Privacy Policy

[Special Notice]
This Policy applies solely to the products, services, and extended features provided by Shanghai Waycan M&E Technology Co., Ltd. and its affiliates (hereinafter referred to as "We" or "Waycan")—collectively referred to as "Waycan Services." This includes the Waycan website, official accounts, video channels, and various products and services provided to you through new forms emerging alongside technological advancements. If a specific product or service we provide has a separate privacy policy, or if there are specific stipulations within its corresponding legal statement, the privacy policy for that specific product shall take precedence. For any matters not covered by the privacy policy or User Service Agreement of that specific product or service, the provisions of this Policy shall govern. Furthermore, if products or services provided by our affiliates utilize Waycan-provided products or services but lack an independent privacy policy of their own, this Privacy Policy shall likewise apply to those specific products or services.

Please read the *Waycan Privacy Policy* carefully (paying particular attention to the **bolded text**) to ensure you fully understand our rules regarding the processing of your personal information. Should you have any questions while reading this Policy, please feel free to contact us using the contact details provided within the *Waycan Privacy Policy*.

Introduction

Welcome to the website of Shanghai Waycan M&E Technology Co., Ltd. (hereinafter referred to as "this Website")!
This Website is provided and controlled by Shanghai Waycan M&E Technology Co., Ltd. (hereinafter referred to as "We").
We attach great importance to the privacy and personal information protection of our users. When you use our products and/or services, we may collect and use information relevant to you. Through this *Waycan Privacy Policy* (hereinafter referred to as "this Privacy Policy"), we aim to explain to you how we collect, use, store, share, and transfer such information when you use our products and/or services, as well as the methods we provide for you to access, update, delete, and protect this information. This Privacy Policy will help you understand the following:
1. What types of information we collect about you
2. How we use your information
3. How we share your information
4. Entrusted Processing
5. How we protect your information
6. How long we retain your information
7. Protection of personal information of minors
8. Notices and Revisions
9. Third-party links
10. Contact Us

Table of Contents
1. What types of information we collect about you
2. How we use your information
3. How we share your information
4. Entrusted Processing
5. How we protect your information
6. How long we retain your information
7. Protection of personal information of minors
8. Notices and Revisions
9. Third-party links
10. Contact Us

1. What types of information we collect about you
When you use this website, we may collect the following categories of information about you:

Information you provide to us.
We may collect personal information that you provide to us. When you send us information via the "Contact Us" page on this website, you are required to provide your personal identity and contact details, such as your name, email address, phone number, country, city, etc.; you may also provide us with your employment information, such as your employer and job title. We may also obtain information about you through your communications with us—for instance, within your comments, questions, feedback, and other content you provide while utilizing the features of this website.

Information we collect about you.
As you use this website, we may automatically collect certain information about you. This information may include:
• Technical and Device Information. We may collect certain technical information regarding you and your device. This information may include, but is not limited to, your IP address, system time zone, system language, and other system or network identifiers.
• Operational and Behavioral Information. We automatically collect information generated when you visit this website and record your usage activities on the site, including the duration of your visit, which sections of the website you accessed, and what specific information you viewed.
• Cookies and Similar Technologies. This website may utilize "Cookies" and other tracking technologies to store information provided by users of the website. Cookies are small pieces of information sent by a web server to a user's browser. Cookies may include information such as user preferences, the time spent on the website, and the pages visited. We use this information to identify you and to customize and enhance your experience on this website. You can manage the Cookie settings on your device through features built into most web browsers. For example, you can configure your browser to notify you when it receives Cookies, or you can choose to block Cookies entirely; however, please note that declining Cookies may limit your ability to use certain features of this website. Additionally, please be aware that, at present, this website does not respond to "Do Not Track" signals sent by your browser.

Information We Collect About You from Third Parties.
We may obtain personal information regarding your use of and access to this website from third-party platforms and our service providers. This information may include details such as the country or region where your system is located, your device's brand and model, your browsing activity (including other services you visited immediately prior to accessing our website), your browsing history, search queries, and clickstream data.

