Vinabot Privacy Policy

LAIPIC AI TECHNOLOGY COMPANY LIMITED

LAIPIC AI TECHNOLOGY COMPANY LIMITED. (hereinafter referred to as "we" or "Vinabot") is well aware of the importance of personal information to you, and will do its best to protect your personal information safely and reliably. We will use this Privacy Policy (hereinafter referred to as "this Privacy Policy") to help you understand how we collect, use, store and share personal information, as well as the relevant rights you enjoy. We are committed to maintaining your trust in us and abiding by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimum necessity, the principle of ensuring safety, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we promise that we will take corresponding security protection measures to protect your personal information in accordance with the mature security standards of the industry.

Before using our products (or services), please read carefully (minors please read with the guardian) and understand this privacy policy to make appropriate choices. When you agree to this privacy policy, you have agreed that we will process your relevant information in accordance with this privacy policy. Unless you have read and accepted all the terms of this privacy policy, you should not use this product or service.

1. How we collect and use your personal information

In order to provide you with services, Vinabot authorized software may need to apply to you for the following permissions within the necessary scope. Please rest assured that Vinabot authorized software will not enable these permissions by default, and will only access them when implementing specific services/functions after your separate consent. Even if you have authorized us to access your corresponding permissions, we will only access them within the scope of your authorization and obtain the corresponding information (if involved); and you can withdraw your authorization at any time. After you withdraw your authorization, we will stop accessing the corresponding permissions and will no longer be able to provide you with certain corresponding services, but it will not affect your enjoyment of other services we provide.

We collect your personal information mainly to make it easier and more satisfactory for you and other users to use our products. Our goal is to provide all Internet users with a safe and convenient Internet experience. And this information helps us achieve this goal.

(I) We will collect and obtain your personal information through the following channels:

1. Information you provide. For example:

1) Information you provide to us when you register a Vinabot account or use our products (or services);

2) Shared information you provide to third parties through our products (or services), and information stored when you use our products (or services).

Please note that if you disclose your information in information uploaded or published in public areas visible to other users in our products (or services), or in your response to information uploaded or published by others, such information may be collected and used by others. If you find that others are improperly collecting or using your information, you can contact us through the feedback channels listed in the "How to Contact Us" section of this Privacy Policy.

2. Your information we obtain. For example: Information we collect, summarize, and record when you use our products (or services), such as log information, location information, and device information.

(II) We will collect and use your personal information for the following purposes as described in this Privacy Policy:

You understand and agree that we hope to provide you with perfect products and services, so we will continue to improve our products and services, which means that with the iteration, expansion, and upgrade of products and services, we may frequently launch new services or business functions or re-divide business functions, and may need to collect new personal information or change the purpose, method or scope of use of personal information. Please note that if we want to use your personal information for other purposes not specified in this Privacy Policy or collect other personal information not mentioned, we will obtain your consent through page prompts, interactive processes, website announcements or other means. Once you agree, such additional uses will be deemed part of this Privacy Policy, and such additional information will also be subject to this Privacy Policy. In the process, if you have any questions, you can contact us through the feedback channels listed in the "How to Contact Us" section of this Privacy Policy, and we will answer you as soon as possible.

1. Help you register as a Vinabot user.

In order to help you complete the creation of an account so that we can provide you with registered user services, we provide you with a variety of registration channels for you to choose. When you choose to register using your mobile phone number, you need to provide us with personal sensitive information such as your mobile phone number, network operator and type. We use this information to send verification code information for you to submit to verify whether your identity is valid.

During the process of registering as a Vinabot user and during the use process, you can choose whether to supplement your nickname (including real name), gender, avatar (including real avatar), date of birth, industry category and work purpose, etc., which will help us provide you with personalized and better user services.

You know that we collect mobile phone numbers, third-party account information and supplementary information to meet the requirements of the online real-name system of relevant laws and regulations. However, if you do not provide your mobile phone number, third-party account information and supplementary information, it will not affect your use of the basic functions of the product or service.

The above information you provide will continue to authorize us to use during your use of this service. When you apply to cancel your account, we will stop using and delete the above information within the specified time in accordance with relevant laws and regulations and the provisions of this Privacy Policy.

