Updated: June 25, 2023
Effective: June 25, 2023

Privacy Policy

Privacy Policy Description

Personal Information We Collect

How We Use Your Personal Information

How We Use Cookies and Similar Technologies

How We Share, Transfer, and Publicly Disclose Your Personal Information

Personal Information Management

Information Storage and Security

Third-Party Providers and Their Services

Minors Terms

How to update this policy and its scope of application

Contact us

Information collection by third-party SDK

Nanjing Zhuxia Culture Communication Co., Ltd. is the operator of the Huazu Video platform (hereinafter referred to as "Huazu Video" or "we"). This Privacy Policy (hereinafter referred to as "this Policy") explains how Huazu Video will handle your personal information and privacy information, and declares Huazu Video's commitment to protecting privacy. Huazu Video may update or modify this policy from time to time in the future based on the information processing situation. Please read, understand and agree to this policy and any supplementary policies before submitting personal information or privacy information to Huazu Video. The key points of this privacy policy are as follows:

• We will explain our collection, use, protection and processing of personal information one by one so that you can understand the overview of personal information.

• When you register a Huazu Video account and use our services, we will collect your personal information (name, gender, age, profile photo or phone number, location information and log information) based on your consent and the need to provide services.

• In addition to the core functions of the product, Huazu Video provides some additional functions to enhance the user experience, including: message settings, email settings, and push notification settings. When you use the additional functions of Huazu Video, we will not collect your personal information in addition unless we inform you and obtain your consent in accordance with this policy.

• At present, Huazu Video will not actively disclose your personal information publicly except for mandatory requirements of laws, regulations, legal procedures, litigation or government authorities. If there are other circumstances that require public disclosure of personal information, we will obtain your explicit consent. At the same time, we ensure that the disclosure adopts security protection measures that comply with laws and industry standards.

• You can access, correct or delete your personal information through the channels listed in this Privacy Policy, or you can set privacy settings or contact us.

• This Privacy Policy applies to all products of Huazu Video, including Huazu Video website, iOS application, Android application, and mini-programs on various platforms.

Your use or continued use of our services means that you agree that we will collect, use, store, share, transfer and publicly disclose your relevant information in accordance with this Privacy Policy.

1. Personal Information We Collect

Personal information refers to various information recorded electronically or otherwise that can identify a natural person's personal identity alone or in combination with other information, including the natural person's name, date of birth, and ID number (users perform personal real-name authentication to create circles and public homepages in the application). This type of information will be collected when you register and use our services. Huazu Video will only collect and use your personal information for the following purposes described in this policy.

1.1 Personal information you directly provide and we automatically collect

In order to collect your information under this guideline, or to provide you with services, optimize our services, and protect the security of your account, we will need to ask you for relevant permissions; Sensitive permissions: precise geographic location, camera, microphone, and album will not be enabled by default, and will only be authorized to us after you explicitly agree. It should be noted that obtaining sensitive permissions is a necessary but not sufficient condition for us to collect specific information. Our acquisition of a specific sensitive permission does not mean that we will necessarily collect your relevant information; even if we have obtained sensitive permissions, we will only collect your relevant information when necessary and in accordance with this privacy policy:
Note:com.qianfanyun.base is the internal module package name of the app, and no private information will be sent to third parties.

• Registration information. You can register and log in to a registered Huazu Video account to use the services provided by Huazu Video. At this time, you need to provide us with the following information: Account name, avatar (if any) and email address. After providing the above information and agreeing to the registration agreement and this policy, you can use the core business functions of Huazu Video, including: browsing the content within the Huazu Video platform, posting dynamics, answering, commenting, and evaluating.

• Additional information. When you use the additional business functions of Huazu Video, in order to provide you with the products and services, in addition to the registration information, you need to further provide us with your personal identity information and location information. If you do not use specific products and services, you do not need to provide relevant information (which will be explained in detail below).

• Location information. When you turn on the device positioning function and use our location-based services, we will collect information about your location. This information is sensitive information. Refusing to provide this information will only prevent you from using functions related to location information, but will not affect your normal use of other functions of Huazu Video.

• Keyword information. When you use the search service provided by Huazu Video, we will collect your query keyword information, device information. In order to provide efficient search services, some of this information will be temporarily stored in your local storage device. This keyword information usually cannot identify your personal identity alone, does not belong to your personal information, and is not within the scope of this policy. Only when your search keyword information is linked to your other information and can identify your personal identity, during the combined use period, we will treat your search keyword information as your personal information, and process and protect it together with your search history in accordance with this policy.

• Real identity information. When you use the identity authentication service provided by Huazu Video, we will collect your name, ID number, and relevant identity certification. If you do not provide this information, we will not be able to provide the relevant services.

