TartTalk Privacy Policy

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TartTalk Privacy Policy

Last updated: September 23, 2026 · Effective date: September 23, 2026

Product name:​ “TartTalk” and “挞嗒” are both official product names. References to either name mean the same product.

Welcome to TartTalk. TartTalk is developed and operated by Shanghai Cain's Words Network Technology Co., Ltd. (上海该隐之言网络科技有限责任公司)​ and/or its affiliates (“we,” “us,” or “this Product”; see the User Agreement for entity details). We understand how important personal information is to you, and your trust matters to us. We protect your personal information and privacy in accordance with applicable laws and industry best practices. Please read and understand this Privacy Policy carefully before using TartTalk and related services so you can make informed choices.

This Privacy Policy has eleven chapters:

We collect and use information under this Privacy Policy, but we will not bundle and collect personal information solely because you agree to it. Please ensure that personal information you provide, and information you authorize us to collect, process, use, and store within the scope of this Policy, does not infringe others’ lawful rights.

When you use or enable a feature or service, we collect and use related information as needed to deliver that feature or service. Except for information that is necessary for a business function or required by law, you may refuse to provide it without affecting other features or services. We describe each category of information we collect in this Policy.

Camera, microphone, storage (photo library), and location permissions are not enabled by default. We use them only after your express authorization for specific features or services, and you may withdraw authorization. Even after authorization, we will not collect related information when those features or services are not needed. See the *App Permission Request and Usage Statement* for details.

The sections below explain how we collect, use, store, share (where applicable), and protect personal information, and how you can manage it. This Policy is closely related to your use of our services. We recommend that you read it in full. Important terms affecting your personal information rights are in bold.

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I. How we collect and use your personal information

We collect information you provide when using the services, and information generated through automated means while you use features or receive services, as follows:

1.1 Registration and sign-in

a. To register and sign in to TartTalk and related services, you create an account with a mobile phone number. The phone number is necessary to meet applicable real-name requirements. Without it, we cannot provide full service functionality.

b. The current version supports phone-number registration and sign-in only. If third-party account sign-in is enabled later, we will update this Policy and in-app notices before launch and, with your consent, may obtain public information from that platform (avatar, nickname, and other information you authorize) to bind to your TartTalk account.

c. Invite codes: During closed beta or certain campaigns, an invite code may be required before registration. We process the invite code you enter and the validation result to determine registration eligibility, establish the invitation relationship, and grant related benefits. So that you can resume an interrupted sign-up, the invite code may be temporarily stored on your device (see Section II of this Policy).

1.2 Completing your profile

When you first complete your profile, we collect your display name (you may use a nickname) and gender to create and display your account profile and to provide a more relevant experience. You may also choose to provide an avatar, date of birth, region, bio, custom ID, interest tags, and similar information. Except for information expressly marked as required, not providing optional information does not prevent basic use, but may limit personalization. These profile details are stored in association with your TartTalk user ID.

Note:​ In Apple App Store privacy labels, “Name” refers to the display name / nickname you set in the app, not your legal name or ID-card name. The current version does not require a legal name for ordinary registration. If real-name verification is required by law, we will notify you separately in that scenario and obtain consent where required.

1.3 Real-person instant messaging and social features

a. Messaging: You may chat one-to-one or in groups and send text, images, voice, video, files, location, and other messages. To deliver messages, maintain history, and display them, message content, sender and recipient identifiers, and attachments are transmitted and stored through OpenIM.

Note:​ In Apple App Store privacy labels, “Email or Text Messages” refers to in-app instant messages, used to provide messaging features. We do not read your device email inbox or carrier SMS inbox.

b. Friends and groups: We store your friend list, friend relationships, group membership, and group information. This information forms your social graph within TartTalk. The current version does not read or upload your device's system address book.

c. Moments: You may post Moments (friends-only / public plaza), browse, and interact through likes, comments, follows, and shares. We collect the text, images, or videos you post and related browsing and interaction records to provide social features and personalized recommendations.

d. Location messages and place tags: Only when you actively share a location in chat or add a place to a Moment do we, after system authorization, obtain precise coordinates, reverse-geocoding results, or coarse place information such as city or district. Location you choose to send or publish is stored in association with the relevant account, message, or Moment to provide location-related features. For content you publish with location, we may also use related interaction and usage signals for necessary analytics and to improve distribution and personalization. Coarse location is mainly used to display city/region place information. You may deny or withdraw location permission; doing so only affects location-related features.