The above information will be stored in the People's Republic of China. If cross-border transmission is required, we will obtain your authorization and consent separately.

2. Provide you with other related product functions and/or services

In order to realize the following product functions and/or services, we may need to collect corresponding personal information from you.

1) Provide basic functional services, network security and operational security guarantees.

In order to ensure the normal operation of basic functional services, provide you with services such as problem diagnosis and data statistics, ensure the security of your account, network, operation and system, and prevent phishing fraud and Trojan viruses, during your use of this product, we may collect your device information, including unchangeable unique device identifiers, such as IMEI number, AndroidID, IDFA, GUID, OPENUDID, SIM card IMSI information, hardware serial number, MAC address, login IP address, and operation log information. This type of information is information that must be collected to provide services, and will be de-identified after collection and will not be used to identify any specific user.

Please note that separate device information and log information are information that cannot identify a specific natural person. If we combine this type of non-personal information with other information to identify a specific natural person, or use it in combination with personal information, then during the period of combined use, this type of non-personal information will be regarded as personal information. Unless you have obtained your authorization or otherwise required by laws and regulations, we will anonymize and de-identify this type of personal information. During the period of combined use, this information will be treated and protected as your personal information in accordance with this privacy policy.

2) Customer service.

When you file a complaint, make an inquiry or appeal to us, in order to facilitate contact with you or help you solve the problem, we may need you to provide personal information such as name, mobile phone number, email and other valid contact information. If you refuse to provide the above information, we may not be able to provide you with timely feedback on the relevant processing results, but it will not affect your normal use of other basic functions.

Types (scopes) of personal information collected: IMEI, device model information, login IP address, operation logs. This type of information is information that must be collected to provide services. After collection, it will be de-identified and will not be used to identify any specific user.

3) Maintain product security and troubleshoot in a timely manner.

In order to maintain the normal operation of our services, as well as to protect your account security, troubleshoot product failures, improve and optimize our services, we will collect your personal information.

Types (scopes) of personal information collected: IMEI, device model information, login IP address, operation logs. This type of information is information that must be collected to provide services. After collection, it will be de-identified and will not be used to identify any specific user.

4) Used for sharing and activating third-party payment and other functions.

If you share content on the Vinabot platform to a third-party platform, we will read your application list information to determine whether the third-party platform exists to achieve the purpose of sharing; if you use the payment function on the Vinabot platform, we will also read your application list information to determine whether the third-party payment application exists to complete the payment function.

5) AI algorithm optimization service.

When you use portrait cutout or dubbing to subtitle, we will collect the edge contour features of the character, identify the edge contour features of the character in the picture, and implement the cutout through the AI algorithm; we will collect audio signals and generate text through natural semantic analysis. This is to achieve AI algorithm optimization, more accurate and fast recognition of text or dubbing, and recognition of portrait background cutout. The more times it is used, the better the AI algorithm optimization effect. This type of information is information that must be collected to provide this service. After collection, it will be de-identified and will not be used to identify any specific user.

3. Provide you with personalized creative services

When you use our products or services for creation for the first time, in order to ensure the normal use of this function, we may request you to authorize sensitive permissions such as photos and microphones. During this process, you can choose whether to provide us with it. If you refuse to authorize it, you will not be able to use the authorized functions under this business, but it will not affect your normal use of other basic functions.

4. Improve our products or services

We may also obtain other information about you for the reasonable needs of improving our products or services, including your privacy settings, the products and functions you use, and basic data such as your draft works, so as to provide you with services and personalized content and suggestions. During this process, you can choose whether to provide us with it. If you refuse to authorize it, you will not be able to use the relevant additional functions, but it will not affect your normal use of other basic functions.

5. Device permission call

In the process of providing services, in order to ensure that you can use the product functions normally, we will apply for the following device permissions from the system. We will ask for your consent before applying, and you can choose to "allow" or "prohibit" the permission application. After your authorization, we will enable the relevant permissions, and you can cancel the authorization in the system at any time. Your cancellation of authorization will cause you to be unable to use the relevant business functions, but it will not cause you to be unable to use other business functions.

