Privacy Policy

Last updated and effected: July 1st, 2024

You can view this Privacy Policy in RingConn App and/or on the bottom of our website (https://www.ringconn.com) .

This Privacy Policy covers:

1.Introduction

2.What data we collect

3.How we use your data

Legal basis for processing data

5.Policy for children

6.How data is shared and disclosed

7.How we store and transfer data

8.How we safeguard your data

9.Data retention

10.What are your rights

11.Policy for European users

12.Policy for California users

13.Update to this privacy policy

14.Severability

15.Dual language

16.SDK partners

17.Who we are and how to contact us

1.INTRODUCTION

Shenzhen Ninenovo Technology Limited, a company established under the laws of People’s Republic of China or Ninenovo-affiliated Company (collectively “RingConn”, “we” or “us”) “RingConn” knows how important privacy and personal data are to our customers.

This Privacy Policy is meant to help you understand what data we collect, why we collect it, how we process, store and protect it and how you can update, manage, export, and delete your data. Please take a moment to carefully review this policy.

This Privacy Policy applies to personal data collected and processed by us through our “Services” which includes: our RingConn devices (“Devices”), Application (“App”), websites, software, APIs, emails ,newsletters and our services.

By clicking “Agree” in the "Personal Information Protection Guidelines" when installing our App, you give consent to our processing of your data in accordance with this Privacy Policy and the applicable laws, and you give consent to and agree to be bound by the terms and conditions of this Privacy Policy.

If you do not agree with the terms contained herein, please do not use our Services.

2.WHAT DATA WE COLLECT

When you use our Services, we collect the following types of data.

2.1 RINGCONN DEVICE DATA

Your RingConn device collects measurement data to estimate a variety of metrics: PPG sensors data, accelerometer data and your skin temperature data. We use the measurement data to calculate and generate data like heart rate, heart rate variability, respiratory rate, calories burned, sleep phases, step count, stress levels and activity intensities throughout the day.

When your RingConn device synchronizaes with our App or software, data recorded on your device are transferred from your device to our servers.

2.2 APP DATA

When you access or use our Services, we collect data about App activity, including information about your interactions with our Services:

2.2.1 Device Information: synchronised RingConn device information, information about the mobile terminal device on which the Application is installed (including device and Application identifiers), IP address information, browser type information, system language information.

2.2.2 App activity: application interaction information, in-app search history, other user-generated content, other user activity information.

2.2.3 Application information and performance: crash logs, application performance diagnostic information, other application performance data.

Some of our integrated third-party SDKs may collect mobile device parameters and system information, App logs, Location information (depending on the permissions you grant us), etc., in the course of their normal operation. For information collected by third-party SDKs, please refer to the description in section "16. SDK partners”.

Some of our integrated SDKs may collect device MAC address and software installation list information during their normal operation. However, please note that we do not authorise or require these SDKs to collect such information.

2.3 LOCATION DATA

If you enable your seld access to or use any of our location-based services, such as by enabling GPS-based activity tracking through your App, we may process the approximate or precise location of your device while the service is active. This data may be obtained via your device's service provider network ID, GPS, and/or Wi-Fi data.

We request location permissions only to ensure the normal connection and data transmission of Bluetooth devices and the normal use of some third-party SDKs.

We do not process such location data without first obtaining your consent. You may disable such location processing at any time via using your mobile device’s location permission settings. We may also derive your approximate location from your IP address.

2.4 DATA YOU PROVIDE

To create an account on our Services, you may provide us with data that includes: your user name, year and month of birth, gender (female, male or you choose not to disclose), height, weight, email address, mobile telephone number, password and country information. This is the data you have to provide to create an account with us. You may also choose to provide other types of information, such as a profile photo. If you contact us or participate in a survey, contest, or promotion, we collect the data you submit such as your name, contact information, and message.

If you enable the "[]" feature in the Application and have agreed to our Privacy Notice, you agree to provide us with the following data: menstrual cycle timeline, typical period length etc. when you first participate in the questionnaire; menstrual cycle timeline, symptoms, flow level, whether you drink alcohol or take medication, and data on the measurements and metrics that you authorise us to collect from your RingConn device. You consent to the collection of this data in order for us to provide you with a complete service; if you do not consent to the collection of this data, please do not activate the "[]" feature and opt out of our Privacy Notice.

