This Privacy Policy applies to all products, services, and their extended functions provided by Beijing ShengShu Technology Co., Ltd. (hereinafter referred to as “we”), including our website (www.shengshu-ai.com) and various products and services provided to you with new forms of technological development (hereinafter referred to as “this Platform”).
We attach great importance to your personal information and privacy, thus the protection of your personal information is one of our priorities. At the same time, we believe that the information you provide can help us to provide you with better services. Therefore, we have formulated this Privacy Policy (hereinafter referred to as “this Policy”) to protect your personal information and privacy. This Policy is applicable to (i) when you visit and browse this Platform; (ii) when you register in this Platform and/or (iii) use the services provided by this Platform. Before using our services, please make sure that you have carefully read and fully understood all the terms of this Policy, especially those marked with bold/bold underline. If you do not agree with part of this Policy and it is necessary for us to provide services or products, we may not be able to provide corresponding services to you.
When we need to collect sensitive personal information, we will obtain your separate consent through pop-ups before collecting. Since such information may be necessary for us to provide some functions, refusing to provide such information may affect your use of related business functions.

I. How We Store and Use Your Personal Information
II. How We Entrust to Process, Share, Transfer and Publicly Disclose Your Personal Information
III. How We Store Your Personal Information
IV. How We Protect Your Personal Information
V. Yours Rights to Manage Your Personal Information
VI. Information Protection for Minors
VII. Update of this Policy
VIII. How We Use Cookies and Other Tracking Technologies
IX. How to Contact Us

I. How We Store and Use Your Personal Information

Personal information means all kinds of information related to identified or identifiable natural persons that are electronically or otherwise recorded,excluding information that has been anonymized; sensitive personal information means the personal information of which the leakage or illegal use could easily lead to the violation of the personal dignity of a natural person or harm to personal or property safety, including information on biometric identification, religious beliefs, specific identity, health care, financial accounts, and personal whereabouts,and personal information of minors under the age of fourteen (14).
Before providing us with any sensitive personal information, please clearly consider whether such provision is appropriate and agree that your sensitive personal information can be processed in the purpose and manner as set forth in this Policy.
In order to provide you with better service and improve your user experience, we will collect your personal information for the following purposes:

1. Help you to create an account
   In order to complete account registration and identify users through our website, you need to provide us with the following information: your name, e-mail, mobile phone number, date of birth or other third-party platform account you agree to provide. If you do not provide us with your name, e-mail and mobile phone number, you will not be able to complete registration, which will not affect your use of browsing services.
2. Provide you with products and services
   Browsing function: You can browse the service interface provided by us. In order to ensure your normal access to the page, we may need to collect information about the devices you use this Platform, such as device attributes (device model, operating system (OS) version, device settings, unique device identifier (UDID), and other software and hardware features), device location (geographic information obtained through GPS, Bluetooth or WIFI signals), and device connection (IP address, browser type, telecom operator, language used, access date and time, DNS record for your web page, etc.). Separate device information usually does not identify you personally, does not belong to your personal information, and is not within the scope of this Policy. Only when your device information is linked with your other information and can detect your personal identity, during the combined use, will we treat your device information as your personal information and process and protect it according to this Policy.
   Search function: When you use the search function, in order to provide you with the content you need, recommend the activities you are interested in and improve the accuracy of the search, we will collect the keywords you inquired and other information and content details you read or requested when using our service; we may also use the network storage mechanism and application data cache to collect the information on your device and store it locally. It’s usually impossible for informational keywords to identify you personally, it does not belong to your personal information, and is not within the scope of this Policy. Only when the keywords you search is linked with your other information and can detect your personal identity, during the combined use, will we treat your keywords as your personal information and process and protect it according to this Policy.
3. Obtain your personal information from a third party
   When you log in to this Platform with a third-party account, you will authorize us to read and obtain your public information (including nickname, avatar/profile picture and gender) on the third-party platform on the premise of meeting the requirements of applicable laws and regulations.
4. Exceptions to prior authorization and consent
   You are fully aware and agree that we do not need your authorization or consent to collect and use your relevant personal information in the following situations:
   (1) Where it is necessary for compliance with a legal obligation to which we are subject; or
   (2) Where it’s related to national security and national defense security; or
   (3) Where it’s related to public security, public health and vital public interests; or
   (4) Where it’s related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and judgment execution; or
   (5) Where it is necessary in order to protect your or others’ vital interests related to life and property in an emergency or respond to public health emergencies;
   (6) Where you disclose your personal information to the the public by yourself; or
   (7) Where it is within reasonable range according to laws to collect the information which has been legally made public , including legitimate news report and government information disclosure; or
   (8) Where it is necessary for performance of contracts or agreements or other written documents entered into between you and us; or
   (9) Where it is necessary for maintenance of safe and stable operation of the provided products/services, for example, detection and handling of errors of the provided products/services; or
   (10) Where it is within reasonable limits to process the information in order to carry out news coverage or media supervision for the public interest; or
   (11) When it is necessary for academic research institutions to carry out statistical or academic research based on public interests and in the provision of the results of academic research or description to the public, the personal information contained in the results is de-identified; or
   (12) Other circumstances stipulated by laws and regulations.
5. Special instructions for third-party services and SDKs
   Our products/services may include third-party products/services (involving payment, location and so on), some of which will be provided in the form of links to third-party websites, while others will be accessed in the form of SDKs (software development kits), API (application programming interface) and so on. Your information may also be collected when you use these products/services. We are not responsible for how third parties use the personal information they collect from you, neither can we control how they use your personal information.