The business functions call the system privacy permissions as follows:

Vinabot platform permissions: https://www.laihua.com/mobile/agreements/rights?source=animation

(III) Exceptions to obtaining authorization and consent:

1. According to relevant laws and regulations, the collection of your personal information in the following circumstances does not require your authorization and consent:

2. Related to national security and national defense security;

3. Related to public security, public health, and major public interests;

4. Related to criminal investigation, prosecution, trial, and judgment execution;

5. For the purpose of protecting the life, property, and other major legal matters of the subject of personal information or other individuals rights and interests but it is difficult to obtain your consent;

6. The personal information collected is disclosed to the public by you;

7. Personal information is collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;

8. It is necessary to sign a contract according to your requirements;

9. It is necessary to maintain the safe and stable operation of the products or services provided, such as discovering and handling product or service failures;

10. It is necessary for legal news reporting;

11. It is necessary for academic research institutions to conduct statistical or academic research based on public interests, and when providing the results of academic research or descriptions to the outside world, the personal information contained in the results is de-identified;

12. Other circumstances stipulated by laws and regulations.

2. How we use cookies and similar technologies

(I) Cookies

To ensure the normal operation of products or services, provide you with an easier access experience, recommend content or advertisements that may be of interest to you, etc., we will store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. We may set authentication and security cookies to confirm whether you have logged into the service safely, or whether you have encountered theft, fraud, or other illegal activities. These technologies will also help us improve service efficiency and increase login and response speed. With the help of cookies, the website can store data such as your preferences or items in the shopping cart, and can help you save the steps and processes of repeatedly filling in your personal information and entering search content.

We will not use cookies for any purpose other than the purposes described in this privacy policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, and most web browsers have the function of blocking cookies. However, if you do this, you will need to change your user settings personally every time you visit our website.

(II) Web beacons and pixel tags

In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on our websites. For example, the email we send you may contain a click URL that links to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences and improve customer service. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tag in the email, we can know whether the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

(III) Do Not Track

You can manage or delete cookies according to your preferences. You can clear all cookies saved on your device, and many web browsers have a Do Not Track function that can issue a Do Not Track request to the website. At present, major Internet standard organizations have not established relevant policies to specify how websites should respond to such requests. But if your browser enables Do Not Track, all our websites will respect your choice.

3. How we share, transfer, and publicly disclose your personal information

(I) Sharing

We share your personal information on the premise of complying with the principles of "legal and legitimate, minimum necessary, and clear purpose". At the same time, we will conduct a personal information protection impact assessment for the sharing of personal information in advance, and take effective technical protection measures for the output form, circulation, and use. At the cooperation agreement level, strictly require partners to fulfill their information protection obligations and responsibilities. For scenarios where personal information is entrusted to be processed, we will sign relevant processing agreements with the entrusted partners in accordance with legal provisions and supervise their personal information use activities. For scenarios where personal information is jointly processed, we will sign relevant agreements with partners in accordance with legal provisions and agree on their respective rights and obligations to ensure compliance with relevant legal provisions and protect data security in the process of using relevant personal information.

We will not share your personal information with any other company, organization or individual, except in the following cases:

1. Sharing with explicit consent: We will share your personal information with other parties after obtaining your explicit consent.

2. We may share your personal information with external parties in accordance with laws and regulations or in accordance with the mandatory requirements of government authorities.

3. Sharing with our affiliates: Your personal information may be shared with our affiliates. We will only share necessary personal information and be subject to the purposes stated in this privacy policy. If an affiliate wants to change the purpose of processing personal information, it will ask for your authorization and consent again.

4. Sharing with authorized partners: Some of our services will be provided by authorized partners only for the purposes stated in this Privacy Policy. We may share some of your personal information with partners to provide better customer service and user experience. For example, companies we hire to provide third-party data statistics and analysis services may need to collect and access personal data for data statistics and analysis. In this case, these companies must comply with our data privacy and security requirements. We will only share your personal information for legitimate, legitimate, necessary, specific and clear purposes, and will only share personal information necessary to provide services.

