Autotodo Privacy NoticeDownload Last updated on: 20 6, 2022 Effective date: 20 6, 2022 Update history In Section 1 "How We Collect and Use Your Personal Information", we added more legal grounds for processing personal information. We also incorporated "Personal Information We Collect" by reference to help you gain a quick understanding of what personal information Autotodo collects. We expanded Section 4 and changed the section heading from "How We Share, Transfer or Publicly Disclose Your Personal Information" to "How We Entrust, Share, Transfer and Disclose Your Personal Information". In addition, we incorporated "Personal Information We Share with Third Parties" by reference to explain how we share personal information with third parties in a clearer and more detailed manner. In Section 7 "How We Protect Minors' Personal Information", we added security measures for processing children's personal information. We optimized the organization of the content in this Privacy Notice to present the content to you in a clearer and intuitive manner so that you can better understand our privacy policy. Foreword Thank you for using Autotodo. Autotodo is a platform (this "Platform" or "Autotodo") developed and operated by Guangdong Autotodo Technology Co., Ltd. ("we", "us", or "our", registered at No. 18 Haibin Road, Wusha, Chang'an, Dongguan City, Guangdong Province, China 523902) to allow users ("you") to access websites and search for or view videos and news. We attach great importance to the protection of your personal information and privacy. We fully understand the importance of personal information to you. We have developed this full version of the Autotodo Privacy Notice (this "Privacy Notice") in accordance with applicable laws, regulations, and state standards. When you use this Platform, we may collect, store, use, process, transfer, provide, disclose, or delete (collectively, "process") your personal information. This Privacy Notice explains what personal information about you we need to process, why and how we process it, your rights to manage your personal information and the methods for you to exercise these rights, and the security measures we use to protect your personal information. [Special Notes] This Privacy Notice is closely related to this Platform. Before using this Platform, please carefully read and fully understand all the content of this Privacy Notice and related user service agreements and make the choices that you deem appropriate. Please note that we will begin to process your personal information only after obtaining your consent. According to personal information protection laws and regulations as well as related national and industry standards, should you use this Platform by choosing not to sign up or sign in (or as a guest) for special reasons, we will not collect personal information about you when providing you with the browsing functionality. This, however, will make you unable to use all the other features or services of this Platform. Regardless of the circumstances, however, if you do not agree to us collecting your personal information, you should immediately stop using or exit this Platform. To provide you with the features or services that you request or to comply with laws and regulations, we will process the necessary personal information relating to you. This Privacy Notice specifically describes what personal information is necessary to use Autotodo. Please pay special attention to such information. We do not collect personal information that is not necessary to provide services. If you do not agree to our collection of personal information in connection with extended services other than the basic services, please do not turn on the extended services. Please rest assured that app permissions will not be turned on without your authorization, which means they are turned off by default. When certain sensitive app permissions are required by our services or features, we will request your consent through a pop-up prompt at the time you attempt to use these services or features. After an app permission is turned on, you may go to the Settings app at any time to turn it off. Your denial of our permission request does not affect your use of the other unrelated services or features. In this Privacy Notice, we will describe the processing of personal information in relation to our services or features. The clauses governing the processing of sensitive personal information and those concerning your rights and interests are highlighted in bold for your special attention. In addition, we have used bold italics to draw your special attention to sensitive personal information. We will separately ask for your consent prior to the processing of your sensitive personal information. We will make continued efforts to improve our technology so as to provide you with a better experience of using our products or services. To this end, we may, from time to time, launch new or optimize our features or services, which may require us to process other additional information about you or change the purpose or method of using your personal information we collected. If the above "Update history" section does not describe the personal information collection and processing rules for a specific feature or service, we will separately explain to you what personal information we need to process and why and how we process it through updates to this Privacy Notice, pop-up windows, page prompts, interactive procedures, website announcements, and other similar methods. We will also allow you to choose whether to agree to our processing. We will process your personal information only after obtaining your express consent. If you have any questions regarding this Privacy Notice, you may contact us as set forth under Section 10 "Contact Us". We will revise this Privacy Notice from time to time. When a material change is made to this Privacy Notice as described in Section 9, we will show you the new content through a push notification, a pop-up window, or any other similar method. This Privacy Notice will help you understand: How We Collect and Use Your Personal Information How We Use Cookies and Other Similar Technologies How We Store Your Personal Information How We Entrust, Share, Transfer and Disclose Your Personal Information How We Protect Your Personal Information How to Exercise Your Data Subject Rights How We Protect Minors' Personal Information Third-Party Service Providers and Their Services How to View This Privacy Notice and How We Update It Contact Us Miscellaneous Definitions of Terms 1. How We Collect and Use Your Personal Information We will protect your personal information in accordance with state laws and regulations and the principles of legitimacy, lawfulness, and necessity. Only with your consent and for the purpose of providing you with services or features stated in this Privacy Notice will we collect and use personal information: (1) directly provided by you during your use of this Platform; (2) automatically generated during your use of the services or features provided by this Platform; and (3) legally obtained from third parties. The information we collect depends on the products you use, the environment in which you interact with us, and the choices you make, including your privacy settings and the products and features you use. You may refer to "Personal Information We Collect" to gain a quick understanding of the personal information to be collected in connection with the features or services provided by Autotodo. Please note that if you provide other people's personal information to us, you must ensure that you have obtained their authorization. This Platform provides both basic services and extended services. Your refusal to our collection of personal information in connection with the extended services does not affect your use of the basic services. If we intend to use your personal information for purposes other than those stated in this Privacy Notice, we will inform you through proper methods and obtain your prior consent again. 