RedCloud Privacy Policy

Welcome to the RedCloud (hereinafter referred to as the "Service" or "RedCloud").

This RedCloud Privacy Policy (hereinafter referred to as "this Policy") aims to inform you of how we collect, use, store, share, and protect your personal information, as well as how you can exercise your related rights when you use the Service.

Please read and understand the entire contents of this Policy carefully before using the Service.

This Privacy Policy is meant to help you understand what personal information we collect, why we collect it, how we use it, and how we protect it. We will collect and use your personal information in accordance with this Privacy Policy, but we will not collect all of your personal information by coercive bundling simply because you have agreed to this Policy. We will strictly comply with legal and regulatory requirements and seek your separate consent in specific circumstances. This Privacy Policy outlines how we process your information in various scenarios; however, we will only process your information to the extent necessary to enable specific features or services when you activate those features or use those services. If you do not activate a feature or use a related service, we will not process the corresponding information. In addition to this Privacy Policy, we may also inform you of the rules for processing your personal information through product page notices, pop-up prompts, push notifications, and other means. The specific rules corresponding to particular business functions shall prevail and have the same effect as this Privacy Policy.

If you are a minor under the age of 18, please read this Policy carefully and ensure you fully understand it under the guidance of your legal guardian, and use our services only after obtaining the consent of your legal guardian.

If you do not agree to any part of this Policy, you shall immediately stop using the Service. By starting or continuing to use RedCloud, you acknowledge that you have fully understood and agreed to our processing of your personal information in accordance with this Policy.

 This Privacy Policy will help you understand the following:

1. Information We Collect and the Purposes for Which We Use It

2. How We Use Cookies and Similar Technologies

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

4. How to Exercise Your Rights Regarding Your Personal Information

5. How We Store Your Personal Information

6. How We Protect Your Personal Information

7. Protection of Minors

8. Revisions to This Policy

9. How to Contact Us

 

1. Information We Collect and Corresponding Purposes of Use

We will follow the principles of legality, legitimacy, and necessity to collect and use your personal information. Specifically, we collect and process your personal information for the purpose of providing you with corresponding business functions. In these functions, if you provide personal information of others, please ensure that you have obtained authorization from the relevant subjects. We reserve the right to verify the legal source of such personal information at any time.

You need to provide us with personal information for us to realize the basic business functions of RedCloud. The information necessary to achieve the basic business functions is essential personal information. If you refuse to provide this essential personal information, we will not be able to provide you with that basic business function and corresponding services. Beyond the basic business functions, you can choose to provide us with some personal information for us to realize the extended business functions of RedCloud. We will inform you of the purpose of use and process this information based on your authorization and consent or the purpose necessary to realize the extended business function you have chosen. Your refusal to provide this extended business function information will not affect your use of our basic business functions. However, if you refuse to provide personal information necessary for an extended business function, we will not be able to provide you with that extended business function.

For your convenience, the business functions we provide, the processing purposes, and the required personal information are listed as follows:

Personal information refers to various information recorded electronically or by other means that can identify a specific natural person alone or in combination with other information, or reflect the activities of a specific natural person. The personal information of children under 14 years old (inclusive) is sensitive personal information. When you use RedCloud, you need to provide or allow us to collect necessary information for us to provide you with services, including:

Information You Actively Provide to Us

(1) To help you become our user, the registration information you fill in, including your phone number and email, is used to register, log in to your RedCloud account to use RedCloud products and services, and for our customer service and after-sales to provide you with consulting services, and to protect the security of your account. If you only need to browse and learn about RedCloud, you do not need to register as our user or provide the above information;

(2) When you contact us, we may save your communication or call records and content or the contact information you leave, in order to help you solve problems, or record the handling plan and results of related issues.

(3) Please note that when you use third-party services within RedCloud, you may need to register or log in to your third-party account, and the third-party operator may collect and use your relevant information for you to use their services. Please be assured that RedCloud does not collect or use any information you provide to third parties. Regarding how third-party operators collect and use your personal information, please refer to the relevant service agreements and privacy policies of those third-party operators.