In order to ensure the realization of related services and the safe and stable operation of applications, our applications may access software development kits (SDKs) provided by third parties to achieve related purposes. We will conduct strict security monitoring of the software tool development kits (SDKs) that our partners use to obtain information to protect data security. We will fulfill our prudent obligations, strive to ensure the security of your information, and update and inform you of the latest situation of all Vinabot's access to third-party SDKs as soon as possible. However, please also understand that if the third-party SDK provider we access does not promptly inform us or is not detected by us to call your device permissions and obtain your relevant information, it may be considered that it does not involve the collection of your personal information, and therefore it is not listed here.

We list the relevant third-party SDKs that we have connected to as follows:

  • SDK name: Pickup Smart SDK

    Purpose of use: Using the power of artificial intelligence and computer vision to provide technical services such as intelligent AI cutouts, trademark recognition, custom stitching, and background replacement

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card, IMSI information, etc.), image data uploaded by users, IP address

    Data types: device identification information, network information, and location information

    Official website address: http://www.picup.shop/aboutUs.html

    Privacy policy link: http://www.picup.shop/servicePrivacy.html

  • SDK name: Umeng SDK

    Purpose of use: Statistical analysis services, and provide basic anti-cheating capabilities through geographic location calibration report data accuracy

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card, IMSI information, etc.), Wi-Fi address, location information, IP address

    Data types: device identification information, application installation list, network information and location information

    Official website address: https://www.umeng.com/

    Privacy policy link: https://www.umeng.com/page/policy

  • SDK name: SensorsAnalytics SDK

    Purpose of use: statistical analysis, improving products and services

    Method: automatically obtain and record after you agree to the privacy policy

    Personal information type (scope) collected: device information (IDFA, operating system, device model, device manufacturer, system version, AndroidID, IMEI and MAC address, etc.), Wi-Fi address, IP address

    Data type: device identification information, network information

    Official website address: https://www.sensorsdata.cn/

    Privacy policy link: https://manual.sensorsdata.cn/sa/latest/tech_sdk_client_privacy_policy-22255998.html

  • SDK name: Jiguang Push

    Purpose of use: Push messages, optimize the network connection request between SDK and Jiguang server, ensure the stability and continuity of the service; realize the function of regional push.

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address, location information, IP address

    Data types: device identification information, network information and location information

    Official website address: https://www.jiguang.cn/

    Privacy policy link: https://www.jiguang.cn/license/privacy

  • SDK name: Jiguang One-click Login

    Purpose of use: User quick login

    Method: Automatically obtain and record when the login operation is triggered after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), location information, mobile phone number

    Data types: device identification information, network information and location information, mobile phone number

    Official website address: https://www.jiguang.cn/

    Privacy policy link: https://www.jiguang.cn/license/privacy

  • SDK name: Meiqia Customer Service SDK

    Purpose of use: Real-time online communication with users

    Method: Automatically obtain and record after you agree to the privacy policy; content you voluntarily enter

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), location information, mobile phone number filled in or provided by the user, IP address

    Data types: device identification information, network information and location information

    Official website address: https://www.meiqia.com/

    Privacy policy link: https://meiqia.com/privacy-clause

  • SDK name: Douyin Share

    Purpose of use: Help users share content to third-party applications

    Method: Automatically obtain and record when sharing to Douyin after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.)

    Data type: device identification information

    Official website address: https://open.douyin.com/platform

    Privacy policy link: https://www.douyin.com/agreements/?id=6773901168964798477

  • SDK name: WeChat Open Platform SDK

    Purpose of use: WeChat authorized login, WeChat sharing and WeChat payment

    Method: Automatically obtain and record when you use WeChat related functions after you agree to the privacy policy

    Personal information collected (scope): Device information (Android ID/IDFA/OpenUDID/GUID, etc.)