2. How We Use Your Information
We may use your information in the following ways:
Based on our legitimate interests in providing this website, we may use your information for the following purposes:
• To review your comments or questions and provide you with appropriate services;
• To enforce our Terms and Policies;
• To process and respond to your requests, inquiries, applications, complaints, and feedback;
• To provide support and respond to your requests, feedback, and inquiries;
• To monitor, operate, maintain, and manage this website;
• To address and resolve technical issues and malfunctions affecting this website;
• To ensure that this website operates effectively and efficiently;
• To detect, prevent, or otherwise address security, fraud, or technical issues;
• To improve and enhance the functionality and performance of this website and related services;
• To properly manage and administer our relationship with you;
• To manage our business operations; and to protect, enforce, or defend our rights and interests (including our rights and interests in the event of a violation of our Terms and Conditions);
• For the purposes of academic research;
• For purposes serving the public interest—such as in the context of public health emergencies—in compliance with applicable laws and regulations.

We may also use your information for the purpose of fulfilling our legal obligations and responsibilities. Furthermore, with your consent—or where permitted by applicable laws and regulations—we may process your information for other purposes as disclosed to you. 


3. How We Share Your Information

We may share your information with the following third parties:
Service Providers. We may share your information with third parties that provide services to us for the purpose of operating and maintaining this website, such as website hosting providers, development service providers, and cloud service providers.
Our Affiliates. In order to provide this website, we may share your information with any member, subsidiary, or affiliate of our company for purposes including, but not limited to, preventing unlawful use and supporting users.
Law Enforcement and Government Authorities. We may share your information with government authorities, courts, third parties, and other entities in response to court orders, subpoenas, lawful discovery requests, regulatory requirements, or where the law permits or requires such disclosure—including situations where we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats to the physical safety of any person.
Sale or Merger. We may disclose your information to any third party that:
• Acquires, or intends to acquire, all or part of our assets or shares;
• Is acquired, in whole or in part, by us;
• Merges with us; or
• Succeeds to all or part of our business operations.
In each of the above scenarios, such third parties are under a legal obligation not to disclose or use your information for any purpose other than as authorized by us.

Please note that any information you voluntarily share—or even publicly disclose—while using our services may involve your personal information, or that of others, including sensitive personal information. Please exercise caution and careful consideration when deciding to share such information.

4. Entrusted Processing
We may entrust authorized partners to process your personal information in order to provide you with corresponding products or services. However, we will only share your personal information for purposes that are lawful, legitimate, necessary, specific, and explicit, and we will only share the personal information that is strictly necessary to provide the products or services. If our partners intend to use your personal information for purposes other than those we have entrusted to them, they will obtain your separate consent.
Our partners include the following types:
Providers of Technical Services. We may provide your personal information to third parties that support our functions, including vendors that provide us with infrastructure technology services, data analytics services, and data processing services.
Advertising and Analytics Partners. We adhere to applicable laws, regulations, and generally accepted industry security standards when engaging these partners to process information related to ad placement, reach, and effectiveness.
In instances where we entrust partners with the processing of personal information, we enter into data protection agreements with them, requiring them to process such information in strict accordance with the terms of the agreement, this Privacy Policy, and relevant laws and regulations.

5. How We Protect Your Information
We implement security measures in accordance with this Privacy Policy and maintain physical, electronic, and administrative safeguards to protect and secure the information we process on your behalf. However, as data transmission over the Internet is never absolutely secure, we cannot guarantee the absolute security of your information. Any transmission of your information to us is undertaken at your own risk.

