Monster Pub Privacy Policy

The Policy is applicable to Monster Pub APP product and relevant services of Sistalk (Beijing) Co., Ltd.

Latest date updated: November 17, 2021

Effective date: November 17, 2021

In case of any doubt, opinion, or suggestion regarding the privacy policy or relevant matters, you may contact us by the following means or other means provided by the platform:

Email of director of personal information protection: support@monsterpub.com

The privacy policy will help you understand the following contents:

0. Foreword

1. How do we collect and use your personal information

2. How do we entrust, share, transfer, and disclose your personal information

3. How do we protect your personal information

4. Your rights

5. How do we deal with personal information of the underage

6. How do we store your personal information

7. Revision and notification of privacy policy

8. Statement on SDK Technology

9. How to contact us

10. Scope of application

Sistalk (Beijing) Co., Ltd. (hereinafter referred to as “we”) are deeply aware of the importance of personal information to you. We will spare no effort to protect your personal information and privacy security pursuant to the laws and regulations. We are dedicated to maintaining your trust in us, and will abide by the following principles to protect your personal information: principle of integration of power and responsibility, principle of definite purpose, principle of selected consent, principle of least sufficiency, principle of security ensuring, principle of subject participation, principle of openness and transparency, etc. We also undertake to adopt corresponding security measures to protect your personal information based on mature security solutions in the industry.

We hope you read carefully and understand fully the privacy policy prior to using our products and services in order to make the proper choice. Once you start using our products and services, you shall be deemed as fully understanding and agreeing to the privacy policy. The privacy policy is applicable to the information collected for products and relevant services of Sistalk (Beijing) Co., Ltd. only, instead of the information collected for third-party services accessed via us. We will strictly screen and choose third-part services that comply with the privacy policy stipulated by laws and regulations.

0 Foreword

We will keep strictly confidential the user information collected, and establish and improve user information protection system to provide every user with reliably and secure services;

1. Clarity

We will try our best to use plain and easy text to explain the privacy policy for you so that you may understand how do we protect and deal with your information collected more clearly.

2. Protection of rights

We will take sufficient and rational measure to protect your privacy rights.

3. Respect to users

We respect the freely exercise of option, right to know, and other rights among users, and allow you to manage your personal information.

4. Necessary security

We will acquire necessary information only, and use such information to provide you with secure and detailed services.

5. Timeliness and wholeheartedness

We will listen to your inquiry at any time and answer your question as soon as possible.

We hope you read the Privacy Policy (hereinafter referred to as “the Policy”) carefully and understand in detail how do we collect and use information, in order to better understand our services and to show your true representations as to whether to choose the services and what service you choose. Please contact us in case of any questions.

I. How do we collect and use your personal information

Personal information refers to the information of all kinds recorded in electronic or other form to identify specific natural person or reflect the activity of the specific natural person independently or jointly with other specific information, including name, date of birth, ID No., personal biometric information, address, contact information, communication record and content, account, password, property information, credit information, track, housing information, health and physiological information, trade information, etc.

To bring you better product and service experience, we keep improving our technology. As a result, we might, from time to time, promote new or optimized functions which might need to collect and use new personal information, or to change the purpose or means of using personal information. Therefore, we will explain to you the purpose, scope, and means of collection of corresponding information including but not limited to updating the Policy and page prompt, and provide you with the means to agree based on independent choice, and collect and use such information after receiving your express consent. In the process, if you hold any doubt, opinion, or suggestion, you may contact us via the contact information we provide. We will answer as soon as possible.

The type of personal information we collect and the rules of collecting and using personal information are shown as follows:

(I) Signup and login

1. When you sign up for the platform and relevant services, we will collect your email, Android ID, IMSI, IMEI, OAID, Mac address, IP address, intended user name and password to create a platform account. If you choose to log in directly via third-party account, we will acquire your third-party account information (including but not limited to nickname, portrait and gender) from the third party based on your authorization, and bind it to your platform account so that you may log in directly via third-party account and use our product or service. We will use your relevant information within the scope of your authorization. When you sign up for and use our services, provision of the following extra personal information will help us provide better service and experience, including: gender, date of birth, constellation, and location. The aforesaid information you provide will be authorized to us during the service period. When you actively cancel the account, we will make it anonymous or delete your personal information as soon as possible pursuant to laws and regulations.