How We Collect and Use Your Personal Information During Your Use of the Service

We may collect information about your use of this Service, including:

(1) Registration and Login

To facilitate our provision of continuous and stable services to you and to ensure the security of your use of this Service, you can create a RedCloud universal account via a mobile phone number, and you can complete your account information. When registering or logging in to the RedCloud universal account, you need to provide us with your mobile phone number. You can choose to set an account name, avatar, and login password.

You can also use a third-party account to log in to RedCloud. In this case, you authorize RedCloud to obtain the public information you registered with that third-party account (including your nickname, avatar, and other information you authorize).

(2) Ensuring Service and Operational Security

To improve the security of your use of our services, protect the personal and property safety of you, other users, or the public from infringement, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, and network intrusion, and more accurately identify violations of laws, regulations, or relevant agreements and rules of the product platform, with your authorization, we will collect or use your registration information, device information (including device attribute information of the terminal device you use to install and run RedCloud, such as hardware model, operating system version and system status, device configuration, International Mobile Equipment Identity IMEI, International Mobile Subscriber Identity IMSI, Media Access Control address MAC, Advertising Identifier IDFA, Identifier for Vendors IDFV, Mobile Equipment Identifier MEID, Open Anonymous Device Identifier OAID, Integrated Circuit Card Identifier ICCID, Android ID, hardware serial number, and other device identifiers), device connection information (such as browser type, telecom operator, language used, WiFi information, BSSID information), device status information, network logs, as well as the list of applications installed on your device, the overall operation, and overall installation and usage of applications, to comprehensively assess your account and transaction risks, and to detect and prevent security incidents.

(3) Optimizing Service Experience and Resolving Issues in Service

When you use RedCloud, to ensure your normal use of automated device services, more accurately locate and resolve issues you encounter when executing commands, and improve and optimize the service experience of automated operation, we will collect device information. For information collected from your various devices, we may associate them to provide you with a consistent service experience across these devices. To facilitate you to more effectively select and upload the required APPs to your cloud phone when using the cloud phone service, we will obtain the list of applications on your device when you upload files to the cloud phone. At the same time, to better optimize the APPs you need to synchronize and install in the cloud phone, we will collect information about applications installed/uninstalled on your device to enhance your user experience.

(4) When you share information or receive shared information, we will read the passcodes, links, etc., in the clipboard to achieve jump and sharing of information content.

(5) To optimize network connections, provide more stable proxy services, and meet the geographical location requirements of some social media platforms, with your authorization, we may obtain your location information through IP address, GPS, Wi-Fi access points, or base station information. You can turn off location permissions in device settings, but this may affect the experience of some services.

(6) To enable you to obtain RedCloud activity information, promotional information, etc., in a timely manner, we will use your phone number, device information, and obtained product information to provide you with unified push notifications for products, services, or activity information.

(7) When you use functions such as image upload, avatar modification, and voice dialogue, we will request access to your device's system permissions for camera, photos, and microphone. If you refuse to authorize, you will not be able to use the corresponding functions, but it will not affect your normal use of other functions of RedCloud that do not require the above permissions.

(8) When you purchase paid services, the payment function is provided by third-party payment institutions (such as Alipay, WeChat Pay, Stripe, etc.). We will only receive payment result status and order numbers from the payment institutions and will not collect or store sensitive financial information such as your bank card number or payment password.

(9) Customer Service or Other User Response Functions

When you contact our customer service or use other user response functions (complaints and requests from other users), we need you to provide necessary identity information to match and verify your user identity, to ensure the security of your account and the system. To handle your requests, human customer service may need to query or verify your relevant information within the scope of your authorization and use it only within the necessary scope. If you refuse to provide or provide incorrect information, we may not be able to provide you with corresponding support. After confirming your user identity, we will also save your contact information (the contact method you use when contacting us or other contact information you proactively provide to us), your communication/call records and content with us, and other necessary information related to your requests, to contact you or help you solve problems, or to record the handling plan and results of related issues.