1.4 AI character chat and interactive features

a. Using generative AI model technology, we provide AI chat and interaction (including chatting with system or user-created AI characters, character settings, and AI interactive games). To deliver these services, we may collect information you actively input (text, voice, or images) and edit or command data for analysis and computation so we can better understand your instructions and context and return more relevant content.

b. We record conversation history between you and AI characters (your inputs and AI replies) to support continuous interaction. You may clear conversation history in character settings.

c. Model improvement: Where permitted by law and relevant standards, after secure encryption, strict de-identification, and where re-identification of a specific individual is not possible, we may analyze and use such data—including to improve understanding of your inputs and the speed and quality of recognition and responses. If you do not want your inputs used for model training or optimization, contact us via Me → Feedback in the app or the channels in this Policy.

d. Game content: When you use interactive games, we collect player profiles, opening preferences, inputs, choices, session events, and saves you submit to run the game, save progress, and restore your experience. Some game content is produced by creators using platform tools and loaded as remote content; such content runs in a platform-controlled environment.

e. Creator Center: If you use creation tools to create and publish AI characters, interactive games, or other works, we collect the character settings, storylines, assets, and publishing configuration you submit for content generation, review, display, and operations management. Works you publish are registered on the platform as platform creation assets; see Article VIII of the Terms of Service and the Account Deletion Agreement for how they are handled.

f. Search records: When you search for users, AI characters, Moments, messages, or other in-app content, we process search terms and search interactions to return results, operate search, and improve personalized recommendations. We do not use this to collect browsing history from other apps or websites.

1.5 Voice messages, voice calls, and speech-to-text

a. Voice messages: When you actively record and send a voice message, the app accesses the microphone and the recording file is uploaded to our object storage and retained with the message record so recipients can play it and you can view message history. This is essential to message delivery.

b. Voice calls (not available in the current version)​: In-app voice calling has been discontinued in the current version; the entry point is no longer shown and the related SDK and native libraries are not distributed with the app, so no call audio or call connection records are collected, transmitted, or retained.

c. Speech-to-text (not available in the current version)​: Speech-to-text has been discontinued in the current version; the on-device recognition model is no longer bundled and the entry point is no longer shown. We do not request or use the iOS or Android system speech-recognition service, and we do not call any third-party cloud speech-recognition service.

d. We do not turn on the microphone in the background unless you are actively recording.

e. The current version does not provide system-level calling (VoIP / CallKit) and does not read or upload your phone call logs. If that capability is integrated later, we will update this Policy and system permission prompts before enabling it and obtain consent where required by law.

1.6 Feedback and customer support

a. To contact you, resolve issues promptly, or retain handling records, we may keep communications and related content (account information, feedback, materials you provide to establish facts, or contact details you leave). These customer-support materials are necessary to handle inquiries, complaints, and disputes.

b. When you complain about others or are complained against, to protect lawful rights we may provide your account/identity information, contact details, and complaint-related content to consumer-protection or regulatory authorities (except where law expressly prohibits disclosure).

1.7 Membership, points, and auto-renewing purchases

a. When you purchase membership, points packs, cosmetics (themes, bubbles, etc.), or other digital goods, we process product identifiers, order information, transaction identifiers, purchase credentials, restore-purchase data, and membership or points entitlement status to fulfill orders, restore purchases, provide support, handle disputes, and conduct necessary business and usage analytics.

b. Payment information: On iOS, payment is completed by Apple StoreKit / the App Store; we do not collect or store payment-card or bank-account numbers. On Android, payment is handled by Alipay (the currently available channel); we receive only the order number, payment status, and similar result information needed to verify fulfillment. WeChat Pay is not available in the current version. If it is enabled later, we will update this Policy and the Third-Party Information Sharing List before doing so.

c. Auto-renewal (continuous monthly subscription)​: If you choose an auto-renewing membership product (such as an auto-renewing monthly plan), we process your subscription identifier, subscription status, auto-renewal switch state, current subscription period start and end dates, renewal charge records, and refund status. The following rules apply:

d. Virtual goods are generally non-refundable: Except where mandatory law provides otherwise or the item itself cannot be used normally, membership, points, cosmetics, and other virtual goods do not support no-reason refunds, cash-out, or transfer to another account. Such entitlements are forfeited upon account deletion (see the Account Deletion Agreement).