(II) Displaying and promoting content or service to you

To improve our product or service and to provide you with personalized information searching and relevant services, we will collect necessary log information, mainly including:

1. The behavioral information of your operation or use: click, follow, search, and browse

2. Information you provide voluntarily: feedback, post, like, and comment

If you don’t accept personalized information searching and relevant services, we have introduced to you the detailed procedure to disable it in [your rights] in the Fourth Part hereunder.

(III) Providing you with information release and interactive service

1. When you post a picture or make a comment, we will collect the information posted and display your nickname, portrait, and the content and information posted.

2. When you post a picture, we will request your authorization for camera, album, microphone, and network status viewing. If you reject, you will be unable to use the function, but it will not affect other functions.

3. When you choose to follow a person you are interested in, we will collect your log information content including your follow, share history, etc. to realize the aforesaid function and the purpose of clearly notify.

(IV) Purpose of providing security guarantee

To provide you with safer and more trustworthy product and use environment, and to provide fine and reliable service and information, we will collect the information on the product or service you use and how you use them, and correlate the information, including:

1. Device information

When you are using our products and relevant services, to provide you with services, interactive display, search result, and account abnormality identification more suited to your need, maintain normal running of product, and guarantee your account security, we will receive and record the information related to the device you use (including device model, hardware SN, OS version, setting parameter, device configuration, International Mobile Subscriber Identity (IMSI), unique identifier (IMEI, OAID, AndroidID), network device hardware address (MAC address), device network information, device environment software & hardware feature information, WLAN access point, Bluetooth, base station, network access mode, type, and status, and network quality data) based on your specific authorization in software installation and use. As for the information related to the device location (IP address, geographic location), as our service is the mobile social networking service based on geographic location, your successful signup of “platform” account shall be deemed as authorizing us to access, publicize, and use your IP address.

2. Log information

When you are using our products and relevant services, we will automatically collect your detailed use of the products or services and record the information as relevant network log, including your browse, click, search, follow, share, post, as well as IP address, browser type, network service provider information, language, date and time of visit, and your Internet history. Please pay attention that specific natural person cannot be identified with device information and log information only. Therefore, the individual device information and log information do not refer to “personal” information hereunder. If we use the information together with other information to identify a specific natural person or use it together with personal information, during the combined use, the information shall be deemed as personal information. We will anonymize and de-identify such personal information unless authorized by you or stipulated by laws and regulations. To provide you with information display and push which are more convenient and more suited to your personal need, we will extract your preferences based on your device information and service log information, and form indirect group portrait based on the featured tags to display and push information.

3. When you contact us, we might save your communication/phone record and content as well as your contact information for the purpose of contacting you or solving your problem. We might also record the solution and result of relevant problem.

4. To improve your security of using the services from us and our affiliated companies and partners, to protect the personal and property of you or other user or public from harm, to better prevent phishing site, fraud, loophole, computer virus, hacking, network invasion, or other security risks, and to more accurately identify violations of laws and regulations or our protocols, we might use or integrate your user information, trade information, device information, relevant network log, and information shared by our affiliated company and partner under your authorization or pursuant to law to further comprehensively judge the trade risk of your account, to check your identity, to detect and prevent security incident, and to lawfully take necessary measures for recording, auditing, analysis, and disposal.

5. Please understand, as our business develops, we might adjust our product functions and services. In principle, when a new function or service is related to the function or service we currently provide, our collection and use of personal information will be directly or rationally related to our original purpose. If it is not directly or rationally related to our original purpose, we will notify you again on the collection and use of your personal information, and ask again for your consent.

(V) Other purposes

1. If the information you provide contains the personal information of other users, you make sure to have been legally authorized before providing it to the platform.

2. If we use your information for other purposes unspecified hereunder, or use the information collected due to specific purpose for other purposes, or voluntarily acquire your personal information from third parties, we will ask for your consent in advance.

3. If we have indirectly acquired your information from a third party, we will expressly ask the third party in writing to collect the information after acquiring your consent lawfully, and notify you the content of information shared. Besides, as for sensitive information, your express confirmation is required before it is provided for us, and the third party shall make undertakings on the legality and compliance of the source of personal information. If the third party commits any violation or causes your personal information to disclose, we will expressly ask the third party to assume the corresponding legal liabilities; meanwhile, our professional security team will protect the personal information (including sensitive information classification, sensitive information access control, sensitive information encrypted storage, etc.). We will take protective measures not lower than that we take for the personal information of our own users, to protect the personal information we acquire indirectly.

