Privacy Policy of Guanting App

Release Date: April 2026

Effective Date: April 2026

Shenzhen Guanting Technology Co., Ltd. (Registered Address: Room 1321, Guoxin Investment Building, No. 07 Gaoxin Nanqi Road, High-tech Zone Community, Yuehai Subdistrict, Nanshan District, Shenzhen City), as the operator of Guanting App, attaches great importance to the protection and management of users' personal information. This Policy aims to clearly inform users of the rules for processing personal information, security safeguards, and relevant rights enjoyed by users during the provision of our products and services. All operations are carried out in compliance with current national laws and regulations.

This Policy applies only to the services related to Guanting App provided within the territory of the People's Republic of China (excluding Hong Kong, Macao and Taiwan regions). For services used by users in overseas regions, the corresponding privacy rules shall be separately formulated by the relevant operating entity, which shall not be related to this Policy. Personal information referred to in this Policy refers to relevant information that can identify the identity of natural persons as defined by law. Our collection, use, storage, transmission and other acts of information during the whole service process are subject to legal supervision and user supervision.

Before using Guanting App, users shall carefully read and fully understand the content of this Policy. If users start to use the products and services, they shall be deemed to have accepted all the terms agreed in this Policy.

1. Rules for Collection and Use of Personal Information

The core purpose of our information collection is to ensure the normal operation of services, optimize product functions and improve user experience. All information collection acts follow the principles of legality, legitimacy and necessity, and we do not collect personal information irrelevant to services. Information sources mainly include three channels: active provision by users, automatic acquisition during service use, and compliant provision by legitimate partners.

According to different usage scenarios, our services are divided into basic services and extended services. Basic services are the core functions for the operation of the App; refusal to provide relevant information will result in the failure of normal use of services. Extended services are additional functions, and users can independently choose whether to provide information. Non-use of extended services will not affect the normal operation of basic functions.

1.1 Collection of Account Registration Information

When registering as an official user of Guanting, users need to provide account-related information, including nickname, mobile phone number and email address. The above information is necessary for account creation. Gender, birthday, country or region are supplementary information, which users can choose to fill in according to their own wishes, and failure to fill in will not affect the completion of the registration process.

If users only use the App as visitors, they do not need to register an account or provide the above information, and can directly use basic service functions such as headset connection and language switching.

1.2 Collection of Information During Service Use

When users use various functions of Guanting App, we will collect corresponding information according to functional requirements:

- To match the system language of the user's device and display adapted policy content and function descriptions, we will obtain the system language information of the user's device;

- To realize the connection, function control and device management between the App and Bluetooth headsets, we will collect the Bluetooth address, product serial number and firmware version information of the headset, and obtain location information to complete the search and pairing of nearby devices;

- To complete product registration, identity verification and after-sales problem handling, we will collect users' names, contact information, product serial numbers and other information to ensure the accuracy of service connection;

- To collect user experience feedback and optimize service quality, we will collect personal information, device information, usage feedback and other contents filled in the research questionnaires on the premise of users' voluntary participation;

- To follow up on user feedback and handle service demands, we will keep communication records and relevant information, and reply through the contact information provided by users;

- We will send users service notifications, product updates, function promotions and other information through the mobile phone numbers and email addresses provided by users during registration.

In addition to personally identifiable personal information, we will collect data such as page access times, stay duration and operation behaviors to analyze service operation and optimize product design. Such data is not directly associated with personal identity. If used in combination with personal information, it shall be implemented in accordance with personal information protection rules.

1.3 Specifications for Device Permission Invocation

To ensure the normal use of functions, the App will apply for invoking some device permissions, and users can independently manage the enabled status of permissions:

- **Bluetooth Permission**: Necessary for realizing the core functions of headset connection and device control. Bluetooth permission must be enabled; otherwise, core services cannot be used;

- **Camera Permission**: Applied for enabling only when users need to take and upload pictures, and users can turn it off in device settings at any time;

- **Album Permission**: Applied for enabling only when users need to upload local pictures and files. Closing it will not affect the use of other functions.

2. Instructions for the Use of Local Storage Technologies

To improve user convenience, we will adopt local storage, Cookie and other related technologies to record user login status, usage preferences, function configurations and other information, reduce repeated operations and improve service fluency. Such technologies are only used for service optimization and not for illegally obtaining user information.

Users can adjust device settings to manage local storage functions according to their own needs. If relevant technologies are turned off, some functions relying on such technologies may not work normally, please understand.

