Zhizhidianzi Privacy Statement

Privacy Statement

Last Updated: November 2, 2025

This Privacy Statement applies to Zhizhi Company (doing business as [Company Name]) (“we,” “us,” or “our”) and describes how and why we may access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

Visit our website at https://zhizhidianzi.com/ or any website that links to this Privacy Statement

Interact with us in other related ways, including any sales, marketing, or events.

Please read this Privacy Statement to understand your privacy rights and choices. We are responsible for determining how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you have any questions or concerns, please contact us at noeber03@gmail.com.

Key Points Summary

This summary provides the key points of our Privacy Statement, but you can find more detailed information on any topic by clicking the links after each point or using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or browse our Services, we may process your personal information depending on how you interact with us and the Services, your choices, and the products and features you use. Learn more about the personal information you disclose to us.

Do we process any sensitive personal information? Some information may be considered sensitive information. “Special” or “sensitive” in some jurisdictions, such as your racial or ethnic origin, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary, with your consent, or as permitted by applicable law. Learn more about the sensitive information we process.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and manage our Services, communicate with you, ensure security and prevent fraud, and comply with the law. With your consent, we may also use your information for other purposes. We only process your information when we have a legitimate reason to do so. Learn more about how we process your information.

In what situations and with what types of parties do we share personal information? In certain circumstances, we may share information with specific parties. Categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information secure? We have sufficient measures in place. We have implemented technical processes and measures to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other attackers will not steal your information. Unauthorized third parties will not be able to bypass our security measures or illegally collect, access, steal, or modify your information. Learn more about how we protect your information.

What rights do you have? Depending on your geographic location, applicable privacy laws may grant you certain rights regarding your personal information. Learn more about your privacy rights.

How to exercise your rights? The easiest way to exercise your rights is to… contact us. We will consider and process any requests in accordance with applicable data protection laws.

Want to learn more about how we handle the information we collect? Please read the full Privacy Statement.

Table of Contents

1. What information do we collect?

2. How do we process your information?

3. What is the legal basis for processing your personal information?

4. When and with whom do we share your personal information?

5. How do we handle your social media logins?

6. Will your information be transferred internationally?

7. How long do we retain your information?

8. How do we protect your information security?

9. Do we collect information from minors?

10. What are your privacy rights?

11. Do Not Track Controls

12. Do US residents have specific privacy rights?

13. Do we participate in the IAB Europe Transparency and Consent Framework?

14. Do we need to update this notice?

15. How to contact us regarding this notice?

16. How can you view, update, or delete the data we collect about you?

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register to use the Services, participate in activities on the Services, or otherwise contact us and express interest in obtaining information about us or our products and services.

Personal information provided by you. The personal information we collect depends on how you interact with us and our Services, your choices, and the products and features you use. The personal information we collect may include the following:

Name

Phone number

Email address

Mailing address

Job title

Username

Password

Contact preferences

Contact or authentication data

Billing address

Debit/credit card number

Information you provide when using our products (e.g., company name, company email, company address, company fax, company website, etc.)

Online survey records and details

Financial information (e.g., the last four digits of your debit or credit card number, billing history, billing address, card type, issuing bank, expiration date, issuing country/region)

Information in blog comments

Website URL

Interest in our marketing campaigns and products

Sensitive information. Where necessary, with your consent or as permitted by applicable law, we process the following categories of sensitive information:

Financial data

Payment data. If you choose to make a purchase, we may collect the data necessary to process your payment, such as your payment instrument card number and the security code associated with your payment instrument. All payment data is processed and stored by us. Stripe’s privacy statement can be found here: https://stripe.com/privacy.

Social media login data. We may provide you with the option to register using your existing social media account details (such as your Facebook, X, or other social media account). If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the “Social Media Account Information” section below. “How do we handle your social media login information?”

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected automatically

In short: We automatically collect some information when you visit our Services, such as your Internet Protocol (IP) address and/or browser and device characteristics. When you access, use, or browse our services, we automatically collect certain information. This information does not reveal your specific identity (such as your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country/region, location, how and when you use our services, and other technical information. We primarily need this information to maintain the security and proper functioning of our services and for our internal analytics and reporting.

The information we collect includes:

Log and Usage Data. Log and usage data refers to service-related, diagnostic, usage, and performance information that our servers automatically collect and record in log files when you access or use our services. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the services (such as date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take, such as the features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

Device Data. We collect device data, such as information about the computer, phone, tablet, or other device you use to access the services. Depending on the device used, this device data may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information, etc.

