Puckly Privacy Policy

Effective Date: January 30, 2026

Welcome to Puckly App (hereinafter referred to as "this App"). This App is a video social platform specifically designed for hockey enthusiasts aged 18 and above in Europe and the United States, with core services including hockey-related video sharing, user interaction, and event information push. We are well aware of the importance of personal information security and privacy protection to you. This Privacy Policy will fully and clearly disclose to you the entire scope, methods, and purposes of our collection, use, storage, and protection of your personal information, as well as your legally entitled privacy rights and exercise channels. Before using this App, please carefully read and fully understand all contents of this Privacy Policy (especially the key clauses marked in bold). Once you click "Agree", "Accept" or actually use/continue to use this App, it means you confirm that you are a user aged 18 or above and explicitly agree to our processing of your personal information in accordance with the provisions of this Policy. If you do not agree to any clause of this Policy, please do not use this App.

1. Definitions

1.1 Sensitive Personal Information: Refers to personal information that may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment if disclosed, illegally provided, or abused, including but not limited to ID number, personal biometric information, communication records and contents, etc.

1.2 You: Refers to the user of this App.

1.3 We refer to the operator of this App, namely Shijiazhuang Liaodui Electronic Science & Technology Co., Ltd.

2. Personal Information We Collect

We strictly follow the principles of legality, legitimacy, necessity, and good faith in collecting your personal information, and will never collect irrelevant information beyond the scope necessary to achieve the purpose of the service. To provide you with better and more tailored services, the specific types of information collected, collection scenarios, purposes, and scopes are as follows:

2.1 Description of Device Permission Calls

2.1.1 Camera Permission: We will only request camera permission from you when you actively initiate the operation of "shooting and uploading hockey-related videos/pictures". The permission is only used to collect the video/picture content you shoot in real time, and the collection will stop immediately after the shooting is completed. We will not arbitrarily call the camera or collect image information without your active operation. You can turn off this permission at any time in the device system settings. After turning it off, you will not be able to use the camera to shoot and upload directly, but it will not affect your use of the alternative function of "selecting and uploading from the album".

2.1.1 Camera Permission: When you shoot hockey-related videos or pictures and upload them to this App, you need to call the camera permission, which is only used to collect the video/picture content you shoot and will not be used for other purposes. You can turn off this permission at any time in the device settings. After turning it off, you will not be able to use the camera to shoot and upload directly, but it will not affect your use of the album to upload saved content.

2.1.2 Microphone Permission: We will only request microphone permission from you when you actively initiate the operation of "shooting hockey videos with audio" or "voice interaction" (such as voice comments, voice private messages). The permission is only used to collect your voice information to ensure the normal recording and transmission of audio content, and the collection will stop immediately after the operation is completed. We will not arbitrarily call the microphone or collect audio information without your active operation. You can turn off this permission at any time in the device system settings. After turning it off, the videos shot will have no audio, and you will not be able to use all voice interaction functions.

2.1.3 Album Permission: We will only request album permission from you when you actively initiate the operation of "selecting and uploading hockey-related videos/pictures from the album". The permission is only used to read the specific video/picture files you manually select, and will not actively scan or read all other contents in your album. You can turn off this permission at any time in the device system settings. After turning it off, you will not be able to use the album upload function, but it will not affect your use of the alternative function of "shooting and uploading directly with the camera".

2.1.4 Storage Read/Write Permission: We will only request storage read/write permission from you when you perform the operations of "uploading videos/pictures to this App" or "downloading videos/pictures from this App to the device". The permission is only used to complete the upload and download storage of files corresponding to the current operation to ensure the normal saving and display of content. We will not use this permission to arbitrarily read, modify, or delete other files in your device. You can turn off this permission at any time in the device system settings. After turning it off, you will not be able to complete file upload and download operations.

2.2 Personal Information You Voluntarily Provide

2.2.1 Personal Profile Information: When you edit your personal profile, you can choose to provide avatar, nickname, personal introduction, hockey-related experience, interest preferences (such as supported teams, favorite players, etc.). This information will help you better display your personal image, facilitate other users to identify you and conduct hockey-related interactions with you.

2.2.2 Content Upload and Publication Information: When you upload hockey-related videos, publish comments, likes, and other content, we will collect the video files you upload, the text content and pictures you publish, so as to display these contents to you and other users and realize the functions of video sharing and social interaction.

