Introduction

Welcome to the products and services of iParllay, a product of IClick Data Technology (Beijing) Limited (Chinese legal name: 爱点击（北京）数据科技有限公司) (the “Company,” “we,” “us,” or “our”). The source policy identifies the service as iParllay and refers to the website http://m.parllay.cn.

We respect and value the protection of personal information. When you access and use our products and related services, we collect, store, process, share, and protect your personal information in accordance with this Privacy Policy. This Policy explains how we process personal information and the rights available to you. We will comply with applicable laws and regulations and follow applicable privacy-protection principles in providing safer and more reliable products and services.

Please read this Policy carefully before using our products and services, in particular any provisions marked in bold or underlined in the source version. If you do not understand or do not agree with any part of this Policy, please contact us using the contact details at the end of this Policy. By clicking “agree” or “confirm” on a web page, or by actually using our products or services, you confirm that you understand and agree to this Policy, understand the personal information necessary for the operation of the functions and services, and authorize the relevant collection and use. This does not mean that you have separately agreed to enable additional functions or to process non-essential or sensitive personal information. Where required, we will seek separate consent based on your actual use of such functions and processing.

This Policy applies to functions and services of our products. It does not apply to third-party applications, platforms, products, or services that you access through our products or services. Before connecting to or using a third-party product or service, please understand its functions, services, and privacy policy.

This Policy describes:

  1. What information we collect;
  2. How we use collected information;
  3. How we use cookies and similar technologies;
  4. When we may share, transfer, or publicly disclose personal information;
  5. How we store collected information and protect its security;
  6. Filtering and removal of harmful information;
  7. Your rights to manage personal information;
  8. Protection of minors;
  9. Changes to this Privacy Policy; and
  10. How to contact us.

1. Information We Collect

We follow the principles of legality, legitimacy, and necessity, and collect only information necessary to provide product functions or services.

To provide product functions, maintain normal operation, improve and optimize our products or services, and protect account security, we may request necessary permissions or collect relevant information as needed.

1.1 Account Registration

When you register an account, you must provide a mobile telephone number in the People’s Republic of China or an email address and set a password. The mobile number or email address will be used for registration, login, account binding, receipt of verification codes for password recovery, and as one of the contact methods designated between you and us for business notices. This information is necessary for use of our products and services. Without it, you may be unable to use the products and services normally.

After registration, you may complete or change information in your account. You agree that we may collect, store, and use that information for identity verification, user service, and security protection so that you can use the products and related functions properly.

1.2 Information You Provide Through Our Products or Services

We collect and store information that you independently publish, upload, or modify through product functions, including text, images, audio, video, files, form information, records collected through forms, geolocation information, and enterprise-verification information attached to content.

Where you complete a form, the form may contain personal information specified by its creator and voluntarily entered by you, such as your name, identification number, address, contact details, bank-account information, location, or audio/video recordings. We will provide notices or obtain consent as required by applicable laws and regulations. Please pay close attention to the red-font notices at the form-submission point in the source product experience. Once you voluntarily complete and submit a form, you authorize the form to collect the information you provide, and that personal information is controlled by the form creator. You should assess the risks of providing personal information. If you do not wish to provide personal information to a form creator, do not complete or submit the form. If you have questions or comments about the purpose, scope, or use of personal information controlled by a form creator, you understand and agree that you may contact us for handling.

1.3 Customer Service and Product Support

We collect questions and information that you submit through customer service or other support services. When you open a customer-support chat window or send an email, we may request contact information, a description of the issue, screenshots, operation recordings, and other documents, screenshots, audio, or video that may help resolve the issue.

To help complete payment for paid versions, refunds, invoice delivery, and continuing customer or technical support during a paid period, we may request the payer’s name, contact details, email address, correspondence address, and payment or refund account information.

1.5 Information Collected During Use

1.5.1 Log Information

When you access and interact with our services, we may automatically collect usage information as network logs, such as search-query content, IP address, browser type, language used, access dates and times, and records of pages visited.

1.5.2 Device and Connection Information

Based on the permissions you grant during use, we may receive and record device-related information, such as device model and operating-system version, and device-location-related information, such as IP address and information from Wi-Fi access points, Bluetooth, and base-station sensors that can provide such information.

1.5.3 Third-Party Account Association

If you associate another method of login or use, such as WeChat, we may request personal information from that third party. If you agree to provide it, you authorize us to read relevant information associated with your account at that third party, such as nickname, avatar, and mobile number.

