Setun Privacy Policy

Overview
    Setun Limited regards user information security and privacy protection as its "life infra". We adhere to the philosophy of "everything centered around user value" and are committed to enhancing the transparency of information processing and safeguarding your information and communication security. Setun Limited will update this Privacy Policy from time to time. When you agree to the Setun Limited Service Usage Agreement, you are deemed to have agreed to all the contents of this Privacy Policy. This Privacy Policy is an integral part of the Setun Limited Service Usage Agreement. If you have any questions, comments, or suggestions regarding the content of this policy, you may contact us through the contact information provided in this Privacy Policy.

    1. 1. How We Collect and Use Your Personal Information
    We will collect and use your personal information for the following purposes as described in this Privacy Policy: 

    (1) Implement the basic functions of the account system
    1. Information collected through account registration. When you register for a Setun Limited account, Setun Limited will collect your mobile phone number. This information is collected to assist you in completing the Setun Limited account registration. If you refuse to provide certain necessary information from this set, you may not be able to successfully register for a Setun Limited account.
    After you register for a Setun Limited account, providing certain necessary information will help us provide you with more personalized services and recommendations, but refusing to provide certain necessary information will not affect your use of other functions of this product. You can also change the above information through the "Personal Center" interface.

    2. Account Security. To ensure the security of your Setun Limited account, we will record information such as the time, IP address, city, and the name of the Setun Limited product you logged into when you registered, logged in, and used your Setun Limited account across all Setun Limited products.

    (2) How We Use Cookies and Similar Technologies

    1. When you register or log in to the Setun Limited User Center through Setun Limited's website-based products, we will use Cookies technology in-app. Cookies are small data files we store on your computer, usually containing identifiers, site names, and some numbers and characters. The Cookies sent to you by each website are unique, and they can only be read by the web server that sent them to you. They are often used to simplify the steps of repeated logins, help us remember your device and preferences for using our services, and analyze your usage of our website, thereby helping you have a more convenient access experience.

    2. We will not use Cookies for any purpose other than those described in this Privacy Policy. You can manage or clear all Cookies stored in this website according to your preferences. If you clear these Cookies, you will need to log in again and manually change relevant settings each time you log in to your Setun Limited account, and all previously recorded corresponding information will also be deleted, which may affect the security and convenience of the services you use.

    (3) Improve our products and services

    1. User Experience Improvement. When you register or log in to your Setun Limited account through Setun Limited products, or agree to the Privacy Policy, we may collect the International Mobile Equipment Identity (IMEI) and Network Device Address (MAC) desensitized by the MD5 algorithm, IP Address, device model, system version number, operating system version number, system serial number, system ID number, screen resolution, Internet access type, version number of this product, software crash logs, information on running processes, and other software information, so that the software can provide services normally (for example, the generation of device codes for the Setun software Client relies on this characteristic information), or to count the number of users of our products, analyze product usage, troubleshoot the causes of crashes, and reduce crashes, in order to continuously improve our products. This information does not involve your personal identity or other privacy information.

    2. Resolve the issues you have reported. You can report any issues you encounter while using this product to us through Setun Limited's Client Server. You may need to provide us with your mobile phone number, email address, or QQ number so that we can contact you and address the issues you have reported. We will analyze the information mentioned in the previous paragraph to identify the root cause of the issues and strive to resolve them. The contact information you provide in your feedback will only be used for communication and feedback between our customer service and you. Setun Limited will not disclose the above information to any third party, except with your affirmative consent or as required by law.

    (4) Camera/Microphone/Album

    1. To implement functions such as screen recording and photo taking, we need to obtain permissions for the camera, microphone, and photo album, and we will only obtain such permissions after obtaining your authorization and consent. If you refuse to authorize these necessary permissions, you will not be able to use the corresponding functions, but it will not affect your normal use of other functions of the software.

    2. We will never privately obtain such permissions to steal your privacy, read the content of your pictures, or collect your conversations during daily chats, etc., and will never use such illegal means to engage in activities such as information or advertisement push (except in cases such as criminal investigations by state organs).

    (5) Auxiliary Control

    1. To implement the auxiliary control feature, we need to obtain the permission for the auxiliary feature, and we will only obtain this permission after obtaining your authorization and consent. If you refuse to authorize this necessary permission, you will not be able to use the corresponding feature, but it will not affect your normal use of other features of the software.

    2. We will never privately obtain such permissions to steal your privacy, read the content of your pictures, or collect your conversations during daily chats, etc. Moreover, we will not use such illegal means to engage in activities such as information or advertisement push (except in cases such as criminal investigations by state organs).

    2. 2. How We Store Your Personal Information
    Personal information collected and generated within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. 
    If it is indeed necessary to transfer relevant personal information collected within China to overseas institutions for the purpose of handling cross-border business, we will comply with the provisions of laws, administrative regulations, and relevant regulatory authorities. We will ensure that your personal information is adequately protected, such as through anonymization, encrypted storage, etc. 
    We only store your personal information for the period necessary for the purposes of this policy and within the time limits required by laws and regulations. 
    If we cease to operate the product or service, we will promptly stop the activities of continuing to collect your personal information, notify you of the cessation of operation in the form of individual delivery or public notice, and delete or anonymize the personal information we store. 