(10) For the joint provision of this Service to you, improvement of service quality, or reasonable needs for product and service security considerations, we may, in accordance with legal regulations or based on your valid authorization, receive your personal information and other information from the product platform, affiliated companies, partners, and other trusted third-party suppliers. We will require the personal information provider to explain the source of the personal information in advance and confirm the legality of its source. At the same time, we will understand the scope of authorization and consent for personal information processing already obtained by the personal information provider. If the personal information processing activities required for business operations exceed the obtained scope of authorization and consent, we will seek your express consent within a reasonable period after obtaining the personal information or before processing the personal information, or obtain your express consent through the personal information provider.

(11) Anonymization Processing of Personal Information

Without publicly disclosing or externally providing your personal information, we have the right to mine, analyze, and utilize (including for commercial use) the user database after anonymization processing, and have the right to statistically analyze the usage of products/services and share the anonymized statistical information with the public/third parties.

(12) Device Permission Invocation

During the service provision process, to ensure that you can normally use product functions, we will apply to the system for your device's system permissions. We will seek your consent before applying. You can choose to "Allow" or "Deny" the permission request. After your authorization, we will enable the relevant permissions. You can cancel the authorization in the system at any time. Your cancellation of authorization will cause you to be unable to use the related business functions, but will not cause you to be unable to use other business functions. You can turn off permissions. The display and closing methods of permissions may vary on different devices. Please refer to the instructions or guidance of the device and system developer.

Exceptions to Prior Consent:

According to relevant laws and regulations, processing your information in the following circumstances does not require your authorization and consent:

● Relating to national security and national defense;

● Necessary for the conclusion or performance of a contract to which you are a party;

● Necessary for the performance of statutory duties or statutory obligations;

● Necessary for responding to public health emergencies or protecting the life, health, and property safety of natural persons in emergency situations;

● Directly related to criminal investigation, prosecution, trial, and execution of judgments;

● Necessary to protect the legitimate rights and interests of you or other individuals, where obtaining consent is impractical;

● Processing, within a reasonable scope, personal information that you have voluntarily disclosed to the public or that has been lawfully disclosed otherwise, in accordance with legal provisions;

● Processing, within a reasonable scope, your personal information collected from legally publicly disclosed information, such as through legal news reports, government information disclosure, and other channels;

● For the public interest in conducting news reporting, public opinion supervision, etc., processing personal information within a reasonable scope;

● Where academic research institutions, for the necessity of conducting statistical or academic research for the public interest, and when providing the results of academic research or descriptions externally, de-identify the personal information contained in the results;

● Other circumstances stipulated by laws and regulations.

 

2. How We Use COOKIES or Similar Technologies

Cookies and anonymous identifiers. A cookie is a mechanism that supports the server (or script) in storing and retrieving information on the client. When you use this Service, we will send one or more cookies or anonymous identifiers to your device. When you interact with this Service, we allow cookies or anonymous identifiers to be sent to the RedCloud server. Cookies usually contain identifiers, site names, and some numbers and characters. Using cookie technology, RedCloud can understand your usage habits, remember your preferences, save you the step of entering repetitive information, provide you with more considerate services, or help us judge the security of your account. Cookies can also help us collect traffic information and analyze page design.

We will not use Cookies for any purposes other than those described in this Policy. You can manage or delete Cookies according to your own preferences. For details, please refer to AboutCookies.org. You can delete all Cookies saved on your computer. Most web browsers have a function to block Cookies. However, if you do so, you will need to manually change the user settings each time you visit our website, and you may be unable to log in or use the services or functions provided by RedCloud that rely on Cookies.

You can clear your Cookies and restrict our use of Cookies.

 

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

Some of our services will be provided by authorized partners. Only for the purposes stated in this Privacy Policy, we may share certain of your personal information with partners to provide better customer service and user experience. We will only share your personal information for lawful, legitimate, necessary, specific, and clear purposes, and will only share the personal information necessary to provide the service. Unless otherwise authorized by you or required by laws and regulations, our partners have no right to use the shared personal information for any other purpose.