Location Data. We collect location data, such as information about the location of your device, which may be precise or imprecise. The amount of information we collect depends on the type of device and settings you use to access the services. For example, we may use GPS and other technologies to collect geolocation data to determine your current location (based on your IP address). You can choose to refuse our collection of this information by denying access to the information or disabling location settings on your device. However, if you choose to refuse, you may not be able to use certain features of the services.

2. How do we process your information?

In short: We process your information to provide, improve, and manage our services, communicate with you, ensure security and prevent fraud, and comply with the law. With your consent, we may also use your information for other purposes. We process your personal information for a number of reasons, depending on how you interact with our services, including:

To facilitate account creation and authentication, and to manage user accounts, we may process your information to allow you to create and log in to your account and ensure your account functions properly.

To provide and assist in providing services to users, we may process your information to provide you with the services you request.

To respond to user inquiries/provide user support, we may process your information to respond to your inquiries and resolve any issues you may encounter while using the requested services.

To send you administrative information. We may process your information to send you details about our products and services, changes to terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information for the following purposes: fulfilling and managing your orders, payments, returns, and exchanges made through the service.

To solicit feedback. We may process your information when necessary to solicit feedback and contact you regarding your use of our services.

To send you marketing and promotional communications. If you have consented to receive marketing communications, we may process the personal information you provide to us for marketing purposes. You can opt out of our marketing emails at any time. See “What are your privacy rights?” below for more information.

To deliver targeted advertising, we may process your information to develop and display advertisements. Personalized content and advertising are tailored based on your interests, location, and other information.

To protect our services, we may process your information to ensure the security and reliability of our services, including fraud monitoring and prevention.

To identify usage trends, we may process information about your use of our services to better understand how the services are used and to improve them.

To evaluate the effectiveness of our marketing and promotional campaigns, we may process your information to better understand how to provide you with the most relevant marketing and promotional campaigns.

To maintain or protect the vital interests of individuals. We may process your information when necessary to maintain or protect the vital interests of individuals, such as preventing harm.

To manage user accounts. We may use your information to manage and maintain our accounts.

To post user testimonials. We post user testimonials on our website, which may contain personal information. We will obtain your consent before using your name and testimonial content. If you wish to update or delete your review, please contact us at noeber03@gmail.com, and be sure to provide your name, review location, and contact information.

We process this information to enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or to fulfill our contractual obligations. This processing is necessary to ensure compliance with our terms and conditions of service.

We also respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to examine the data we hold to determine how to respond.

3. What legal basis do we rely on to process your information?

In short: We only process your personal information when we believe it is necessary and we have a valid legal basis to do so (i.e., legal basis) under applicable law, such as with your consent, to comply with laws, to provide you with services, to enter into a contract or fulfill our contractual obligations, to protect your rights, or to pursue our legitimate business interests.

If you are located in the European Union or the United Kingdom, this section applies to you.

The General Data Protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR) require us to explain the valid legal bases we rely on to process your personal information. Therefore, we may process your personal information based on the following legal bases:

Consent. We may process your information if you have given us permission (i.e., you consent to us using your personal information for a specific purpose). You can withdraw your consent at any time. Learn more about withdrawing consent.

Performance of a contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our services, or at your request before entering into a contract with you.

Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, and these interests do not override your interests, fundamental rights, and freedoms. For example, we may process your personal information for some of the following purposes:

Sending users information about special offers and discounts on our products and services

Developing and displaying personalized and relevant advertising content to our users

Analyzing how our users use our services to improve them and attract and retain users.

Supporting our marketing activities

Diagnosing problems and/or preventing fraudulent activity

Understanding how users use our products and services so that we can improve the user experience.

To achieve business objectives, comply with laws and regulations, and fulfill contractual obligations, we will implement our various policies.

Responding to legal requests

Legal obligation. We may process your information when we believe it is necessary to comply with a legal obligation, such as cooperating with law enforcement or regulatory agencies, exercising or defending our legal rights, or disclosing your information as evidence in our litigation.

Vital interests. We may process your information when we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving a potential threat to anyone’s personal safety. From a legal perspective, we are typically the “data controller” under European data protection law. The personal information described in this Privacy Statement is subject to this Privacy Statement because we determine the means and/or purposes of our data processing. This Privacy Statement does not apply to personal information that we process as a third-party “data processor” on behalf of our clients. In this case, our client, for whom we provide services and with whom we have a data processing agreement, is the “data controller,” and we process your personal information solely on their instructions. If you would like to learn more about our clients’ privacy practices, please read their privacy policies and direct any questions to them.