We may collect personal information without first obtaining authorization or consent in the circumstances permitted by applicable laws and regulations, including where collection is related to performance of statutory duties by a personal-information controller; directly related to national security, national defense, public security, public health, or major public interests; directly related to criminal investigation, prosecution, trial, or enforcement of judgments; necessary to protect material lawful rights and interests in life or property where consent is difficult to obtain; information has been made public by the individual; necessary to enter into or perform a contract at the individual’s request; obtained from lawfully publicly disclosed information; or necessary to maintain the safe and stable operation of the products or services, including identifying and addressing faults.

2. How We Use Collected Information

We use collected information in accordance with applicable laws and regulations and our agreements with users. If we use information beyond the purposes below, we will explain the new purpose and obtain consent where required.

2.1 Providing Product Functions or Services

To provide functions or services, we may send information, notices, or business communications, including verification codes necessary to complete services and push notifications necessary for use. We may use contact information and a linked WeChat account to send notices by email, SMS, official-account messages, or other methods, including account scanning statistics, responses to questions and requests, customer support, updates, notices, reminders, and warnings.

To maintain and improve products or services, we may use information you submit to provide displays more relevant to your personalized needs, for example by presenting different content according to your industry or whether you are using a function for the first time. If you do not agree to the use of targeted push information, you may contact customer service for handling.

2.2 System and Data Security

To protect system and data security, we use security technologies and procedures, or third-party products and services, to improve system stability and protect the authenticity, integrity, and verifiability of data against loss, unauthorized access, or disclosure. We may also record relevant information to understand system operation.

2.3 Identity Verification and Security

We use information about you and your use of services to verify accounts and activities and to monitor suspicious or fraudulent activity. For example, we may use information for identity verification, security protection, fraud monitoring, archiving, and backup.

2.4 Analytics and Product Development

We seek to make our services more intelligent, faster, and safer. We may understand how users use our products and services and collect feedback directly provided by users to investigate issues and determine how to improve product logic, functions, service integration, and services. For example, when we iterate and update, we may record usage of new functions and usage habits to design more useful functions. The source policy states that this information does not include information that identifies you.

2.5 Support Services

We use information you submit to resolve technical issues, respond to assistance requests, analyze crash information, and repair and improve services. When you contact customer service about a usage issue, for example, we may share relevant information with technical personnel in order to respond to and support the request.

2.6 Service Surveys

To improve your experience or services, or for other purposes with your consent and as permitted by applicable laws, we may invite you to product research, feedback, questionnaires, or offline events. We may need identity or address information to verify participation or send gifts. Participation is entirely your choice.

We may use personal information without first obtaining authorization or consent in the circumstances permitted by applicable laws and regulations, including the categories described in Section 1.6.

3. Cookies and Similar Technologies

Cookies are a neutral technology that allows a website server to store data on, or read data from, a client device. Cookie files store information related to visits to a website, usually in a text-file format, and their content is generally encrypted. Secure cookie technology can make online services more convenient.

3.1 How We Use Cookies

To ensure normal website operation, provide a more convenient access experience, and recommend content that may interest you, we may use cookie storage technologies on your computer or mobile device. Cookies commonly contain identifiers, site names, and numbers or characters.

We use cookies for:

  • Authentication: to verify identity information and protect account security;
  • Preferences: to provide services in the style and personalized settings you request, such as recording that you have read a notice so that it is not repeatedly displayed;
  • Product functions: to improve products and services, such as recording the state of your last logout so that you can return to the last page used after logging in again; and
  • Analytics and research: to understand and improve products and services and to provide reference data for research and development, including understanding the time spent at different steps of a web page.

3.2 How to Disable Cookies

We will not use cookies for purposes beyond those described in the user agreement or this Policy. You may manage cookies according to your preferences, including clearing cookies stored on your computer. Most browsers provide a function to block cookies. For details about changing browser settings, please visit the settings page of the browser you use.

4. Sharing, Transfer, and Public Disclosure of Personal Information

4.1 Sharing

We do not share your personal information with other organizations or individuals except in the following circumstances:

  1. where we have obtained your explicit authorization or consent; or
  2. where sharing is required by laws and regulations, litigation or arbitration needs, or lawful requests from administrative or judicial authorities.