4. We might use the information collected via certain functions for our other services, including: we use the information collected from your use of our certain function or service on another function or service we might provide you with, including display of advertisement, prompt on information security of the content you’ve read, generating indirect group portrait based on feature tags, and providing more precise and personalized services and contents. If we use your personal information beyond the purpose we claim upon collection or the scope directly or rationally related, we will notify you again and ask for your express consent before using that personal information.

5. APP device call

Authorization to read and write external memory: when you use the portrait setting or send image in Android APP, you may enable the authorization to store or save image or file. If you don’t enable it, you will be unable to use the functions related to reading or buffering of memory card, but other services will not be affected.

Album authorization: when you use Android or IOS APP to set portrait or send image, you may enable the album authorization to upload the image from device. If you don’t enable the authorization, you will be unable to use functions related to picture upload and sending, but other services will not be affected.

Camera authorization: when you use Android or IOS APP to set portrait or send image, you may enable camera authorization for real-time shooting and upload of image for portrait setting and image sending. If you don’t enable the authorization, you will be unable to use functions related to photo shooting, but other services will not be affected.

Location authorization: when you use the remote control function in Android or IOS APP, you may enable location authorization for the function to view the approximate distance between the parties of remote control. If you don’t enable the authorization, you will be unable to use the function, but other services will not be affected.

Location authorization: when you use Android APP, we will acquire the authorization to connect the APP to Monster Pub hardware device and provide you with the function to directly control the device with APP. If you don’t enable the authorization, we will be unable to use the function, but other services will not be affected.

Microphone authorization: when you use the voice service in Android or IOS APP, you may enable microphone authorization to record voice bar on your personal information, send voice message, or start voice communication. If you don’t enable the authorization, you will be unable to use the functions related to voice input, but other services will not be affected.

Bluetooth authorization: when you use Android or IOS APP, we will ask for the authorization to connect APP to Monster Pub hardware device to provide you with the function to directly control the device with APP. If you don’t enable the authorization, you will be unable to use the function, but other services will not be affected.

Authorization to view network status: when you use Android or IOS APP, we will ask for the authorization to view the status of all networks, such as the existing and connected networks. If you don’t enable the authorization, you will be unable to receive the prompt on changes in network status in a timely manner, but other services will not be affected.

You understand and agree that the aforesaid services might need you to enable access to your location information (geographic location), camera, album & storage, microphone (voice), or network status to realize the collection and use of information involved in the authorities. You may view the status of the aforesaid authorities in “setting-APP authorization” in your device, and may solely decide to enable or disable them at any time. Please pay attention that enabling any authorization represents you authorizing us to collect and use relevant personal information to provide corresponding services. Once you disable any authorization, the authorization is canceled, and we will no longer collect and use relevant personal information based on the corresponding authorization or provide you with the corresponding services. Nonetheless, your decision to disable the authorization will not affect the previous collection and use of information based on your prior authorizations.

You understand and agree that the function and service scenario we provide you with keep upgrading. If we fail to express you the personal information we need to collect in the aforesaid scenarios, we will express the content, scope, and purpose of information collection to you separately by means of page prompt, interactive design, etc., and ask for your consent.

Application for permissions and instructions for use in Android operating system

For the purpose of keeping Monster Pub running safely and stably, we may apply for or use relevant permissions in Android operating system: to safeguard your right to know, we will describe the relevant permissions that our product may apply for or use in the operating system as follows, so you can manage the relevant permissions as needed:

1. Access the Internet

android.permission.INTERNET

• Description of the permission function: access the Internet, which may cause GPRS traffic.

2. Record audio

android.permission.RECORD_AUDIO

• Description of the permission function: record audio with the mobile phone or headset mic.

3. Access network state

android.permission.ACCESS_NETWORK_STATE

• Description of the permission function: access the network information state, for example, whether the current network connection is valid.

4. Access WiFi state

android.permission.ACCESS_WIFI_STATE

• Description of the permission function: access the current WiFi connection state and WLAN hotspot information.