If you are located in Canada, this section applies to you.

We may process your information if you have explicitly authorized us to do so (for example, we may process your information). You explicitly agree to the use of your personal information for specific purposes, or where your consent can be inferred (e.g., implied consent). You can withdraw your consent at any time.

In certain exceptional circumstances, we may lawfully process your information without your consent, as permitted by applicable law, for example:

If collecting the information is clearly in the individual’s interest and consent cannot be obtained in a timely manner;

For investigation, fraud detection and prevention;

For business transactions that meet specific conditions;

If the information is contained in a witness statement and the collection of the information is necessary for the assessment, processing or settlement of an insurance claim;

To identify injured, ill or deceased persons and to contact next of kin;

If we have reasonable grounds to believe that someone has been, is, or may be a victim of financial abuse;

If it is reasonably expected that obtaining consent would impair the availability or accuracy of the information, and the purpose of collecting the information is reasonable, such as for investigating a breach of agreement or a violation of Canadian or provincial law;

If disclosure is required to comply with a subpoena, search warrant, court order or court rules relating to the production of records;

If the information was produced by an individual in the course of their work, business or profession, and the collection of the information is consistent with the purpose for which the information was produced;

If the collection is solely for journalistic, artistic or literary purposes;

If the information is publicly available and complies with relevant regulations.

4. When and with whom do we share your personal information?

In short: We may share information in the specific situations described in this section and/or with the following categories of third parties.

Vendors, consultants and other third-party service providers. We may share your data with third-party vendors, service providers, contractors or agents (“Third Parties”). Personnel who provide services to us or on our behalf and who need access to such information to perform their work. We have contracted with third parties to help protect your personal information. This means that they may not use your personal information in any way unless instructed by us. They will also not share your personal information with any third party. Organizations other than ourselves are also committed to protecting the data they hold on our behalf and retaining that data according to our instructions. Third parties must maintain the same level of protection as required by law, including the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework principles.

The categories of third parties with whom we may share personal information are as follows:

Advertising networks

Affiliate marketing programs

Cloud computing services

Communication and collaboration tools

Data analytics services

Data storage service providers

Financial and accounting tools

Order fulfillment service providers

Payment processors

Performance monitoring tools

Product engineering and design tools

Sales and marketing tools

Social networks

Testing tools

User account registration and authentication services

Website hosting service providers

We may also need to share your personal information in the following circumstances:

Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Statement. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business partners. We may share your information with business partners to offer you certain products, services, or promotions.

5. How do we handle your social media account logins?

In short: If you choose to register or log in to our services using a social media account, we may collect certain information about you.

Our services allow you to register and log in using third-party social media account information (such as your Facebook or X account). If you choose to do so, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider, but typically includes your name, email address, friends list, and profile picture, as well as other information you choose to make public on that social media platform.

We will only use the information we receive for the purposes described in this Privacy Statement or as otherwise explicitly explained to you in the relevant service. Please note that we have no control over, and are not responsible for, your third-party social media provider’s other uses of your personal information. We encourage you to review their privacy statements to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their websites and applications.

6. Will your information be transferred internationally?

In short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us and third parties with whom we may share your personal information (see “When and with whom do we share your personal information?” above) in the United States, Taiwan, the Philippines, Tunisia, and other countries.

If you reside in the European Economic Area (EEA), the United Kingdom, or Switzerland, these countries may not have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Statement and applicable law.

EU Commission Standard Contractual Clauses:

We have implemented measures to protect your personal information, including using the European Commission’s Standard Contractual Clauses for the transfer of personal information between our group companies and between us and our third-party vendors. These clauses require all recipients to protect all personal information originating from the European Economic Area or the United Kingdom that they process in accordance with European data protection laws and regulations. We can provide copies of the Standard Contractual Clauses upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners, and further details can be provided upon request. EU-U.S. and UK Extension to the EU-U.S. Data Privacy Frameworks and Swiss-U.S. Data Privacy Framework:

We comply with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data received from the European Union, the United Kingdom (and Gibraltar), and Switzerland. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles and the Swiss-U.S. Data Privacy Framework Principles. If there is any conflict between the terms in this privacy statement and the Data Privacy Framework Principles, the Principles shall govern. Learn more about the Data Privacy Framework program. To view our certification, please visit https://www.dataprivacyframework.gov/list.