If you enable the "Sleep Apnea Monitoring" feature in the Application and have agreed to our Privacy Notice, you agree to provide us with the following data: height, weight, age, BMI, sex, [neck circumference], medical history, OSA symptoms, sleep quality etc. For the purpose of generating an OSAHS assessment report，using the data you provide about sleep quality, OSA symptoms, etc. as well as authorising us to collect measurement data and generate metrics data collected by your RingConn device. You consent to the collection of this data in order for us to provide you with a complete service; if you do not consent to the collection of this data, please do not activate the "OSAHS" feature and opt out of our Privacy Notice.

2.5 DATA FROM THIRD PARTIES

When you choose to access to our Services via a Wechat, QQ (including Tim), Google, Facebook or Apple account, we collect its account name and profile photo.

3.HOW WE USE YOUR DATA

We use the data we collect for the following purposes.

3.1 To provide and maintain our Services

We process personal data to provide our Services. For example, to provide you with daily insights about your heart rate variability, sleep, and activity.

There may be automatic or associated startup actions (depending on the notification permissions you grant us), primarily used for sending notifications, including reminders and other information related to the app's functionality, to enhance the user experience and ensure that you receive important information promptly.

3.2 To improve and develop our products and services

We use third-party SDKs to optimise our products and services, including to enable application crash detection, push notifications, third-party account login, location, maps and navigation. Please refer to section "16. SDK Partners" in this Privacy Policy to learn about the privacy policies of third-party SDKs.

We process data about your use of RingConn devices and App with the help of the Sensors Data SDK, which may collect data including Device information, App logs, Location information (IP address resolved location information, GPS location information), App identifier information, ANDROID ID. This data is collected to improve our services and develop new features. When possible, we will do this using only pseudonymized, aggregated, or non-personally identifiable data.

In the event that you agree for us to access your location data, and in the event that you agree to enable the positioning, mapping and navigation features in the App, we will provide you with the relevant services with the help of third-party mapping SDK(s), which may collect data such as your location information, device information, device parameters and system information.

3.3 To provide customer service

We process personal data for the purpose of providing customer service and managing our customer communication. If you contact our customer support with questions regarding your app data, we may use the provided data to answer your questions and for solving any issues you may have.

3.4 To comply with statutory obligations

In certain cases, we must process certain data when it is required by applicable laws and regulations. Such statutory obligations are related, for example, to accounting and tax requirements, legal claims, or other legal purposes.

4.LEGAL BASIS FOR PROCESSING DATA

Our lawful basis for processing your data depends on the particular processing purposes, including:

4.1 Contract

When processing personal data for the purpose of providing Services we process it on the basis of a user contract, which is formed when you create your account and accept of our terms and conditions.

4.2 Consent

We process your health-related data only with your consent. Please note that some of the personal data we process, including any data concerning your health, is considered special or sensitive personal data. Under applicable law, such data is processed only if you have given your consent for processing.

4.3 Legitimate Interest

We process your personal data based on our legitimate interests when we process it for the purposes of marketing our products and services, providing our customer service and improving our products and services. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy, in compliance with applicable law.

4.4 Legal obligation

We must process certain information to comply with statutory obligations which may vary in each country.

5.OUR POLICY FOR CHILDREN

Persons under the age of 18, or any higher minimum age in the jurisdiction where that person resides, are not permitted to create RingConn accounts. If we learn that we have collected the personal data of a child under the relevant minimum age, we will take steps to delete the data as soon as possible. Parents who believe that their child has submitted personal data to us and would like to have it deleted may contact us (see “How To Contact Us” below).

6.HOW DATA IS SHARED AND DISCLOSED

We do not sell personal data of our users. We do not share your personal data except in the limited circumstances described below.