2.2.3 Communication Information: When you use the private message function to communicate with other users, we will collect your private message content to ensure the smoothness of your communication, and at the same time, it is used to handle possible illegal communication behaviors and maintain a good social environment.

2.3 Personal Information We Automatically Collect

2.3.1 Account-Related Information: When you use this App for the first time, we will automatically generate a unique account for you (no manual registration/login required), and at the same time only collect the unique association information between this account and your current device (such as desensitized information of the device's unique identifier) to realize the binding between the account and the device and ensure your subsequent normal login and use of functions such as content publishing and interaction. This association information is only used for account security verification and will not be used for other purposes.

2.3.2 Device Information: When you use this App, we will automatically collect information related to your device, specifically including: device model, device brand, operating system version, device unique identifier (such as IMEI, IDFA, all of which will be desensitized), network type (such as Wi-Fi/4G), IP address (dynamic IP, only used to locate the service area). The sole purpose of collecting this information is to optimize the compatibility and performance of the App on different devices, ensure the stable operation of the service; identify abnormal login, malicious attacks and other illegal use behaviors, and protect the security of your account. We will not use device information to accurately locate your physical location.

2.3.3 Usage Behavior Information: We will record relevant behavior information of you when using this App, specifically including: the video content you watched and its duration, the videos you liked/collected, the comments/replies you published, the users/teams/accounts you followed, search keywords and history, video upload records, video editing operation records. The sole purpose of collecting this information is to accurately recommend hockey videos, event information and related users that you are interested in through personalized recommendation algorithms; analyze overall user preferences, and optimize product functions and content layout. We will not use behavior information for other irrelevant commercial marketing purposes.

3. How We Use Your Personal Information

After collecting your personal information, we will use it strictly in accordance with the following purposes:

3.1 Provide You with Core Services: Including the management of automatically generated accounts, video upload and playback, social interaction (likes, comments, private messages), event information push, etc., to ensure that you can normally use all functions of this App.

3.2 Personalized Recommendation: Based on your viewing history, likes, comments, follows, interest preferences and other behavior information, use recommendation algorithms to accurately recommend hockey videos, event information, related users and other content that you are interested in, so as to improve your user experience.

3.3 Optimize Products and Services: According to the collected device information, usage behavior information, etc., analyze user needs and usage habits, optimize and improve the functions, interface, content of this App, and develop new functions and services that better meet user needs.

3.4 Ensure Account and Information Security: Use the collected device information, association information of automatically generated accounts, usage behavior information, etc., to identify and prevent risks such as account theft, fraud, and illegal use, and ensure that your account security and personal information are not illegally infringed.

3.5 Handle User Feedback and Complaints: When you submit feedback or complaints to us, use the contact information and relevant information you provided to communicate with you in a timely manner, handle your problems and give replies.

3.6 Comply with Laws and Regulations and Fulfill Obligations: Use your personal information within the scope required by laws and regulations or to fulfill our legal obligations.

3.7 Other Purposes Explicitly Authorized by You: If we need to use your personal information for other purposes not listed in this Policy, we will obtain your explicit authorization in advance, and the purpose will not exceed the scope of your authorization.

4. Storage of Personal Information

4.1 Storage Location: Considering that the target users of this App are mainly distributed in Europe and the United States, to ensure service stability and response speed, we will store your personal information on the servers of third-party cloud service providers located in the European Union or the United States (specific service provider name: Amazon Web Services, service area: Ireland/European Union, Virginia/United States). If it involves transferring your personal information from the European Union/United States to other regions, we will strictly comply with the requirements of relevant laws and regulations such as GDPR and CCPA, take security measures such as data encryption and signing cross-border data transfer agreements, and obtain your explicit authorization when necessary.

4.2 Storage Period: We follow the principle of "minimum necessary period" to store your personal information. The specific storage periods are as follows: 1) Account-related information (including device association information): From the date you register/generate the account to 180 days after you actively cancel the account (used to handle possible disputes after cancellation); 2) The videos you upload, comments you publish and other content: From the date you publish to 180 days after you actively delete or cancel the account; 3) Device information and usage behavior information: Retained for 1 year from the date of generation, and will be desensitized (delete information that can identify personal identity) after the expiration; 4) If otherwise stipulated by laws and regulations, the storage period shall be extended in accordance with the regulations. After you cancel your account, we will take irreversible measures such as complete deletion and anonymization to process your personal information in a timely manner after the above-mentioned period expires.