1.8 Notices

You understand and agree that we may send notices—such as system alerts or experience surveys—using contact details you provide (e.g., phone number). You may unsubscribe via in-app settings, SMS unsubscribe instructions, or by contacting us.

1.9 Operations, analytics, and security

a. To keep services running and protect you, other users, or the public, we collect information necessary for authentication, fraud prevention, security controls, troubleshooting, and stable operation.

b. Device and network information: We collect device brand and model, OS version, app version, device identifiers (IDFV “identifier for vendor” on iOS; on Android, the device build fingerprint, falling back to the system build identifier Build.ID where unavailable), network access method, type, and status. Device identifiers support sign-in security, invitation validation, and operational analytics; they are not used to track you across apps or websites. User ID and device ID may be used for app functionality, product personalization, and analytics. Push delivery uses an installation identifier and a push token (currently iOS only).

We do not collect IMEI / MEID, OAID, MAC address, IDFA (advertising identifier), SIM or carrier information, contacts, calendar, or SMS inbox content. The app does not request the system permissions required to read such information and has no technical ability to collect it.

c. Product interaction and analytics data: We collect page views, button taps, content impressions, searches, browsing, posts, follows, likes, comments, shares, membership feature use, game interactions, session identifiers, membership status, and necessary related dimensions to provide features, evaluate feature effectiveness, measure usage, and improve personalized experiences.

d. Crash and other diagnostic data: When an exception or API failure occurs, we may collect the exception type or error message, API path and method, status code, device model, OS version, and app version to troubleshoot and improve stability. The current version does not collect or upload separate performance-monitoring metrics such as launch time, frame rate, memory use, or energy use. If performance monitoring is enabled later, we will update this Policy and our App Store privacy disclosures before collection begins.

1.10 Sharing and copy

When you actively tap “Copy,” we write the content you chose to copy (such as a user ID, group ID, chat text, or invitation message) to your device clipboard so you can paste it elsewhere. We only write to the clipboard; we do not read, monitor, or upload your clipboard contents, and we do not scan the clipboard when unrelated to such a feature. Copied content is managed by your device’s operating system until you paste it or the system clears it.

When you actively share or open a shared link, we process the title, description, thumbnail, and link you chose to share in order to invoke the sharing target (such as WeChat) and complete the share.

1.11 App Store privacy disclosure

To help you understand our Apple App Store privacy disclosures and keep them aligned with our current App Store Connect “App Privacy” answers, the current iOS version may collect the following categories:

To safeguard service security and conduct statistical analysis, we will collect your IP address while you use the App and resolve it to the province/city level for internal distribution statistics and risk control. This information is used solely for internal operational and security purposes; it will not be displayed publicly, nor used for advertising or cross-app tracking.

Except for data irreversibly de-identified before collection, these categories are generally linked to you through your account, user ID, device ID, messages, orders, or sessions. The current version does not use names, phone numbers, location, user content, identifiers, purchase records, usage data, or diagnostics to track you across other companies' apps, websites, or offline properties; does not sell data to data brokers; and does not use these categories for third-party advertising. If we later introduce advertising, attribution, or another feature that changes these purposes, we will obtain any authorization required by law and update this Policy, our App Store privacy labels, and relevant system permission notices before enabling it.

The current version does not specifically collect health or fitness data, credit information, residential or mailing addresses, the system address book, external email or carrier-SMS inbox content, call logs, clipboard contents, cross-site browsing history, advertising data, environment scans, or hand or head data. We use the clipboard only to write content you actively copy; we do not read it. If users voluntarily include such information in free-form inputs, we process it as user content; please do not provide sensitive personal information in public content or where it is unnecessary.

1.12 Exceptions to consent

Under applicable laws and standards, we may collect and use personal information without prior consent in the following cases:

a. Related to fulfilling legal obligations;

b. Directly related to national security or defense;

c. Directly related to public security, public health, or major public interests;

d. Directly related to criminal investigation, prosecution, trial, or enforcement of judgments;

e. Necessary to protect your or others’ life, property, or other major lawful rights where consent is difficult to obtain;

f. Personal information you have made public yourself;

g. Necessary to conclude or perform a contract at the request of the data subject;

h. Personal information collected from lawful public disclosures (e.g., lawful news reports, government information disclosure);

i. Necessary to maintain secure, stable operation of software and related services (e.g., detecting and handling faults);

j. Necessary for lawful news reporting;

k. Necessary for statistics or academic research by academic institutions in the public interest, where results are de-identified when provided externally;

l. Other circumstances provided by law.