Sharing

We attach great importance to the protection of your personal information. We will only provide your personal information to third parties for lawful, legitimate, necessary, specific, and clear purposes. We will sign strict confidentiality agreements with the companies, organizations, and individuals that receive the personal information we provide, requiring them to process the information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures.

To achieve the purposes stated in this Policy, we may integrate applications provided by third-party service providers (such as in the form of embedded code, plugins, H5, SDKs, etc.) to provide you with better customer service and user experience. The situations in which we may entrust processing or share personal information for the realization of our services are as follows:

(1) For third-party account login;

(2) For collecting device information and log information, etc., with your consent;

(3) For supporting product function modules;

(4) For optimizing product performance and service quality, including improving hardware network configuration capability, reducing server costs, hot-fixing functions, security analysis, optimizing services, and improving user experience;

(5) For account security and product reinforcement-related services, including network monitoring, domain name resolution, anti-hijacking, anti-spam and anti-cheating, encryption and decryption services, etc.;

(6) Third-party SDK service providers. To ensure the provision of services described in this Privacy Policy, we may integrate Software Development Kits (SDKs) provided by third parties to realize related functions, to better improve customer service and user experience. At this time, these third-party SDK service providers may collect your personal information on behalf of RedCloud or for one or more purposes of this Privacy Policy.

Our services may be integrated with or linked to other products we operate or services provided by third parties. Including:

(1) You can use the "Share" function to share certain content of this product's services to other products or third-party products or services, or you can share content from other products or services or third-party products or services to this product;

(2) Providing you with links through service announcements or other means, allowing you to link to other products or services, third-party products or services, or websites;

(3) Other situations of integrating third-party services. For example, third parties we integrate may collect your personal information. When you use such services provided by third parties within our services, you agree that they will directly collect and process your information. We will evaluate the legality, legitimacy, and necessity of such third-party services collecting personal information, require such third parties to take protective measures for your personal information, and strictly comply with relevant laws, regulations, and regulatory requirements.

The above third-party services are operated by the relevant third parties. Your use of such third-party services (including any information you provide to such third parties) is subject to the third party's own terms of service and personal information protection rules (not this Policy), and you need to read their terms carefully. This Policy only applies to the personal information we collect and does not apply to any services provided by third parties or the information use rules of third parties. If you find risks in these third-party services, it is recommended that you terminate related operations to protect your legitimate rights and interests and contact us promptly.

To better protect the physical and mental health of minors, guide minors to use the internet properly, and prevent minors from impersonating or borrowing information from adults, based on the requests of minors' guardians or our initiative to protect minors, we may attempt to contact their guardians to inform them of the relevant service account, online duration, online behavior, and other information for reminder, confirmation, and handling.

We and our affiliated companies or users of the same account system have highly consistent data security measures and management levels. To jointly provide you with services, improve the security and convenience of your use of products, and ensure a consistent service experience, and subject to legal requirements, we may share your personal information among affiliated companies or users of the same account system. In such cases, we will only share necessary personal information. If we share your sensitive personal information or the recipient changes the purpose of use and processing of personal information, we will seek your authorization and consent again.

For users of the same account system, to fulfill regulatory requirements, ensure account security, achieve consistent display, and be able to contact you, based on your valid authorization, we may share your account-related information.

Third-party Software Development Kits (SDKs) We Integrate

To adapt to the use of RedCloud and third-party platform services on different mobile devices, achieve your mobile device identity authentication, mobile device security, login to third-party platform accounts, sharing information through third-party platforms, and payment security, RedCloud integrates third-party SDKs. The providers of the aforementioned third-party SDKs include mobile communication operators and third-party payment institutions. Some third-party SDKs may call your device permissions and collect your device information (such as network device hardware address MAC, Advertising Identifier IDFA, Identifier for Vendors IDFV, Open Anonymous Device Identifier OAID, Integrated Circuit Card Identifier ICCID, Android ID, hardware serial number, and other device identifiers) to enable you to normally use corresponding functions on different mobile devices or third-party platforms. The types of device permissions called by different third-party SDKs and the information obtained may vary, and may include obtaining your location information, reading/writing your external storage card, reading your phone status and identity, viewing WLAN connections, and retrieving running applications/Bluetooth. Regarding the specific types of device permissions called by third-party SDKs and how they collect and use your personal information, it is recommended that you refer to the relevant service agreements and privacy policies of the third-party SDKs.