    Data type: device identification information

    Official website address: https://open.weixin.qq.com/

    Privacy policy link: https://developers.weixin.qq.com/doc/oplatform/Mobile_App/Access_Guide/Android.html

  • SDK name: QQ Open Platform SDK

    Purpose of use: QQ authorized login, QQ sharing

    Method: Automatically obtain and record when you use QQ related functions after you agree to the privacy policy

    Personal information collected (scope): device information (Android ID/IDFA/OpenUDID/GUID, etc.), Wi-Fi address, location information

    Data types: device identification information, network information and location information

    Official website address: https://connect.qq.com/index.html

    Privacy policy link: https://ti.qq.com/agreement/qqface.html?appname=mqq_2019

  • SDK name: Weibo Open Platform SDK

    Purpose of use: Weibo authorized login, Weibo sharing

    Method: Automatically obtain and record when you use Weibo related functions after you agree to the privacy policy

    Personal information collected (scope): Device information (Android ID/IDFA/OpenUDID/GUID, etc.), Wi-Fi address

    Data type: device identification information

    Official website address: https://open.weibo.com/

    Privacy policy link: https://weibo.com/signup/v5/privacy?spm=a1zaa.8161610.0.0.4f8776217Wu8R1

  • SDK name: Alipay SDK

    Purpose: To help users use Alipay in the app

    Method: Automatically obtain and record when you use Alipay related functions after you agree to the privacy policy

    Personal information collected (scope): Device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address

    Data type: device identification information

    Official website address: https://open.alipay.com/platform/home.htm

    Privacy policy link: https://render.alipay.com/p/c/k2cx0tg8

  • SDK name: Tencent Advertising Youlianghui SDK

    Purpose of use: Advertising cooperation

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information type (scope) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address, location information, IP address

    Data type: device identification information, network information and location information

    Official website address: https://e.qq.com/resources/adn/

    Privacy policy link: https://e.qq.com/optout.html

  • SDK name: Xiaomi Push

    Purpose of use: Push messages to users using Xiaomi devices

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information type (scope) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address\operator information

    Data types: device identification information, network information and operator information

    Official website address: https://dev.mi.com/console/appservice/push.html

    Privacy policy link: https://dev.mi.com/console/doc/detail?pId=1822

  • SDK name: vivo push

    Purpose of use: Push messages to users of vivo devices

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information collected (scope): Device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), operator information

    Data types: device identification information, operator information

    Official website address: https://dev.vivo.com.cn/home

    Privacy policy link: https://www.vivo.com.cn/about-vivo/privacy-policy

  • SDK name: Meizu Push

    Purpose: Push messages to users of Meizu devices

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address, operator information

    Data types: device identification information, network information and operator information

    Official website address: https://open.flyme.cn

    Privacy policy link: https://www.meizu.com/legal.html

  • SDK name: Huawei Push

    Purpose: Push messages to Huawei mobile phone users

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI Information, etc.)

    Data type: device identification information

    Official website address: https://developer.huawei.com/consumer/cn/hms/

    Privacy policy link: https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides-V5/privacy-statement-0000001050042021-V5

  • SDK name: OPPO Push

    Purpose of use: Push messages to OPPO mobile phone users

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information collected (scope): Device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address, operator information

    Data types: device identification information, network information and operator information

    Official website address: https://push.oppo.com/

    Privacy policy link: https://www.oppo.com/cn/privacy/policy

  • SDK name: Tencent Browsing Service SDK

    Purpose: Web browsing adapted to kernel functions above X5

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address, location information, IP address

    Data types: device identification information, network information and location information

    Official website address: https://x5.tencent.com/docs/index.html

    Privacy policy link: https://x5.tencent.com/tbs/guide/develop.html#5

  • SDK name: Mobile Authorization Login SDK

    Purpose: One-click authorization of mobile phone number login

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address, operator information

    Data types: device identification information, network information and operator information

    Official website address: https://dev.10086.cn/docInside?contentId=10000067541479

    Privacy policy link: https://dev.10086.cn/docInside?contentId=10000009826805

  • SDK name: China Unicom Authorization Login SDK

    Purpose: One-click authorization of China Unicom phone number login

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information types (scopes) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address, operator information

    Data types: device identification information, network information and operator information

    Official website address: https://saas.wostore.cn/solution.html?param=1&num=14

    Privacy policy link: https://saas.wostore.cn/docIndex.html

  • SDK name: Telecom Authorization Login SDK

    Purpose: One-click authorization of Telecom mobile phone number login

    Method: Automatically obtain and record after you agree to the privacy policy

    Personal information type (scope) collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.), Wi-Fi address, operator information

    Data types: device identification information, network information and operator information

    Official website address: http://id.189.cn/banner/unPassword

    Privacy policy link: http://id.189.cn/api?initialSrc=/html/api_detail_109.html

For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them and require them to handle personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

(II) Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

2. As our business continues to develop, we may conduct mergers, acquisitions, asset transfers or similar transactions, and your information may be transferred as part of such transactions. We will require new companies or organizations that hold your personal information to continue to be bound by this Privacy Policy. If the purpose and method of processing personal information agreed in this Privacy Policy change, we will require the company or organization to re-ask your authorization and consent;

3. We will transfer your personal information to other parties to meet the requirements of laws, regulations, legal procedures, or mandatory government requirements or judicial rulings.