6.1 FOR EXTERNAL PROCESSING

We share your personal data with certain trusted partners, including our affiliates, service providers, and other partners, so that we can provide you with our services and operate our business. (For affiliates, service providers and other partners currently involved in this situation, please refer to section "16. SDK Partners" of this Privacy Policy.) We require our partners to process your personal data based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. We also require these partners to protect your personal data to at least the same standards that we do.

We use external processing services such as:

(1)storing our users’ data;

(2)providing customer services;

(3)managing and organizing our marketing activities. We only share website usage data with our advertising network partners for the purposes of analyzing and optimizing our marketing. We do not share the health-related data or other sensitive personal data with third party advertisers.

(4)analyzing information regarding the use of our online service to improve our service quality.

6.2 WHEN YOU AGREE OR DIRECT US TO SHARE

You may direct us to disclose your information to others, for example, when you give a third-party application such as Apple Health or Google Fit permission to access to your data, and we may share your data with this third-party based on your requirements. Remember that their use of your data will be governed by their privacy policies and terms. Please carefully read their latest policies and terms. You can revoke your consent to share with third-party applications via using your account settings. We also reserve the right to disclose personal data when we have your express consent to do so.

RingConn use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy , including the Limited Use requirements.

RingConn will use:

https://www.googleapis.com/auth/fitness.sleep.writehttps://www.googleapis.com/auth/fitness.sleep.readhttps://www.googleapis.com/auth/fitness.heart_rate.writehttps://www.googleapis.com/auth/fitness.body_temperature.writehttps://www.googleapis.com/auth/fitness.oxygen_saturation.writehttps://www.googleapis.com/auth/fitness.body.writehttps://www.googleapis.com/auth/fitness.activity.write

to write health data to Google Fit, including sleep, activity, body, blood oxygen, heart rate and other information, so that users can view the data generated by the ring through Google Fit, and synchronize the health data with Google Fit.

6.3 FOR LEGAL REASONS

We reserve the right to disclose personal data to protect our legal rights and property; and to comply with valid legal requirements.

We may preserve or disclose data about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.

We may share non-personal data that is aggregated so that it cannot reasonably be used to identify an individual with or without combining additional information. We may disclose such data publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us, or as part of the community benchmarking data we provide to users of our subscription services.

We will not transfer your personal information to any companies, organisations or individuals, except in the following circumstances:

a) Transfer with explicit consent: We will transfer your personal information to other parties after obtaining your explicit consent;
b) In cases involving merger, acquisition, or sale of assets, we will continue to take measures to protect the personal data privacy and give affected users notice before transferring any personal data to a new entity. Where a transfer of personal data is involved, we will require the new entity to continue to be bound by this privacy policy before we it is requested to seek independent consent from you to collect and process your data.

7.HOW WE STORE AND TRANSFER DATA

We process and back up personal data through a global operating and control infrastructure. Currently, we use cloud services deployed in United Kingdom for processing personal data of users from the United States, United Kingdom and EEA.

We rely on multiple legal basis to lawfully transfer personal data around the world. These include your consent and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us. We are subject to the oversight of the US Federal Trade Commission and remains responsible for personal data that we transfer to others who process it on our behalf as described in “HOW DATA IS SHARED AND DISCLOSED” section.

In cases where personal data is processed outside of the jurisdiction in which it was collected, we always ensure your personal data is protected with appropriate safeguards in accordance with applicable privacy and data protection laws. Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a RingConn account and click “I agree” to data transfers.

If you have a complaint about our international data transfer, please contact us by means described in “HOW TO CONTACT US” section. You may make a complaint to the competent regulatory authority in your jurisdiction.

8.HOW WE STORE, TRANSMIT AND RETEND YOUR DATA

As we provide our Products or Services through resources and servers around the world, by submitting your consent to this Privacy Policy, you agree that:

(1) If you use our Services, the personal information we collect from and generate in the People's Republic of China will be stored on servers in the People's Republic of China;

(2) If you use our Services, the personal Information that we collect and generate outside the People's Republic of China will be stored on servers outside of the People's Republic of China, including in jurisdictions other than the one in which the data was collected, or subject to access from such jurisdictions;

(3) Currently, we use cloud servers deployed in the [UK] to process personal data of users in the United States, the United Kingdom and the European Economic Area (EEA).

