HoldLink Privacy and Data Processing Statement

Important Notice: This Privacy Statement (hereinafter referred to as "this Statement") is formulated by Shenzhen Shandian Water Technology Co., Ltd. (hereinafter referred to as "we" or "our company") to explain the principles and measures regarding the processing of users' personal information in HoldLink products and services. Please read and understand the entire content of this Statement before use. If you are under 18 years of age, you must obtain the consent of your guardian before using our services.

This Statement covers the following main areas:

• Definitions and Explanations
• Collection and Use of Personal Information
• Use of Technical Tools
• Sharing of Data with Third Parties
• Security Measures and Retention Period
• Guidance on User Rights
• Special Provisions for Minors' Information
• Revisions to This Statement
• Contact Us

1. Definitions and Explanations

HoldLink Products: Refers to the various functions and services we provide to you.

Scope of Services: Includes but is not limited to functions such as translation, speech recognition, meeting minutes, intelligent dialogue, and text generation.

User: A natural person who uses HoldLink products and submits personal information.

Account: The unique identity identifier formed after user registration. The user shall bear legal responsibility for all operations under this account.

Device Identifier: Information related to the device collected to provide services, such as model, operating system, network status, etc.

De-identification: The process of handling personal information so that it cannot be associated with a specific individual.

2. Collection and Use of Personal Information

• To provide basic services, we collect necessary information. If you refuse to provide such information, it may affect the use of some or all functions.
• Some optional features may require additional authorization, which you can decide whether to enable.
• To improve service adaptability, we may obtain your approximate geographic location after obtaining your consent.
• Local storage permissions are used to save your history and generated content.
• When using voice features, microphone permissions are required.
• To ensure account and transaction security, we may collect device information for risk identification and control.

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

3. Use of Technical Tools

We use technologies such as cookies only to the extent necessary to achieve the purposes of the service. You can manage related data through your device or browser settings.

4. Sharing of Data with Third Parties

We will 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 cooperative third parties to complete the required services;
• Necessary sharing among affiliated companies under uniform privacy standards;
• If changes in corporate structure occur (such as mergers or divisions), we will notify you and continue to fulfill our protection obligations.

5. Security Measures and Retention Period

• Industry-standard encryption and de-identification technologies are used to protect data security.
• Strict data access permission management and approval processes are implemented.
• Your information is retained only for the shortest time necessary to achieve the purposes.
• After the termination of service, your information will be deleted or anonymized in accordance with the law.
• In the event of a data security incident, we will promptly inform you in accordance with the law.

6. Guidance on User Rights

You can manage your information through the following methods:

1. View account information in the [Personal Center];
2. If information is incorrect, you can apply for correction through customer service;
3. You may request deletion of personal information under circumstances permitted by law;
4. Complete account cancellation via [Settings] → [Account Management] → [Delete Account].

7. Special Provisions for Minors' Information

We attach great importance to the protection of minors' personal information:

• Users under 18 years of age should use the service only with the consent of their guardian;
• We process minors' information only to the extent permitted by law and necessary for their protection;
• If we find that we have inadvertently collected minors' information, we will delete it immediately.

8. Revisions to This Statement

We may update this Statement from time to time. After updates, we will notify you through in-app messages or other methods. In the event of significant changes listed below, we will provide prominent notice:

• Significant changes in the purpose, method, or scope of personal information processing;
• Changes in the company entity or control rights;
• Major adjustments in the recipients or methods of information sharing or transfer;
• Substantive changes in your personal information rights or the methods of exercising them.

9. Contact Us

If you have any questions or suggestions regarding this Statement or the processing of personal information, please contact us via:

Email: dadakang233@gmail.com

In-app customer service channel