1.1 Basic services Autotodo provides both basic and extended services. In the basic service mode, you can perform searches, browse webpages, enjoy news feeds (excluding the local news feed channel and the Quick Games channel), download files, add bookmarks and favorites locally, and check your browsing history. In this mode, however, you are not able to use our extended premium services, such as weather services and local news feeds on the homepage, voice search, and personalized content. In the basic service mode, we do not collect your personal information. Your bookmarks, favorites, and browsing and search history will only be kept locally on your device, and they will not be uploaded to our server. If you wish to receive a variety of premium and convenient services relating to Autotodo, you may authorize us to turn on the extended services at any time during your use of our services. 1.2 Extended services During your use of this Platform, we may collect and use your personal information as set forth below. Please note that if you provide other people's personal information to us, you must ensure that you have obtained their authorization (and separately obtain their consent in the event of a special scenario). 1.2.1 Account services Account sign-up and sign-in To use this Platform, you may choose to sign up for a Autotodo Account (if you do not have one) or sign in to your Autotodo Account. During the sign-up or sign-in process, you need to provide us with the information needed to fulfill legal obligations and perform the contract, including your phone number, email address, and account password or the SMS verification code, so that we can create an account for you and assist you in signing in to the account to use this Platform. In addition, we may use your date of birth to determine your age and provide you with appropriate services so as to fulfill our legal obligation to protect minors. Such information is necessary to provide the sign-up and sign-in services. If you refuse to provide it, we will not be able to provide you with such services. Completing account details After you have signed up for a Autotodo Account, you may choose whether to provide us with information such as your username, profile picture, gender, name, and contacts for manual account recovery to complete your account details. You are not obliged to provide such information to use account services. If you do not provide it, you can still use the account sign-up and sign-in services. When you use the Videos app with your Autotodo Account, you may also choose whether to complete the real-name authentication process. If you wish to do so, you need to provide your name and ID card number. You are not obliged to provide such information to use account services. If you do not provide it, you can still use the account sign-up and sign-in services. After you sign in to your Autotodo Account, the auto sign-in feature will be turned on for the products or services provided by us or our affiliates so that your user experience will not be interrupted. Therefore, we will sync your profile picture, display name, and Autotodo Account ID among these products or services. For more details on the protection of personal information needed for account sign-up and sign-in, please refer to the Autotodo Account Privacy Notice. 1.2.2 Commercial settlement and website blocking When you browse websites, we will need to collect your browsing history. We collect this information to help us provide you with commercial settlement and website blocking services. Your browsing history will be anonymized. Such information is necessary to provide you with the aforementioned services. If you do not provide it, the aforementioned services will not be available to you, but you can use the other services of Autotodo. 1.2.3 Help and feedback and violation reporting When providing feedback in the "Help & feedback" section of Autotodo, you need to specify the feedback category and describe your issue or suggestion. You may also share your error logs or device information in order for us to pinpoint your issue. In addition, you need to provide your phone number, QQ account number, or email address, so that we will be able to contact you about your feedback at a later time. If you do not provide such information, you will not be able to use the "Help & feedback" feature, but this does not affect your use of the other features or services. If you find any webpage content that violates national laws and regulations, you may report it to us through Autotodo. We will collect your report content, report type, and contact information to further verify the content and contact you about your report at a later time. The aforementioned information is necessary for you to report a webpage violation. If you do not provide it, we may not be able to know why you file such a report and, as a result, we will not be able to determine whether the webpage concerned contains content that infringes upon other people's rights or constitutes any other violation. If you do not provide your contact information, we may not be able to inform you of our handling results. 1.2.4 Leaving comments When you post comments on news feeds in Autotodo, we will collect your comments to make them public. Such information is necessary to provide you with the aforementioned service. If you do not provide it, the aforementioned service will not be available to you, but you can use the other services of Autotodo. 1.2.5 Weather and local news feed channels on the homepage If you wish to use the weather and local news feed channels on the Autotodo homepage, we will need to obtain your location information as it is necessary to provide the local weather and news feed services to you. Therefore, we will collect your location information. You are not obliged to provide such information to use the services. If you do not provide it, you may manually enter your location information so that we can provide you with the news feed channel based on your location. 1.2.6 Fast data entry In order to provide you with a faster search service, we need to access your clipboard items to help you quickly enter the keywords when you use the search bar. Such information is necessary to provide you with the aforementioned service. If you do not provide it, the aforementioned service will not be available to you, but you can use the other services of Autotodo. 