We are deeply aware of the importance of protecting data security and private information. When providing products and services, we always respect and pay attention to protecting data security and the legitimate rights and interests of personal information subjects, and process data in accordance with laws, regulations, national standards and other normative documents. In line with the business principles of honesty, openness and transparency, we hope to introduce our behavior of collecting, storing and using data and the ways we provide for personal data subjects to exercise their rights (inquiry, copying, correcting, supplementing, and deleting personal information, etc.) through this policy.

Before using the products or services of YOYI, please be sure to read this policy carefully and we will do our best to explain the technology-related terms in this policy in a concise way. Highlights have been highlighted in bold and we hope you will pay special attention to them. If you do not agree with the content of this policy, please do not follow up and provide any of your personal information.    

I. The scope of application of this policy

1. This privacy policy( “this policy”) is applicable to all products and services provided by YoYi Media (Beijing) Interactive Advertising Co., Ltd. (“YOYI”, or “we”), including but not limited to our webs, SDKs, APIs, plug-ins, components, codes, tools, and new products and services that we provide with innovative development.

2. Before using our products or services, please be sure to read this policy, and use the relevant products or services after fully understanding and agreeing to this policy. If there is any inconsistency or more specific agreement between this policy and the product service terms, the latter shall prevail when using such part of the products and services, and if there are different interpretations, we will interpret them in the manner that most closely matches the meaning expressed in the relevant terms.

3. It should be noted that third-party websites such as new media platforms may embed our SDK, code and other products and disclose our privacy policies, and you must also follow the privacy policies and other statements of third-party websites, and you need to understand our data processing practices together with the privacy policies and other statements of third-party websites and our privacy policies.

II. Entry into force and modification of this policy

Once using or continuing to use our services, it means that you have fully understood and agreed that we collect, store, use and process the data in the products and services you use in accordance with this policy.

We may amend certain provisions of this policy at any time, and such amendments form part of this policy. If such modification results in a substantial reduction of your rights under this policy, we will notify you by reminding you at a prominent position on the home page or sending you an email or by other means before the modification takes effect. In this case, if you continue to use our services, it means that you agree to be bound by the revised policy.

If there are any questions, comments or suggestions about this policy or related matters, you can contact us through the contact information posted on websites.

III. Definition

1. You: users who use products or services of YOYI through any terminals.

2. Products and services: products and services provided by YOYI to users through its own or cooperative party websites, apps, apples and other clients, including assisting advertisers and publishers to provide advertising services, display advertising business content introduction, etc. The specific functions of YOYI’s products and services shall be subjected to the functions that are actually displayed by each client.

3. Data: it refers to the data in the products and services we provide to you, and in this policy, it may refer to data that you voluntarily provide, data that we generate in the course of providing services to you, data that third parties provide us with that is legally authorized by you, and data that is legally obtained from publicly available sources.

4. Personal information: it refers to all kinds of information recorded electronically or otherwise that can identify a specific natural person, alone or in combination with other information, or reflect the activities of a specific natural person. Under normal circumstances, the personal information mainly involved in our products and services is personal commonly used equipment information, and will not include sensitive personal information such as ID card numbers and personal biometric information.

5. Sensitive personal information: it refers to the personal information that, if leaked and illegally used, could easily lead to infringement of a natural person's human dignity or endangerment of their personal or property safety, including information such as biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts and tracks, as well as the personal information of minors under the age of 16.

6. De-identification: it refers to the technological processing of personal information, which means the personal information subject cannot be identified or associated without additional information.

7. Anonymization: it refers to the process of technologically processing personal information so that the personal information subject cannot be identified and associated and the processed information cannot be recovered. The information derived from anonymization is not personal information.

8. Cookie: it refers to a text file containing a string generated by the server and sent to the user's browser when you visit a website or watch other web content. You can set whether or not to save these text files through your browser.

IV. Collecting and using of data

(i) Data sources

We are in line with the principle of legitimacy, legality and necessity, and only collect the personal information you voluntarily provide or generate while you using YOYI’s products and services for the following purposes, scopes and methods in this policy. When you use our products and services, we only collect the information necessary for the normal operation of the business and obtain your prior consent. If we want to use your personal information for other purposes not specified in this Policy, or use the collected information for other purposes for specific purposes, we will reasonably inform you and obtain your consent again. We will stop collecting your personal information while you turn off or stop this business. Please be aware that, during the course of using YOYI’s products and services, if you provide us with the personal information of other subjects, you should ensure that you have obtained the consent of the relevant subjects before we process such personal information.

1. Advertising: We will obtain encrypted device ID information( such as OAID, IDPA), IP address, browser type/model/ language and operating system authorized by you from the advertising publisher while you use the advertising services provided by YOYI to assist advertisers and publishers, so that YOYI can assist advertisers in predicting your preferences through its own advertising prediction strategy and provide you with high-quality advertising content.

2. User portrait: We will obtain encrypted device ID information( such as OAID, IDPA) authorized by you, and user portrait based on the data you have authorized from the advertising publishers and third parties designated by advertisers while you use the advertising services provided by YOYI to assist advertisers and publisher, so that YOYI help advertisers predict your preferences through its advertising prediction strategy, and provide you with high-quality advertising content.