5. Change WiFi state

android.permission.CHANGE_WIFI_STATE

• Description of the permission function: change the WiFi state.

6. Wake lock

android.permission.WAKE_LOCK

• Description of the permission function: allow the app to run as a background process after the mobile phone screen is locked.

7. Modify audio settings

android.permission.MODIFY_AUDIO_SETTINGS

• Description of the permission function: modify audio settings.

8. Allow autorun

android.permission.RECEIVE_BOOT_COMPLETED

• Description of the permission function: allow the app to run automatically at boot-up.

9. Write external storage

android.permission.WRITE_EXTERNAL_STORAGE

• Description of the permission function: allow the app to write the external storage, for example, write files to the SD card.

10. Use vibration

android.permission.VIBRATE

• Description of the permission function: allow to vibrate.

11. Make calls

android.permission.CALL_PHONE

• Description of the permission function: allow the app to enter a phone number in the non-system dialer.

12. Use camera

android.permission.CAMERA

• Description of the permission function: allow to access the camera to take photos.

13. Use bluetooth

android.permission.BLUETOOTH

• Description of the permission function: allow the app to connect to paired Bluetooth devices.

14. Bluetooth administration

android.permission.BLUETOOTH_ADMIN

• Description of the permission function: allow the app to find and pair with new bluetooth devices.

15. Access fine location

android.permission.ACCESS_FINE_LOCATION

• Description of the permission function: collect GPS information through GPS chip with an accuracy of positioning within 10m.

16. Get tasks

android.permission.GET_TASKS

• Description of the permission function: allow the app to get the currently running or recently run apps.

Application for permissions and instructions for use in iOS operating system

For the purpose of keeping Monster Pub running safely and stably, we may apply for or use relevant permissions in iOS operating system: to safeguard your right to know, we will describe the relevant permissions that our product may apply for or use in the operating system as follows, so you can manage the relevant permissions as needed:

1. NSBluetoothAlwaysUsageDescription

• Description of the permission function: connect to the bluetooth devices via bluetooth.

2. NSBluetoothPeripheralUsageDescription

• Description of the permission function: connect to the bluetooth devices via the bluetooth (compatible with iOS 13 or earlier versions).

3. NSCameraUsageDescription

• Description of the permission function: use the camera.

4. NSLocationAlwaysUsageDescription

• Description of the permission function: allow the app to access your location all the time.

5. NSLocationUsageDescription

• Description of the permission function: allow the app to access your location.

6. NSLocationWhenInUseUsageDescription

• Description of the permission function: allow the app to access your location only when it is used.

7. NSMicrophoneUsageDescription

• Description of the permission function: use the microphone.

8. NSPhotoLibraryAddUsageDescription

• Description of the permission function: add content to the album.

9. NSPhotoLibraryUsageDescription

• Description of the permission function: read the content in the album.

(IV) Exception of authorized consent

You fully understand and agree that your authorized consent is not needed for us to collect and use your personal information in the following cases, and that we might disagree with your request for correction/revision, deletion, cancellation, or revocation of consent or information retrieval.

1. It is related to state security and national defense;

2. It is related to public security, public health, or significant public benefit;

3. It is related to criminal investigation, lawsuit, judgment or enforcement;

4. It is for the purpose of protecting the life, property, or other significant lawful rights of the personal information subject or other individuals but it is difficult to receive the consent;

5. The personal information collected is made public to the society at your discretion;

6. The personal information is collected from legally disclosed information, such as legal news report, government information publicity, or other channels;

7. It is necessary for signing contract based on your requirement;

8. It is necessary for protecting the security and stability of product or service provided, such as finding and treating product or service failure;

9. It is necessary for legally reporting new regulations;

10. It is necessary for statistical or academic research by research institutes based on public benefit, and the personal information contained in the result is de-identified upon external provision of academic research findings or descriptions;

11. Other situations stipulated by laws and regulations.

Please be aware, pursuant to governing law, if we take technical measures and other necessary measures to process the personal information, and make the data recipient fail to re-identify specific person and make it irrecoverable, or we might de-identify the information collected for study, statistical analysis, and forecast, for improving platform content and layout, for providing product or service support for business decisions, and for improving our products and services (including use of anonymous data for machine learning or model & algorithm training), use of such processed data does not need notification to you or your consent.