4.3 Storage Security: We adopt security technologies and measures that meet industry standards, including but not limited to data encryption, access control, firewalls, security audits, etc., to protect your personal information from unauthorized access, use, disclosure, tampering or damage. At the same time, we have established a sound security management system, clarified the security responsibilities of each position, and regularly conducted security training and assessments for employees to ensure the security of personal information.

5. Sharing, Transfer and Public Disclosure of Personal Information

5.1 Sharing: We will not take the initiative to share your personal information with any third party unless it meets the following circumstances:

5.1.1 Obtain Your Explicit Authorization: Share your personal information with the third party designated by you after obtaining your written authorization or oral authorization (confirmed effectively).

5.1.2 Necessary for Providing Services: To provide you with the core services of this App, it is necessary to share necessary personal information with the following partners. The shared information is only the minimum scope necessary to achieve the purpose of the service, and we will sign strict "Data Processing Agreements" and "Confidentiality Agreements" with all partners, clarify their data processing rights and obligations, require them to use the information only for the agreed purposes, and not disclose, tamper with or abuse it. The specific sharing situation is as follows: 1) Video storage and distribution service provider (Amazon Web Services): The shared information is the video files you upload (excluding personal identity information), and the purpose of sharing is to realize the safe storage and rapid distribution of videos; 2) Event information partner (NHL Official Data Provider): The shared information is your interest preferences (such as supported teams) and follow records, and the purpose of sharing is to push accurate event information to you; 3) Security detection service provider (Cloudflare): The shared information is your desensitized device information and IP address, and the purpose of sharing is to prevent network attacks and ensure account security.

5.1.3 Comply with Laws and Regulations and Fulfill Obligations: Share your personal information with relevant departments within the scope required by laws and regulations or to fulfill the legitimate instructions of judicial organs and administrative organs.

5.1.4 Protect Legitimate Rights and Interests: Share your personal information with relevant parties in reasonable and necessary circumstances to protect your legitimate rights and interests, those of other users or ours (such as handling disputes between users, preventing fraudulent behaviors, etc.).

5.1.5 Exercise of the Right to Opt Out of Data Sharing/Sale: You have the right to refuse us to share or sell your personal data to third parties at any time, and exercising this right will not have any adverse impact on your use of the core services of this App. The specific opt-out methods are as follows: 1) For third-party sharing authorized by you: You can send an opt-out application through the email agreed in "9. Contact Us" of this Policy. The email needs to clearly indicate "Data Sharing Opt-Out Application", your account ID and contact information, and provide identity verification materials (such as a screenshot of the device bound to the account). We will notify the relevant third parties to stop sharing within 10 working days after verifying your identity, require them to delete your personal data that has been obtained, and feed back the processing result to you at the same time; 2) For partner sharing necessary for providing services: If you wish to opt out, you can do so by canceling your account (see Article 6.4 of this Policy for the account cancellation process). After canceling the account, we will immediately notify the relevant partners to stop using and delete your personal data (unless otherwise stipulated by laws and regulations); 3) For data sale: You can exercise the right to refuse through the two methods (in-app setting switch/email application) agreed in Articles 7.2.7 and 7.4.6 of this Policy. After we receive the request, we will immediately stop selling your personal data, and will not require you to submit the opt-out application repeatedly unless you explicitly agree to resume data sale subsequently.

5.2 Transfer: We will not transfer your personal information to any third party unless there is an enterprise asset transfer event such as merger, acquisition, or bankruptcy liquidation, and we obtain your explicit consent before the transfer. At the same time, we require the transferee to continue to perform the privacy protection obligations agreed in this Policy. If the transferee cannot perform this obligation, we will require it to stop using your personal information and take necessary remedial measures.

5.3 Public Disclosure: We will not publicly disclose your personal information unless we obtain your explicit authorization, or publicly disclose it within the necessary scope to comply with laws and regulations and fulfill legal obligations (such as cooperating with investigations related to public interests). When making public disclosure, we will take necessary measures to protect the security of your personal information and avoid information leakage.