3. Rules for Sharing, Transfer and Disclosure of Personal Information

3.1 Information Sharing

We will not take the initiative to share users' personal information with third parties, and shall conduct compliant sharing only under the following circumstances: explicit requirements of laws and regulations, requirements of administrative and judicial organs in accordance with the law, obtaining explicit authorization from users, providing necessary information to service partners to realize user needs, and sharing necessary service information with affiliated companies. Partners can only use information within the authorized scope and shall not use it for other purposes.

3.2 Information Transfer

In principle, we will not transfer users' personal information. In special circumstances such as company merger, acquisition, bankruptcy and liquidation involving information transfer, we will require the transferee to continue to abide by this Policy to protect user information, or obtain user authorization again.

3.3 Information Disclosure

We will not publicly disclose users' personal information unless we obtain explicit consent from users or it is required to be disclosed in accordance with laws and regulations.

3.4 Compliance Exceptions

We may legally process information without further obtaining user consent under circumstances such as involving national security, public interests, criminal investigation, urgent protection of personal and property safety, information voluntarily disclosed by users, and information obtained from legally public channels. After information is anonymized and de-identified and cannot identify specific users, sharing, transfer and disclosure acts shall not be restricted by this Policy.

Third-party SDK information

4. Storage and Management of Personal Information

We strictly abide by legal provisions, and all user personal information collected in the territory is stored within the territory of mainland China, and shall not be arbitrarily stored overseas. If cross-border transmission is really necessary for business needs, we will complete compliance procedures such as security assessment and filing in accordance with legal requirements.

The storage period of personal information shall be the shortest period required for realizing service purposes and legal provisions. After the expiration of the period, we will delete or anonymize the information. For information that cannot be deleted immediately due to technical restrictions or needs to be retained in accordance with legal provisions, we will stop other processing acts and only conduct secure storage and protection.

5. Security Safeguards for Personal Information

We have established a comprehensive information security protection system to protect user information security through technology, management and personnel dimensions. We adopt technical means such as encrypted storage, permission control and security audit to prevent unauthorized access, use and disclosure of information; conduct security audits on partners, and clarify information protection responsibilities through contractual agreements; regularly carry out employee privacy protection training to strengthen information security awareness.

The Internet environment has unforeseeable risks, and we cannot absolutely guarantee the absolute security of information transmission, but we will make every effort to fulfill security protection obligations. In case of security incidents such as information leakage, damage or loss, we will immediately start the emergency response process, inform users in accordance with legal requirements, and report the disposal situation to regulatory authorities.

Users shall properly keep account, password and other information to avoid information leakage due to improper storage. If any abnormal use of account or information leakage is found, users should contact us immediately through the official email for handling.

6. Users' Rights to Personal Information

Users enjoy the right to manage personal information in accordance with the law, and may exercise such rights through in-app functions or official email applications. We will respond and handle within 7 working days after completing identity verification:

- Inquire, correct and supplement personal information to ensure the accuracy of information;

- Delete personal information, which will be handled in a timely manner under circumstances compliant with legal provisions;

- Withdraw granted authorization consent, and may turn off device permissions or withdraw all authorizations in the App;

- Obtain a copy of personal information and apply for exporting relevant information;

- Apply for account cancellation. After account cancellation, we will stop providing services and delete or anonymize information in accordance with regulations.

We will legally refuse to respond to relevant applications under statutory circumstances such as involving national security, public interests, criminal investigation, trade secrets, malicious abuse of rights. No fees will be charged for reasonable requests, and cost fees may be charged for repeated or excessive requests.

7. Rules for Cross-border Transmission of Personal Information

In principle, the collection, processing and storage of personal information of domestic users shall be completed domestically. If it is really necessary to transmit information overseas due to business needs, we will strictly comply with national laws and regulations to carry out compliance work such as data exit security assessment, signing of standard contracts, completion of filing and certification, and fully protect users' information rights and interests.

8. Protection of Minors' Information

Our products and services are not promoted to minors, and we do not take the initiative to collect or use minors' personal information. If a guardian finds that a minor has used the service without permission and submitted information, he/she may contact us through the official email, and we will immediately delete the relevant information and terminate the corresponding service.

9. Update of Privacy Policy

We may update this Privacy Policy due to adjustments of laws and regulations, service function upgrades, technical iterations and other reasons. When material changes occur to the Policy, we will inform users through pop-ups, announcements and other means to obtain user authorization again. Users can judge whether the Policy is updated by the effective date, and continued use of the service shall be deemed to have accepted the updated Policy.

10. Contact Information

If you have any questions or suggestions about this Policy, or need to exercise personal information rights or file complaints and reports, please contact us via email at guanting@clise.cn or call the customer service hotline 400-960-9601. We will reply and handle in a timely manner in accordance with laws and regulations.