If we stop running the platform or service, we will stop collecting your personal information in a timely manner, and notify you by sending service ceasing notice one by one or making announcement. Your personal information we hold will be deleted or anonymized.

II. How do we entrust, share, transfer, and disclose your personal information

(I) Entrustment

Some modules or functions on the platform are provided by external suppliers. Please refer to SKD technical specification in Chapter X hereunder for details. As for the companies, organizations, or individuals entrusted by us to process individual information, we will ask them to process your personal information in accordance with our requirements, the Policy on personal information security, and any other relevant measures for confidentiality and security.

(II) Sharing

We will not share your personal information with companies, organizations, and individuals beyond the platform service provider, except the following cases:

1. Share based on express consent: after receiving your express consent, we might share your personal information with other third parties.

2. Share under legal circumstances: we might share your personal information with the outside based on laws, regulations, need for dispute settlement, or requirements from the administrative or judicial authority.

3. Share in the Company: for the convenience of joint provision of services, recommended information you might be interested in, separate account abnormality, protection of the Company or other users, and the personal and property safety of the public from harm, your personal information might be shared in the Company. We will share necessary personal information only, including: to facilitate your use of platform account or use of products and services in the Company, we will share your necessary account information in the Company. Such information shall be bound by the purposes set forth hereunder. If we share your sensitive information or our affiliated company changes the purpose of using and processing personal information, we will ask for your authorization again.

4. Share with authorized partners: we might entrust our authorized partners to provide you with certain services or perform duties on our behalf. We will share your information based on the legal, just, necessary, specific, and express purposes set forth hereunder. Our authorized partner may only be exposed to information necessary for them to perform their duties, and shall not use such information for any other purposes.

5. Share your personal information based on express consent: to send gift to you in person, we will share your cell phone number, consignee name, and consignee address with our logistics partner.

Currently, our authorized partners include the following types:

Partner on advertising and analysis service. Unless permitted by you, we will not share your personal information with partners on advertising and analysis service. We will entrust these partners to deal with information on advertisement coverage and effectiveness, but will not provide your personal information. We might also de-identify the information so that you are not identified. Such partners might combine the aforesaid information with other data they acquire legally to implement the advertising service or decision-making suggestions we entrust:

(i) Type of personal information shared in advertising: nickname and portrait

(ii) Type of personal information shared with analysis service provider: gender, age, and location

We will perform strict security test on the application port (AP) and software development kit (SDK) for authorized partners to retrieve relevant information, and agree upon strict data security measures with authorized partners so that they follow our entrusted purpose, service description, the privacy policy, and any other measures for confidentiality and security to process personal information.

(III) Transfer

We will not transfer your personal information to any company, organization and individual, unless:

1. We transfer with explicit consent: With your explicit consent, we might transfer your personal information to other third party;

2. If personal information transfer is involved in the merger, acquisition, or bankruptcy liquidation or other situation related to merger, acquisition, or bankruptcy liquidation, we will require the company and organization holding your personal information to be restricted by the Privacy Policy. Otherwise, we will require such company, organization and individual to further seek your authorization.

(IV) Public Disclosure

We will only disclose your personal information publicly under the following situations:

1. We have acquired your explicit consent or authorization;

2. If we confirm that you break the laws and regulations or seriously violate relevant platform agreement and rules, or we need to protect the personal safety and property of the users of the platform and the affiliates or the public from any damage, we may disclose your personal information after seeking your consent in accordance with the laws, regulations or relevant platform rules, including relevant violation act and the measures imposed on you by the platform.

(V) Exception for Prior Authorization or Consent Sought for Sharing, Transfer and Public Disclosure of Personal Information

Under the following situation, no your prior authorization or consent is required for the sharing, transfer, and public disclosure of your personal information.

1. It is related to state security and national defense;

2. It is related to public security, public health, or significant public benefit;

3. It is related to criminal investigation, lawsuit, judgment, or enforcement;

4. It is for the purpose of protecting the life, property, or other significant lawful rights of you or other individuals but it is difficult to receive the consent;

5. The personal information collected is made public to the society at your discretion;

6. The personal information is collected from legally disclosed information, such as legal news report, government information publicity, or other channels;

Pursuant to the provisions of the laws, if we take technical measures and other necessary measures to process the personal information, and make the data recipient fail to re-identify specific person and make it irrecoverable, we need not notify you and seek your consent to the sharing, transfer, and public disclosure of such processed data.