1.2.7 Video play If you wish to activate another app when using Autotodo, for example, if you wish to activate the Videos app when accessing a video on a webpage so that you can watch the video in the Videos app, we may locally process your list of installed apps so as to help activate the relevant app and direct you to that app. Such information is necessary to provide you with the aforementioned service. If you do not provide it, you will not be directed to the relevant video app but will remain in Autotodo to watch the video. In addition, your refusal to provide such information will not affect your use of the other services of Autotodo. 1.2.8 Voice search We have integrated the Breeno Assistant SDK into this Platform to enable you to perform voice searches. Specifically, when you tap the Voice Input icon in the search bar, the Breeno Assistant SDK will be called to allow you to perform a voice search as long as: (1) your phone runs Android 10 or later and has Breeno Assistant 800 or later installed, or (2) it runs Android 9 or earlier and has Breeno Assistant 5190 or later installed. If neither of the two conditions is met, Autotodo will continue to provide you with the voice search service. But before making the service available to you, it will request access to your microphone so as to obtain your voice commands. When providing you with the voice search service, Autotodo will request access to your microphone. If you reject the request, Autotodo will not be able to obtain your voice commands and, as a result, it cannot provide you with the voice search service. 1.2.9 Personalized recommendations and advertising To provide you with personalized recommendations such as personalized news, we need to obtain your device identifiers and behavioral data (taps, impressions, and content sharing). You may go to "Me - Settings - Privacy - Personalized recommendations" to turn off personalized recommendations. In addition, we may combine your personal information collected via our various services to provide you with an optimal user experience as a whole. To provide you with personalized advertising services, we may collect your tokens, online user ID information (IP address), your list of installed apps, the Autotodo version in use, the digital signature and name of the Autotodo app package, device connection information (telecoms carrier and network environment), and device attributes (device model, OS version, IMEI number, MAC address, OpenID, and serial number). You may turn off personalized advertising by going to "Settings - Additional settings - Device & privacy - Device ID & ads - Limit ad tracking" on your phone. The operation path may vary by the phone model or Autotodo version. Please note that after you turn off personalized advertising, the ads we display to you are solely based on the content of the website you are visiting rather than your identity. 1.2.10 Publicity activities and push notifications Activity participation If you choose to participate in our activities, including lucky draws, competitions, promotional or marketing activities (organized by us or our business partners), surveys, or user forums or blogs (held by us or our business partners), you may need to provide us with relevant personal information such as your name, phone number, email address, and shipping address (subject to activities) in order for us to contact you and send you prizes. The aforementioned information is necessary for you to participate in our activities. (If an activity does not involve the delivery of physical prizes, then we will not collect your shipping address.) If you do not provide such information, you will not be able to participate in our activities, but this does not affect your use of the other features or services. Push notifications To provide you with the push notification service, we need to launch the associated push service. This is to ensure that app service messages and personalized recommendations described in this Privacy Notice will be pushed to your device in a timely manner. Therefore, when you use the push notification feature, we will collect and use your network information, device information, operating system version, and notification bar status. With your consent, we will obtain your permission to push notifications. The aforementioned information is necessary to use the push notification feature. If you do not provide such information, you will not be able to receive timely push notifications, but this does not affect your use of the other features or services. You may manage and control push notifications as set forth under this Privacy Notice, such as by turning off the Notifications permission. Push notifications may contain marketing information relating to our or relevant third-party products or services. To evaluate the marketing effectiveness, we may collect your device identifier (IMEI or OpenID), IP address, your device's Android version, the type of the network connected to your device, and the time you receive the push notifications. For more details on the protection of personal information needed to provide push services, please refer to the Privacy Notice for Push Services. With your consent, we may also use the phone number and email address you have provided in the aforementioned scenarios to send you SMS messages or emails relating to user notifications, app updates and installations, verification codes, user research and follow-up surveys, and more. We may also send you commercial information such as ads and activity messages that may be of interest to you. If you do not want to receive commercial information from us, you may unsubscribe in the manner as described in the SMS messages or emails that you receive or you may contact us directly to unsubscribe. 1.2.11 Customer services For account and system security purposes, when providing you with customer services, we may need you to first provide us with your account information so that we can compare this information with the personal information you already submitted to verify your identity. In addition, subject to the types of customer services that you request, we may ask you to provide related supporting documents and we may record the calls between you and our customer service representatives. We use the data to diagnose product issues, repair customers' devices, and provide other customer care and support services. All the aforementioned information is necessary for us to provide you with customer services. If you do not provide such information, you may not be able to use our customer services. For more details on the protection of personal information needed to provide customer services, please refer to the Autotodo Services Privacy Statement. 1.2.12 Security management To fulfill our cybersecurity protection obligations, ensure the normal functioning of our products and services and the security of your account, and help us improve the security and reliability of our products and services, we will collect the following necessary information (including sensitive personal information) during your use of our products and services: information about your device such as the device name, device model, device identifiers (including OpenID and IMEI number), MAC address, serial number, IP address, and operating system version, behavioral data relating to your account (information about changing your password or the linked phone number or email address, manual account recovery history, etc.), the time and duration of your use of this Platform, the search keywords entered by you through our services, and information about software events (such as restarts, upgrades, errors, and crashes). We will store such information in a log. 1.3 Required app permissions When you use Autotodo, we may request certain app permissions as necessary to provide you with the required features or services. Please rest assured that we will only access the authorized scope of information and, if needed, obtain relevant information. We will obtain your sensitive personal information only after obtaining your consent separately. After a permission is turned on, you may go to the Settings app at any time to withdraw your authorization. (The operation paths to manage app permissions may vary by the phone model and OS version. For the operation paths, please refer to your actual phone.) After you withdraw your authorization, we will stop using the permissions. For more details, please refer to "Required App Permissions and Usage Descriptions". 