(III) Public Disclosure

We will only publicly disclose your personal information in the following circumstances and on the premise of taking security protection measures that meet industry standards:

1. Disclose your designated personal information in accordance with your needs and in the disclosure method you explicitly agree to;

2. In the case where your personal information must be provided in accordance with the requirements of laws, regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information based on the required type of personal information and disclosure method. Under the premise of complying with laws and regulations, when we receive a request for disclosure of information, we will require the presentation of the corresponding legal documents. We firmly believe that the information we are required to provide should be as transparent as possible within the scope permitted by law, and we will carefully review all requests to ensure that they have a legal basis. And it is limited to data that law enforcement agencies have the legal right to obtain for specific investigation purposes.

(IV) Exceptions to obtaining prior authorization and consent when sharing, transferring, and disclosing personal information

1. According to the provisions of relevant laws and regulations, in the following circumstances, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

2. Directly related to national security and national defense security;

3. Directly related to public security, public health, and major public interests;

4. Related to criminal investigation, prosecution, trial, and execution of judgments;

5. For the purpose of safeguarding the major legal rights and interests of the subject of personal information or other individuals, such as life and property, but it is difficult to obtain the consent of the person concerned;

6. The personal information collected is disclosed to the public by the subject of personal information on its own initiative;

7. Other circumstances stipulated by laws and regulations.

According to legal provisions, sharing and transferring personal information that has been de-identified and ensuring that the data recipient cannot restore and re-identify the subject of personal information does not constitute external sharing, transfer, and public disclosure of personal information, and the preservation and processing of such data will not require separate notification to you and your consent.

4. How we store and protect your personal information

(I) How we store your personal information

1. Storage location

In accordance with the provisions of laws and regulations, we will store your personal information collected and generated during operations in mainland China in mainland China. At present, we will not transfer your personal information overseas. If we transfer it overseas, we will comply with relevant national regulations or seek your consent.

2. Storage period

We will take reasonable and feasible measures to avoid collecting irrelevant personal information. Unless otherwise provided by laws, regulations or regulatory authorities or you agree to extend the retention period, we will only store your information for the minimum period necessary for the purposes described in this privacy policy.

If we terminate the service or operation, we will promptly stop the collection of your personal information, and will notify you in advance in accordance with the requirements of relevant laws and regulations, and delete or anonymize your personal information after the termination of the service or operation, except as otherwise provided by laws, regulations or regulatory authorities.

(II) Technical protection

We will strictly abide by the relevant laws and regulations of mainland China on the processing of personal information, and strive to use security protection measures that meet industry standards to protect your personal information and prevent your personal information from being accessed, disclosed, used, modified, damaged or lost without authorization. The security measures we take are as follows, but please understand that no security measures can be impeccable:

1. When exchanging data (such as credit card information) between your browser and the "Service", it is encrypted and protected by SSL or other appropriate algorithms, and we also provide https secure browsing for the website.

2. We will use encryption technology to ensure the confidentiality of data.

3. All your personal information is stored on secure servers and protected in controlled facilities. We classify your information according to importance and sensitivity, and ensure that your personal information has the corresponding security level. Similarly, we have special access control measures for cloud-based data storage, and we regularly review information collection, storage and processing practices, including physical security measures, to prevent any unauthorized access and use.

4. We will conduct due diligence on third-party partners to ensure that they are capable of protecting your personal information. We will also check whether third parties have adopted appropriate security standards by implementing appropriate contractual restrictions and conducting audits and assessments when necessary. In addition, employees and third-party partners who access your personal information are subject to strict contractual confidentiality obligations.

