Xuntu Zhilian Privacy Policy

Xuntu Zhilian (hereinafter referred to as "the APP") respects and protects the personal privacy of all users of the APP services. Except as otherwise provided in this Privacy Policy, we will not disclose such information to the public or provide it to third parties without your prior consent. We will update this Privacy Policy in a timely manner when necessary. By agreeing to the APP's Network Service Usage Agreement, you are deemed to have agreed to all the contents of this Privacy Policy. This Privacy Policy is an inseparable part of the APP's Network Service Usage Agreement. Before using the APP, please carefully read the Xuntu Zhilian Privacy Policy.

I. Circumstances Where You Must Authorize Us to Collect and Use Your Personal Information

Personal information refers to various types of information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information.

Xuntu Zhilian is a smart hardware control tool product. In order to provide you with the basic and additional functions of our products and services, you may choose to authorize us to collect, store, and use the following information related to you. If you refuse to provide such information, you will be unable to normally use the relevant additional functions or achieve the intended functional effects, but this will not affect your normal use of our basic functions. Such information mainly includes:

(1) During the use of our application products, we need to access the software installation list information of your mobile device. The APP needs to access the software installation list information of your mobile device to facilitate scene linkage with installed games or applications when you customize the RGB lighting effects of the cooler (for example, automatically switching lighting modes when launching a certain game), thereby simplifying the operation process. (2) In the background state, the application obtains your device's MAC address, unique device identifier (IMEI) information, manufacturer information, and device model information. As a Bluetooth smart device accessory tool APP, we will continue to interact with matched cooler devices for necessary information and status updates in the background state (such as temperature reporting and battery monitoring). This process involves mobile phone compatibility adaptation issues. We will record mobile devices where the APP exhibits abnormal behavior and subsequently improve compatibility.

II. How We Use Your Personal Information

1. To Provide Services to You

(1) For archiving and backup purposes when providing our services, to ensure the security of the products and services we provide to you; (2) Through information data analysis, to help us design new services and improve our existing services; (3) To enable us to better understand how you use our services, so as to specifically meet your personalized needs, such as lighting effect settings, temperature alert thresholds, personalized help services, and instructions; (4) Software certification or management of software upgrades (such as cooler firmware OTA updates); (5) To invite you to participate in surveys regarding our products and services; (6) Other circumstances where you have authorized and consented to the provision of personal information.

2. After collecting your personal information, we will de-identify the data through technical means, and the de-identified information will no longer be able to identify the data subject. Please understand and agree that in such cases we have the right to use the de-identified information; and to the extent permitted by relevant laws and regulations, we have the right to conduct holistic analysis and utilization of user data, including your personal information.

3. When we intend to use information for purposes not specified in this Policy, we will seek your consent in advance.

4. You are fully aware that we may use personal information without your authorized consent in the following circumstances:

(1) Related to national security or national defense; (2) Related to public safety, public health, or major public interests; (3) Related to criminal investigation, prosecution, trial, and execution of judgments; (4) To protect the life, property, or other significant legitimate rights and interests of the personal information subject or other individuals where it is difficult to obtain their consent; (5) Where the personal information collected has been voluntarily disclosed to the public by the personal information subject; (6) Where your personal information is collected from legally and publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels; (7) Necessary for entering into a contract at your request; (8) Necessary for maintaining the safe and stable operation of the products and/or services provided, such as discovering and handling product and/or service malfunctions; (9) Necessary for legitimate news reporting; (10) Necessary for academic research institutions to conduct statistical or academic research in the public interest, and where the personal information contained in the results is de-identified when providing the results of academic research or descriptions externally; (11) Other circumstances provided by laws and regulations.

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

1. Sharing

We will not share your personal information with any company, organization, or individual outside of Xuntu Zhilian, except in the following circumstances:

(1) Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties. (2) We may share your personal information externally in accordance with laws and regulations, or as required by mandatory government authorities. (3) Sharing with our affiliated companies: Your personal information may be shared with our affiliated companies. We will only share necessary personal information and shall be bound by the purposes stated in this Privacy Policy. If the affiliated company wishes to change the purpose of processing personal information, it will again seek your authorized consent. Our affiliated companies include any companies and institutions that are now or in the future controlled by, under the control of, or under common control with Xuntu Zhilian, as well as the legal successors of the aforementioned companies or institutions. (4) Sharing with authorized partners: Solely for the purpose of achieving the purposes stated in this Policy, certain of our services will be provided by authorized partners. With your explicit consent, 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 legitimate, proper, necessary, specific, and explicit purposes, and will only share personal information necessary for providing services. Our partners have no right to use the shared personal information for any other purposes.

2. Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

(1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties; (2) In the event of a merger, acquisition, or bankruptcy liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy, otherwise we will require that company or organization to seek your authorized consent again.

3. Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

(1) After obtaining your explicit consent; (2) Disclosure based on law: We may publicly disclose your personal information where required by law, legal procedures, litigation, or mandatory requirements of government authorities.