Under the Data Privacy Framework, individuals in the EU, UK, and Switzerland have the right to request confirmation from us as to whether we maintain personal information relating to them in the United States. Upon request, we will provide you with access to the personal information we hold about you. You may also correct, amend, or delete the personal information we hold about you. Under the Data Privacy Framework, any individual who wishes to access, correct, amend, or delete inaccurate data transferred to the United States should direct their inquiries to: noeber03@gmail.com. If a request for deletion of data is received, we will respond within a reasonable timeframe.

If we receive your personal information in the United States and subsequently transfer that information to a third-party agent acting on our behalf, and that third-party agent processes your personal information in a manner inconsistent with the Data Privacy Framework Principles, we will be liable unless we can prove that we are not responsible for the event giving rise to the damage.

Before sharing your data with third parties other than our agents, or for purposes other than those for which it was originally collected, we will provide you with an opt-out option, or an opt-in option for sensitive data. To restrict the use and disclosure of your personal information, please submit a written request to noeber03@gmail.com.

In accordance with the Data Privacy Framework Principles, we commit to resolving complaints about your privacy and our collection or use of your personal information transferred to the United States under the Data Privacy Framework. Individuals in the EU, UK, and Switzerland with inquiries or complaints regarding the Data Privacy Framework should first contact us by email at noeber03@gmail.com. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, you may contact our independent dispute resolution body. Headquartered in the United States, BBB National Programs. Please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information or to file a complaint, please contact us.

If your Data Privacy Framework complaint cannot be resolved through the channels described above, in certain circumstances, you may be able to pursue binding arbitration for certain residual claims that have not been resolved through other redress mechanisms.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). In certain circumstances, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Please be sure to review the following sections of this Privacy Statement for more detailed information about our participation in the Data Privacy Framework program:

What information do we collect? Learn more about the types of personal data we collect.

How do we process your information? Click here to learn about the purposes for which we collect and use your personal information.

When and with whom do we share your personal information? To learn more about the types or identities of third parties to whom we disclose personal information and the purposes for doing so.

What are your privacy rights? Learn more about individuals’ rights to access their personal data.

7. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy statement, unless otherwise required by law.

Unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements), we will only retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy statement. No purpose in this notice will require us to keep your personal information for longer than the period of time that users have an account with us.

When we no longer need to process your personal information for legitimate business purposes, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How do we protect your information?

In short: We aim to protect your personal information through the following systems: organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures to protect the security of any personal information we process. However, despite our security measures and efforts to protect your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, and therefore we cannot promise or guarantee that hackers, cybercriminals, or other attackers will not steal your information. Unauthorized third parties cannot breach our security defenses or illegally collect, access, steal, or modify your information. While we will do our best to protect your personal information, you still assume the risk of transmitting personal information through our services. You should only access our services in a secure environment.

9. Do we collect information from minors?

In short: We do not knowingly collect or market data to anyone under the age of 18.

We do not knowingly collect, solicit, or market products/services to children under the age of 18, nor do we knowingly sell such personal information. By using this service, you represent that you are at least 18 years of age, or that you are the parent or guardian of a minor and consent to that minor’s use of this service. If we discover that we have collected personal information from a user under the age of 18, we will deactivate that account and take reasonable steps to immediately delete such data from our records. If you believe we may have collected data from a child under the age of 18, please contact us at noeber03@gmail.com.

10. What are your privacy rights?

In short: Depending on your state/province of residence in the United States or other countries, some regions, such as the European Economic Area, the United Kingdom, Switzerland, and Canada, grant you certain rights that allow you to better access and control your personal information. Depending on your country, province, or state, you can view, change, or terminate your account at any time. In certain regions (such as the European Economic Area, the United Kingdom, Switzerland, and Canada), you have certain rights under applicable data protection laws. These rights may include: (i) requesting access to and obtaining a copy of your personal information; (ii) requesting correction or deletion; (iii) restricting the processing of your personal information; (iv) data portability, where applicable; and (v) not being subject to automated decision-making. In some cases, you also have the right to object to the processing of your personal information. You can make such requests by contacting us using the contact details provided in this section, “How can you contact us regarding this notice?” below.

We will consider and process any requests in accordance with applicable data protection laws.

If you are located in the European Economic Area or the United Kingdom, and you believe that we have processed your personal information unlawfully, you also have the right to lodge a complaint with your member state data protection authority or the UK data protection authority.