5. We will conduct information security and privacy protection training and examinations to enhance employees' awareness of the importance of protecting personal information.

We will revise and improve the above measures and management methods from time to time to improve overall security.

(III) Security Guarantee

We have established a data security management system around the data life cycle, and have improved the security of the entire system from multiple dimensions, including organizational construction, system design, personnel management, product technology, and personal information security impact assessment.

We will do our best to ensure the security of any information you send to us. However, the Internet is not an absolutely safe environment, and emails, instant messaging, and communication methods with other our users are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use a complex password to help us ensure the security of your account.

(IV) Information Security Incident Handling

After an unfortunate personal information security incident occurs, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, your own suggestions for preventing and reducing risks, and your remedial measures. We will promptly inform you of the relevant situation of the incident by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take reasonable and effective means to issue an announcement.

At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

5. Your rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights to your personal information:

(I) Review and copy your personal information

You have the right to review your personal information, except for exceptions stipulated by laws and regulations.

1. If you want to exercise your right to review data, you can review it yourself in the following ways:

Account information - If you want to review or edit your personal information and payment information in your account, change your password, add security information or close your account, etc., you can modify it yourself by visiting the https://www.vinabot.ai/ website or contact online customer service to perform such operations.

Search information - You can review or clear your search history, view and search history, view and modify personal information, and manage other data in https://www.vinabot.ai/.

If you cannot access this personal information through the above link, you can send an email to user@laihua.com at any time. We will respond to your review request within 15 working days.

2. If you want to exercise your right to copy data, you can send an email to user@laihua.com at any time. We will respond to your copy request within 15 working days.

(II) Correct your personal information

When you find that the personal information we process about you is wrong, you have the right to modify it yourself or ask us to make corrections. You can make a correction request through the methods listed in "(I) View and copy your personal information".

If you cannot correct the personal information through the above link, you can send an email to user@laihua.com at any time. We will respond to your correction request within 15 working days.

(III) Delete your personal information

In the following circumstances, you can ask us to delete your personal information:

1. If the purpose of collecting and using your personal information has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of processing;

2. If we collect and use your personal information without your consent;

3. If our processing of personal information violates laws, administrative regulations or agreements;

4. If you withdraw your consent or cancel your account;

5. If we no longer provide you with products or services, or the information retention period has expired.

If we decide to respond to your deletion request, we will also notify the entity that obtained your personal information from us and require it to delete it in a timely manner, unless otherwise provided by laws and regulations, or these entities obtain your independent authorization.

When you delete information from our services, we may not immediately delete the corresponding information from the backup system, but we will delete the information when the backup is updated.

(IV) Withdraw your authorization

If you wish to withdraw your consent for us to collect, use and disclose your other personal information or wish us to correct, update or delete your personal information, you can send an email to user@laihua.com, and we will respond to your withdrawal, correction or update request within 15 working days.

However, please understand and agree that when you withdraw certain authorizations, the related product functions will become unavailable, and we will no longer be able to provide you with the specific functions and/or services corresponding to the withdrawal of consent or authorization, and your decision to withdraw authorization will not affect the personal information processing previously carried out based on your authorization.

(V) Account cancellation by the subject of personal information

We respect the user's usage habits. If you decide not to use our products and services, after you successfully cancel your account, we will stop providing you with products or services and delete your personal information or anonymize it in accordance with the requirements of applicable laws. You can cancel your account by yourself in the following ways:

Method (1): You can cancel your account in [Settings] - [Personal Information] - [Account Cancellation]. We will provide you with account cancellation service after verifying your identity and clearing the assets in your account.

Method (2): You can send an email to user@laihua.com. We will respond to your cancellation request within 15 working days.

After canceling your account, we will stop providing you with products or services and delete your personal information at your request, unless otherwise provided by laws and regulations.

(VI) Responding to your above requests

For security reasons, any of your requests may require you to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request.

We will respond within 15 working days. If you are not satisfied, you can also complain through the following channels:

Call: 4008126909.

In principle, we do not charge any fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost fee depending on the situation. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, the development of new systems or fundamental changes to current practices), pose risks to the legitimate rights and interests of others, or are extremely impractical (for example, information stored on backup tapes).