Please note: information that cannot identify you alone or combined with other information is not personal information in the legal sense. When information can identify you, or when we combine non-identifying data with your personal information, we treat and protect the combined data as personal information under this Policy during such use.

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II. How we store information on your device

TartTalk is a mobile application. We do not use browser cookies or similar network-tracking technologies, and we do not set identifiers for the purpose of tracking you across apps or websites. To keep you signed in, remember your preferences, and speed up loading, the app stores necessary information locally on your device (together, “on-device storage”).

2.1 What we store on your device and why

| Category | Content | Storage method | Purpose |
|---|---|---|---|
| Sign-in credentials | Access token, refresh token, IM session token, user ID | System secure storage (see 2.2) | Keep you signed in, avoid repeated sign-in, authenticate the messaging channel |
| Preferences | Language, theme and skins, notification settings, privacy settings, AI chat history toggle | Local key-value store inside the app sandbox | Remember your settings so they persist between sessions |
| Transactional flow data | Sign-up progress, invite code pending validation, pending push registration cleanup data | System secure storage | Keep sign-up and account flows continuous and secure |
| Cache | Image and media cache, conversation list and message summary cache, game asset cache | App sandbox directories | Speed up loading and reduce data usage |

The data above is stored only on your device. Through on-device storage we do not read other apps’ data, your personal files, or your photo library; reading your photo library requires your separate authorization (see the *TartTalk App Permission Usage Guide*).

2.2 Protecting sensitive information

Sensitive information such as sign-in credentials is encrypted using operating-system secure storage: on Android we use EncryptedSharedPreferences (keys protected by the system Keystore); on iOS we use the Keychain with accessibility set to “first unlock, this device only.” We do not store tokens or keys in plain text in ordinary configuration files.

2.3 Viewing and clearing on-device data

Please note that after clearing on-device data you may need to sign in again, and cached content will need to be downloaded again.

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III. How we share, transfer, or publicly disclose your personal information

3.1 Sharing

3.1.1 Principles

a. Lawfulness: Data use with partners must have a lawful purpose and legal basis.

b. Legitimacy and minimum necessity: Use must have a legitimate purpose and be limited to what is necessary.

c. Security and diligence: We carefully assess partners’ purposes and security capabilities and require them to follow contractual terms.

See the *Third-Party Information Sharing List* for details.

3.1.2 Entrusted processing

For entrusted processing, we sign agreements required by law and supervise use of personal information. Main processor types include:

3.1.3 Joint processing

For joint processing, we sign agreements allocating rights and duties so processing complies with law and protects data security.

3.1.4 Sharing without consent where law allows

Under applicable laws and standards, we may provide personal information to partners without your consent when:

a. Necessary to conclude or perform a contract to which you are a party;

b. Necessary to perform statutory duties or obligations;

c. Directly related to national security or defense;

d. Directly related to criminal investigation, prosecution, trial, or enforcement;

e. Necessary to respond to a public-health emergency or to protect life, health, or property in an emergency;

f. Processing, within a reasonable scope, for public-interest news reporting or public opinion oversight;

g. Processing personal information you made public or that is otherwise lawfully public, as permitted by law;

h. Other circumstances provided by laws or administrative regulations.

We do not sell your personal information to any third party.

3.2 Transfer

As our business develops, we may merge, acquire, or transfer assets, which may include transfer of your personal information. In such cases, we will require the successor to continue fulfilling processor obligations at a security standard no lower than this Policy. If the successor changes purposes or methods of processing, we will require them to obtain your authorization again.

3.3 Public disclosure

a. We do not publicly disclose your personal information unless required by law or with your consent. When we disclose, we use industry-standard safeguards.

b. When announcing penalties for violating accounts or fraud, we may disclose related account information.

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IV. How we store and protect personal information

4.1 Storage location

In accordance with law, personal information collected and generated in our domestic operations is stored in the People’s Republic of China. We do not currently transfer such information abroad. If we do, we will strictly comply with PRC law and regulatory policy and obtain required approvals or your consent.