Entrusted Processing and Joint Processing

To better serve you, we may entrust third-party partners to process your personal information. We will only entrust third-party partners to process your information for legitimate, legitimate, necessary, specific, and clear purposes. We will strictly limit the information processing purposes of the entrusted parties and require the entrusted parties to take sufficient data security measures. If a third-party partner uses your information for purposes not entrusted by us, it shall separately obtain your consent. Our authorized partners include advertising and analytics service partners. We will, under the premise of complying with industry-standard security technologies, entrust these partners to process information related to advertising delivery, advertising effectiveness, and advertising reach rates. Without your valid authorization, we will not entrust third-party partners to process information that can directly identify your personal identity. If you proactively leave your contact information, address information, and other personal information for a specific third-party partner for them to contact you, they will directly process your personal information.

In joint processing scenarios, we will also sign relevant agreements that comply with legal requirements with partners and fulfill relevant personal information protection obligations.

Exceptions to Prior Authorization and Consent for Sharing, Transferring, or Publicly Disclosing Personal Information

In the following circumstances, sharing, transferring, or publicly disclosing personal information does not require prior authorization and consent from the personal information subject:

● Related to national security and defense security;

● Necessary for the conclusion or performance of a contract to which the individual is a party;

● Necessary for the performance of statutory duties or statutory obligations;

● Directly related to public security, public health, and significant public interests. For example: necessary for responding to public health emergencies or protecting the life, health, and property safety of natural persons in emergency situations;

● Directly related to criminal investigation, prosecution, trial, and execution of judgments;

● Where it is necessary for protecting the life, property, and other significant legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the consent of the individual;

● Processing, within a reasonable scope, personal information that the individual has voluntarily disclosed to the public or that has been lawfully disclosed otherwise, in accordance with legal provisions. For example: through legal news reports, government information disclosure channels, etc.;

● Other circumstances stipulated by laws and administrative regulations.

 

4. How to Exercise Your Rights Regarding Personal Information

During your use of RedCloud, we will provide you with corresponding operation settings to manage your personal information based on the specific situation of RedCloud, so that you can access, copy, transfer, correct, supplement, delete, or withdraw your relevant personal information.

Right to Access

You have the right to access your personal information, except in circumstances stipulated by laws and regulations. You can query or edit personal information in your account, etc., through customer service.

Right to Rectification

When you find that we have processed your personal information incorrectly, you can contact online customer service to request modification.

Right to Deletion

Under the following circumstances, you can contact online customer service to request deletion of your personal information:

(1) If our processing of personal information violates laws and regulations;

(2) If we collect or use your personal information without obtaining your consent;

(3) If our processing of personal information violates our agreement with you;

(4) If you no longer use our products or services, or you cancel your account;

(5) If we no longer provide you with products or services.

Right to Withdraw Consent

Each business function requires some basic personal information to be completed. For the collection and use of additionally collected personal information, you can give or withdraw your authorization and consent at any time. After withdrawal of authorization, we will not be able to continue providing you with the services corresponding to the withdrawn authorization, and will no longer process your corresponding information. However, your decision to withdraw authorization will not affect the information processing previously carried out based on your authorization.

Right to Cancel Account

If you decide to stop using RedCloud, you can cancel your account. You can also cancel with the assistance of online customer service.

After applying for cancellation, we will respond within 5 working days. After the account is canceled, the data within this account cannot be recovered, including but not limited to asset information in the account, etc. The account information content will also be completely cleared. This cancellation operation cannot be undone. Please apply carefully.