1.4 Other legal grounds for personal information processing According to relevant laws and regulations, we can collect, store, use, process, transmit, share, disclose, or delete (collectively, "process") your personal information without your consent on the following legal grounds: as necessary to enter into a contract at your request or to perform the contract to which you are a party; as necessary for us to comply with a legal obligation or duty; as necessary to respond to public health emergencies or to protect the life, health, and property of natural persons in emergencies; the processing of personal information is within a reasonable scope and intended for news reports, public opinion supervision, and other similar tasks carried out in the public interest; the personal information that we process has been made public by you or otherwise legally disclosed and is within a reasonable scope; other circumstances as specified by laws and regulations. 2. How We Use Cookies and Other Similar Technologies A cookie is a small text file that a web server places on your computer, mobile phone, or any other device when you visit or browse a website, serving to collect, identify, and store information about your activity for later retrieval. This small text file usually includes the identifier that distinguishes your device from other devices, the website you visit, and some numbers and letters. After you visit a website, it will be able to identify you through the cookie stored on your device when you visit it the second time. The following describes how to use and manage cookies. 2.1 How to use cookies When you use Autotodo, we may collect your device model, operating system version, device identifiers, and IP address used for sign-in, and cache your browsing history and tap events through cookies or any other similar technology to check your network environment. Through cookies or other similar technologies, Autotodo is able to identify whether you are our user each time you use it, so that after you visit a website through Autotodo, you do not need to execute the sign-in or user verification process again at later times. With the cookies, we can also continuously optimize our websites to make them more user-friendly and make adjustments to the websites depending on your needs, thus improving your user experience. Cookies may retain user preferences and other information. If you disable cookies or other similar technologies, you may not be able to use some extended services of our websites, but you can still use the basic services in addition to the other extended services. 2.2 How to manage cookies You may manage or delete cookies or other similar tracking technologies based on your preferences. Specifically, you can disable some or all cookies and other similar tracking technologies by changing the settings of your web Autotodo so that the Autotodo does not accept cookies from our website. In addition, you may send a "Do Not Track" request to Autotodo on your web Autotodo. For more information about cookies, please go to the Help menu in your Autotodo or the document packed together with your device. We undertake not to use cookies for any purpose other than those stated in this Privacy Notice. 3. How We Store Your Personal Information 3.1 Where we store your personal information According to laws and regulations, we will store your personal information collected and generated during our operations within the territory of the People's Republic of China ("Chinese territory") on our server deployed in the Chinese territory. Where we comply with laws, regulations, and the relevant rules of regulatory authorities, we may provide your personal information to entities outside the Chinese territory only: (1) when laws and regulations explicitly allow us to do so; (2) after we separately obtain your consent; or (3) the products and/or services you use require the global transfer of personal information and you provide your personal information to entities outside the Chinese territory of your own volition. We will strictly require the data recipients to process your personal information in compliance with relevant laws and regulations in addition to this Privacy Notice. 3.2 How long we store your personal information Pursuant to laws and regulations, we will retain your personal information for the minimum period needed to provide you with products and/or services. For example, when you use our account sign-up and/or sign-in services, we will need to collect your phone number. After you provide it, we will need to save it in our system for your future use of our account services. This is to provide you with the account services on an ongoing basis and protect the security of your account and phone system. After you take the initiative or request us to delete your personal information or account, or when the minimum retention period expires, we will delete or anonymize your personal information as soon as possible in accordance with laws and regulations, unless otherwise specified by laws and regulations. Except for your personal information stored locally on your device, personal information about you generated when you sign in to your account to use Autotodo will be synced with your account information and stored on our server. Once your account is deleted, your personal information stored on our server will be deleted or anonymized in accordance with the law. We determine the minimum retention period mainly based on the following: (1) The purposes for which the personal information is processed have been fulfilled or are unable to be fulfilled, or the processing becomes unnecessary due to business changes or discontinuance; (2) It is necessary for us to maintain relevant transaction and activity records to address your information query requests or complaints; (3) You authorize us to retain the personal information for a longer period; (4) Laws or administrative regulations have otherwise specified the retention period for personal information. If you have seriously violated laws, regulations, or agreements, policies, or rules relating to this Platform during your use of this Platform, the records of your violations as well as your credit records and personal information in relation to this Platform will be retained for the maximum period permitted by law. If we stop some or all of the services of this Platform for special reasons, we will publish an announcement on this Platform at least 30 days in advance, and we will stop collecting your personal information and no longer use it for commercial purposes. Within the minimum time limit permitted by laws and regulations, we will delete or anonymize the personal information we hold that relates to this Platform, unless otherwise specified by laws and regulations. 