4.2 Retention period

We retain personal information only as long as necessary to provide TartTalk services. For example:

After account deletion, active deletion of personal information, or expiry of the necessary period, we delete or anonymize personal information, except where:

4.3 Security measures

a. We take reasonable technical and organizational measures to protect personal information against improper use and unauthorized access, disclosure, use, alteration, damage, loss, or leakage.

b. We use encryption, anonymization, and other reasonably practicable means no less protective than industry peers, and security mechanisms against malicious attacks.

c. We maintain security management systems and data-security processes, strict access controls (authorized personnel only), and periodic security audits.

d. Despite reasonable measures and legal standards, internet security cannot be guaranteed 100% against every technical limit or malicious means. We will do our best to keep the personal information you provide secure.

e. We maintain incident-response plans. If a user-information security incident occurs, we will activate the plan promptly to contain impact. Where required by law, we will inform you of the basic facts and possible impact, measures taken or to be taken, steps you can take to mitigate risk, and remedies available. We will notify via push, email, letter, SMS, or similar means; where individual notice is difficult, we will publish an effective announcement.

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V. How you manage your personal information

We support your rights to access, copy, correct, supplement, delete, withdraw consent, delete your account, complain, and set privacy preferences.

5.1 Access, copy, correct, supplement, or delete

a. In Me, you may view and edit username, avatar, nickname, gender, region, bio, and similar profile fields.

b. In Settings → Account & Security, you may view account-related information (such as your phone number); in Settings → Storage & Cache, you may view and clear on-device cache; in Me → About, you may view app information such as the app version.

c. In Me, you may access, edit, or delete Moments you posted and AI characters you created.

d. In chat screens, you may browse history and delete selected chat records.

5.2 Changing or withdrawing authorization

You may enable or disable camera, microphone, storage (photo library), location, and similar permissions in the OS or TartTalk privacy settings to change or withdraw consent. After withdrawal, we will stop collecting information related to that permission. Some features require certain information; after withdrawal we cannot continue those features or process the corresponding personal information. Withdrawal does not affect processing based on prior authorization.

5.3 Your personal information rights

To exercise rights under applicable law, contact us via the channels in this Policy. After verifying your identity, we will reply within fifteen (15) business days.

5.4 Account deletion

You may request account deletion via Settings → Account & Security → Delete account. The process works as follows:

a. 7-day cooling-off period: After you submit a deletion request, the account enters a 7-day cooling-off period. During this period the account is restricted but you can still sign in, and you may withdraw the request before the period ends. If you do not withdraw, the account enters an irreversible deletion process.

b. Pre-checks: We verify your identity, security status, and device information. If you are still the owner of any group, you must first transfer ownership or disband that group. If you have an active Apple auto-renewing subscription, the system will ask you to cancel auto-renewal first; otherwise Apple may continue charging after deletion.

c. Processing time: We process promptly and reply within 15 business days or any shorter period required by law.

d. Deletion is irreversible. After deletion we delete or anonymize related information, except where law requires otherwise. See the TartTalk Account Deletion Agreement for virtual entitlements, created content, and refunds.

5.5 Feedback and complaints

Contact us via Me → Feedback or the channels in this Policy. After identity verification, we will reply within 15 business days.

5.6 Cessation of operations

If we stop operating, we will stop collecting personal information, notify you individually or by announcement, and delete or anonymize personal information we hold.

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VI. How we protect minors

6.1 General terms for minors

a. We take protection of minors’ personal information seriously. TartTalk is primarily for adults. If you are under 18, read and agree to this Policy with a parent or other guardian before using the Product and related services.

b. Persons under 14 may not use this app. We do not knowingly collect their personal information. If we learn we have collected personal information of a person under 14 without verifiable guardian consent, we will delete it as soon as practicable.

c. Minors aged 14 to under 18 should use the app with guardian consent and assistance. Guardians may exercise the rights in Section V on their behalf.

d. If you are a guardian and have questions about a minor’s personal information, contact us via the channels in this Policy.

6.2 Minor Mode

To protect minors, we may ask you to confirm age when registering or using TartTalk. You or your guardian may turn on Minor Mode at any time via Me → Minor Mode and set a 4-digit numeric passcode; several consecutive incorrect attempts temporarily lock the passcode, during which no action can be taken—please retry later. While Minor Mode is on, we surface content better suited to minors and top-ups, membership purchases, and other paid actions are unavailable, with some features disabled or restricted. See the *TartTalk Rules on Personal Information Protection for Minors* for details.

Note:​ Minor Mode is turned on by the user or guardian themselves (self-declared mechanism). If you are a guardian and find that a minor is using the product without Minor Mode enabled, please help them enable it or stop using the product, and contact us via the channels in this Policy.