4.2 Entrusted Processing

To maintain stable operation and functions and to allow more services and functions, our applications may embed partners’ SDKs or similar applications. We conduct security testing of partners’ APIs and SDKs that obtain relevant information and agree appropriate data-protection measures with authorized partners so that they process personal information in accordance with this Policy and other relevant confidentiality and security measures, unless an authorized partner separately obtains your consent. If product functions or services change, we may adjust integrated third-party SDKs and will publicly explain the latest position. Third-party SDK data types may change because of version upgrades or policy changes; please refer to the SDK provider’s official notices.

The source policy includes a “List of Third-Party SDKs Integrated by This Platform.” The visible source list identifies:

SDK/API Use scenario Main personal-information types Recipient Privacy policy
WeCom Server API Users authorize us to administer WeCom permissions, account functions, and operational content and receive related services. Including avatar, nickname, mobile number, enterprise short name, and job title. IClick Data Technology (Beijing) Limited https://work.weixin.qq.com/nl/privacy
WeChat Official Account API Users authorize us to administer WeChat Official Account permissions, account functions, and operational content and receive related services. Including avatar, nickname, mobile number, openid, and unionid. IClick Data Technology (Beijing) Limited https://weixin.qq.com/agreement?lang=zh_CN&cc=CN&s=privacy&v=1&need

If you entrust us, or use our products or services, to process personal information, you represent that you have obtained lawful authorization from relevant individuals for the applicable scope of processing and comply with applicable data and personal-information protection laws. You must conduct data and personal-information processing activities, including collection, storage, use, processing, transmission, provision, and disclosure, in accordance with laws and regulations and to a standard no lower than this Policy.

4.3 Transfer

We do not transfer your personal information to any company, organization, or individual, except where you have provided explicit consent or where a merger, acquisition, or bankruptcy liquidation occurs. In such event, we will require the new holder of your personal information to remain bound by this Policy. If collection or processing methods change, that company or organization will seek authorization or consent again as required.

4.4 Public Disclosure

We publicly disclose personal information only where we inform you of the purpose and type of disclosure and obtain your explicit consent or act based on your active choice; where necessary to protect the personal or property safety of users or the public under applicable laws; or where required by law, legal process, litigation, or a compulsory request from a competent government authority. In the latter case, we will require the requesting party to provide valid legal documents and take security measures consistent with law and industry standards for disclosed information.

We may share, transfer, or publicly disclose personal information without prior authorization or consent in circumstances permitted by applicable laws and regulations, including the categories described in Section 1.6.

5. Storage and Security

5.1 Storage and Security of Information

We attach great importance to information security. We endeavor to take reasonable security measures to prevent unauthorized access, public disclosure, use, alteration, damage, or loss.

The source policy states that personal information collected and generated within the People’s Republic of China is stored within the People’s Republic of China. If the storage location is moved outside China, we will do so in accordance with applicable laws and regulations.

The source policy further states that we use multi-site disaster-recovery backup and encrypted transmission, maintain a comprehensive hybrid-cloud security protection system including intrusion detection, attack protection, and secure storage, and conduct security and privacy training.

No method of transmission or storage can be guaranteed to be completely secure. We recommend that you actively protect your information, including by using strong passwords, changing passwords regularly, and not disclosing account passwords or other private information. Where you communicate with third parties, exchange information, or analyze content through our services, provide personal information only where necessary to reduce the risk of theft or telecommunications fraud.

If you discover a leak of your personal information, especially your account or password, please contact customer service immediately so that we can take appropriate measures upon your request.

If a personal-information leak or other security incident occurs, we will activate emergency-response plans to prevent expansion of the incident. As required by laws and regulations, we will promptly notify you of the basic circumstances and possible impact, measures taken or to be taken, recommendations for independently preventing and reducing risks, and remedial measures. We may notify you by email, letter, telephone, push notification, or other appropriate means; where individual notice is difficult, we may publish an announcement through reasonable and effective means.

5.2 Retention Period

In general, we retain personal information only for the period necessary to achieve the purposes described in the user agreement and this Policy.

5.3 Cessation of Operations

If our products or services cease operating, we will take reasonable measures to protect personal-information security, including promptly stopping further collection, notifying users by push notification or announcement, and deleting or anonymizing personal information held within a reasonable period.