4. How We Entrust, Share, Transfer and Disclose Your Personal Information 4.1 How we entrust third parties to process personal information To provide you with better and more premium platform services, we may entrust our affiliates or other professional service providers to process personal information on our behalf. For example, we may hire service providers to help us provide technical and customer support services. We will require the entrusted party (a company, organization, or individual) to observe strict confidentiality obligations and take effective confidentiality measures through a written agreement, on-site audits, or any other means as required by the law. We will require the party to process your personal information only within the scope of entrustment and not to use your personal information for their own benefit. In the written agreement, we will strictly define the purpose for which the processing is carried out, the time limit, the processing method, the type of personal information, protection measures, and the rights and obligations of the two parties. We will supervise the entrusted party's processing of personal information. 4.2 How we share personal information To provide you with better and more premium platform services, we may share your personal information with our affiliates, partners, and other third parties. We will share your personal information only for legitimate, proper, necessary, specific, and explicit purposes, and, where explicitly required by laws and regulations, we will separately obtain your consent before we do so. Such third parties will have no right to use your personal information shared by us for any other purpose. We will sign a data protection agreement with each of such third parties to clarify their responsibility and obligation to protect your personal information. When our partners provide services to you, if you do not allow them to collect your personal information necessary to provide specific services, you may not be able to use this Platform or enjoy the services that they provide. We will not share your personal information with any third party except for the circumstances as described below or unless this Privacy Notice specifies otherwise. 4.2.1 Sharing with our affiliates To provide you with more complete and a greater variety of features of or relating to this Platform, we may legally share the necessary personal information with our affiliates from time to time through interfaces or offline channels. For example, in order for our affiliates to provide you with services and meet the user identification requirement of regulators, or in order for us and our affiliates to jointly provide or recommend services and products to you, we may need to share your personal information with the affiliates. We will only share the necessary personal information, and we will do so only for the purposes stated in this Privacy Notice. 4.2.2 Sharing with third-party service providers Some of the services in this Platform are provided by third-party service providers. To provide you with the product or services that you request, we need to share the necessary personal information about you with these third parties. To learn more about what personal information we will share with third-party service providers, refer to "Personal Information We Share with Third Parties". 4.2.3 Sharing with third-party software development kit (SDK) providers Autotodo contains SDK plugins provided by our authorized partners. When you use relevant services provided by the authorized partners in Autotodo, the plugins will collect and process your personal information. To protect the security of your information to the maximum extent possible, we strongly recommend that you read the privacy terms of any third-party SDKs before using the services provided by such SDKs. If you find any risks relating to such SDKs or other similar apps, we recommend that you immediately stop using them and promptly contact us to safeguard your legitimate rights and interests. To find out more about what third-party SDKs we use in this Platform, refer to "Personal Information We Share with Third Parties". 4.2.4 Sharing in other circumstances Should we be legally required to comply with laws and regulations, legal procedures, litigations, and/or mandatory requirements of public institutions and government authorities, we may share your personal information to the least necessary extent. We may also disclose your personal information if we sincerely believe that disclosure is necessary to protect our users or to detect, prevent, and deal with fraud, unauthorized use of our products, violation of our terms or policies, or other harmful or illegal activities. (To the extent and only as expressly permitted by local data protection laws, we will collect, use, or disclose your personal information without your consent.) This may include providing information to public institutions or government agencies and communicating with our partners about the reliability of your account to prevent fraud, violation, and other harmful acts committed in or out of our products. 4.3 How we transfer personal information In general, we do not transfer your personal information to any company, organization, or individual, except in the following situations: The transfer is made at your request and in compliance with the requirements of relevant government authorities; We are required to provide your personal information by applicable laws, regulations, legal procedures, and mandatory administrative or judicial requirements; When we are in the process of a merger, acquisition, or bankruptcy liquidation, and if such process requires the transfer of your personal information, we will request the new company or organization that holds your personal information to continue to be bound by this Privacy Notice; otherwise, we will require this company or organization to obtain your authorization or consent again. 4.4 How we disclose personal information We will need to disclose the desensitized phone numbers or Autotodo Account IDs of activity winners. In addition, we will disclose your personal information only in the following situations: After separately obtaining your consent, we will disclose the personal information of the specified type in the specified way; When required by applicable laws, legal procedures, litigations, or the mandatory requirements of government authorities, we may publicly disclose your personal information. When we receive information disclosure requests, we will, in compliance with laws and regulations, require the issuance of corresponding legal documents, such as subpoenas or investigation letters. We strongly believe that when we are asked to disclose personal information, the whole disclosure process should stay as transparent as possible to the extent permitted by law. To this end, we carefully review all requests to ensure that there is a legal basis and the requests are only limited to data that law enforcement agencies are legally permitted to obtain for the specific purposes of investigation. Please note that the information you publish or publicly share on this Platform may contain personal information or even sensitive personal information concerning you or others, such as your transaction information and comments in various forms including text, image, or video. When using this Platform, please exercise caution and consider carefully whether to publish or publicly share relevant information. Once you perform such actions, it is difficult to ensure that the information you shared will be deleted from all the receiving or forwarding Internet platforms even if you delete it from this Platform. Such information may still be retained in publicly accessible places, and other users or third parties of no relation to us or not under our control may still be able to independently cache, copy, or store such information, or they may keep it in other publicly accessible places. 