Where personal data is processed in a jurisdiction other than the one in which it was collected, we will always ensure that your personal data is appropriately protected in accordance with applicable privacy and data protection laws. You are aware and fully understand that different jurisdictions have their own regulatory requirements for the collection, storage, use, and sharing of data and processing of personal information and may have lesser protections than the laws in your jurisdiction. When you create a RingConn account and click "I agree" to data transfers, you agree to assume this risk.

We may provide your personal information to third party entities (located in or outside of the country where the data was collected) after fulfilling our obligations under the law: (1) as expressly required by applicable law; and (2) with your sole consent. In the foregoing cases, we will keep your personal data secure as required by law in accordance with this Privacy Policy.

By submitting your consent to this Privacy Policy, you agree to enable third-party SDK services (see section "16. SDK Partners" in this Privacy Policy), and that we will store, transfer and retain personal and non-personal data collected in accordance with the requirements of the third-party's privacy policy.

The retention period for your personal data generally depends on the duration of your RingConn account lifecycle. Your personal data will be deleted when it is no longer needed for the purpose it was originally collected, unless we have a legal obligation to retain data for a longer period of time. For example, your measurement data regarding your sleep, stress and activity is stored only so long as your RingConn account is active.

We also have legal obligations to retain certain personal data for a specific period of time, such as for tax purposes. These required retention periods may include, for example, accounting and tax requirements, legal claims, or for any other legal purposes. Please note that obligatory retention periods for personal data vary based on the relevant laws.

If you wish, you may request deletion of your RingConn account by contacting data_protect@ringconn.com.

9.HOW WE SAFEGUARD YOUR DATA

We use technical and organizational safeguards to keep your data safe and secure. Where appropriate, these safeguards include measures such as anonymization or pseudonymization of personal data, strict access control, and the use of encryption to protect the data we process. We also use industry standard data protection measures to safeguard all international transfers of personal data through data protection agreements with our service providers. However, no method of transmitting or storing data is completely secure. If you have a security-related concern, please contact us by means described in “HOW TO CONTACT US” section.

We also ensure that our staff receives adequate training to ensure personal data is processed only in accordance with our internal policies, consistent with our obligations under applicable law. We also limit access to your sensitive personal data to personnel that have specifically been granted such access.

We regularly test our service, systems, and other assets for possible security vulnerabilities. We also update the RingConn App and the RingConn device firmware regularly. We recommend that you make sure that you always have the latest App and firmware versions installed in order to maximize protection of your data.

If you enable "Shared with friends and family" feature in the Application and have agreed to our Privacy Notice, you consent to us sharing your weekly health report data, sleep data, activity data, stress data, vital sign data, high heart rate abnormalities, including measurements and metrics collected by your RingConn device and data you provide to us in the course of your use of the Application, with other registered users of the Application whom you have designated to be invited. Shared with friends and family is accomplished through the creation of a share link that is a one time effective link for each single invitation you share with other Application user, and you may choose to stop sharing your weekly health report data, sleep data, activity data, stress data, vital sign data, high heart rate abnormalities with other users by removing any user from your sharing list which is under your sole management . You consent to the sharing of these data in order for us to provide you with a complete service; if you do not consent to the sharing of these data, please do not activate the "Shared with friends and family" feature and opt out of our Privacy Notice. When you choose to remove any user from your sharing list, the historical report data that you have shared with other users will no longer be accessible by the removed user. YOU AGREE THAT WHEN YOU ARE INVITED BY ANOTHER REGISTERED USER TO ACCESS ANOTHER PERSON'S WEEKLY HEALTH REPORT DATA,SLEEP DATA, ACTIVITY DATA, STRESS DATA, VITAL SIGN DATA, HIGH HEART RATE ABNORMALITIES, YOU SHOULD NOT DISCLOSE, TRANSMIT, COPY, DOWNLOAD OR OTHERWISE SHARE THE USER'S DATA WITH OTHER INDIVIDUALS OR ORGANISATIONS THAT HAVE NOT BEEN AUTHORISED BY THE USER, AND THAT ANY ACTIONS THAT RESULT IN A VIOLATION OF PRIVACY LAWS ARE NOT ENCOURAGED OR PERMITTED, AND THAT WE WILL NOT BE RESPONSIBLE FOR ANY LEGAL LIABILITIES THAT MAY ARISE FROM ANY OF YOUR INAPPROPRIATE ACTIVITIES.