Right to Copy and Right to Data Portability

You have the right to copy your personal information that we have collected. Under the conditions stipulated by laws and regulations, and meeting the regulations and conditions stipulated by the national cybersecurity authority, if technically feasible, you can also require us to transfer your personal information to another entity designated by you.

Right to be Informed in Advance of Cessation of Product/Service Operation

If this service ceases operation due to special reasons, we will notify you within a reasonable period through the main page of the product or service, internal messages, or by sending you an email or other appropriate means that can reach you, and will stop collecting your personal information. At the same time, we will delete or anonymize your collected personal information in accordance with legal provisions.

In the following circumstances, in accordance with legal requirements, we will be unable to respond to your above requests:

(1) Related to the performance of legal obligations by the personal information controller;

(2) Directly related to national security and defense security;

(3) Directly related to public security, public health, and significant public interests;

(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;

(5) The personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abuses rights;

(6) Where it is necessary for protecting the life, property, and other significant legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the individual;

(7) Responding to the request of the personal information subject will seriously harm the legitimate rights and interests of the personal information subject or other individuals or organizations;

(8) Involving trade secrets.

If you have other needs for access, copying, transfer, correction, supplementation, or deletion, or if you have any questions or difficulties during your use of this service, you can choose to contact us through the feedback channels listed in the "How to Contact Us" chapter of this Policy. We will handle it promptly for you.

Except as otherwise provided by laws and regulations, when you correct, supplement, delete your personal information, or apply to cancel your account, we may not immediately correct, supplement, or delete the corresponding information from the backup system, but will correct, supplement, or delete this information when the backup is updated. Once relevant information is deleted or the account is canceled, it cannot be recovered. Please operate with caution.

 

5. How We Store Your Personal Information

Retention Period

We will retain your personal information for the period necessary to provide the service. However, if laws and regulations stipulate different retention periods, you agree to a longer retention period, it is necessary to ensure service security and quality, achieve dispute resolution purposes, or it is technically difficult to achieve, etc., we will extend the retention period in accordance with the law, agreements, or within a reasonable range after the aforementioned retention period expires.

After the retention period expires, we will delete your personal information or anonymize it according to legal provisions.

Storage Location

The personal information collected when we operate this service will be stored on servers in the Singapore region and other global regions necessary for our operations. This means your information may be transmitted to and processed or accessed in jurisdictions outside the country/region where you use the service. Data protection laws vary from country to country, and the strength of data protection also varies. Wherever your information is processed, we will uniformly adopt the protection measures described in this Policy to ensure that your personal information receives an equal level of protection as required by applicable laws.

 

6. How We Protect Your Personal Information

We attach great importance to information security, have established a dedicated security team, and take all reasonably feasible measures to protect your personal information:

Data Security Technical Measures

● We will collect, use, store, and transmit user information following the principle of "minimization" and inform you of the purpose and scope of use of such information through user agreements and privacy policies.

● We take information security very seriously. We have established a dedicated team responsible for developing and applying various security technologies and procedures, etc. We conduct security background checks on security management personnel and key security personnel, and we have established sound information security management systems and internal security incident handling mechanisms. We will take appropriate security measures and technical means that meet industry standards to store and protect your personal information to prevent loss, unauthorized access, public disclosure, use, alteration, damage, or leakage of your information. We will take all reasonably feasible measures to protect your personal information. We use encryption technology to ensure data confidentiality; we use trusted protection mechanisms to prevent data from malicious attacks.

● We conduct awareness training and competency assessments on data security for employees to enhance their understanding of the importance of protecting personal information. We authenticate and control the permissions of employees who handle personal information and will sign confidentiality agreements with employees and partners who have access to your personal information, clarifying job responsibilities and codes of conduct to ensure that only authorized personnel can access personal information.