5. How We Protect Your Personal Information 5.1 How we protect your personal information We adopt technical and organizational measures that are reasonable and actionable to protect the information we collect in connection with our services. We have introduced safeguards up to industry standards to protect the personal information provided by you from unauthorized access, disclosure, use, or alteration, or from damage or loss. We take all reasonable and actionable measures to protect your personal information. For example: We use mainstream security means such as SSL to encrypt many of our services. We regularly review our practices regarding information collection, storage, and processing (including physical security measures) to protect our systems from unauthorized access or alteration. Subject to relevant regulations, we have appointed a person in charge of personal information protection and set up a personal information protection task force. We have also established relevant internal control processes to ensure compliance with the principle of least privilege. We strictly control access to personal information and only grant access permissions to our employees and those of an authorized service provider who need to access personal information in order to help us process such information. These employees are subject to strict contractual confidentiality obligations. If they fail to perform these obligations, they may be held legally liable or be terminated. Personal information access logs will be kept and audited periodically. Employees who need to access sensitive personal information must obtain permission from relevant management personnel. In addition, we take technical measures to prevent people from accessing, modifying, copying, or downloading such information without authorization. The security of your information is very important to us. Therefore, we will continue our efforts to protect the security of your personal information and implement safeguards such as encrypting stored data and using end-to-end encryption during transmission to protect your information from unauthorized access, use, or disclosure. In addition, certain encrypted data is inaccessible to anyone other than the user. When transmitting and storing your personal information of special types, we will use security measures such as encryption. When storing your personal biometric information, we will take technical measures to process it, such as only storing a summary of your personal biometric information. We carefully select business partners and service providers and include our requirements for personal information protection in our business contracts, audits, or assessments. Internally, we publish and implement data security regulations to define the standards and requirements for protecting user data (including users' personal information). We conduct security and privacy protection training, tests, and publicity activities to raise our employees' awareness of the importance of personal information protection. We use international and industry-recognized standards to protect your personal information and actively acquire security and privacy protection certifications. We have established sound mechanisms to ensure smooth coordination and communication with regulators, third-party security service providers, and security evaluation and certification organizations to promptly defend against and deal with information security threats so as to protect your personal information and privacy. 5.2 Notification and response to personal information security events Please note that although we take reasonable measures to protect your information, no websites, Internet transfers, computer systems, or Wi-Fi connections are 100 percent secure. In the event of any security breach of your personal information, we will, pursuant to applicable laws and regulations, promptly notify you of the particulars and possible impact of such event, the measures taken or to be taken by us, suggestions on how you can prevent and reduce risks, and remedies available to you. We will promptly inform you of the information about such event by email, letter, phone, or push notification. When it is difficult to inform the personal information subjects concerned one by one, we will publish an announcement in a reasonable and effective manner. We will also report the handling of the event in accordance with the requirements of regulatory authorities. 6. How to Exercise Your Data Subjects Rights We respect your rights to your personal information, and we do our best to protect your rights. To this end, we provide you with a variety of ways to make privacy settings and personal information management more secure and convenient for you to ensure the security of your personal information. Please note that the settings may vary by the operating system and software version. In addition, we may adjust the settings from time to time to improve your user experience. Therefore, the operation paths described below are for your reference only. If you have any questions regarding the operation paths or ways of exercising your rights, you may contact us as set forth under Section 10 "Contact Us" of this Privacy Notice. We will respond to your data subject rights requests as long as your requests comply with relevant laws and regulations and are technically feasible. 6.1 Right to access, rectify, and complete your personal information To view your account information, such as the linked phone number and email address, go to "Me - Account". To view your bookmarks, favorite news articles, browsing history, and reading history, go to "Me - Bookmarks/History". To view the homepage bookmarks, tap "Bookmarks" on the Autotodo homepage. To view your download history, go to "Me - Downloads". To correct your personal information, such as the linked phone number and email address, go to "Me - Account". To revise information relating to your bookmarks or favorite news articles, go to "Me - Bookmarks/History". Please understand that to ensure the quality of your personal information and avoid adverse effects on your personal rights due to information inaccuracy and incompleteness, we may need to verify your identity before you exercise the right to rectify and complete information. 