II. How We Entrust to Process, Share, Transfer and Publicly Disclose Your Personal Information

1. Entrusted Processing
   Some specific modules and functions in the business functions in Article I of this Policy may be provided by external suppliers. When you use the relevant modules and functions, we will inform the external suppliers of the name, contact details, processing purpose, processing method and types of personal information by pop-up. If you do not agree to entrust the external service providers with processing, you may not be able to enjoy the services entrusted by us.
   We will enter into strict non-disclosure agreements with all companies, organizations and individuals with which we entrust to process personal information according to our instructions, this Privacy Policy and any other related measures for confidentiality and security.
2. Sharing
   We will not share your personal information with any other company, organization or individual unless we obtain your explicit consent. You are fully aware and agree that we will share your personal information only for lawful, legitimate, necessary, specific, and explicit purposes, and only as much personal information as is necessary; we will not share your personal information with any third party without your prior separate consent, unless in the circumstances as follows.
   Sharing with the affiliates: We may share your personal information with our affiliated companies/designated service providers to help us provide our products or services based on this Platform, detect account anomalies, protect the personal and property security of our affiliated companies, other users or the public from infringement. We will only share the necessary personal information for the purposes specified in this Privacy Policy.
   We will enter into strict non-disclosure agreements with all companies, organizations and individuals with which we share information and require them to process personal information according to our instructions, this Privacy Policy and any other related measures for confidentiality and security.
3. Transfer
   Without your separate consent, we will not transfer your personal information to any other company, organization or individual, except
   in the case of merger, acquisition, insolvency or bankruptcy liquidation, or business transfer with our affiliated companies where the transfer is necessary. In such cases, we will inform you of the identity and contact details of the personal information recipient as per applicable laws and regulations as well as request the said recipient to comply with this Policy. If the personal information recipient changes the purposes and methods of personal information processing activities under this Policy, it shall re-obtain the consent from you.
4. Public Disclosure
   We may disclose your personal information to the public only under the following circumstances:
   (1) Where with your explicit consent or on your own initiative; or
   (2) Where it is necessary for compliance with a legal obligation to which we are subject, i.e., at the mandatory requirements of laws, regulations, legal procedures, lawsuits or regulatory or governmental authorities.
5. Special Circumstances without Obtaining Prior consent in Sharing, Transfer and Public Disclosure of Personal Information
   To the extent allowed by laws and regulations, we may share, transfer and publicly disclose your personal information without your prior consent under the following circumstances:
   (1) Where it is necessary for compliance with a legal obligation to which we are subject; or
   (2) Where it’s related to national security and national defense security; or
   (3) Where it’s related to public security, public health and vital public interests; or
   (4) Where it’s related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and judgment execution; or
   (5) Where it is necessary in order to protect your or others’ vital interests related to life and property in an emergency or respond to public health emergencies; or
   (6) Where you disclose your personal information to the the public by yourself; or
   (7) Where it is within reasonable range according to laws to collect the information which has been legally made public , including legitimate news report and government information disclosure; or
   (8) Where it is within reasonable limits to process the information in order to carry out news coverage or media supervision for the public interest; or
   (9) Other circumstances stipulated by laws and regulations.
   Please kindly note that according to the applicable laws and regulations, if we take technical and other necessary measures to process personal information, which could not enable the data receiver to re-identify a specific individual and enable it to be recovered, the sharing, transfer and public disclosure of such processed data need not be notified to you separately and obtain your consent.