● We remind you to note that the internet is not an absolutely secure environment. When you interact with other users about your geographic location or trajectory information through third-party social software, emails, SMS, etc., embedded/installed in RedCloud, it is uncertain whether the third-party software fully encrypts the transmission of information. Please pay attention to ensuring the security of your personal information.

● We also ask for your understanding that in the internet industry, due to technical limitations, rapid development, and possible malicious attack methods, even if we do our best to strengthen security measures, it is impossible to always guarantee 100% security of information. Please understand that the systems and communication networks you use when using our products and/or services may have security issues in other links beyond our control.

According to our security management system, incidents of personal information leakage, damage, or loss are classified as major security incidents. Once they occur, the company's highest-level emergency plan will be activated, and a joint emergency response team composed of multiple departments such as the Security Department and Legal Department will handle it.

Security Incident Notification

● We will formulate cybersecurity incident emergency plans, promptly address security risks such as system vulnerabilities, computer viruses, network attacks, and network intrusions. In the event of an incident that endangers network security, we will immediately activate the emergency plan, take corresponding remedial measures, and report to the relevant competent authorities as required.

● Personal information leakage, damage, or loss is classified as a company-level major security incident. We are responsible for regularly organizing team members to conduct security plan drills to prevent such security incidents. If such an incident unfortunately occurs, we will activate the emergency plan with the highest priority, form an emergency response team, trace the cause and minimize losses in the shortest possible time.

● After the unfortunate occurrence of a personal information security incident, we will promptly inform you of the basic situation of the security incident and its possible impact, the measures we have taken or will take, suggestions for you to prevent and reduce risks independently, and remedial measures for you, etc., in accordance with legal requirements. We will promptly notify you of the relevant situation of the incident through internal site notifications, SMS notifications, phone calls, emails, and other contact methods you have provided. If it is difficult to inform each individual, we will issue an announcement in a reasonable and effective manner. At the same time, we will also proactively report the handling of personal information security incidents to regulatory authorities as required. Please understand that according to legal provisions, if the measures we take can effectively avoid harm caused by information leakage, tampering, or loss, unless required by regulatory authorities to notify you, we may choose not to notify you of the personal information security incident.

 

7. Protection of Minors

Our products and services are mainly aimed at adults. We will only process the personal information of minors when permitted by laws and regulations and with the consent of parents or other guardians.

If you are a minor under the age of 14, before using RedCloud, please ask your parents or other guardians to read this Privacy Policy carefully, or read it carefully together under the guidance and supervision of your parents or other guardians. Use our products and services or provide us with information only after obtaining the consent of your parents or other guardians.

If we find that we have collected the personal information of minors under the age of 14 without obtaining verifiable consent from parents or other guardians in advance, we will take measures to delete the relevant information as soon as possible. If at any time a guardian has reason to believe that we have collected the personal information of a minor without the guardian's consent, please contact us, and we will take measures to delete the relevant data as soon as possible.

 

8. Revisions to This Policy

Our Privacy Policy may change.

We will not diminish your rights under this Privacy Policy without your explicit consent. We will post any changes to this Privacy Policy on this page.

For major changes, we will notify you through the main exposure page of the product or service, internal messages, or by sending you an email or other appropriate means that can reach you. If you do not agree to such changes, please stop using this product and service immediately.

Major changes referred to in this Policy include but are not limited to:

● Major changes in our service model. Such as the purpose of processing personal information, the types of personal information processed, the use of personal information, etc.;

● Major changes in our ownership structure, organizational structure, etc. Such as changes in ownership due to business adjustments, bankruptcy, mergers and acquisitions, etc.;

● Changes in the main objects of external provision, transfer, or public disclosure of personal information;

● Major changes in your rights regarding personal information processing and how to exercise them;

● Changes in the responsible department, contact information, and complaint channels for personal information security;

● When the personal information security impact assessment report indicates high risks.

 

9. How to Contact Us

The growth of RedCloud cannot be achieved without the joint efforts of all users. We greatly appreciate your contribution to RedCloud's data updates and usage feedback.