III. How do we protect your personal information

(I) We have used the security measures meeting industry standard to protect your personal information, and prevent unauthorized access, public disclosure, use, revision, damage or loss of data. We will take all the reasonable and feasible measures to protect your personal information.

1. We will take encryption technology, anonymous processing, and relevant reasonable and feasible measures not inferior to these of the industry peers to protect your personal information, and apply security mechanism to prevent the malicious attack from your personal information.

2. We will establish specialized security department, security management regulations, and data security procedure to protect your personal information security. We will apply strict data use and access system to guarantee that only authorized person can access your personal information.

3. Though the aforesaid reasonable and effective measures have been taken, and we have met the standard prescribed by relevant laws, you shall understand that the security measures enhanced to the utmost cannot always guarantee 100% security in Internet industry due to the restriction of technology and various potential malicious means. We will do the best to guarantee the security of your personal information.

4. You hereby know and understand that the system and communication network that you use to access our service might break down due to the factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of your personal information, including using complicated password, regularly changing the password, and not disclosing your account password and relevant personal information to others. If your personal act leads to the disclosure of the account password or relevant personal information, you shall independently undertake the consequence arising therefrom.

5. We will formulate emergency response plan, and immediately initiate the emergency response plan in case of user information security event, and endeavor to prevent the aggravation of the influence and consequence of such security event. In case of user information security event (disclosure and loss), we will inform you in time according to the requirements of the laws and regulations: The general condition and potential influence of security event, response measures taken or to be taken by us, advice on autonomous prevention and risk lowering by you, and remedial measures for you. We will inform you of the event information in time via push notification, email, correspondence, text message, and relevant mode. If it is difficult to notify one by one, we will publish the announcement in reasonable and effective mode. Meanwhile, we will report the handling of the user information security event according to relevant requirements of the regulatory departments.

(II) Our data security capacity

1. Content security: We will enhance our content security storage and protection capacity through purchasing third-party service, including Alibaba Cloud;

2. Data security: We have applied Alibaba Cloud service, especially purchased cloud security center, security group, security manager, situation awareness, Alibaba Cloud shield, web application firewall, bastion host, database audit, DDOS protection and vulnerability scanning based on basic data security service provided by Alibaba, and guaranteed users’ personal information security with multiple security services. Meanwhile, we have achieved encrypted storage in international standard encryption method to further guarantee safe data storage.

3. Access security: We will transmit all the requests via HTTPS, add authorized access mechanism for business, and purchase web application firewall, DDOS defense service, and HTTPDNS provided by Alibaba Cloud to guarantee access security and stability.

(III) We will take all the reasonable and feasible measures to guarantee no gathering of irrelevant personal information. We will only keep your personal information within the period required to fulfill the purpose of the Policy, unless the storage period shall be extended or the storage is permitted by the laws.

(IV) Internet environment is not 100% secure. We will endeavor to guarantee or ensure the security of the information sent by you. If our physical, technical or management protection facilities are damages and jeopardize your legal interests due to unauthorized access, public disclosure, tampering or damage of the information, we will assume corresponding legal responsibility.

(V) If you find that your personal information, especially your account or password, is disclosed, please immediately contact the customer service of the platform so that we can take corresponding measures according to your application.

IV. Your rights

According to universal practices of relevant laws, regulations, and standards, we will protect your following rights for personal information:

(I) Access your personal information

You shall be entitled to access your personal information, unless prohibited by the laws and regulations under certain situations. If you need to exercise the right of data access, you may access in the following mode on your own:

Profile - If you need to access or edit the nickname, constellation, age and address in your profile, you may operate in “Profile” in personal homepage after logging in the account.

Dynamic information - You may access or remove the history of your posts from “Monster Pub Moments” after logging in the account.

If you cannot access your personal information from the aforesaid path, you may contact us according to the contact information provided by us at any time. We will assess the problem reported as soon as possible, and assign specialized personnel to reply to your request for access within 15 working days after verifying your user identity.

