HoldLink Privacy Policy

Important Notice: This Privacy Policy (the "Policy") is established by Shenzhen Shandianshui Technology Co., Ltd. ("we", "us") to explain how the HoldLink application (the "App") processes your personal information. Please read and fully understand this Policy before use, paying particular attention to clauses highlighted in red that involve sensitive personal information. If you are under 18, you may only use the App with the consent of a guardian.

This Policy covers the following:

• Definitions
• Collection and use of personal information (by feature scenario)
• Device permission descriptions
• Third-party SDK list
• Use of technical tools
• External provision of data
• Security safeguards and retention period
• Your rights
• Special provisions for minors
• Revisions to this Policy
• Contact us

1. Definitions

HoldLink Product: the companion application for smart wearable devices and related features and services we provide to you.

Scope of Service: includes connection and management of smart watches/bands and other wearables, watch face and wallpaper creation, health data display (heart rate, blood oxygen, blood pressure, sleep, steps, etc.), workout records, AI voice assistant, recording, message notification push, and weather.

User: a natural person who uses the HoldLink product and submits personal information.

Account: the unique identity formed after user registration; users bear legal responsibility for account operations.

Device Identifier: device-related information collected to provide services, such as device model, operating system version, Android ID, and network status.

De-identification: processing personal information so that it can no longer be linked to a specific individual.

Version Note: the App is distributed in a domestic (China) version and an overseas version (Google Play). Features and permissions marked "Domestic version only" are enabled only in the domestic version; the overseas version does not include SMS, call, or contact-related features, nor the Tencent Bugly SDK.

2. Collection and Use of Personal Information

We describe the types of personal information collected and their purposes feature by feature. To provide basic services we collect necessary information; refusing to provide it may affect the corresponding feature but does not affect others.

(1) Registration and Login. You may register with a phone number or email address; we collect your phone number/email address, verification code, and login password to create your account, verify your identity, and recover passwords. You may also use basic features in guest mode.

(2) Profile Information. To calculate and display health data, you may voluntarily provide your nickname, avatar, gender, year of birth, height, and weight, used for personalized display of health metrics (such as step goals and calorie estimates); you may modify these at any time.

(3) Device Connection and Binding. To connect your smart wearable device, we use Bluetooth permission to scan for and connect to devices, and collect your bound device's Bluetooth MAC address, device name, and device model for binding, status synchronization, and firmware upgrades.

(4) Message Notification Push (requires enabling system "Notification Access"). To push phone messages to your wearable device, we read the app name, title, and content of status-bar notifications locally via the system notification listener service, and send them only to your bound wearable device; they are never uploaded to our servers.

(5) SMS Alerts (Domestic version only). To push new SMS messages to your wearable device, after you grant SMS permission we read locally the sender number and content of received SMS messages, used solely to forward them to your bound wearable device for display; they are never uploaded to our servers.

(6) Incoming Call and Call Features (Domestic version only). To provide incoming call alerts, caller name display, and answering/ending calls from the device, after you grant phone permission and call log permission we read locally the incoming call number, call state, and contact name, used solely to push to your bound wearable device and to control calls from the device; they are never uploaded to our servers.

(7) Contacts (Domestic version only). To sync favorite contacts to the device, set SOS emergency contacts, and match caller names, after you grant contacts permission we read the names and phone numbers of contacts you select, used solely to sync to your bound wearable device; they are never uploaded to our servers.

(8) Location Information. To provide weather services and workout track recording, after you grant location permission we obtain your precise geographic location (latitude/longitude): in weather scenarios the coordinates are transmitted to our servers and weather providers (Gaofen Weather, QWeather) to query local weather; in workout scenarios location is used to draw your workout track (the domestic version includes background location, used only while you actively start a workout recording).

(9) Microphone. To provide AI voice Q&A and recording, after you grant microphone permission we capture audio data: audio in AI Q&A scenarios is transmitted to the Dana cloud platform for speech recognition and conversation processing; recording files are stored only locally on your device.