In the following circumstances, we will not be able to respond to your request in accordance with laws and regulations:

1. Relevant to national security and national defense security;

2. Relevant to public security, public health, and major public interests;

3. Relevant to criminal investigation, prosecution, and trial;

4. There is sufficient evidence that you have subjective malice or abuse of rights;

5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations.

6. How we handle children's personal information

Although local laws and customs define children differently, we regard anyone under the age of 14 as a child.

We recommend that any child participating in online activities obtain the consent of their guardian in advance. If you are a child, please inform your guardian to read this privacy policy together, and seek your guardian's consent and guidance before you use our products or services or submit personal information. Or your use/continued use of our products or services, submission of personal information, all indicate that you have obtained your guardian's permission, and your guardian agrees that we collect, use, store, share, transfer and disclose your personal information in accordance with this privacy policy (including updated versions).

For the collection of children's personal information by using our products or services with the consent of the guardian, we will only collect, use, store, share, transfer and disclose your personal information when permitted by laws and regulations, with the explicit consent of the guardian or when necessary to protect the child.

If your guardian does not agree that you use our services or provide us with personal information in accordance with this privacy policy, please immediately stop using our services and notify us in a timely manner.

If you are a parent or guardian and have any questions about the use of our products or services by your children or the user information they provide to us, you can contact us through the feedback channels listed in the “How to Contact Us” section of this Privacy Policy.

7. How your personal information is transferred globally

In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China.

Since we provide products or services through resources and servers around the world, this means that, after obtaining your authorization and consent, your personal information may be transferred to or accessed by jurisdictions outside the country/region where you use the product or service.

If cross-border transfer is required, we will inform you of the name or name of the overseas recipient, contact information, processing purpose, processing method, type of personal information, and the method and procedure for you to exercise relevant rights against the overseas recipient, and obtain your authorization and consent separately.

Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information is sufficiently protected in the territory of the People's Republic of China. For example, we will ask for your consent to the cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfer.

8. Applicable Law and Jurisdiction

This Privacy Policy shall be governed by the laws of mainland China. Any disputes arising under this Privacy Policy shall be subject to the jurisdiction of the court where the defendant resides.

9. How this Privacy Policy is updated

Our Privacy Policy may be changed from time to time in accordance with business adjustments, changes in laws, regulations or policies. Without your explicit consent, we will not reduce your rights under this Privacy Policy. When the terms of the guidelines change, we will display the changed guidelines to you through the website at [https://www.vinabot.ai/], push notifications, pop-ups or other appropriate forms when you log in and update the version. Vinabot recommends that you log in to the webpage at [https://www.vinabot.ai/] to review this policy regularly to keep abreast of any changes to this policy and the content of the changes.

Except where otherwise mandatory by laws, regulations or regulatory provisions, the adjusted or changed content shall take effect 7 days after notification or publication. If you do not agree to the modified Privacy Policy, you have the right and should immediately stop using our products and/or services. If you continue to use our products and/or services, you will need to agree and accept the changes we make to the relevant terms of this Privacy Policy.

10. This Privacy Policy does not apply to:

1. Other third-party products or services, which may include products or websites and advertising content displayed to you in personalized recommendations or other products or websites linked to in our services.

2. Other third parties that advertise our products and services.

3. Your use of these third-party services (including any personal information you provide to these third parties) will be subject to the terms of service and privacy policy of these third parties (not this Privacy Policy). Please read the terms of the third party carefully for specific provisions. Please properly protect your personal information and provide it to third parties only when necessary.

4. The products and related services described in this Privacy Policy may vary depending on factors such as the terminal device, mobile phone model, system version, software application version, etc. that you use. The final products and services are subject to the software and related services you use.

11. How to Contact Us

If you have any questions, comments, suggestions or complaints about the content of this privacy policy, you can contact us in the following ways:

Manual customer service channel: You can call our customer service hotline: 400-8126-909 during working hours (9:00-18:00) on weekdays (if there are any changes, they will be updated on the website, and the updated phone number will prevail)

Specialized email channel: We have set up a special mailbox user@laihua.com, you can contact us by sending an email to this mailbox;

Generally, we will reply within 15 working days after receiving your notice.