III. How We Store Your Personal Information

In principle, the personal information we collect and generate within the territory of the People’s Republic of China will be stored in the territory of the People’s Republic of China.
In the case of cross border data transfer, we will comply with applicable laws and regulations related to that and will try to ensure that personal information processing activities of the overseas recipient meet the personal information protection standards in the People’s Republic of China. For example, we will keep you informed of the following information separately and clearly by pop-up or e-mail: purpose of the cross border data, data processing method, type or classification of the cross border personal information, name or contact details of the recipient, way and procedures for you to exercise the rights stipulated in the Personal Information Protection Law of the People’s Republic of China to overseas recipient, and obtain your consent. We will conclude a contract with the overseas recipient in accordance with the template standard contract in the Measures on the Standard Contract for the Outbound Transfer of Personal Information (Measures) released by the National Internet Information Office, and stipulate the rights and obligations of both parties.
Except as otherwise provided by any laws or regulations, we will only keep your personal information for the shortest time necessary to achieve the purpose stated in the Policy. For example, the Electronic Commerce Law requires that goods, services and transactions shall be preserved for no less than three years from the date of completion of the transaction. After the expiration of the retention period, we will delete or anonymize it.
If we cease our operation due to poor management or other reasons, we will immediately stop collecting your personal information and delete the collected personal information at the same time.

IV. How We Protect Your Personal Information

1. We have taken reasonable and feasible security measures in line with industry standards to safeguard your personal information against unauthorized or accidental access, public disclosure, use, modification, damage or erasure. For example, we use encryption technology to safeguard the security of your personal information; we use a trusted protection mechanism to prevent personal information from being maliciously attacked; we deploy an access control mechanism to ensure that only authorized personnel can access personal information; and we will hold security and privacy protection training courses to enhance our employees’ understanding of the importance of protecting personal information.
2. The Internet is not in an absolutely secure environment, and such digital communication media as e-mail, instant messaging and social software with other users cannot be completely encrypted. We suggest that you use complex passwords when using such media, and pay attention to protecting your personal information. You should keep and use your username and password carefully and reasonably, and please do not lend your account to others for use, otherwise you will bear all the responsibilities arising therefrom.
3. If an unfortunate personal information security incident occurs, we will keep you informed of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions that you may independently prevent and mitigate risks, and the remedial measures for you, according to the requirements of laws and regulations. We will inform you about the incident by e-mail, letter, telephone, push notice, etc.; if it is difficult to inform the subject of personal information one by one, we will make an announcement in a reasonable and effective way. At the same time, we will also report the handling of personal information security incident according to the regulatory requirements.

V. Yours Rights to Manage Your Personal Information

You have the right to consult, copy, correct, supplement, delete your personal information or cancel your account.