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VII. Personalized recommendations

To show and recommend more relevant information and services, we may collect and use personal information and use algorithmic models to infer preferences and match content or services you may find interesting.

7.1 Scope

Personalized recommendations may include, without limitation, AI characters, interactive content, and search results.

7.2 Data used

We may use device information; behavior while using TartTalk (search, clicks, posts, follows, likes, browsing, etc.); and profile details you provide (nickname, avatar, gender, content preferences, etc.).

7.3 Training and intervention

We may use the above data for real-time training and feedback to improve recommendations. If you do not want your data used for model training or optimization, contact us via in-app feedback or the channels in this Policy.

7.4 Turning off personalized recommendations

If you prefer not to receive personalized recommendations, contact us via the channels in this Policy or in-app via Me → Feedback. After verifying your identity, we will stop showing personalized recommendations to you; you can still browse non-personalized content.

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VIII. Changes and notices

a. To improve services, TartTalk and related offerings may change from time to time. We may revise this Privacy Policy; revisions form part of this Policy and have the same effect. Without your express consent, we will not reduce rights you enjoy under the then-effective Policy.

b. After updates, we will publish the new version in TartTalk and, before the updated terms take effect, remind you via website announcement or other appropriate means so you can review the latest Policy.

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IX. How to contact us

If you have questions, comments, or suggestions about this Privacy Policy or your personal information, contact us through:

  1. Operating entity / company name: Shanghai Cain's Words Network Technology Co., Ltd. (上海该隐之言网络科技有限责任公司) and/or its affiliates
  2. Email: service@tartalk.cn
  3. Official website: https://tartalk.cn (ICP filing: 沪ICP备2026042021号)
  4. In-app: Me → Feedback

After verifying the relevant facts, we will generally reply within 15 business days. To protect your personal information, we may ask you to submit a written request or otherwise verify your identity.

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X. Special notes on AI-generated content

This Product uses generative AI model technology. Under applicable rules (including the PRC Interim Measures for the Administration of Generative Artificial Intelligence Services and rules on deep synthesis), we specially note:

a. AI-generated content is produced automatically by algorithms and may be inaccurate, fabricated, or biased. It is for entertainment or reference only and does not constitute professional advice (medical, legal, financial, or otherwise).

b. We label AI-generated content. Methods include, without limitation: continuously displaying “Content generated by AI” in AI interaction UIs; marking AI-generated images/videos with “AI-generated” in a corner.

c. You must not use deep-learning or similar technologies to create, publish, or spread false information. When publishing or disseminating AI-generated information, label or disclose it conspicuously.

d. For generative AI services used in this Product, we will fulfill labeling, safety, and disclosure obligations under applicable PRC rules. Algorithm filings and public disclosures follow the latest information published by competent authorities and by us; see also the in-app *Basic Feature Description*.

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Value-added telecom licenses, algorithm filings, and similar matters that must be obtained or disclosed by law are governed by the competent authority’s registration/publication results and by our public announcements. The ICP filing number for related TartTalk websites is 沪ICP备2026042021号.

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XI. Special notes for users in Hong Kong, Macao, and Taiwan of China

When providing services to users in the Hong Kong SAR, Macao SAR, and Taiwan region of China (collectively, the "HKMOT Regions"), the following special notes apply in addition to this Privacy Policy:

a. Governing law: For users in the HKMOT Regions, the protection of personal information is also governed by local personal data protection laws, including the Personal Data (Privacy) Ordinance of Hong Kong, China, the Personal Data Protection Act of Macao, China, and the Personal Data Protection Act of the Taiwan region of China. Where this Privacy Policy conflicts with local law, the stricter local requirement prevails.

b. Access and correction: Users in these regions have the right to access, correct, and obtain a copy of their personal data in accordance with law. If your personal data is inaccurate or has changed, you may submit a request via the channels in "IX. How to contact us."

c. Direct marketing (Hong Kong, China)​: If we intend to use your personal data for direct marketing, we will obtain your consent in advance. You may, at any time and free of charge, require us to stop using your personal data for direct marketing.

d. Cross-border transfer: Your personal information is stored within the territory of the People's Republic of China. When users in the HKMOT Regions use this Product, related personal information is transferred to the mainland for storage and processing, and we will take appropriate security measures as required by law; where local law provides otherwise, such law prevails.

e. Complaint channels: If you have any complaint about our handling of personal information, you may first contact us via the channels in "IX. How to contact us"; you also have the right to file a complaint with the local personal data protection authority in accordance with law.