6. Your Rights

You are legally entitled to inquire about, access, correct, supplement, delete your personal information, cancel your account, withdraw authorization, make complaints and reports, and refuse the sale/sharing of your personal data. The following are the specific and clear exercise methods, which you can operate at any time:

6.1 Inquiry and Access: You can log in to the account automatically generated by this App and enter the "Personal Center" to view your personal profile, account information, uploaded videos, published comments and other personal information.

6.2 Correction and Supplement: If you find that your personal information is incorrect or incomplete, you can log in to the account automatically generated by this App and enter the "Personal Center" to edit your personal profile to correct and supplement the incorrect or incomplete information.

6.3 Deletion: You can directly delete personal information in the following ways: 1) Log in to this App and directly delete the videos you uploaded, comments you published and other content in "Personal Center - My Publications" (effective immediately after deletion); 2) If you need to delete other personal information (such as personal profile, device association information), you can send a deletion request through the email agreed in "9. Contact Us" of this Policy. Please clearly indicate "Personal Information Deletion Request", your account ID, contact information in the email, and provide identity verification materials (such as a screenshot of the device bound to the account). We will complete the processing within 15 working days after verifying your identity and feed back the result via email.

6.4 Account Cancellation: You can independently cancel your account through the following steps: 1) Log in to the account automatically generated by this App; 2) Enter "Settings - Account Security - Account Cancellation"; 3) Read and confirm the account cancellation notice (including the impact on rights and interests after cancellation); 4) Complete identity verification (such as SMS verification, device verification); 5) Submit the cancellation application. After submission, the account will enter a 30-day cooling-off period. During the cooling-off period, you can cancel the cancellation at any time; after the cooling-off period expires, the account will be officially cancelled. After the account is cancelled, we will stop providing all services for you and process your personal information in accordance with the storage period agreed in Article 4.2 of this Policy. Special Reminder: After the account is cancelled, the parts of the content you published that are quoted or shared by other users may not be completely deleted. We will try our best to assist you in contacting the relevant users to delete them, but we cannot guarantee that they can be completely removed.

6.5 Withdrawal of Authorization: You can withdraw your authorization in the following ways:

6.5.1 For device permissions (such as location permission, camera permission, microphone permission, etc.), you can turn off the corresponding permissions in the device settings to withdraw the authorization for us to collect such information.

6.5.2 For third-party service authorization (such as event information push service), you can revoke the authorization for the corresponding service in "Settings - Third-Party Services" of this App, or ask us to assist in revoking it by contacting us.

Please note that after withdrawing the authorization, we will not be able to continue to provide you with relevant services based on the authorization, but it will not affect the validity of the personal information that we have legally collected and used based on your authorization before the withdrawal of the authorization.

7. Privacy Rights Under Major International and Regional Data Protection Laws and Regulations

Puckly is committed to complying with major international and regional data protection laws and regulations around the world to protect the privacy rights and interests of users in different regions. The main laws and regulations we comply with include the European Union's General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) of the United States, Brazil's General Data Protection Law (LGPD), and the Virginia Consumer Data Protection Act (VCDPA) of the United States. The specific rights you enjoy under these laws and regulations and the details of the exercise methods are as follows:

7.1 Rights Under the European Union's General Data Protection Regulation (GDPR) (For EU Users)

If you are located in the European Union (EU) or the European Economic Area (EEA), you enjoy the following rights in accordance with GDPR:

• Right of Access: You may request access to your personal data held by us and obtain detailed information on data processing, including the purpose of processing, the category of personal data, the data recipient (including third parties in third countries), the retention period, and the source of the data (if not collected from you).

• Right to Rectification: You may request us to rectify inaccurate or incomplete personal data without undue delay; if necessary, you may request to supplement incomplete data.

• Right to Erasure (Right to be Forgotten): You may request the erasure of your personal data, especially when the data is no longer necessary for the purpose of collection, you withdraw your consent and there is no other legal basis for processing, you object to the processing and there is no overriding legitimate reason for continuing the processing, or the data processing is illegal.

• Right to Restriction of Processing: You may request the restriction of the processing of your personal data, especially when you dispute the accuracy of the data (during the verification period), the processing is illegal but you do not want the data to be erased, we no longer need the data but you need it for legal claims, or you have filed an objection (during the objection review period).