6.2 Right to delete your personal information We will take the initiative to delete your personal information in any of the following circumstances: (a) The purposes for which we process your personal information have been fulfilled or cannot be fulfilled, or the personal information becomes unnecessary to fulfill the purposes; (b) We have stopped the products or services relating to this Platform or the retention period expires (such as when you no longer use the products or services relating to this Platform or after your account is deleted); (c) You have revoked your consent; (d) We have violated laws, administrative regulations, or the data processing agreement with you; (e) Other circumstances specified by laws and administrative regulations. For the personal information that we have not deleted in any of these circumstances, you may contact us as set forth under this Privacy Notice to request us to delete such information. We will decide whether to respond to your request in accordance with state laws, regulations, and regulatory requirements. If we decide to respond, we will delete or anonymize your personal information, unless otherwise provided by laws, regulations, or normative documents. We will also require the entities that obtain your personal information from us to promptly delete the information, unless otherwise provided by laws and regulations or unless these entities have separately obtained your authorization. You can delete such information directly on the relevant product or service page. Specifically: To delete your bookmarks, favorite news articles, browsing history, or reading history, go to "Me - Bookmarks/History". To delete a homepage bookmark, tap "Bookmarks" on the Autotodo homepage. To delete your download history, go to "Me - Downloads". You hereby agree that once your deletion request is accepted, your personal information will be deleted or anonymized, unless otherwise provided by laws, regulations, or normative documents. You understand that after you delete or we help you to delete relevant information from this Platform, we may, subject to applicable laws and the limitations of security technology, not be able to immediately delete it from our system. We will securely store your personal information and restrict further processing of it until it can be deleted or anonymized. 6.3 Right to copy and transfer your personal information You have the right to copy and transfer your personal information. If you need a copy of your personal information, please refer to Section 10 "Contact Us" of this Privacy Notice and send us a request. We will provide you with a copy in a timely manner. If you request us to transfer your personal information to a specified data processor, we will complete the transfer as long as it complies with the regulations issued by the Cyberspace Administration of China. 6.4 Right to delete your account We grant you the right to delete your Autotodo Account. You may go to the Settings app, tap "Account settings - Delete account", and then submit an account deletion request following the prompted steps. You may go to https://id.Autotodo.com/profile.html. After signing in to your Autotodo Account, you can select "Personal Data Management", tap "Delete Account", and then submit an account deletion request by following the prompted steps. After you submit an account deletion request, we may need to manually review your request in order to make sure that you satisfy the conditions for deleting your account. We will assist you with the deletion of your account within 15 workdays after you submit your request. After your request is approved, we will delete or anonymize all your relevant personal information, unless otherwise specified by laws and regulations. After your account is deleted, we will no longer be able to provide you with platform services that are only accessible with a Autotodo Account. 6.5 Right to change the scope of authorization or withdraw consent The performance of each service function requires certain basic personal information (see the "How We Collect and Use Your Personal Information" section of this Privacy Notice). You can change the scope of the personal information you authorize us to collect or withdraw your consent by deleting information, turning off app permissions, changing settings on the product or feature settings page, or deleting your account. Specifically: App permission settings: You may go to the Settings app and tap "Permission & privacy - Permission manager" to withdraw your consent to our use of related app permissions. Commercial information management: The advertising messages or marketing notifications we send to you contain information on how to unsubscribe. You may unsubscribe in the manner as described therein. Personalized content management: You may go to "Me - Settings - Additional settings - Personalized news" to turn off personalized recommendations. Personalized advertising management: You may open "Settings" on your device and go to "Additional settings - Device & privacy - Device ID & ads - Limit ad tracking" to turn off personalized advertising. Withdrawing your consent to the Privacy Notice: You may go to "Me - Settings - About Autotodo" and tap "Withdraw consent to the Privacy Notice". By withdrawing your consent to the Privacy Notice, you are deemed not to agree to the Autotodo Privacy Notice, so you can no longer use Autotodo and will exit it automatically. In addition, your local behavioral data relating to Autotodo will be deleted, such as search history, browsing history, downloaded files, bookmarks, and favorite websites and news. Please note that if you withdraw your consent, we may no longer be able to provide you with the related services. We will also no longer process related personal information, but the withdrawal of your consent shall not affect the lawfulness of data processing based on consent before its withdrawal. 6.6 Right to complain You have the right to file a complaint by contacting us in the manner disclosed in this Privacy Notice. We will respond within 15 workdays from the date we receive your complaint. If you are not satisfied with our reply, particularly if our processing of your personal information damages your legitimate rights and interests, you can also file a complaint or report it to regulatory authorities such as the Cyberspace Administration of China, a relevant public security organ, and the State Administration for Market Regulation, or file a lawsuit with the court with jurisdiction. 6.7 Right not to be subjected to automated decision-making In some service features, we may only rely on the automated decision-making mechanism realized by information systems or algorithms to make decisions without human involvement. If you think that the decisions significantly affect your legitimate rights and interests, you can contact us as set forth under Section 10 "Contact Us" of this Privacy Notice. 6.8 Transfer of data subject rights of deceased persons to their close relatives Provided any user of Autotodo dies and they have not informed us of any arrangements in writing or through any other reasonable method before they die, their close relatives may, for the sake of their own legitimate interests, contact us as set forth under Section 10 "Contact Us" for guidelines on how to exercise the rights of the deceased data subject, including rights to access, copy, rectify, and delete personal information. 