10.WHAT ARE YOUR RIGHTS

10.1 YOUR RIGHTS UNDER APPLICABLE LAWS

You have rights and choices to your data under applicable laws. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. Please note that by exercising some of your following rights, for example, by withdrawing your consent to our Privacy Policy, we may not be capable to maintain our Services to you.

You may choose to exercise the following rights about your data :

(1)Right of confirmation and access. You can ask us to confirm whether your data has been processed, or request access to your data and receive a copy of personal data we have collected and stored about you.

(2)Right of rectification. You can update, rectify or change your data in the account settings of App. You can ask us to update, rectify or change your data where that data is not accurate.

(3)Right of erasure. You have right as provided by applicable laws to request us to erase, destroy, or anonymize your personal data. You may request us to cease the supply of personal data to a third party under certain circumstances according to applicable laws.

(4)Right of portability. You have the right to data portability in circumstances where we rely on contractual necessity and consent as our legal basis. This means that you have the right to receive your data in a structured, commonly used, and machine-readable format and to share it with a third party.

(5)Right to withdraw consent. You can withdraw consent to the processing of personal data based on your consent, unless such withdrawal is restricted by the law or by contract. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made.

a.You can withdraw your consent in the account settings of your App;

b.If you want to unsubscribe from the electronic communications, please see your notification settings under account settings of your App to control our marketing communications to you.

(6)Right to object or restrict processing. You have the right to object to or restrict our processing of your data in certain circumstances, relying on legitimate interest or public interests on the basis of applicable laws. For example, according to applicable laws, you may require us to cease or not to begin processing their personal data for purposes of direct marketing. You may object to decision-making based solely on automated processing related to your profile, under certain circumstances according to applicable laws.

In submitting an objection or restriction request, you should explain what specific processing activity you are objecting to or should be restricted, and why the processing should be stopped. We will stop the particular processing if we don’t have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

10.2 HOW TO EXCERCISE YOUR RIGHTS

You may exercise these rights by logging into your account and using your account settings, or contacting us as specified in the “How To Contact Us” section in writing or by other means permitted by applicable laws.

We will ensure you can exercise your rights in accordance with the applicable laws. Depending on the applicable laws, there may be situations where we may refuse your requests, for example, when refusing is in pursuant to a court order, or exercising your rights would adversely affect the rights and freedom of others.

When you need to exercise your rights, we may ask you to authenticate your identification, such as through your RingConn account.

Normally, you don’t have to pay us when you’re exercising your rights under the applicable laws; however, we reserve the right to charge you a reasonable fee for the processing of any data access, correction request or other scenarios where charge of fee is permitted by applicable laws.

We will respond to your requests within the time limits provided under applicable laws in the country/regions of your residence.

If you have any questions regarding this Privacy Policy or about exercising your rights, you may send your request in writing to the email address we provide below in “How to Contact Us”.

If you are of the opinion that the processing of your personal data by us is not in compliance with this Privacy Policy or applicable laws, you have the right to make a complaint to the competent regulatory authority in your jurisdiction.

11.POLICY FOR EUROPEAN USERS

If you live in the European Economic Area (EEA), United Kingdom (UK) or Switzerland, please review these additional privacy policy terms under the European Union’s General Data Protection Regulation (“GDPR”).

11.1 YOUR DATA CONTROLLER

Shenzhen Jiu Zhi Technology Co.Ltd, a company established under the laws of People’s Republic of China, is your data controller and provides the Services if you live in the EEA, UK or Switzerland. For our contact information, please see the How To Contact Us section.

11.2 HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA

To the extent that data we collect is health data or another special category of personal data subject to the GDPR, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you pair your device to your account. You can use your account settings in App and settings in your mobile device to withdraw your consent at any time, including by unpairing your device, or deleting your data or your account.

