Our products are developed based on DCloud uni-app (5+ App/Wap2App). During application operation, your device's unique identification code (IMEI/android ID/DEVICE_ID/IDFA, SIM card IMSI information, OAID) needs to be collected to provide statistical analysis services, and performance and user experience are improved through application startup data and abnormal error log analysis, so as to provide users with better services.

This application integrates the Google AdMob advertising SDK, which internally uses Android WorkManager for advertising request scheduling. We have disabled listening for system time change broadcasts (ACTION_TIME_SET), and will not conduct auto-start or background keep-alive behavior.

Third-party SDK list:
• Getui SDK: To implement complete functions, Getui services may remain enabled both in the foreground and background of the application. When Getui services are enabled, the purposes, processing methods, types of personal information processed, and processing rules for your user information are as follows: (I) How we collect and use your user information 1. Information collected and used by Getui during the provision of message push services: 1.1 Device information: obtaining Android_ID and MAC address (see "VIII. Definitions: Device Identifiers" for details), device platform, and device manufacturer are used to generate a unique push target ID (CID) and device ID (GID), thereby ensuring accurate delivery of push messages and accurate identification of message devices. Device brand, device model, and system version are used to optimize the effectiveness of channel resources and improve push message arrival rate and stability. In addition, to ensure the uniqueness of CID and improve the stability and accuracy of push messages, you also need to authorize storage permission (WRITE_EXTERNAL_STORAGE) and device permission (READ_PHONE_STATE). 1.2 Obtaining installed APP information: we use merged-link technology for technical push. When multiple APP push links are active on one device at the same time, we randomly merge them into one link to save power and data for you, and therefore need to obtain application list information. At the same time, we provide an intelligent push function and use this information to provide push content more suited to your needs and reduce disturbance from unnecessary push messages. 1.3 Network information (see "VIII. Definitions: Network Information" for details) and location-related information: to maintain network connection stability to the greatest extent and establish long connections, we need to understand the device's network status and changes so as to provide stable and continuous push services. We provide contextual push functions, and location-related information will help us provide refined offline-scenario push, so that we can provide push content more suited to your needs and reduce disturbance from unnecessary push messages.
• Mobile Intelligent Terminal Supplementary Device Identifier System Unified Invocation SDK (com.bun.miitmdid):
  Developer: China Academy of Information and Communications Technology Scope of information collected: mainly to obtain OAID. Purpose: the Mobile Intelligent Terminal Supplementary Device Identifier System and SDK strictly comply with the Cybersecurity Law of the People's Republic of China, the Data Security Law of the People's Republic of China, the Provisions on Protecting the Personal Information of Telecommunications and Internet Users, and other relevant laws and regulations, as well as national standard requirements such as Information Security Technology - Personal Information Security Specification. The SDK will not actively collect any data. It only obtains the following data when invoked by the APP for local judgment and will not conduct any network transmission:
      · Device manufacturer, device model, and device brand, used to determine the terminal invocation interface
      · Device network operator name, used to determine the virtual machine environment
      · APP package name, used to verify the signature
  Privacy Policy: https://www.msa-alliance.cn/col.jsp?id=122
• DCloud SDK (io.dcloud.appstream): main purposes
      · Our products are developed based on DCloud uni-app (5+ App/Wap2App). During application operation, your device's unique identification code (IMEI/android ID/DEVICE_ID/IDFA, SIM card IMSI information, OAID) needs to be collected so that it can perform statistical analysis, improve performance and user experience through application startup data and abnormal error log analysis, and provide better services.
• iFlytek SDK (com.iflytek): main purposes
      Used for the voice dictation function, converting recorded voice into text, which can then be printed.
• Pangle Advertising SDK - Android (com.bytedance.sdk.openadsdk):
  Developer: Beijing Ocean Engine Network Technology Co., Ltd.
  Scope of information collected: device brand, model, software system version, screen density, screen resolution, and device language. Purpose: advertising enhancement, used for ad display functions, displaying ads, and collecting users' ad click data for ad performance statistics and optimization. Privacy Policy: https://www.csjplatform.com/privacy
• Huawei Ads SDK (com.huawei.hms.ads):
  Developer: Huawei Software Technologies Co., Ltd.
  Scope of information collected: device information, network information, location information, app information, app usage information, and contextual information
  Purpose: advertising enhancement, ad targeting for a single request, programmatic advertising, ad monitoring attribution, and anti-fraud. Privacy Policy: https://developer.huawei.com/consumer/cn/doc/HMSCore-Guides/whale-hong-kinetic-energy-sdk-privacy-statement-0000001658283582
• WeChat OpenSDK Android:
  Developer: Shenzhen Tencent Computer Systems Co., Ltd.
  Scope of information collected: obtaining account avatar and name information
  Purpose: used only for account login. Privacy Policy: https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8