If you are in Switzerland, you can contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we rely on your consent to process your personal information, this may be express consent and/or implied consent, depending on applicable law. You have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in this section, “How can you contact us regarding this notice?” below, or by updating your preferences.

However, please note that this will not affect the lawfulness of processing before the withdrawal, nor will it affect whether personal information processing is carried out on other lawful grounds besides consent, where permitted by applicable law.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send you, or by contacting us using the contact information provided in this section. After following the steps shown below under “How can you contact us regarding this notice?”, you will be removed from our marketing list. However, we may still contact you – for example, to send you necessary service messages related to account management and use, respond to service requests, or for other non-marketing purposes.

Account Information

If you wish to view or change the information in your account at any time, or terminate your account, you can:

Log in to your account settings and update your user account.

Please contact us using the contact information provided.

noeber03@gmail.com

If you request to terminate your account, we will deactivate or delete your account and all information in our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

If you have any questions or comments about your privacy rights, please email [email address]. noeber03@gmail.com.

11. Do Not Track Controls

Most web browsers and some mobile operating systems and mobile applications include a “Do Not Track” (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  Currently, there is no uniform technology standard for recognizing and implementing DNT signals that has been finalized. Therefore, we do not currently respond to “Do Not Track” (DNT) browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Statement.

California law requires us to inform you how we respond to web browser “Do Not Track” (DNT) signals. Because there is currently no industry or legal standard governing this, we do not currently respond to DNT signals.

12. Do US residents have specific privacy rights?

In short: If you are a resident of California, you have the right to request access to and obtain details about the personal information we hold about you and how we process it, correct inaccuracies, obtain copies, or request the deletion of your personal information. You also have the right to withdraw your consent to our processing of your personal information. In some cases, these rights may be limited by applicable law. See below for more information.

Categories of Personal Information We Collect

In the past twelve (12) months, we have collected the following categories of personal information:

Category | Examples | Collected

A. Identifiers

Contact information, such as real name, alias, postal address, telephone or mobile number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

Yes

B. Personal information as defined in the California Customer Records Act

Name, contact information, educational background, work experience, employment history, and financial information

Yes

C. Protected classification characteristics under state or federal law

Gender, age, date of birth, race and ethnicity, nationality, marital status, and other demographic data

Yes

D. Commercial information

Transaction information, purchase history, financial details, and payment information

Yes

E. Biometric information

Fingerprints and voiceprints

No

F. Internet or other similar network activity

Browsing history, search history, online behavioral interest data, and interactions with us and other websites, applications, systems, and advertisements

Yes

G. Geolocation data

Device location

Yes

H. Audio, electronic, visual, or similar information

Images, audio, video, or call recordings related to our business activities

Yes

I. Professional or employment-related information

To provide you with business-level services, we require your business contact information, and if you apply to join our company, your job title, work experience, and professional qualifications.

No

J. Education information

Student records and directory information

No

K. Inferences drawn from collected personal information

Information inferred from any of the personal information collected above to create a profile or summary, such as about an individual’s preferences and characteristics. No

L Sensitive Personal Information: Account login information and debit or credit card numbers

Yes

We only collect sensitive personal information within the scope defined by applicable privacy laws or for purposes permitted by law, or with your consent. Sensitive personal information may be used for other specific purposes or disclosed to service providers or contractors. You have the right to restrict our use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information to infer your characteristics.

We may also collect other personal information beyond the categories listed above through your interactions with us, such as in-person, online, telephone, or email interactions:

Seeking assistance through our customer support channels;

Participating in customer surveys or contests; and

Assisting us in providing services and responding to your inquiries.

We will use and retain the personal information collected as needed to provide services or for the following purposes:

Category A – As long as the user has an account with us

Category B – As long as the user has an account with us

Category C – As long as the user has an account with us

Category D – As long as the user has an account with us

Category F – As long as the user has an account with us

Category G – As long as the user has an account with us

Category H – As long as the user has an account with us

Category L – We may retain debit or credit card numbers for a period after the service ends, in accordance with applicable law.

Sources of Personal Information

Learn more about the sources of personal information we collect in the section “What information do we collect?”

How We Use and Share Personal Information

Please see this section for more information on how we use your personal information. “How do we process your information?”

We collect and share your personal information in the following ways:

Beacons/Pixels/Tags

Is your information shared with others?