11.3 HOW TO EXCERCISE YOUR LEGAL RIGHTS

Please review the “WHAT ARE YOUR RIGHTS” section for how you may exercise your rights under GDPR.

Under the GDPR, you have a general right to object to the use of your data for direct marketing purposes. Please see your “Reminder Settings” under “Me” in App to control our marketing communications to you about our Services.

12.POLICY FOR CALIFORNIA USERS

If you are a California resident, please review these additional privacy policy terms under the California Consumer Privacy Act ("CCPA").

12.1 HOW WE COLLECT, USE AND SHARE YOUR INFORMATION

Where a customer interacts with our Services, we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, defined as “Personal Information” under CCPA.

Information about the categories of personal information we collect, the purposes for which your personal Information is processed, and any sharing of your personal information can be found from relevant sections of this privacy statement above.

We never sell (in the manner defined by CCPA) the personal information of our users.

12.2 CALIFORNIA CONSUMER RIGHTS

If you are a California resident, you have certain rights under the CCPA:

(1)Right to know about the personal information we collect and share

The CCPA gives you the right to request that we disclose the personal information we have collected about you over the past 12 months, which we do after we receive and validate your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:

a.The categories of personal information we have collected about you;

b.The categories of personal information we have disclosed about you (if any);

c.The categories of sources for the personal information we have collected about you;

d.Our business or commercial purposes for collecting or selling that personal information;

e.The categories of third parties with whom we share that personal information; and

f.The specific pieces of personal information we have collected about you.

(2)Right of deletion

You have the right to request erasure of your personal information, subject to certain exceptions, such as where we have a legal obligation to retain the data in question. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information unless an exception applies.

(3)How to exercise your privacy rights under CCPA

If you are a California resident, you can request disclosure, access to, and/or deletion of your personal as described above by submitting a verifiable consumer request to us by either:

Sending an e-mail to data_protect@ringconn.com, including the following information along with your request: your full name, company name (if applicable), address, e-mail address and a phone number. We may request that you provide additional information if necessary to confirm your identity. This is for security purposes and is required by law in some cases.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You have the right to make a free request up to two times in any 12-month period. We will respond to all validated requests within 45 days since receiving your request, unless we request an extension. In the event that we reasonably require an extension in order to respond to your request, we will notify you of any such extension within the initial 45-day period.

12.3 NON-DISCRIMINATION

We do not discriminate against users who request exercise their privacy rights under the CCPA. Unless an exception applies, this includes our promise not to:

a.Deny you goods or services;

b.Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;

c.Provide you a different level or quality of goods or services; or

d.Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

13.UPDATE TO THIS PRIVACY POLICY

We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services. You can review previous versions of the policy at our website ( https://www.ringconn.com ).

We will not reduce your rights under this Privacy Policy without your express consent. We will post any changes to this policy on this page.

For material changes, we will also provide more prominent notice (including, for certain Services, email notification of specific changes to the Privacy Policy ).

Material changes within the meaning of this Policy include, but are not limited to:

a.Significant changes to our service model. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;

b.Significant changes in our ownership structure, organisational structure, etc.. Such as changes in ownership caused by business restructuring, bankruptcy and mergers and acquisitions;

c.Changes in the primary recipients of personal information shared, transferred, or publicly disclosed;

Significant changes in your right to participate in the handling of personal information and the manner in which it is exercised;
Changes in the department responsible for handling personal information security, contact information and complaint channels;
When the security impact assessment report of personal information indicates that there is a high risk.

14.SEVERABILITY

If any part of this Privacy Policy is found by any court or other competent authority to be invalid, unlawful or unenforceable then such part shall be severed from the rest of the provisions of this Privacy Policy which shall continue to be valid and enforceable to the fullest extent permitted by law.

15.LANGUAGE

For users outside the People’s Republic of China, this Privacy Policy is made in English language and in the language of your residence country (if applicable). For users outside the People’s Republic of China, English version and other language versions are equally authentic. In case of any discrepancy among different versions, the English version shall prevail.