6. Filtering and Removal of Harmful Information

Under relevant laws, users are prohibited from creating or storing unlawful or harmful information, including information that: violates basic constitutional principles; endangers national security or discloses state secrets; harms national honor or interests; incites ethnic hatred or discrimination; undermines religious policy or promotes cults or superstition; spreads rumors or disrupts social order; disseminates obscenity, pornography, gambling, violence, terrorism, or criminal incitement; insults or defames others or infringes lawful rights and interests; incites unlawful assemblies, associations, processions, demonstrations, or gatherings that disrupt social order; operates in the name of unlawful civil organizations; or contains other content prohibited by laws or administrative regulations.

The source policy states that we will establish filtering and blocking mechanisms. For violations, we may, without notice, take measures including disconnecting links, deleting created content, and publicly displaying handling results. For serious circumstances, we may suspend accounts, record IP-address information, report to public-security cyber-supervision authorities, and reserve the right to pursue legal liability. The source policy states that we do not bear contractual or other legal liability for such actions.

7. Your Rights to Manage Personal Information

We value your attention to personal information and seek to protect your rights to access, correct, and delete it.

7.1 Access, Correction, and Supplementation

You may log in to the Platform and use “Profile and Password” to access, correct, and supplement personal information.

You may send an email or call customer service to change the scope of authorization, delete personal information, or withdraw consent. After you take such action, we may be unable to continue providing the service corresponding to the withdrawn consent or authorization, but this will not affect processing already carried out based on your authorization.

7.3 Account Cancellation

You may cancel an account by logging in and using “Profile and Password → Cancel Account” or by sending an account-cancellation request to the customer-service email.

Once an account is cancelled, you will not be able to log in to or use it. Information, content, data, and records associated with the account may be deleted or anonymized, may not be retrievable, accessible, usable, or recoverable, and you may not require us to recover them. Please back up any content you consider necessary before requesting cancellation.

7.4 Identity Verification and Fees

To protect security, we may require written materials or other methods to verify your identity before handling a request. We generally do not charge fees for reasonable requests. However, we may charge a cost fee for repeated requests or requests beyond reasonable limits, and may refuse requests that are unfounded, repetitive, require excessive technical measures, risk the lawful rights of others, or are impractical.

7.5 Exceptions to Rights Requests

Where permitted by applicable laws and regulations, we may be unable to respond to requests to correct, delete, or cancel information, including where the request concerns performance of statutory duties; national security, national defense, public security, public health, or major public interests; criminal investigation, prosecution, trial, or enforcement of judgments; malicious conduct or abuse of rights; protection of material lawful rights and interests where consent is difficult to obtain; serious harm to lawful rights and interests of others; or trade secrets.

7.6 Further Contact

If you cannot access, correct, or delete personal information or cancel an account through the methods above, or believe that we collect or use personal information in violation of law, you may contact us using the contact details in this Policy.

8. Protection of Minors

Our products and services are primarily for adults. Without consent from a parent or guardian, minors may not create accounts or provide personal information through forms or related functions. Where we collect a minor’s personal information with parental or guardian consent, we will use, share, transfer, or disclose it only as permitted by applicable laws, with explicit parental or guardian consent, or where necessary to protect the minor.

If you are under 14 years old, please ask your parent or guardian to read this Policy and use our services or provide information only with their consent.

9. Changes to This Privacy Policy

We may revise this Policy from time to time and will publish the updated Policy on this page. Where changes are material, we will notify you by website announcement, push notification, or a more prominent pop-up, and allow a reasonable period before the changes take effect. If you continue using products or services after a new Policy and user agreement take effect, you confirm that you have read and agree to the updated terms. If you do not agree, please stop using the products and services.

Material changes include significant changes to service models, purposes or types of personal-information processing, methods of use, ownership or organizational structure, principal recipients of sharing, transfer, or public disclosure, rights and methods of exercising them, responsible departments, contact details or complaint channels, or a personal-information protection impact assessment showing a high risk.

10. Contact Us

For questions, comments, or suggestions about this Privacy Policy, the source policy provides the following details:

Company: IClick Data Technology (Beijing) Limited
Registered Address: Room 401, 3A Floor, Building F, Huateng Century Headquarters Park, No. 9, Chenjialin, Balizhuang Village, Gaobeidian Township, Chaoyang District, Beijing, China
Customer Service Email: intessa.wan@optaim.com
Customer Service Telephone: 400-0350-798