(II) Correct your personal information

If you find that your personal information processed by us is incorrect, you shall be entitled to require us to correct. You may submit the application for correction in the method stated in “(I) Access your personal information” in this Article.

(III) Delete your personal information

You may delete part of your personal information in the method stated in “(I) Access your personal information” in this Article. Under the following situations, you may submit the application for deletion of personal information to us:

1. Our processing of personal information violates the laws and regulations;

2. We gather and use your personal information without your explicit consent;

3. Our processing of personal information goes against our agreement with you;

4. You stop using our product or service, or you proactively deregister the account;

5. We no longer offer the product or service to you.

If we decide to respond to your application for deletion, we will also notify the third party acquiring your personal information from us and require such third party to delete the information in time, unless it is otherwise specified by the laws and regulations, or such third party acquires your independent authorization.

After you delete your personal information from our product or service, we may not immediately delete corresponding information from the backup system according to the requirements of the laws and regulations, but shall delete such information when the backup is updated.

(IV) Change of the scope of your authorization

1. You may close GPS location, camera, microphone, and library authorization in the operating system of the device, and change the scope of consent or withdraw your authorization. After the withdrawal of authorization, we will not gather the information related to such authorization. You may also withdraw the authorization through deregistration of the account.

2. Specific business functions and services shall be finished with your information. After you withdraw the consent or authorization, we will not be able to offer the functions and services corresponding to the withdrawn consent or authorization, or process your corresponding personal information. However, your decision to withdraw the consent or authorization will not influence our previous processing of personal information based on your authorization.

(V) Account deregistration by personal information owner

You may click [My Profile Photo] - [Customer Service] - [Software Q&A] - [Account Deregistration] on the top of Monster Pub APP for deregistration. Before you deregister the account, we will verify your personal identity, security status, and device information. Please refer to the reminder of deregistration page for the procedure and contents of deregistration. You shall know and understand that the deregistration of account shall be irreversible, and we will delete or anonymize your relevant information after you deregister the account, unless otherwise specified by the laws and regulations.

(VI) Restrain automatic decision-making of information system

In certain business functions, we may make decision only according to non-human automatic decision-making mechanism, including information system and algorithm. If such decision significantly influences your legal interests, you shall be entitled to require us to explain, and we will provide appropriate relief method.

(VII) Complaint and whistle-blowing

If you think that your personal information rights are probably infringed, or find any clue of infringement of personal information rights, you may click [My Profile Photo] - [Customer Service] on the top of Monster Pub APP to enter relevant interface to submit relevant information. We will verify and process your complaint and whistle-blowing within 15 working days. If you are unsatisfied with the result, you may initiate the complaint through customer service of the platform. We may reject the unreasonably repeated or extremely unrealistic request or the request bringing risks to others’ legal interests. Under the following situations, we will not respond to your request according to the requirements of the laws and regulations:

1. It is related to the personal information controller’s performance of the obligations prescribed by the laws and regulations;

2. It is related to state security and national defense;

3. It is related to public security, public health, or significant public benefit;

4. It is related to criminal investigation, lawsuit, judgment, or enforcement;

5. The personal information controller shows adequate evidence to prove that the personal information owner has subjective malice or abuses the rights;

6. It is for the purpose of protecting the life, property, or other significant lawful rights of the personal information subject or other individuals but it is difficult to receive the consent;

7. The response to the request of the personal information owner will lead to serious damage to the legal interests of personal information owner, other individual, or organization;

8. Related to business secrets.

V. How we deal with personal information of the underage

Our products, websites, and services target the adults over 18 years old. The underage below 18 years old shall not create user account and use our services. If we find or identify that any underage registers or uses our products, we will take the measures to prohibit and restrict the use by the underage, such as account deregistration and information deletion.

VI. How we store your personal information

(I) We will store your personal information gathered and created during the operation in China in the People’s Republic of China in accordance with the provisions of the laws and regulations. Currently, we will not transmit the aforesaid information overseas. If we transmit the information overseas, we will comply with relevant national provisions or seek your consent.

(II) We will only keep your personal information during necessary period for the purpose to provide the “platform” and the services.

When your personal information is not recalled or deleted by you, or the account is not deregistered by you, we will keep relevant information. After necessary period, we will delete or anonymize your personal information, unless otherwise specified by the laws and regulations.