• Right to Data Portability: You may request to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit it to another data controller without hindrance; if technically feasible, you may request us to transmit the data directly to another data controller designated by you.

• Right to Object: You may object to the processing of personal data based on legitimate interests or public interests at any time; for processing for direct marketing purposes, you have an absolute right to object, and we will immediately stop the relevant processing after receiving the objection.

• Right to Withdraw Consent: You may withdraw the authorization for data processing based on consent at any time. The withdrawal will not affect the legality of the processing before the withdrawal; the method of withdrawal shall be as simple as the method of giving consent.

• Right to Lodge a Complaint: If you believe that your data rights have been infringed, you may lodge a complaint with the data protection authority of the EU Member State where you reside or work, or where the alleged infringement occurred.

7.2 Rights Under the California Consumer Privacy Act (CCPA) of the United States (For California Residents of the United States)

If you are a resident of California, USA, you enjoy the following rights in accordance with CCPA (including the California Privacy Rights Act (CPRA)):

• Right to Know About Personal Information: You may request us to disclose the details of the collection, use, sharing or sale of your personal information in the past 12 months, including the specific category of personal information collected, the specific content of your personal information held by us, the specific purpose of collecting, using, sharing or selling your personal information, and the specific category of third parties with whom we share or sell personal information. You may submit two "Right to Know Requests" free of charge each year.

• Right to Request Deletion of Personal Information: You may request us to delete your personal information collected or stored. However, we may not be able to legally satisfy the deletion request in the following circumstances:

• Complete the transaction initiated by you or provide the service explicitly requested by you;

• Detect security incidents, prevent malicious or illegal activities or prosecute the responsible person;

• Comply with legal obligations or exercise legal rights (such as tax declaration or responding to legal requests);

• Ensure the integrity and security of our services.

Right to Opt Out of Data Sale: You have an absolute and unconditional right to opt out of data sale and may request us to stop selling your personal data to any third party at any time. "Sale" under CCPA refers to the exchange of personal data for money or other valuable consideration. After you exercise this right, we will immediately stop selling your personal data, and will not reduce the quality of service, increase service fees, or restrict your use of the core functions of this App because you exercise this right; unless you explicitly agree to resume data sale through written or in-app operations subsequently, we will not sell your personal data again.

Right to Opt Out of Targeted Advertising: You may request us not to use your personal data for targeted advertising. That is, we will not use your data to push advertisements customized according to your interests or behaviors to you on different websites, applications or services.

Right to Non-Discrimination: You have the right to be free from discrimination when exercising your privacy rights. We will not refuse to provide you with goods or services, charge you different prices or rates, or provide you with services of different levels or quality solely because you exercise your rights under CCPA.

Right to Correct Inaccurate Personal Information: You may request us to correct your inaccurate personal information. After receiving the request and verifying your identity, we will review and correct the relevant information within a reasonable time.

Right to Know the Status of Data Sale: You have the right to know whether we have sold your personal data, as well as the category of personal data sold and the category of buyers. You may submit a "Data Sale Information Request" through the contact information specified in "9. Contact Us" of this Policy, and we will disclose the relevant information of the past 12 months within 15 working days.

Email Application: Send an email requesting "Opt Out of Data Sale" to the official service email blancaalle24@gmail.com. The email needs to include the following information: 1) Subject: Opt Out of Data Sale Request; 2) Body: Your account ID, registered/used device model, contact information; 3) Attachment (optional): Screenshot of the account's personal center (for quick identity verification). After receiving the email, we will complete the processing within 10 working days, feed back the result to you via email, and synchronously record your opt-out preference in the system to ensure that your personal data is no longer sold to third parties.

7.3 Rights Under Brazil's General Data Protection Law (LGPD)

If you are located in Brazil, you enjoy the following rights in accordance with LGPD:

• Right of Access: You may request to obtain information related to your personal data held by us, including the purpose of processing, the category of data, the data recipient, the retention period, and the source of the data.

• Right to Rectification: If your data is inaccurate, incomplete or outdated, you may request to rectify, update or supplement it to ensure the accuracy and completeness of the data.

• Right to Erasure: You may request us to delete your personal data from the system (within the scope permitted by law), which applies when the data is no longer necessary for the purpose of collection, you withdraw your consent, the processing is illegal, or you object to the processing and there is no overriding legitimate reason for continuing the processing.