3. Exceptions to prior consent:

• Where it is related to the personal information controller's performance of obligations prescribed by laws and regulations;
• Where it is directly related to national security or national defense security;
• Where it is directly related to public safety, public health, or major public interests;
• Where it is directly related to criminal investigation, prosecution, trial, or execution of judgments;
• Where it is for the purpose of protecting the life, property, or other major lawful rights and interests of the personal information subject or another individual, but it is difficult to obtain the individual's authorization and consent;
• Where the personal information involved has been disclosed to the public by the personal information subject;
• Where it is necessary for signing and performing a contract at the request of the personal information subject;
• Where personal information is collected from information lawfully and publicly disclosed, such as lawful news reports, government information disclosure, and other channels;
• Where it is necessary to maintain the safe and stable operation of the products or services provided, such as discovering and handling faults in products or services;
• Where the personal information controller is a news organization and the processing is necessary for its lawful news reporting.

4. Anonymization

For the information we collect from you, we will anonymize it in a timely manner through technical means. Provided that your personal information is not disclosed, we have the right to analyze, mine, and use anonymized user data, and to conduct statistical analysis of the use of FriendAI products and use it for possible third-party information sharing.

5. Data Transfer

FriendAI operates globally, and personal information may be transferred, stored, and processed outside the country or region where it was originally collected. Furthermore, the applicable laws in the countries and regions where we operate may differ from the laws applicable in your country of residence. Under the personal information protection framework, for the convenience of our operations, we may transfer, store, and process your personal information in jurisdictions outside your place of residence.

Regardless of where personal data is processed, we protect personal data in accordance with this Privacy Policy and take appropriate contractual or other measures to protect personal data in accordance with applicable law.

The European Commission has determined that certain countries/regions outside the European Economic Area (EEA), the United Kingdom, or Switzerland provide an adequate level of personal data protection. When personal data of EEA, Swiss, or UK users is transferred to recipients located in countries/regions outside the EEA, Switzerland, or the UK that have not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission's Standard Contractual Clauses. You may review the agreement based on the approved EU Standard Contractual Clauses pursuant to Article 46 of the GDPR. For more information, please see here.

If you would like to learn more about the safeguards we have put in place regarding data transfers, such as a copy of the Standard Contractual Clauses we have entered into with affiliated recipients to whom personal data may be transferred, you may contact us directly as described in this Privacy Policy.

6. Data Subject Rights

We respect your rights and control over your personal data. You may exercise any of the following rights. Please refer to how you can manage your information and delete your account.

III. How We Use Cookies and Similar Technologies

We or our third-party partners may collect and use your information through cookies and web beacons, and store such information as log information. We use our own cookies and web beacons to provide you with a better user experience and services, and for the following purposes:

1. Remembering your identity. For example, cookies and web beacons help us identify you as our registered user, or save preferences or other information you provide to us.
2. Analyzing your use of our services. For example, we may use cookies and web beacons to understand what activities you perform when using our services, or which services are most popular with you.

While using cookies and web beacons for the above purposes, we may provide non-personally identifiable information collected through cookies and web beacons to other partners after statistical processing, for the purpose of analyzing how users use our services.

Other partners may place cookies and web beacons on our products and services. These cookies and web beacons may collect non-personally identifiable information related to you to analyze how you use such products or services. The collection and use of such information by third-party cookies and web beacons are not governed by this Privacy Policy, but by the privacy policies of the relevant third parties. We are not responsible for such cookies and web beacons.

You can refuse or manage cookies through your browser settings.Howeverplease note that if you disable cookiesorweb beacons, youmaynot be able to enjoythe bestserviceexperience,and certainproducts or services may notfunctionproperly.

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

1. We will treat your information with a high duty of care. Unless we obtain your explicit consent, we will not share your personal information with any company, organization, or individual outside the Company, except where the information has been processed so that a specific individual cannot be identified and cannot be restored. Currently, we will ask for your authorization and consent to share personal information in the following circumstances:

• Sharing your device information with the Getui SDK of Zhejiang Merit Interactive Network Technology Co., Ltd. for sending messages, including operational campaigns and version updates;
• Sharing your crash environment, including crash information and thread stacks, ROM/RAM/SD card capacity, network/language status, app information such as package name, version, and process name, and device information such as IMEI and other device identifiers, with the Bugly SDK of Shenzhen Tencent Computer Systems Co., Ltd. for crash device statistics.
• Sharing your phone status, network status, and read/write external storage information with the Alipay SDK of Alipay (China) Network Technology Co., Ltd. for processing and caching your payment orders and payment status;
• Sharing your phone status, network status, and read/write external storage information with the WeChat Pay SDK of Shenzhen Tencent Computer Systems Co., Ltd. for processing and caching your payment orders and payment status.
• Sharing your uploaded content, including avatar and wrong-question data, with the Alibaba Cloud SDK of Alibaba Cloud Computing Co., Ltd. for storing your content.
• Our products are developed based on DCloud uni-app (5+ App/Wap2App), and will send the phone International Mobile Equipment Identity code IMEI, commonly known as the phone serial number, to the SDK of Digital Paradise (Beijing) Network Technology Co., Ltd., so that it can perform statistical analysis, improve performance and experience through application startup data and abnormal error log analysis, and provide better services.
• Message push service provider: push technology services are provided by Zhejiang Merit Interactive Co., Ltd. We may provide your device platform, device manufacturer, device brand, device identifier, and other device information, software installation list, network information, and location-related information to Zhejiang Merit Interactive Co., Ltd. for providing message push technology services to you. When we push messages to you, we may authorize Zhejiang Merit Interactive Co., Ltd. to perform link adjustment and mutually activate closed SDK push processes, so as to ensure that you can receive messages we push to you in a timely manner. For details, please visit the Getui User Privacy Policy (the Getui User Privacy Policy should be hyperlinked to: http://docs.getui.com/privacy).

We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes. For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements with them and require them to process information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures.

2. We will not illegally sell or illegally provide your information to others. We will not provide such information to any third party, nor use it for any other purpose, except in the following circumstances:

• Disclosure to a third party with your prior consent;
• Disclosure to a third party or administrative or judicial authority in accordance with relevant laws or the requirements of administrative or judicial authorities;
• When providing services, we may use your information for identity verification, customer service, security prevention, fraud monitoring, archiving, and backup, in order to prevent, discover, and investigate fraud, security risks, illegal acts, or violations of our agreements, policies, or rules; to protect the lawful rights and interests of you, other users, our affiliates, partners, and other trusted third-party suppliers, service providers, agents, and the public; and to ensure the security of the products and services we provide to you;
• Where we cooperate with third parties to provide services related to the FriendAI platform or other network services to you, and such third parties agree to bear the same responsibility as us for protecting user privacy;
• Other disclosures required by laws, regulations, or policies.

3. We will publicly disclose your personal information only under the following circumstances:

• After obtaining your explicit consent;
• Disclosure based on law: we may publicly disclose your personal information where required by law, legal procedures, litigation, or mandatory requirements of government authorities.

4. Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information:

• Where it is related to the personal information controller's performance of obligations prescribed by laws and regulations;
• Where it is directly related to national security or national defense security;
• Where it is directly related to public safety, public health, or major public interests;
• Where it is directly related to criminal investigation, prosecution, trial, or execution of judgments;
• Where it is for the purpose of protecting the life, property, or other major lawful rights and interests of the personal information subject or another individual, but it is difficult to obtain the individual's authorization and consent;
• Where the personal information subject has disclosed the personal information to the public by themselves;
• Where personal information is collected from information lawfully and publicly disclosed, such as lawful news reports, government information disclosure, and other channels.

5. According to law, sharing, transferring, or disclosing personal information that has been de-identified, while ensuring that the data recipient cannot restore and re-identify the information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data do not require your separate consent.

V. How You Manage Your Information andAccount Cancellation

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we protect your exercise of the following rights over your personal information:

1. Right to query

You have the right to query your personal information, except in circumstances provided by laws and regulations.

2. Right to correction

When you find that the personal information we process about you is incorrect, you may modify the information through the query path.

3. Right to deletion

In the following circumstances, you may request that we delete your personal information:

• If our processing of personal information violates laws or regulations;
• If we collect or use your personal information without obtaining your consent;
• If our processing of personal information violates our agreement with you;
• If you no longer use our products or services, or you cancel your account;
• If we no longer provide products or services to you.

4. Right to withdraw

• For information that you actively provide, you may withdraw your personal information in your personal account through "FriendAI-My-Avatar-Personal Information" and "FriendAI-My-Settings-Change Phone Number/Change Password";
• For information you have authorized us to access, you may withdraw it through "Phone-Settings-Privacy-Permission Management".Please note that paths may vary across different devices. Please refer to the instructions and guidance of your device and system developer.