(III) We will protect your personal sensitive information better in the method of encrypted storage, including your email address.

VII. Revision and notification of privacy policy

To offer better services to you, Monster Pub APP and relevant services will be updated and changed from time to time. We will revise the Privacy Policy from time to time, and such revision shall constitute part of the Privacy Policy and have equal force to the Privacy Policy. Without your explicit consent, we will not reduce the rights entitled to you according to the Privacy Policy currently effective.

After the update of the Privacy Policy, we will publish the updated version on the platform, and inform you of the update in appropriate mode so that you will learn the latest version of the Privacy Policy in time.

As for major changes, we will provide more remarkable notification (as for certain services, we will send the notification via email to state the specific changes of the privacy policy of personal information).

The major changes herein shall include but not be limited to:

1. Major changes of our service mode, such as the purpose of personal information processing, type of personal information processed, and use mode of personal information, etc.;

2. Major changes of our ownership structure and organizational structure, such as owner change due to business adjustment and bankruptcy merger & acquisition, etc.;

3. Change of major object of personal information sharing, transfer or public disclosure;

4. Major changes of your rights to participate in the personal information processing and the implementation mode;

5. Change of the liable department, contact information, and complaint channel for personal information security;

6. High risk indicated in the impact assessment report of personal information security.

VIII. Statement on SDK technology

SDK technology will be provided by third-party institution in partnership with us. We will only learn the authorization required by third-party institution. Your information shall be gathered by third-party institution, and we will not acquire your information. The authorization required by third-party institution and the personal information gathered according to its explicit disclosure to us are hereby indicated as follows.

Please note that third-party SDK may change the data processing type to certain extent due to the version upgrade and strategy adjustment. Please refer to the official announcement. You shall only fail to use the functions based on the technology of third-party institution if you refuse to provide the information for third-party institution, but you can continue using other functions of the platform.

List of third-party SDK applied in IOS version and Android version:

Third-party SDK name: WeChat SDK

Third-party SDK provider: Tencent

Application scenario: WeChat authorized login and sharing function

Type of personal information gathered: Network status information and device information

Third-party SDK name: Facebook SDK

Third-party SDK provider: Facebook

Application scenario: Facebook authorized login and sharing function

Type of personal information gathered: Network status information and device information

Third-party SDK name: Kakao SDK

Third-party SDK provider: Kakao

Application scenario: Kakao authorized login and sharing function

Type of personal information gathered: Network status information and device information

Third-party SDK name: Line SDK

Third-party SDK provider: Line

Application scenario: Line authorized login and sharing function

Type of personal information gathered: Network status information and device information

Third-party SDK name: WhatsApp SDK

Third-party SDK provider: WhatsApp

Application scenario: WhatsApp authorized login and sharing function

Type of personal information gathered: Network status information and device information

Third-party SDK name: Umeng SDK

Third-party SDK provider: Umeng

Application scenario: Data statistics and notification pushing

Type of personal information gathered: Network status information and device information

Third-party SDK name: easemob SDK

Third-party SDK provider: easemob

Application scenario: Data statistics

Type of personal information gathered: Device information

Third-party SDK name: Baidu Statistics SDK

Third-party SDK provider: Baidu

Application scenario: Notification pushing

Type of personal information gathered: Network status information and device information

Third-party SDK name: Firebase SDK

Third-party SDK provider: Google

Application scenario: Crash monitoring

Type of personal information gathered: Network status information and device information

Third-party SDK name: Google GMS SDK

Third-party SDK provider: Google

Application scenario: Data statistics

Type of personal information gathered: Network status information and device information

IX. How to contact us

We have established specialized department of personal information protection. If you have any question about or advice on the Privacy Policy or relevant affairs, you can contact us according to the following contact information:

Email address of chief officer of personal information protection: support@monsterpub.com

We will properly accept and report your complaint in time, and reply within 15 working days after verifying your user identity.

If you are unsatisfied with our reply, especially if you think that our personal information processing jeopardizes your legal interests, you may also file a lawsuit in the court with competent jurisdiction in the locality of the defendant to seek the solutions.

X. Scope of application

All the services offered by Sistalk shall be governed by the Privacy Policy. However, please note that the Privacy Policy shall not be applicable to the services offered by other company or individual, and such services shall be governed by the privacy policy of other company or individual.