16.SDK PARTNERS

We may use or work with Mobile SDKs to collect information, such as Mobile IDs, and information related to how mobile devices and their users interact with our App. The SDK is computer code that app developers can include in their apps to enable data to be collected, and related services to be implemented.

SDK	Purpose of use	Data collected	SDK Provider	SDK Privacy Policy
Alibaba Cloud OSS（Object Storage Service）	App functionality:Upload user profile picture	User profile picture	Alibaba Cloud LLC	http://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud201902141711_54837.html?spm=5176.7933691.J_9220772140.78.195e4c59UzoTQe
Facebook	Facebook authorized login	App events	Meta Platforms,Inc	https://www.facebook.com/business/m/one-sheeters/gdpr-developer-faqs
Sentry	Analytics: APP crashes monitor	APP crash log	Functional Software, Inc.,	https://sentry.io/privacy/
Sensors Data	User identification ,User behaviors analysis	Device information，App log，IP address，App identifier, ANDROID ID	Sensors Data Network Technology (Beijing) Co., Ltd. and related parties	https://manual.sensorsdata.cn/sa/latest/zh_cn/sdk-22255999.html
Tencent Push Notification Service	Developer communications：allow APP notification push	User Device Information, Application Information, Network Information, Application Data	Shenzhen Tencent Computer Systems Co Ltd	https://privacy.qq.com/document/preview/8565a4a2d26e480187ed86b0cc81d727
Google Map SDK	App functionality：allow map display and search, walking/cycling navigation, sports tracking display	Location Information, Device Information, Device Identifier Information, Information about the interaction of your apps, browsers, and devices with Google services, Device Parameters and System Information	Google LLC and it affiliates	https://policies.google.com/privacy https://business.safety.google/controllerterms/
Application Performance Monitoring Full-Link - WebPro Monitoring	View web crash information, monitor memory performance, and monitor network exceptions	Device information, IP address, carrier information.	Beijing Volcengine Technology Co., Ltd	https://www.volcengine.com/docs/6431/69429

SDK	Purpose of use	Data collected	SDK Provider	SDK Privacy Policy
Alibaba Cloud OSS（Object Storage Service）	App functionality:Upload user profile picture	User profile picture	Alibaba Cloud LLC	http://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud201902141711_54837.html?spm=5176.7933691.J_9220772140.78.195e4c59UzoTQe
Facebook	Facebook authorized login	App events	Meta Platforms,Inc	https://www.facebook.com/business/m/one-sheeters/gdpr-developer-faqs
Sentry	Analytics: APP crashes monitor	APP crash log	Functional Software, Inc.,	https://sentry.io/privacy/
Sensors Data	User identification ,User behaviors analysis	Device information，App log，IP address，App identifier, ANDROID ID	Sensors Data Network Technology (Beijing) Co., Ltd. and related parties	https://manual.sensorsdata.cn/sa/latest/zh_cn/sdk-22255999.html
Tencent Push Notification Service	Developer communications：allow APP notification push	User Device Information, Application Information, Network Information, Application Data	Shenzhen Tencent Computer Systems Co Ltd	https://privacy.qq.com/document/preview/8565a4a2d26e480187ed86b0cc81d727
Google Map SDK	App functionality：allow map display and search, walking/cycling navigation, sports tracking display	Location Information, Device Information, Device Identifier Information, Information about the interaction of your apps, browsers, and devices with Google services, Device Parameters and System Information	Google LLC and it affiliates	https://policies.google.com/privacy https://business.safety.google/controllerterms/
Application Performance Monitoring Full-Link - WebPro Monitoring	View web crash information, monitor memory performance, and monitor network exceptions	Device information, IP address, carrier information.	Beijing Volcengine Technology Co., Ltd	https://www.volcengine.com/docs/6431/69429

17.WHO WE ARE AND HOW TO CONTACT US

If you have questions about this policy, or need help exercising your privacy rights, please contact our Data Protection Officer at

data_protect@ringconn.com

Customer Support Email Address：

cs@ringconn.com

Telephone:+86 760 88586096