We may disclose your personal information to service providers pursuant to written contracts between us and those service providers. For more information on how we disclose personal information, please see the relevant section. “When and with whom do we share your personal information?”

We may use your personal information for our own business purposes, such as conducting internal research for technological development and demonstrations. This is not considered “selling” your personal information. In the past twelve (12) months, we have disclosed the following categories of personal information to third parties for business or operational purposes:

Category A. Identifiers

Category B: Personal information as defined in the California Customer Records Act

Category C: Characteristics of protected classifications under state or federal law

Category D: Commercial information

Category F: Internet or other electronic network activity information

Category G: Geolocation data

Category H: Audio, electronic, visual, and similar information

Category L: Sensitive personal information

The categories of third parties to whom we disclose personal information for business or operational purposes can be found in the following section: “When and with whom do we share your personal information?”

In the past twelve (12) months, we have sold or shared the following categories of personal information to third parties:

Category A. Identifiers

Category B: Personal information as defined in the California Customer Records Act

Category C: Characteristics of protected classifications under state or federal law

Category D: Commercial information

Category F: Internet or other electronic network activity information

Category G: Geolocation data

The categories of third parties to whom we sell personal information include:

Data analytics services

The categories of third parties with whom we share personal information include:

Data analytics services

Your Rights

Under the data protection laws of certain US states, you have certain rights. However, these rights are not absolute, and in some cases, we may refuse your request in accordance with the law. These rights include:

The right to know whether we are processing your personal data

The right to access your personal data

The right to correct inaccuracies in your personal data

The right to request the deletion of your personal data

The right to obtain a copy of the personal data you have previously shared with us

The right to non-discrimination when exercising your rights

The right to opt out of the use of your personal data for targeted advertising (or sharing as defined under California privacy law), the sale of personal data, or profiling for decisions that produce legal or similarly significant effects (“profiling”)

Depending on the laws of your state of residence, you may also have the following rights:

The right to obtain a list of the categories of third parties to whom we have disclosed personal data (to the extent permitted by applicable law, including… California privacy law)

The right to limit the use and disclosure of sensitive personal data (to the extent permitted by applicable law, including California privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by sending an email to [email address]. noeber03@gmail.com, or refer to the contact information at the bottom of this document.

We will honor your opt-out preference if you have enabled the Global Privacy Control (GPC) opt-out signal in your browser.

Under certain U.S. state data protection laws, you may designate an authorized agent to make requests on your behalf. We may deny a request from an agent who fails to provide proof that they have been legally authorized to act on your behalf under applicable law.

Request Verification

Upon receiving your request, we will need to verify your identity to confirm that you are the same person whose information is recorded in our system. We will only use the personal information you provide in your request to verify your identity or your authority to make the request. However, if we are unable to verify your identity with the information we already have, we may ask you to provide additional information to verify your identity and for security or fraud prevention purposes.

If you submit a request through an authorized agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide written authorization signed by you to submit such requests on your behalf.

California “Shine the Light” Law

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes, and the names and addresses of all third parties with whom we shared personal information in the preceding calendar year. If you are a California resident and wish to make such a request, please submit your request to us in writing using the contact information provided in the section “How can you contact us about this notice?”

13. Do we participate in the IAB Europe Transparency and Consent Framework?

We participate in the IAB Europe Transparency and Consent Framework and comply with its specifications and policies. Our User Consent Management Platform identification number is 412.

14. Do we need to update this notice?

In short: Yes, we will update this notice as needed to comply with relevant laws.

We may update this Privacy Statement from time to time. The updated version will be identified by an updated version date at the top of this Privacy Statement. If we make significant changes to this Privacy Statement, we may notify you by posting a notice in a prominent location or by sending you a direct notification. We recommend that you review this Privacy Statement regularly to understand how we protect your information.

15. How to contact us regarding this notice?

If you have any questions or comments about this notice, you can contact us by email at noeber03@gmail.com, by phone at +86 15937386999, or by mail at:

Zhizhidianzi Company

2nd Floor, Torch Park, High-tech Zone, Muyue District, Xinxiang City, Henan Province, China

16. How can you view, update, or delete the data we collect about you?

You have the right to request access to your personal information that we collect, understand how we process this information, correct inaccuracies, or delete your personal information. You may also have the right to… request that we restrict the use or disclosure of your personal information or you may withdraw your consent to our processing of your personal information. In some cases, applicable law may limit these rights. To view, update, or delete your personal information, please contact us.