If you have any comments or suggestions regarding RedCloud or any part of this Agreement, you can contact us through the company's customer service department (email: [email protected]).

Generally, we will reply within fifteen working days after receiving your questions, comments, or suggestions and verifying your user identity. Disputes concerning this Agreement shall be resolved through friendly negotiation. If negotiation fails, you may complain to the consumer rights protection department or file a lawsuit with the competent court in the location of RedCloud.

 

Appendix: Terminology Explanation

Personal Information​ refers to various information recorded electronically or by other means related to an identified or identifiable natural person, excluding information after anonymization processing. Personal information includes name, date of birth, ID number, personal biometric information, address, communication contact information, communication records and content, account password, property information, credit information, whereabouts trajectory, accommodation information, health and physiological information, transaction information, etc.

Sensitive Personal Information​ refers to personal information that, once leaked or illegally used, is likely to infringe upon the human dignity of a natural person or endanger personal or property safety. It includes biometrics, religious beliefs, specific identity, medical health, financial accounts, whereabouts trajectory, and other information, as well as the personal information of minors under the age of fourteen.

Device​ refers to equipment that can be used to use RedCloud products and/or services, such as desktop devices, tablets, or smartphones.

Device Information​ may include device attribute information of the terminal device you use to install and run RedCloud (e.g., hardware model, operating system version and system status, device configuration, International Mobile Equipment Identity IMEI, International Mobile Subscriber Identity IMSI, Media Access Control address MAC, Advertising Identifier IDFA, Identifier for Vendors IDFV, Mobile Equipment Identifier MEID, Open Anonymous Device Identifier OAID, Integrated Circuit Card Identifier ICCID, Android ID, hardware serial number, and other device identifiers), device connection information (e.g., browser type, telecom operator, language used, WiFi information), and device status information (e.g., device application installation list, device sensor information).

Log Information​ refers to requests automatically recorded by our servers when you access RedCloud, such as your IP address, browser type and language used, hardware device information, operating system version, network operator information, the date, time, and duration of your visit to the service, and other information you provide, generate, or retain when using our products or services.

Cookie​ refers to a mechanism that supports the server (or script) in storing and retrieving information on the client, extending Web-based client/server applications by adding simple, persistent client state. The server sends a piece of state information while returning an HTTP object to the client, and the client saves it. The state information describes the valid URL range for that state. Subsequently, HTTP requests initiated by the client within this range will return the current value of this state information from the client to the server. This state information is called a Cookie.

Location Information​ refers to precise location information obtained through GPS information, WLAN access points, Bluetooth, base stations, and other sensor information, as well as approximate geographic location information obtained through IP address or other network information.

User Profiling​ refers to the process of analyzing or predicting certain personal characteristics of a specific natural person, such as their profession, economy, health, education, personal preferences, credit, behavior, etc., by collecting, aggregating, and analyzing personal information, forming a model of their personal characteristics. Directly using the personal information of a specific natural person to form the characteristic model of that natural person is called direct user profiling. Using personal information from sources other than the specific natural person, such as data from the group they belong to, to form the characteristic model of that natural person is called indirect user profiling.

De-identification​ refers to the process of processing personal information so that a specific natural person cannot be identified without the use of additional information.

Anonymization​ refers to the technical processing of personal information so that the personal information subject cannot be identified, and the processed information cannot be restored. Information obtained after anonymization processing of personal information does not belong to personal information.

Affiliated Companies​ refers to the operator of RedCloud and other companies that have an affiliated relationship with the company, individually or collectively. "Affiliated relationship" means, for any subject (including individuals, companies, partnerships, organizations, or any other entity), a subject that directly or indirectly controls it, a subject that is directly or indirectly controlled by it, or a subject that is directly or indirectly under the control of the same subject as it. The aforementioned "control" refers to the power, directly or indirectly, through voting rights, contracts, or other means, to direct or cause the direction of the management and decision-making of the relevant subject, or other relationships that constitute de facto control.

Thank you again for your trust and use of RedCloud!

 

Effective Date: June 11, 2026