

b. To achieve the purposes described in Section II "How We Collect and Use Information" of this Privacy Policy;

c. To maintain and improve our services. We may share your information with partners and other third parties to help us provide you with more targeted and improved services, such as communication service providers sending emails or push notifications on our behalf;

d. To fulfill our obligations under this Privacy Policy or other agreements we have reached with you, and to exercise our rights;

e. To share with third parties such as partners who entrust us with promotions. However, we only provide these clients with information on the reach and effectiveness of the promotion, and not information that can identify you, such as name, phone number, or email address; or we aggregate this information so that it does not identify you personally;

f. To the extent permitted by laws and regulations, in order to comply with the law, protect us, our affiliates or partners, you, or other ZHANGHUI TECH LIMITED users or the public interest, property, or safety from harm, such as preventing fraudulent and other illegal activities and reducing credit risk, we may exchange information with other companies or organizations;

g. To assist in handling disputes or conflicts between you and others upon your legitimate request;

h. To provide your information upon the legitimate request of your guardian;

i. To provide information as stipulated in a separate service agreement (including electronically signed agreements online and corresponding platform rules) or other legal documents signed with you;

j. To provide information based on academic research;

k. To provide information based on social public interests in accordance with laws and regulations.

We will only share your information for lawful, legitimate, necessary, specific, and explicit purposes. With companies, organizations, and individuals with whom we share information, we will sign strict confidentiality agreements and require them to process information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

2. Disclosure

We will only disclose your information in the following circumstances:

a. Subject to security protection measures that meet industry standards;

b. With your explicit consent, disclosing information you specify according to your request;

c. In cases where providing your information is necessary due to legal or regulatory requirements, mandatory administrative law enforcement, or judicial requests, we may disclose your information according to the type of information requested and the method of disclosure. In compliance with laws and regulations, when we receive such requests for information disclosure, we will require the receiving party to provide corresponding legal documents, such as subpoenas or investigation letters.

V. Protection and Processing of Your Information

1. Data Security Technical Measures

a. We will adopt security protection measures that meet industry standards, including establishing reasonable system specifications and security technologies to prevent your information from unauthorized access, use, modification, and to avoid data damage or loss;

b. Network services have adopted multiple encryption technologies, such as SSL, TLS, etc., to protect your information;

c. And isolated through isolation technology;

d. When using information, such as information display and information correlation calculation, we will use multiple data masking techniques to enhance the security of information in use. Strict data access control and multi-factor authentication technologies are used to protect information from unauthorized use.

2. Other Security Measures Taken to Protect Information

a. Regulating the storage and use of information by establishing data classification and grading systems, data security management specifications, and data security development specifications;

b. Comprehensive security control of data through confidentiality agreements with information handlers, monitoring, and auditing mechanisms;

c. Strengthening security awareness. We also conduct security and privacy protection training courses to enhance employees' understanding of the importance of information protection.

3. Only allow necessary personnel to be aware of this information and ensure they do not record or save it.

Strict access control and monitoring mechanisms have been set up for this purpose. We also require all personnel who may come into contact with your information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability.

4. We will take all reasonably practicable measures to ensure that irrelevant information is not collected.

5. We will strive to ensure or guarantee the security of any information you send to us.

If our physical, technical, or management safeguards are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information, causing damage to your legitimate rights and interests, we will bear corresponding legal responsibility.

6. How to Handle Security Incidents

a. When communicating or receiving services through ZHANGHUI TECH LIMITED with other parties, you inevitably disclose your information to others, such as mobile phone numbers, email addresses, etc. Please protect your information properly and only provide it to others when necessary;

b. To address possible risks such as information leakage, damage, and loss, we have established multiple systems, clarifying the classification and grading standards for security incidents and vulnerabilities, and corresponding handling procedures. We have also established a dedicated emergency response team for security incidents. According to the requirements of security incident handling specifications, we activate security plans for different security incidents, carry out loss prevention, analysis, positioning, formulate remedial measures, and cooperate with relevant departments to combat them;

c. If a security incident unfortunately occurs, we will inform you in a timely manner in accordance with legal and regulatory requirements: the basic situation of the incident, the handling plans we have taken or will take, and possible consequences, suggestions for you to protect yourself and mitigate risks, and remedial plans for you. At the same time, we will proactively report information security incidents and handling situations to regulatory authorities as required;

d. Due to the limitations of technology and risk prevention, even though we have tried our best to strengthen security measures, we cannot always guarantee 100% security of information. Therefore, you need to understand that situations and problems may occur beyond our control.

VI. How You Manage Your Information

1. Access, Update, and Deletion

We encourage you to update and modify your information to keep it accurate and effective. You can access your information through ZHANGHUI TECH LIMITED and modify, supplement, or delete it yourself or reasonably request us to do so according to the corresponding information management method. We will take appropriate technical measures to ensure, as far as possible, that you can access, update, and correct your information or other information provided when using ZHANGHUI TECH LIMITED services.

When accessing, updating, correcting, and deleting the aforementioned information, we may require you to verify your identity to ensure information security.

2. Publicity and Sharing

During your use of our services, you will share information related to your use of the service (such as gender, nickname, etc.). Such information can be modified by you after accessing it yourself. We caution you not to fill in personal information in public information areas (such as nicknames). We are not responsible for information leakage caused by this.

3. Cancellation

In compliance with the ZHANGHUI TECH LIMITED Service Agreement and relevant national laws and regulations, your account or related information may be canceled or deleted. After your account or related information is canceled or deleted, this information will be processed in accordance with the ZHANGHUI TECH LIMITED Service Agreement.

4. Changing the Scope of Your Authorization

You can choose whether your information is disclosed, and you can change the scope of your authorization for us to continue collecting information or withdraw your authorization by deleting information, turning off device functions, etc.

5. Sensitive Information

Certain information may be considered sensitive due to its specific nature, such as your race, religion, personal health and medical information, as well as identification documents, personal biometric information, property information, travel history, and information of minors. Therefore, you need to carefully consider before using the products or services we provide to you. You agree that this sensitive personal information will be processed in accordance with the relevant terms of the Privacy Policy.

You need to carefully consider the content and information you provide in ZHANGHUI TECH LIMITED services.

VII. Third-Party Services

We select reputable third parties as our partners to provide users with information and services. However, each partner has a different privacy policy from ZHANGHUI TECH LIMITED. When you enter a third-party service, the terms of ZHANGHUI TECH LIMITED's privacy policy will no longer apply. We recommend that you review the third party's privacy policy to ensure your information is secure.

VIII. Restrictions for Minors

Any minor participating in online activities should obtain prior consent from their parents or legal guardians. We will protect the relevant information of minors and implement relevant restrictions in accordance with relevant national laws and regulations.

IX. Updates and Revisions

This Privacy Policy takes effect upon publication. We will update and revise this Privacy Policy from time to time in accordance with national laws and regulations. After this Privacy Policy is changed, if you do not accept the revised terms, you should immediately stop using ZHANGHUI TECH LIMITED products and services. If you continue to use this service seven days after the change of this Privacy Policy, you will be deemed to have accepted all revised terms.