6.9 Rights to explanation and reason If you are unable to access, rectify, or delete your personal information, or withdraw your consent, or delete your account through the ways described above, or if you have any questions when exercising the above-mentioned rights, you may contact our customer service representatives as set forth under Section 10 "Contact Us" for an explanation and reason. After receiving your request, we may first verify your identity for security reasons and then handle your request within 15 workdays. In general, we do not charge a fee for handling your reasonable requests. For repeated requests beyond a reasonable limit, however, we may charge a fee to cover the costs of handling such requests depending on the actual situation. We may reject unreasonably repeated requests, requests that require excessive technical means (such as developing a new system or fundamentally changing existing practices), requests that present risks to the legitimate rights and interests of others, or very unrealistic requests. If we do so, we will state the reason in our reply. In addition, we may not respond to your request if it directly involves any issues that directly concern public interests such as national security, national defense, public health, and criminal investigations, or if it may result in serious damage to the legitimate rights and interests of you or any other individual or organization. If you have any questions, concerns, or suggestions regarding your data subject rights or if you wish us to make an explanation regarding this Privacy Notice, you may contact us as set forth under Section 10 "Contact Us". We will provide an explanation in a timely manner. 7. How We Protect Minors' Personal Information We attach great importance to the protection of minors' personal information. If you are a child (a minor under the age of 14), you and your parent or guardian together must carefully read this Privacy Notice and the Autotodo Privacy Notice for Children before you use this Platform. In addition, you must obtain their consent before using the products or services in this Platform or providing information to us. For child protection purposes, child users may only use child accounts. Parents or guardians shall create a child account for their child to use our products or services. When children use Autotodo with their child account, Autotodo will provide them with age-appropriate images, text, and videos. It will prevent them from accessing inappropriate content, disable personalized news and advertising, and prompt advice when they make comments. 8. Third-Party Service Providers and Their Services This Platform and our services therein may contain links to third-party websites, products, or services. You can choose whether to access or use any website, product, or service provided by a third party. For example, the "Follow Us" feature on our official website will guide you to our official social media accounts, where you can find marketing or promotional information posted by us. The operators of the third-party websites that this Platform directs you to and the providers of the third-party services that you access through Autotodo have their own privacy policies. When you access a third-party website or use a third-party app, the website or app may obtain and use your personal information. Such acts are out of our control and not bound by this Privacy Notice. Before you submit personal information to third parties, please refer to their privacy policies. We will use commercially reasonable efforts to require such third parties to take measures to protect your personal information, but we cannot guarantee that they will take protection measures as per our requirements. Before using third-party services, please carefully read their privacy policies to determine whether to use or continue to use such services. 9. How to View This Privacy Notice and How We Update It 9.1 How to view this Privacy Notice In Autotodo, you may go to "Me - Settings - Privacy - Privacy Notice" to view this Privacy Notice. You may also tap the hypertext provided at the bottom of this Privacy Notice to view its previous version. 9.2 We reserve the right to update or modify this Privacy Notice from time to time. To provide you with better services, we will make updates and changes to our products and services from time to time, and we will revise this Privacy Notice accordingly from to time. In the event of any change to this Privacy Notice, we will inform you through reasonable methods such as using this Platform to push a notification to you and displaying a pop-up prompt when you use this Platform so that you can promptly understand all the changes. You can check the latest updates in "Update history" at the beginning of this Privacy Notice. Please note that we will process your personal information in accordance with the updated Privacy Notice only after obtaining your consent. Without your express consent, we will not diminish your rights under this Privacy Notice. 10. Contact Us If you have any questions, complaints, or suggestions regarding this Privacy Notice or our privacy practices, you may contact us using either of the following methods. We will respond within 15 workdays. Contact by email. If you have any questions regarding our products and services, you may contact us by email at kf@Autotodo.com. Contact through the Data Subject Rights Platform. To better protect your rights and interests, we have specifically established the Data Subject Rights Platform at https://brand.Autotodo.com/en/privacy-feedback.html. If you have any questions regarding personal information protection, you may sign in to the platform to contact us. 11. Miscellaneous 11.1 The interpretation of this Privacy Notice and the resolution of disputes arising from and related to this Privacy Notice shall be governed by the laws of the People's Republic of China (excluding the laws of Hong Kong SAR, Macao SAR, and Taiwan). Any disputes arising out of or relating to the conclusion and performance of this Privacy Notice shall be resolved through friendly consultation between the two Parties. Should the consultation fail, either Party shall have the right to refer the dispute to the People's Court with jurisdiction in the place where the alleged defendant is domiciled. 11.2 All headings in this Privacy Notice are intended solely for convenience and ease of reference and shall not have any effect on the interpretation of any clause in this Privacy Notice. 12. Definitions of Terms Personal information: Any information that is recorded electronically or otherwise and is related to identified or identifiable natural persons, but excludes anonymized information. Sensitive personal information: Personal information that, once leaked or unlawfully used, is likely to result in damage to the personal dignity, physical wellbeing, or property of any natural person, and includes among others, information such as biometric identification, religious belief, special identity, medical records, financial account, whereabouts, as well as the personal information of minors under the age of 14. Affiliate: Any company that is controlled by or controls, either directly or indirectly, Guangdong Autotodo Technology Co., Ltd., or that is under the direct or indirect control or significant influence of the same entity as Guangdong Autotodo Technology Co., Ltd. "Control" means having the ability, directly or indirectly, to influence the management of the affiliate, whether through ownership, voting shares, contracts, or other means approved by China's people's courts.