• Right to Information: You may inquire about which institutions we have shared your data with, the reasons for sharing, and the scope of sharing, and we will provide you with clear and detailed information about the sharing behavior.

• Right to Revoke Consent: You may withdraw your consent to specific data processing activities at any time. The withdrawal will not affect the legality of the processing before the withdrawal; we will provide a simple way to revoke consent.

• Right to Object: If the data processing is based on legitimate interests, public interests or the performance of public duties, you may raise an objection; unless we can prove that there is a mandatory legal reason overriding your interests, rights and freedoms, we will stop the processing.

• Right to Data Transmission: You may request us to transmit your personal data to you or a third party designated by you in a structured, commonly used and machine-readable format; if technically feasible, we will assist in completing the transmission.

• Right to Lodge a Complaint: If you believe that your data protection rights have been infringed, you may lodge a complaint with Brazil's National Data Protection Authority (ANPD).

7.4 Rights Under the Virginia Consumer Data Protection Act (VCDPA) of the United States (For Virginia Residents of the United States)

If you are a resident of Virginia, USA, you enjoy the following rights in accordance with VCDPA:

• Right to Opt Out of Targeted Advertising: You may opt out of the use of your personal data for targeted advertising, including the display of advertisements to you based on your personal data collected on unrelated websites or applications.

• Right to Opt Out of Data Sale:You have the right to request us to stop selling your personal data to third parties at any time. Exercising this right does not require any payment and will not affect your normal use of all functions of this App. "Sale" under VCDPA refers to the exchange of personal data for money or other valuable consideration. After you submit the opt-out request, we will immediately stop selling your personal data and retain your opt-out preference for a long time unless you explicitly revoke the opt-out instruction subsequently.

• Right to Opt Out of Profiling: You may opt out of profiling that supports decisions that have legal or similar significant effects on you. Profiling refers to the automated processing of personal data to evaluate, analyze or predict your behavior, preferences, health status or credit status.

• Right of Access, Rectification and Deletion: You may request access to your personal data held by us (including the category of collected data, the purpose of processing, and the third parties with whom the data is shared); request correction of inaccurate or incomplete data; request deletion of your personal data (except as required by laws and regulations or legitimate business purposes).

• Right to Appeal: If we refuse your request to exercise the above rights, you have the right to appeal our decision. After receiving the appeal, we will review and issue a written reply within 60 days; if the appeal is still rejected, we will inform you of the reasons and the way to lodge a complaint with the Attorney General of Virginia.

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• Methods of Exercising the Right to Opt Out of Data Sharing/Sale: You can conveniently exercise the right to opt out of the sharing or sale of personal data through the following two methods. The operation process is simple and easy to understand, and both can take effect immediately or within the promised time limit: In-app operation (recommended): Open this App, enter the "Settings - Privacy - Data Sharing and Sale Control" page, and you can separately turn on the three independent switches of "Opt Out of Targeted Advertising", "Opt Out of Data Sale", and "Opt Out of Automated Decision Analysis". After turning on, the corresponding personal data processing behavior will stop immediately; you can turn off the switch on this page at any time to resume the relevant authorization (before turning off, the system will pop up a second confirmation window to clearly inform you of the impact after resuming the authorization);

• Email Application: Send an email requesting "Opt Out of Data Sharing/Sale" to the official service email blancaalle24@gmail.com. The email needs to include: 1) Subject: Opt Out of Data Sharing/Sale Request; 2) Body: Clearly state the specific matters you want to opt out of (such as "Opt out of all data sale behaviors", "Opt out of sharing data with event information partners"), your account ID, used device model and contact information; 3) Identity verification materials: Screenshot of the device bound to the account or screenshot of the personal center page. After receiving the email, we will complete all operations within 20 working days, stop the relevant data processing behaviors, and send you a confirmation notice and certificate of completion of processing via email.

7.5 Methods of Exercising Rights Under the Above Laws and Regulations

To exercise any of the above rights (including the right to opt out of data sale/sharing), please contact us through the official service email blancaalle24@gmail.com. When submitting a request, please clearly state the right you want to exercise (such as "Right to Opt Out of Data Sale"), the specific content of the request, and provide necessary identity verification materials (such as account ID, device screenshot, etc., to ensure that the request is initiated by you personally). We promise that the processing of requests to exercise the right to opt out of data sale/sharing is free of charge throughout the process, and we will not restrict your use of the core services of this App in any form.