1. Consult, copy, correct, or enrich your personal information
   You can contact our customer service to update or modify your personal information.
2. Delete your personal information
   Regarding your other personal information, you can contact us in the way listed in this Policy and request us to delete some of your personal information.
   Possible circumstances in which you can ask us to delete your personal information:
   (1) In the case that our handling of personal information violates laws and regulations; or
   (2) In the case that we collect and use your personal information without your prior consent; or
   (3) In the case that our handling of personal information violates our agreement entered into with you; or
   (4) In the case that you no longer use our products/services, or you close your account; or
   (5) In the case that your withdraw consent; or
   (6) In the case that the handling purpose has been achieved handling purpose, the handling purpose is unable to be achieved, or there is no necessity to achieve the handling purpose; or
   (7) In the case that we no longer provide products/services for you, or the storage period has expired.
   When you or we assist you to delete the related information, we may not be able to immediately remove the information from the backup system due to applicable legal restrictions and/or security technology limitations. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be cleared or be made anonymous.
3. Change the scope of your authorization
   You can change or limit the scope or extent of your consent previously provided for us to allow us to continue to collect your personal information or withdraw your consent previously provided to us by turning off the device functions, manage permissions for your smart device in Settings, or other ways. You can also withdraw all your permissions granted to us to collect your personal information by closing your account. Please kindly note that the realization of each function requests the availability of some basic personal information; so when you withdraw your consent, we have no right to provide you with the services corresponding to the withdrawal of consent, neither will we process your relevant personal information; however, your withdrawal of consent will not affect the lawfulness of processing based on consent given by you before its withdrawal.
4. Closure of your account
   You can request the closure of your account by contacting us in the ways listed in this Policy:
   After you submit an application for closing the account, we will contact you for identity verification and account verification, and respond to your request as soon as we can after the results of above two verifications are acceptable.
   After you close your account on your own, we will stop providing you with products/services, delete your personal information based on the requirements of applicable laws and regulations (that is, remove your personal information from the systems involved in our business functions so that it will not be retrieved or accessed), or anonymize it. Please kindly note that according to applicable laws, we cannot permanently and completely delete some of your personal information immediately. For example, according to the requirements of the Network Security Law, after the account is closed, the monitoring, recording of network operation status and network security event logs related to you will remain for no less than six months; according to the requirements of the Electronic Commerce Law, the product/service information and transaction information shall be kept for at least three years from the date of transaction completion.
5. Response to your above requests
   For security, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. We will reply within fifteen (15) working days from the date of receiving your request. If you are not satisfied, you can also lodge a complaint with us in the way listed in Article IX of this Policy.
   Please kindly note that according to applicable laws and regulations, we will not respond to your request in the following circumstances:
   (1) Where it is necessary for compliance with a legal obligation to which we are subject; or
   (2) Where it’s related to national security and national defense security; or
   (3) Where it’s related to public security, public health and vital public interests; or
   (4) Where it’s related to criminal investigation, prosecution, trial and judgment execution; or
   (5) Where there is sufficient evidence to show that you have subjective malice or abuse of rights; or
   (6) Where it is necessary but difficult to obtain your consent in order to protect your or others’ vital legitimate rights and interests related to life and property; or
   (7) Where the response to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations; or
   (8) Where it is related to business secret; or
   (9) Other circumstances stipulated by laws and regulations.

VI. Information Protection for Minors

We do not knowingly collect or solicit personal information from anyone under the age of 14 or knowingly allow such persons to provide us with their personal information without verifiable parent or guardian consent. If you are minors under the age of 14, please do not use our products or services.

VII. Update of this Policy

In order to provide you with better service, this Privacy Policy may also be updated or modified by the Company from time to time in accordance with laws. However, any such update or modification will be publicized in this Platform, the Company will not reduce your rights that you should enjoy under this Policy. In the case of any change of the terms of the Policy, prior to its entry into force, the Company will remind you of the update or modification of relevant content by prompting in a prominent position on the page, issuing an announcement, or in other appropriate ways. For critical changes, the Company will keep you informed of with more prominent notices (e.g., explanation of specific changes of some services under this Policy via email/SMS).
The critical changes referred to in this Policy include but are not limited to:
(1) Significant change of our business functions; or
(2) Change of personal exit situation; or
(3) Change of the purpose of using personal information; or
(4) Change of the contact information of the Data Privacy Officer (DPO).
If you do not agree with the updated or modified Privacy Policy, you will immediately be stopped to use this Platform; if you want to continue to use this Platform, you need to reconfirm that you agree with the update or modification of our Privacy Policy.

VIII. How We Use Cookies and Other Tracking Technologies

Our website uses cookies and IP address tracking to improve our service quality and enhance your user experience.
Cookies are small text files that websites place on a user’s browser to collect data about their online activities. They are used by us to remember specific user preferences and frequency of user access so that personalized experiences can be created. For example, cookies will store your password and help websites “remember” that you’re logged in, so you do not have to enter your credentials every time your visit. Most browsers automatically accept cookies. You can disable and clear all the cookies in the browser. Use the “Help” option of your browser to get relevant information. If you disable cookies, we can't guarantee that you can use this website normally. If you do not disable cookies, you can better visit and use this website. If you do not disable cookies, it means that you agree that we can use cookies to collect and store any personal information collected by cookies.

IX. How to Contact Us

If you have any questions, comments, or suggestions about this Policy or any complaints or claims related to this Policy, please contact us as follows. We have set up a specialized Privacy & Security Department to solve your problems in time. Usually, we will respond to you within 15 days.
Beijing ShengShu Technology Co., Ltd.
E-mail of the Data Privacy Officer (DPO): contact@shengshu.ai
This Platform is provided by Beijing ShengShu Technology Co., Ltd..
Registered address: Dongsheng Building Haidian District, Beijing