6. How Long We Retain Your Information
During your use of this website's services, your personal information will be retained for the period necessary to fulfill the purposes outlined in this Policy. This retention period is also determined in conjunction with mandatory legal retention requirements—for instance, the *E-commerce Law of the People's Republic of China* mandates that information regarding goods, services, and transactions must be retained for a period of no less than three years from the date the transaction is completed. Once the retention period has expired, we will either delete your personal information or anonymize it, in accordance with applicable laws.
We may also retain your information for other legitimate purposes—for example, in situations where we are bound by laws, regulations, mandatory requirements from administrative or judicial authorities, contractual obligations, or similar duties that necessitate the retention of personal information. We respect and attach great importance to your rights regarding your personal information, including:
Right of Access: You have the right to request confirmation from us as to whether we are processing your personal information, and to request a copy of your personal information.
Right of Correction: If any of the personal information we have collected from you is incomplete or inaccurate, you may request that we correct or update such information.
Right of Deletion: Under certain circumstances, you may request that we delete all or part of your personal information.
Right to Withdraw Consent: If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. However, please note that if you withdraw your consent, you may no longer be able to utilize certain features of this website or access our services.

You may exercise any of these rights by contacting us as described in Section 10 ("Contact Us") of this Privacy Policy. To safeguard your privacy, we may request that you provide additional information to verify your identity before we proceed to process your request. 


7. Protection of Personal Information of Minors

Waycan places great importance on the protection of the personal information of minors. If you are a minor under the age of 18, you must obtain the prior consent of your guardian before using our products and/or services. Waycan protects the personal information of minors in accordance with relevant national laws and regulations.
We do not actively or directly collect personal information from minors. In instances where we collect a minor's personal information with the guardian's consent, we will only use, share, transfer, or disclose such information when permitted by law, with the guardian's consent, or when necessary to protect the minor.

8. Notices and Revisions
We reserve the right to revise this Privacy Policy from time to time at our sole discretion. We will notify you of any material changes to this Privacy Policy through notices published on this website; such changes shall apply only to information collected after the revised Privacy Policy takes effect. Any revisions to this Privacy Policy shall become effective immediately upon publication. We encourage you to review this Privacy Policy regularly to stay informed of any changes and to understand how we protect your personal information.

9. Third-Party Links
This Privacy Policy does not apply to any other websites or platforms, unless the context explicitly states otherwise. Please note that this website may contain links to other websites, platforms, or products whose privacy policies and actual practices differ from ours. These links are provided solely for your convenience and for informational purposes; they do not constitute an affiliation or sponsorship relationship between us and the third-party websites, nor do they imply our endorsement of the information contained on such third-party websites. If you provide your information to any of these third parties or interact with these third-party websites, we assume no responsibility for the collection and processing of your information by such parties.

10. Contact Us
If you have any questions regarding this Privacy Policy, please contact us via our official website.
Generally, we will respond within 15 days. If you are dissatisfied with our response—particularly if you believe our handling of personal information has infringed upon your legitimate rights and interests—you may also file a complaint or report with the relevant regulatory authorities, such as those governing cyberspace administration, telecommunications, public security, and market supervision.
Appendix: Examples of Personal Information and Sensitive Personal Information (Note: These are not necessarily the specific types of personal information collected by Waycan's website, official accounts, or video channels; they are provided solely for illustrative purposes.)
Personal Information: Various types of information recorded electronically or by other means that relates to an identified or identifiable natural person, excluding information that has undergone anonymization processing. **Sensitive Personal Information:** Personal information that, if leaked or unlawfully used, is liable to infringe upon the personal dignity of a natural person or endanger their personal or property safety. This includes information such as biometric data, religious beliefs, specific identities, medical and health records, financial accounts, and location tracking data, as well as the personal information of minors under the age of 14.
**Device Information:** Includes device identifiers (IMEI, IDFA, AndroidID, MAC, OAID, IMSI, and other device-related information); application information (app crash logs, notification toggle status, list of installed applications, and other app-related information); device parameters and system information (device type, device model, operating system, and hardware-related information); and device network environment information (IP address, Wi-Fi details, base station information, and other network-related information).

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