(10) Camera. To provide the screen-mirroring camera feature (real-time preview of the phone camera on your wearable device), after you grant camera permission we capture real-time images, transmitted only between your phone and your bound device and never uploaded to servers.

(11) Photos and Storage. To create watch faces and wallpapers (dynamic wallpapers, video wallpapers, photo watch faces), after authorization we read the image, video, and audio files you select; to save recordings and history we use local storage permission to write data on your device. These files are processed locally only and are not uploaded to servers (except an avatar you actively upload).

(12) Sensor Information (Domestic version only). To provide on-device step counting and activity recognition, after you grant physical activity recognition permission we use step counter and accelerometer sensor data; the camera feature uses the device orientation sensor to adapt to landscape/portrait state. Sensor data is used locally only.

(13) Device Information and Runtime Status. To ensure service security, perform compatibility adaptation, and analyze crashes, we collect device model, operating system version, Android ID, network status, running process information (used only to identify the state of the App's own processes), and crash logs. Such information is used for risk identification and service quality improvement.

(14) Feedback. When you actively submit feedback, we collect the email address, problem description, and attachments (screenshots/log files) you choose to upload, used to locate and resolve the issue you reported.

Where required by laws, regulations, or state authorities, we may process relevant information without separate consent.

3. Device Permission Descriptions

The table below summarizes the system permissions the App requests and their purposes. All permissions can be revoked at any time in system settings; revoking affects only the corresponding feature.

4. Third-Party SDK List

To implement certain features, the App integrates the following third-party SDKs; their information collection is governed by their respective providers' privacy policies:

Weather service note: when querying weather, your coordinates are forwarded via our servers to weather providers (Gaofen Weather/QWeather) to obtain local weather data, without being linked to your account identity.

5. Use of Technical Tools

We use Cookies and similar technologies only to the extent necessary to achieve service purposes. You can manage related data through your device or browser settings.

6. External Provision of Data

We do not arbitrarily provide your personal information to third parties, except in the following circumstances:

• Requirements of laws, regulations, or government authorities;
• Sharing the minimum necessary information with cooperating third parties (such as the SDKs and weather providers listed in Section 4) as required to complete services;
• Necessary sharing among affiliated companies under unified privacy standards;
• In the event of corporate structural changes (e.g., merger, division), we will notify you and continue to fulfill our protection obligations.

In particular: your notification content, SMS content, contacts, and call information are processed locally on your phone and sent only to your bound wearable device; we never upload such information to our servers.

7. Security Safeguards and Retention Period

• We use industry-standard encryption and de-identification to protect data security.
• We enforce strict data access management and approval procedures.
• We retain your information only for the shortest period necessary to achieve the stated purposes.
• After service termination, we will delete or anonymize your information in accordance with the law.
• In the event of an information security incident, we will inform you promptly as required by law.

8. Your Rights

You can manage your information through the following:

1. View account information in [Profile];
2. Request corrections via customer service if information is inaccurate;
3. Submit deletion requests where permitted by law;
4. Delete your account via [Settings] → [Account Management] → [Delete Account];
5. Revoke granted permissions at any time in system settings; revoking affects only the corresponding feature.

9. Special Provisions for Minors

We attach great importance to protecting minors' personal information:

• Users under 18 should use the service with guardian consent;
• We process minors' information only to the extent permitted by law and necessary for their protection;
• If we discover that we have collected a minor's information by mistake, we will delete it immediately.

10. Revisions to This Policy

We may update this Policy from time to time. Updates will be announced via in-app messages or similar means. We will provide prominent notice in the event of the following material changes:

• Significant changes to the purposes, methods, or scope of personal information processing;
• Changes to the corporate entity or control;
• Major adjustments to the recipients or methods of information sharing or transfer;
• Substantive changes to your personal information rights or how they may be exercised.

11. Contact Us

If you have any questions or suggestions about this Policy or our processing of personal information, please contact us via:

Email: dadakang233@gmail.com

In-app customer service