5. Right to cancel account

If you decide to stop using FriendAI, you may cancel your account. Account cancellation can be completed through "FriendAI-My-Settings-Cancel Account".After account cancellation, the data in this accountcannotbe restored. After account cancellation, all rewards, levels, and related content in the account will be cleared and cannot be recovered afterward;except as otherwise provided by laws and regulations, your personal information will be deleted or anonymized. We recommend that you make backups.Thiscancellationoperationcannot be revoked,so pleaseapply with caution.

6. In the following circumstances, in accordance with laws and regulations, we will be unable to respond to your above requests:

• Where it is related to the personal information controller's performance of obligations prescribed by laws and regulations;
• Where it is directly related to national security or national defense security;
• Where it is directly related to public safety, public health, or major public interests;
• Where it is directly related to criminal investigation, prosecution, trial, or execution of judgments;
• Where the personal information controller has sufficient evidence showing that the personal information subject has subjective malice or abuses rights;
• Where it is for the purpose of protecting the life, property, or other major lawful rights and interests of the personal information subject or another individual, but it is difficult to obtain the individual's authorization and consent;
• Where responding to the personal information subject's request will cause serious harm to the lawful rights and interests of the personal information subject or other individuals or organizations;
• Where trade secrets are involved.

VI. How WeStore YourPersonalInformation

Personal information collected and generated during our operations within the territory of the People's Republic of China is, in principle, stored within China, and we store your personal information in accordance with the storage periods prescribed by laws, regulations, departmental rules, and other provisions of the People's Republic of China.

VII.How WeProtect YourPersonalInformation

1. We attach great importance to the security of your personal information. We strive to adopt various reasonable physical, electronic, and administrative security measures to protect your personal information, and use our greatest reasonable efforts to prevent your personal information from being leaked, damaged, or lost, including but not limited to SSL, encrypted information storage, and data center access control. We also strictly manage employees or outsourced personnel who may have access to your personal information, including but not limited to adopting information access permission controls, signing confidentiality agreements with personnel who access personal information, and monitoring the operations of such personnel.
2. Notwithstanding the agreement in paragraph 1 above, please understand that due to various unforeseeable malicious methods or methods that cannot be defended against by existing technology, even if we have made every effort to adopt necessary protective measures, your information may still be leaked, damaged, or lost. If you discover that your account or password has been or may be leaked for any reason, you should contact us immediately so that we can take timely measures to prevent or reduce related losses to you.
3. If we undergo a corporate merger, division, or similar event, your information will continue to be protected by the surviving business entity at that time, and we will notify you by announcement, SMS, or other written means. If our products or services cease operation, we will promptly stop continuing to collect your information and notify you by announcement, SMS, or other means. At that time, we will delete or anonymize your information.

VIII. Protection of Minors

We value the protection of minors' personal information. If you are a minorunder the age of 18,please, underthe guidance ofyour guardian,carefully read this Privacy Policy, and use our services and submityourpersonal information only after obtaining your guardian's consent. Ifyour guardian does not agree with thisPrivacyPolicy,youshould immediatelystopusing FriendAI services and refuse to provide personal information.

If you are a minor under the age of 14, please notify your guardian to read and accept our FriendAI Children's User Privacy Policy together with youand seek your guardian's consent and guidance before you use FriendAI services or submit personal information.

Forchildren'spersonal information collected with guardian consent, wewill onlyuseordisclose such information within the scope permitted bylaws and regulations,with explicit guardian consent, or for protectingchildusers.Forpersonalinformation provided bychildusers without guardian consent,after receivingnotification fromtheirguardian,wewilldeletethe relevantinformation as soon as possible.

IX.Revisions to This Policy

We may revise this Privacy Policy from time to time. The revised Privacy Policy will be announced on the FriendAI platform or notified to you by other appropriate means before the revision becomes effective. Under such circumstances, if you continue to use our services, you are deemed to have agreed to be bound by the revised Privacy Policy.

X.Dispute Jurisdiction

1. The execution, effectiveness, performance, and dispute resolution of this Privacy Policy shall be governed by the laws of the People's Republic of China.
2. Disputes relating to this agreement shall be resolved through friendly consultation. If consultation fails, the dispute shall be submitted to a court with jurisdiction at the location of the Company for litigation.

XI. Account Cancellation Process

Users are allowed to cancel their accounts within the APP. The cancellation process is as follows:

    Tap "My" in the APP, enter "System Settings", and tap "Cancel Account" to complete the cancellation process.

XII. Contact Us

If you have any questions, complaints, or reports, you may contact us through the following method.

Email: weizhengsl@vip.qq.com

Publication Date: May 23, 2019

Effective Date: May 23, 2019