• Contact information. When you file an account complaint with Huazu Video, we will collect and record your name and mobile phone number to facilitate contact with you or help you solve the problem. If you refuse to provide the above information, we may not be able to provide you with timely feedback on the results of the complaint.

• User-shared information. When you use services provided by a third party in Huazu Video, you agree that Huazu Video allows the third party to collect your account name, avatar and other personal information necessary to provide services. If you refuse the third party to collect the above information when providing services, you may not be able to use the third-party service in Huazu Video.

• When you use the publishing function, the text, photos, videos, comments, and likes information you upload will be stored in our server because storage is necessary to achieve this function. We will store them in an encrypted manner. Unless you choose to do so or comply with relevant laws and regulations, we will not provide the above information to the outside world or use it for any purpose other than this function.

• In order to provide you with one-click sharing service, our products integrate U-Share SDK, which will collect your device identification information (IMEI/android ID/IDFA) and the public information of the social account you need to share in order to complete the one-click sharing service. For the security of your information, we have entered into a data security and confidentiality agreement with third-party SDK service providers, and these companies will strictly abide by our data privacy and security requirements. We will not share your personally identifiable information with them unless you agree. To help you better understand the type of data and purpose collected by [Umeng+], as well as how to protect your personal information, you can log in to https://www.umeng.com/policy to learn about [Umeng+]'s privacy policy.

• Get installed apps:Get installed app information to determine whether a third-party app (QQ, WeChat) is installed on the phone, so that when sharing and three-party login are performed, the user can be prompted that the app is not installed.

• Get mac address/Android ID/IP address: The collected mac address/Android ID/IP address is used to provide basic anti-cheating capabilities and related logs.

• Get running process information: Used to determine whether the current app is in the foreground or background to help process the logic of sharing passwords.

1.2 Permissions we obtain

1.2.1 The following is a list of permissions obtained

• Positioning permission:To provide you with weather services, people nearby, chat positioning, and publishing positioning

• Network permission:To interact with the interface for data, download image/video elements

• Dialing:Used to call up the dialing interface. This function does not automatically dial out a call, but only calls up the dialing interface. The user decides whether to dial or not. This function is mainly used to highlight the phone number for the convenience of users to click

• Mobile information:To protect account security, this permission will not record user personal information

• Install application:Used for app update

• Pop-up window permission:Apply for floating window permission. Due to some models, such as Meizu and some Xiaomi models, Toast cannot be displayed. You must have floating window permission to display Toast

• Recording permission:Used to record video and save sound when publishing

• Modify recording settings permission:Used to perform related recording configuration when publishing recorded video and saving sound

• Camera permission:Used to record video and take photos when publishing

• Flash permission: Used to increase the brightness in dark environments when publishing recorded videos and taking photos
• Autofocus permission: Used to implement the autofocus function when publishing recorded videos and taking photos
• Settings related: Used to remind users to turn on push messages
• Message related: Used to support push and chat
• Broadcast related: Used to keep the background push chat process alive

1.2.2 Permission Description

Users can refuse to grant the above permissions, but some permissions may cause abnormal application usage, such as network permissions and storage permissions, because these permissions are necessary for application use. It is particularly important to point out that even if we obtain these sensitive permissions with your authorization, we will not collect your information when the relevant functions or services do not require it.

1.3 Circumstances in which we may obtain your personal information from a third party

You can also use a third-party account (such as WeChat, QQ, etc.) to log in to Huazu Video. At this time, you can choose to authorize Huazu Video to read the public information you have registered, published, and recorded on the third-party platform under the premise of complying with relevant laws and regulations. For the mobile phone number that we require but the third party cannot provide, you still need to provide it so that we can provide the relevant services required later.
Huazu Video may obtain your above information from a third party in order to remember your login identity as a Huazu Video user, so that Huazu Video can provide you with better products and services.
You can choose the scope of personal information that Huazu Video is authorized to obtain when logging in to Huazu Video with a third-party account, or set the permission for Huazu Video to obtain your personal information through [General Settings-Third-Party Social Login] during the use of Huazu Video. However, please note that if certain permissions are stopped, you may not be able to enjoy the best service experience, and some services may not work properly.

1.4 Exceptions to Authorization and Consent

According to relevant laws and regulations, your personal information is collected in the following circumstances without your authorization and consent:
(1) Involving national security and interests, social public interests;
(2) Related activities related to criminal investigation;
(3) For the purpose of protecting the life and property of you or others, but unable to obtain your timely authorization under special circumstances;
(4) Collecting your personal information from other legal and public channels;
(5) Other circumstances stipulated by laws and regulations.

1.5 Personalized Push Instructions

The APP will not provide personalized push based on user behavior.