IV. How We Protect Your Personal Information

1. We will strictly comply with relevant local laws and regulations, establish information security safeguard systems, and adopt technical measures and other necessary measures to protect the security of your personal information.

2. We will only retain your personal information for the period necessary to achieve the purposes described in this Policy, unless an extended retention period is required or permitted by law.

3. Please understand: the internet environment is not 100% secure. We will do our utmost to ensure or guarantee the security of any information you send to us. However, due to technical limitations and the potential existence of various malicious methods, even if we do our best to strengthen security measures, we cannot always guarantee 100% information security. In the unfortunate event of a personal information security incident, we will, in accordance with legal and regulatory requirements, promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take to handle it, suggestions for you to independently prevent and reduce risks, and remedial measures for you, etc. We will promptly inform you of the relevant situation of the incident by email, letter, telephone, push notification, or other means. If it is difficult to notify personal information subjects individually, 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 in accordance with the requirements of regulatory authorities.

V. Your Rights

1. In the following circumstances, you may request us to delete your personal information:

(1) If our handling of personal information violates laws and regulations; (2) If we collect or use your personal information without obtaining your consent; (3) If our handling of personal information violates our agreement with you; (4) If you no longer use our products or services, or you have canceled your account; (5) If we no longer provide products or services to you.

After you delete information from our services, we may not immediately delete the corresponding information from backup systems, but will delete such information when backups are updated.

2. After you cancel your account, we will cease providing products or services to you and, at your request, delete your personal information, unless otherwise provided by laws and regulations.

VI. How This Policy Will Be Updated

Our User Privacy Policy may be subject to change.

Without your explicit consent, we will not diminish the rights you are entitled to under this Privacy Policy. We will publish any changes to this Policy in the form of a notice. In such circumstances, if you continue to use our services, you are deemed to agree to be bound by the revised privacy policy.

VII. App Permissions

1. "android.permission.ACCESS_NETWORK_STATE"

Permission Description: View network status

Usage Explanation: The APP requires internet access and checks whether the device is currently connected to a network.

2. "android.permission.ACCESS_WIFI_STATE"

Permission Description: View WLAN status

Usage Explanation: The APP requires a good network connection and checks the current network signal strength.

3. "android.permission.READ_PHONE_STATE"

Permission Description: Read phone status and identity

Usage Explanation: Reads the user's phone status for device deduplication and statistical analysis.

4. "android.permission.INTERNET"

Permission Description: Access network

Usage Explanation: Download firmware upgrade packages, upload device logs, and obtain official cooler information.

5. "android.permission.WRITE_EXTERNAL_STORAGE"

Permission Description: Modify/delete content on SD card

Usage Explanation: This permission is required when downloading cooler firmware upgrade packages.

6. "android.permission.BLUETOOTH"

Permission Description: Bluetooth search, connection, and communication

Usage Explanation: Used to connect to Xuntu Zhilian devices, adjust fan speeds, and read temperature and battery levels.

7. "android.permission.MANAGE_EXTERNAL_STORAGE"

Permission Description: Adapt to Android 11, modify/delete content on SD card

Usage Explanation: Adapt to Android 11; this permission is required when downloading firmware upgrade packages.

8. "android.permission.QUERY_ALL_PACKAGES"

Permission Description: Obtain the software installation list information of your mobile device

Usage Explanation: The APP needs to access the software installation list information of your mobile device. When setting up smart lighting effect linkage, you can choose to associate with installed games or applications to achieve automatic scene switching.

9. "android.permission.ACCESS_FINE_LOCATION"

Permission Description: Precise location permission

Usage Explanation: Location permission is required for Bluetooth scanning (Android system requirement).

10. "android.permission.ACCESS_COARSE_LOCATION"

Permission Description: Approximate location permission

Usage Explanation: Location permission is required for Bluetooth scanning.

11. "android.permission.BLUETOOTH_SCAN"

Permission Description: Bluetooth scanning permission (Android 12+)

Usage Explanation: Used to scan for nearby Xuntu Zhilian devices.

12. "android.permission.BLUETOOTH_CONNECT"

Permission Description: Bluetooth connection permission (Android 12+)

Usage Explanation: Used to connect to and control cooler devices.

13. "android.permission.POST_NOTIFICATIONS"

Permission Description: Notification sending permission (Android 13+)

Usage Explanation: Used to push messages such as device over-temperature alerts and firmware update completion notifications.

14. "android.permission.WAKE_LOCK"

Permission Description: Prevent phone from sleeping

Usage Explanation: Prevents the phone from automatically turning off the screen during firmware updates to avoid interruption.

VIII. How to Contact Us

If you have any complaints or reporting needs regarding our personal information handling practices, you may contact us via email (jimmyli0621@163.com). We will respond to your request within 5 business days after verifying your identity and will make every effort to resolve the matter. Contact Phone: 18165725008 Company Name: Shenzhen Zhiwan Innovation Technology Co., Ltd. Company Address: Room 1602, Runchuang Building, Xin'an Subdistrict, Bao'an District, Shenzhen, Guangdong, China Effective Date: 2026-5-11