We will respond to your request within the time limit required by applicable laws (usually 30 to 45 days). If it is necessary to extend the processing time due to the complexity of the request or the need to collect more information, we will notify you in writing within the initial response time limit, explaining the reason for the extension and the expected processing time.

No fee will be charged for processing your reasonable requests, but we may charge a reasonable fee for obviously excessive, repetitive or unfounded requests.

8. Protection of Minors' Privacy

This App strictly restricts its service objects to adults aged 18 and above, and will never take the initiative to collect any personal information from minors (under 18 years old). If a minor uses this App without the explicit consent of their legal guardian, the legal guardian has the right to request us to delete all relevant personal information of the minor.

8.1 Guardian's Supervision Right: If you are the legal guardian of a minor and find that your ward has used this App and generated relevant personal information, you can send an application through the email agreed in "9. Contact Us" of this Policy.Please clearly indicate "Minor Information Deletion Application" in the email and provide the following materials for identity verification: 1) Your identity certificate (such as a scanned copy of your ID card); 2) Guardianship certificate (such as a scanned copy of the household registration book); 3) The account ID used by the ward (if any). We will delete all relevant personal information of the minor within 10 working days after verifying the authenticity of the materials and take technical measures to prevent them from continuing to use this App.

8.2 If you have any questions about the privacy protection of minors during their use of this App as a legal guardian, you can contact us through the email agreed in this Policy, and we will verify and handle it in a timely manner.

9. Contact Us

If you have any questions, suggestions about this Privacy Policy, or need to exercise your rights related to personal information, you can contact us through the following methods:

Official Email: blancaalle24@gmail.com

We will verify and reply within a reasonable time (generally no more than 30 working days) after receiving your contact request.

10. Controller and Data Protection Officer

10.1 Personal Information Controller: The personal information controller of this App is Shijiazhuang Liaodui Electronic Science & Technology Co., Ltd.

10.2 Company Address: 26-3-502, Jianling Area, No.126, Jianhua S. Street, Yuhua District Shijiazhuang, Hebei, 050000 China

10.3 Data Protection Officer: Our company designates Zhang Ming as the Data Protection Officer, who is responsible for supervising personal information processing activities and responding to users' privacy-related consultations and requests. If you need to communicate with the Data Protection Officer, you can contact us through the official email blancaalle24@gmail.com.

11. Update and Notification of the Privacy Policy

11.1 We will revise this Privacy Policy from time to time in accordance with changes in laws and regulations, updates of product functions, adjustments of regulatory requirements, etc. The revised Privacy Policy will be displayed to you in a prominent way in this App (such as pop-up windows, homepage announcements, etc.) for a period of not less than 7 days to ensure that you have sufficient time to read it. If you continue to use this App after the revised Privacy Policy takes effect, it means you agree to all the clauses of the revised Privacy Policy.

11.2 If the revision of this Privacy Policy involves your core rights (specifically including: expansion of the scope of personal information collection, change of use purpose, change of sharing/transfer/disclosure rules, restriction on the way you exercise your rights, etc.), we will notify you in advance 30 days in a prominent way such as pop-up windows and emails (if you have provided an email). And we will clearly inform you of the specific content of the revision, the effective time and its impact on you. The revised Privacy Policy will take effect only after obtaining your explicit consent (such as clicking the "Agree to Revision" button); if you do not agree to the revision, you can choose to cancel your account and stop using this App.

12. Others

12.1 The establishment, effectiveness, performance, interpretation and resolution of disputes under this Privacy Policy shall all apply to the relevant laws and regulations in Europe and the United States, including but not limited to: the European Union's General Data Protection Regulation (GDPR), the European Union's ePrivacy Directive, the California Consumer Privacy Act (CCPA) of the United States, the California Privacy Rights Act (CPRA) of the United States, Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), the United Kingdom's Data Protection Act (DPA 2018), etc. We will strictly comply with the requirements of the above laws and regulations to protect your personal information rights and interests.

12.2 Any dispute arising between you and us due to this Privacy Policy shall first be resolved through friendly negotiation; if negotiation fails, either party has the right to file a lawsuit with the competent court where the operator of this App is located.

12.3 This Privacy Policy shall take effect from the date you use this App.