2. How Huazu Video Uses Your Personal Information

We will use your personal information for the following purposes:

• Help us design new services and improve existing service experience.
• When we provide services, it is used for identity authentication, customer service, security prevention, fraud monitoring, archiving and backup purposes to ensure the security of the products and services we provide to you.
• Invite you to participate in Huazu Video activities and market research.
• Conduct internal audits, data analysis and research to better improve our products, services and communication with users.
3. How we use cookies and similar technologies

3.1 Cookies

When you use our services, 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 use this information to determine whether a registered user has logged in, improve service/product quality, and optimize user experience. If you do not want personal information to be saved in cookies, you can configure your browser and choose to disable the cookie function. Disabling the cookie function may affect your access to Huazu Video or your inability to fully obtain the services provided by Huazu Video.
Huazu Video will not use cookies for any purpose other than the purposes described in this 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.

3.2 Device Permission Calling

Huazu Video may need you to open some device permissions, notification, album, and camera access permissions in the process of providing services. You can also choose to close some or all permissions at any time in the device's settings function to refuse Huazu Video to collect the corresponding personal information. The display and closing methods of permissions may vary on different devices. Please refer to the device and system developer's instructions or guidelines for details.



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

4.1 Sharing

Huazu Video will not provide your personal information to a third party without your consent or authorization. However, with your confirmation and consent, Huazu Video may share your personal information in the following circumstances.

• Sharing with consent: After obtaining your explicit consent, Huazu Video will share your personal information with other parties.
• Shared with Huazu Video's affiliates: Within the scope of the purpose of use stated in this policy, your personal information may be shared with Huazu Video's affiliates. As a policy, we will only share necessary information. If the affiliate wants to change the purpose of processing personal information, it will ask for your authorization and consent again.
• Shared with authorized partners: Huazu Video may share some of your personal information with its partners to provide better customer service and user experience. When Huazu Video sends you a gift (if any), Huazu Video must share your personal information with the logistics service provider to arrange the delivery, or arrange for the partner to provide you with services. We will only process your personal information for specific, clear and legitimate purposes, and will only share the information necessary to provide services. At the same time, we will sign a strict confidentiality agreement with them, requiring them to process personal information in accordance with our instructions, this policy and any other relevant confidentiality and security measures.
• Sharing under legal circumstances: We may share your personal information externally in accordance with the provisions of laws and regulations, the needs of litigation dispute resolution, or the requirements of administrative and judicial authorities in accordance with the law.
• Detailed description of the collection of personal information by the third-party SDK is provided below this article.

4.2 Transfer

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

• Transfer with explicit consent: We will transfer your personal information to other parties after obtaining your explicit consent;
• In the event of mergers, acquisitions or bankruptcy liquidation, if personal information is transferred, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy, otherwise we will require the company or organization to re-ask your authorization and consent.

4.3 Public Disclosure

We will only publicly disclose your personal information in the following circumstances and on the premise of taking security measures that comply with laws and industry standards

• with your explicit consent;
• based on laws, regulations, legal procedures, litigation or mandatory requirements of government departments. However, we guarantee that, under the premise of complying with laws and regulations, when we receive the above-mentioned request for disclosure of information, we will require the production of corresponding legal documents.
5. Personal Information Management

We attach great importance to your concern about personal information and do our best to protect your rights to access, correct, delete and withdraw consent to your personal information so that you have sufficient ability to protect your privacy and security. We will do everything possible to take appropriate technical means to ensure the accuracy of the personal information collected about you and ensure timely updates.

5.1 Access and Correction of Your Personal Information

(1) You can query and access your avatar, user name, profile, gender, birthday, registration time,

through [General Settings->General Settings].

5.2 How to Delete Your Personal Information

(1) You can cancel your account through [Settings->Cancel Account].
(2) If there are virtual currency or balance in your account, please be sure to transfer it before canceling the account. After the account is cancelled, the wallet information will be cleared.
(3) After you cancel your account, you will not be able to log in to the app with this account, your personal information will no longer be displayed on the app and will be deleted from the server.
(4) We will complete the verification and processing of your cancellation application within 15 working days.