    3. III. How We Share, Transfer, and Publicly Disclose Your Personal Information
    (1) Sharing
    We will not share your personal information with any company, organization, or individual, except in the following circumstances: 
    1. With your affirmative consent, we will share your personal information with other parties.
    2. We may share your personal information externally in accordance with laws and regulations, the needs of litigation and dispute resolution, or as required by administrative or judicial authorities in accordance with the law. 
    3. We will not share your personal information with third-party advertisers, app developers, open platforms, or other partners without your explicit authorization and consent. We may provide these partners with aggregated information, anonymized information, or other information that does not identify your personal identity. For example, we may inform app developers how many people have installed the apps they developed. 
    4. Only for the purposes stated in this Privacy Policy, we may share your personal information with our suppliers, service providers, consultants, or agents to provide better Client Server and User Experience. These suppliers, service providers, consultants, and agents may provide us with technical infrastructure services, analyze how our services are used, measure the effectiveness of advertising and services, provide Client Server and payment services, conduct academic research and surveys, or provide legal, financial, and technical consulting services, etc. For example, we may periodically invite registered users to participate in a lottery. If you are lucky enough to win, we need to provide your personal information to the logistics service provider to send you our prize.
    For the companies, organizations, and individuals with whom we share personal information, we will sign strict data protection agreements with them, requiring them to process personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures. 

    (2) Transfer
    We will not transfer your personal information to any other company, organization, or individual, except in the following circumstances:
    1. As Setun Limited's business develops, we and our affiliated companies may engage in mergers, acquisitions, asset transfers, or other similar transactions. If such transactions involve the transfer of your personal information, we will still require the new holders of your personal information, including companies, organizations, and individuals, to continue to be bound by this policy; otherwise, we will require them to obtain your authorization and consent again. 
    2. Transferring with your affirmative consent, that is, after obtaining your affirmative consent, we will transfer the personal information we have collected about you to other parties.

    (3) Disclosure
    We will only publicly disclose your personal information in the following circumstances:
    1. has obtained your affirmative consent. 
    2. We may publicly disclose your personal information in cases involving legal provisions, judicial procedures, administrative mandatory provisions of government authorities, etc. 
    3. Other circumstances stipulated by laws and regulations.


    4. 4. How We Use Cookies and Related Technologies
    We or our third-party partners may collect your information through the placement of secure cookies and related technologies, with the aim of providing you with a more personalized User Experience and services. We will strictly require third-party partners to comply with the relevant provisions of this Policy. 
    You can also manage cookies through your browser settings. However, please note that if you disable cookies, you may not be able to enjoy the best service experience, and some services may not function properly.

    5. 5. How We Protect Your Personal Information
    1. We have implemented security protection measures that comply with industry standards to safeguard the personal information you provided, preventing data from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonable and practicable measures to protect your personal information.
    2. We will encrypt the transmission and storage of identifiable personal information to ensure data confidentiality. For your Device ID, International Mobile Equipment Identity (IMEI), and Media Access Control (MAC) address, we will anonymize and encrypt them using the MD5 algorithm on your device, and only collect and upload the anonymized and encrypted identifiers. 
    3. We deploy access control mechanisms at the server level, implement the principle of least privilege for staff who may have access to your personal information to control access, and regularly review the list of authorized personnel and access records.
    4. We will regularly organize training on laws and regulations related to personal information protection for staff to strengthen their awareness of protecting users' personal privacy.
    5. In the event that our physical, technical, or administrative safeguards are compromised, we will promptly activate the emergency response plan to prevent the escalation of the security incident, report it to the relevant national competent authorities in accordance with the requirements of laws and regulations, and promptly notify you of the basic details of the security incident, possible impacts, measures already taken or to be taken, etc., through reasonable and effective means such as push notifications and announcements. 


    6. 6. Your Rights to Manage Personal Information
    During your use of the Setun Limited User Center, you can access and manage your personal information in the following ways: 
    (1) Access and correct your personal information
    You can query and correct your account info and other information you provided through the User Center at https://setun.com.

    (2) Delete your personal information
    You have the right to request Setun Limited to delete your personal information when the following circumstances occur: 
    1. We collected your personal information without obtaining your affirmative consent.
    2. Our handling of your personal information has violated the requirements of laws and regulations.
    3. We have violated our agreement with you by using and processing your personal information.
    4. We will stop providing services to you. 
    5. Other circumstances where a claim may be made. 

    (3) Cancel your personal account
    You can log out of your account at any time in the User Center at https://setun.com. Please note that if you choose to log out of your account, your account will no longer be available, and relevant account information will be deleted. You will no longer be able to log in to Setun Limited's services using your account (we will delete the corresponding data from the system within 7 working days).


    7. 7. Changes and Amendments to the Privacy Policy
    Our Privacy Policy may change. Without your affirmative consent, we will not restrict your rights as provided for in this Privacy Policy.
    For significant changes to this Privacy Policy, we will also provide prominent notice (for example, in the form of a pop-up window to notify you promptly when the software is revised or upgraded, or when you log in again). 

    Material changes referred to in this policy include but are not limited to:
    1. Our service model has undergone significant changes, such as the purpose of processing personal information, the types of personal information processed, the manner of using personal information, etc.;
    2. We have undergone significant changes in aspects such as control rights, including changes in ownership caused by mergers, acquisitions, reorganizations, etc.;
    3. The main recipients of personal information sharing, transfer, or public disclosure have changed; 
    4. There are significant changes to your rights regarding personal information processing and the ways to exercise them; 
    5. When there are changes to the responsible department, contact information, and complaint channels for handling personal information security; 
    6. When the Personal Information Security Impact Assessment Report indicates the existence of high risks. 

    8. 8. Contact Us
    If you have any questions, comments, suggestions, or complaints regarding our Privacy Policy and the handling of your personal information, please contact us via [email protected].