5.3 Obtaining a copy of your personal information

You have the right to obtain a copy of your personal information. If you need to obtain a copy of your personal information collected by us, you can contact us at any time (the contact information is at the end of the Privacy Policy). We will provide you with your personal information upon your request, subject to compliance with relevant laws and regulations and technical feasibility

6. Information storage and security

6.1 Security protection measures and capabilities

We strive to provide protection for the information security of users to prevent information leakage, loss, improper use, unauthorized access and disclosure, etc. We use multi-faceted security protection measures to ensure that the protection of users' personal information is at a reasonable level of security, including technical protection measures, management system control, security system protection and many other aspects. We adopt industry-leading technical protection measures. The technical means we use include but are not limited to firewalls, encryption (SSL, SHA256), de-identification or anonymization, access control measures, key authentication, data encryption, malicious code filtering, regular data backup, automatic reconciliation, etc. In addition, we will continue to strengthen the security capabilities of the software installed on your device. We will complete some information encryption work locally on your device to consolidate secure transmission;
We will understand the application information installed on your device and the process information running to prevent viruses, Trojans and other malicious programs. We have established a special management system, process and organization to protect personal information security. We strictly limit the scope of personnel who access information, require them to comply with confidentiality obligations and conduct audits, and those who violate their obligations will be punished according to regulations. We will also review the management system, process and organization to prevent unauthorized personnel from accessing, using or disclosing user information without authorization.

6.2 Security Incident Handling Measures

If a security incident such as leakage, damage, or loss of personal information occurs, we will activate the emergency plan to prevent the security incident from expanding. After a security incident occurs, we will promptly inform you of the basic situation of the security incident, the disposal measures and remedial measures we will or have taken, and our response suggestions for you in the form of push notifications, emails, etc. If it is difficult to inform you one by one, we will issue a warning through announcements, etc.

6.3 Processing of expired information

In general, for the processing of expired information, we will delete or anonymize your personal information. However, the following exceptions are made: complying with the requirements of laws and regulations on information retention (for example: the "E-Commerce Law" stipulates that the storage period for product and service information and transaction information shall not be less than three years from the date of completion of the transaction). For financial, auditing, dispute resolution and other purposes, it is necessary to reasonably extend the period.

6.4 Information storage location and period

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, the information generated by users will be stored permanently, and the log information will store the request logs of the last three months. If it is necessary to transfer relevant personal information collected in China to overseas institutions in order to handle cross-border business in the future, we will obtain your consent in advance, implement it in accordance with the provisions of laws, administrative regulations and relevant regulatory authorities, and take effective measures (signing agreements, verification) to require overseas institutions to keep the personal information obtained confidential.
We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, but in order to comply with applicable laws and regulations, court judgments or rulings, the requirements of other competent authorities, and safeguard the public interest, we may appropriately extend the retention period of personal information.

7. Third-party providers and their services

To ensure a smooth browsing experience, you may receive content or web links provided by third parties outside of Huazu Video and its partners (hereinafter referred to as "third parties"). Huazu Video has no control over such third parties. You can choose whether to access the links, content, products and services provided by third parties.
Huazu Video cannot control the privacy and personal information protection policies of third parties, and such third parties are not subject to this policy. Before you submit personal information to a third party, please make sure you read and agree to the privacy protection policies of these third parties.

8. Minor Terms

We attach great importance to the protection of minors' personal information. This application is mainly for adults.

• If you are a minor under the age of 18, you should read and agree to this Privacy Policy under the supervision and guidance of your parents or other guardians before using this product and related services.
• If you are the guardian of a minor under the age of 14, you should read and agree to this Privacy Policy for your guardian before using this application and related services.
• We protect the personal information of minors in accordance with the provisions of relevant national laws and regulations, and will only collect, use or disclose the personal information of minors when permitted by law, with the explicit consent of parents or other guardians, or when it is necessary to protect minors; if we find that we have collected the personal information of minors without obtaining the verifiable guardian's consent in advance, we will try to delete the relevant information as soon as possible.
• If you are the guardian of a minor, when you have other questions about the personal information of the minor you are protecting, please contact us through the contact information published in this privacy policy of the company.
9. How this policy is updated and its scope of application

We reserve the right to update or modify this policy from time to time. If the modification results in a substantial reduction of your rights under this policy, we will send you a change notice through different channels, including website announcements and private message notifications.
Please note that only after you click the consent button in the pop-up window will we collect, use and store your personal information in accordance with the updated guidelines.
This policy applies to all our services. However, some services have their own specific privacy policies, which more specifically describe how we handle your information in that service. If there is any inconsistency between this Policy and the privacy policy of a specific service, the specific privacy policy shall prevail.



10. Contact Us
• If you have any questions or inquiries or complaints about the contents of this Privacy Policy or any privacy protection-related matters you encounter when using our services, you can contact us in any of the following ways:
• You can submit feedback by clicking “Contact Us” at the bottom of our page;
• You can contact us through our customer service phone number (+86)025-66011660;
• You can contact us by sending emails to tv@huazu.email;
• We will respond to you as soon as possible within 15 working days after receiving your comments and suggestions and verifying your user identity. In addition, you understand and acknowledge that we will be unable to respond to your request in the following circumstances related to personal information:
• Related to national s