3. Optimization of advertising effect: We will obtain encrypted device ID information (such as OAID, IDFA) and advertising exposure/view/playback/conversion information authorized by you from the advertisers while you use the advertising services provided by YOYI to assist advertisers and publishers for measuring the effectiveness of advertising services, optimizing advertising strategies, and better assisting advertisers and publishers in providing advertising content to you, so as to collect statistics on the effectiveness of advertising strategies and continuously optimize them.

Please be aware that YOYI may cooperate with advertisers and publishers in connection with the above-mentioned advertising through its affiliates while providing products and services. In this case, we will indirectly obtain the personal information you provide in each business scenario from our affiliates for the purpose of providing technical support for advertising in various business scenarios, so as to provide sufficient technical support for advertising in each business scenario for our affiliate so that assist our affiliates, advertisers and publishers in providing you with advertising delivery, user portrait or advertising effect optimization services. 

(ii) Using of data

We use the information we collect for the following purpose in strict compliance with laws and regulations and in accordance with our agreement with you. If we use your information beyond the following purposes, we will explain this to you again and obtain your consent.

1. To provide you with service to achieve the purpose for which personal information was collected as agreed above;

2. To provide, maintain, protect and improve our service, including optimizing strategy model to assist advertisers and publishers in providing advertising services;

3. To protect the rights and property of YOYI or you;

4. To report to the relevant departments according to laws, regulations and supervising requirements;

5. Other purposes of use you agreed that are in accordance with laws and regulations.

After we de-identify the data through technical means, the de-identified information will not be able to independently identify the personal information subject. You acknowledge and agree that we will use the de-identified information, and we have the right to analyze the user database and use it commercially without disclosing your personal information.

We will make statistics on the use of YOYI’s products and services and the statistics data may be shared with the public or third parties to show the overall use trend of our products and services. The statistics information will not include your personal information.

We will obtain your prior consent if we want to use your personal information other than the purposes stated in this policy or, when we want to use the information collected for a specific purpose for other purposes. Please understand that the products or services we provide to you will be constantly updated and changed. If you choose to use other products or services that are not listed in this policy, we will explain to you in detail the purpose, method and scope of information collection by using a separate product or service agreement/ page prompts and seek your explicit consent before we collect your personal information. If you do not agree to provide the above information, you may not be able to use that product or service, but this will not affect your use of other products or services.

(iii) Exceptions where data collection and use are authorized

According to laws and regulations, we do NOT need your authorization under the following situations:

1. Necessary for the conclusion and performance of a contract to which an individual is a party, or for the implementation of human resources management in accordance with the labor rules and regulations established according to the law and the collective contract signed following the law;

2. Necessary for the implementation of legal duties or obligations;

3. Necessary in response to a public health emergency or critical situation for protecting the life and property of a natural person;

4. Handing personal information within a reasonable scope to carry out acts such as news reporting, opinion monitoring for public interests;

5. Handing personal information that has been voluntarily disclosed by individuals or legally disclosed by the public within reasonable scope in accordance with laws and regulations;

6. Other situations stipulated by laws and regulations.

V. How we use Cookie and similar technologies

Cookie and its similar technologies are commonly used in Internet fields. While you use our services, we may use relevant technologies to send one or more Cookie or anonymous identifiers to your devices to collect and store information when you visit and use our websites or systems. Cookies and similar technologies often contain identifiers, site names, and some numbers and characters. We use this information to determine whether a registered user has logged in, to ensure the safe and efficient operation of products and services, and to improve the product and service and user experience. If you do not want your personal information to be stored in cookies, you can configure your browser to ban cookies and similar technologies.

If your browser or browser add-on services allow it, you can modify your acceptance of cookies and similar technologies or reject our cookies and similar technologies. Most browsers offer end users the ability to clear their browser's cache data, which you can do in your browser's settings. Please note, however, that if you ban cookies, you may not be able to enjoy a better service experience.

VI. Sharing, transfer and public disclosure of data

(i) Sharing of data

We will share data under the following circumstances on the prerequisite of complying with relevant laws and regulati:

1. Sharing under legal circumstances: we may share data in accordance with provisions of laws and regulations, the need to resolve litigation disputes, or at the legal request of administrative and judicial organs.

2. Sharing with affiliates: To better provide products and services, we will share data with our group or affiliate companies. We and our group or affiliate companies will protect your service-related data and information at a standard no less favorable than that required by this policy and in accordance with laws and regulations.

3. Sharing with cooperative partners: we may share anonymized device ID information with our advertisers and relevant partners entrusted by advertisers to jointly provide services with us, such as e-commerce platforms, for the purpose of evaluating the effectiveness of advertising. We may also share anonymized device ID information with third parties, including telecom operators, to the extent necessary to obtain your preferences held by third parties when assisting advertisers and publishers in providing advertising services, so as to form your user portrait and optimize advertising. We will agree with them to strict data protection measures so that they will process data in accordance with this policy and any other relevant confidentiality and security measures.

4. Please note that, according to the law, if we take technological measures or other necessary measures to de-identify or anonymize the personal information so that the recipient of the data cannot identify a specific person or recover the data, the sharing of such processed data will not require separate notification and your consent.  

(ii) Transfer of data

We would certainly not transfer your personal information to any other third parties except the following circumstances:

1. Obtaining your consent.

2. In the event of a merger, acquisition, liquidation, or sale of some or all of its assets in any form, there will be a transfer of personal information, in which case we will ensure the confidentiality of all personal information involved in these transactions and notify you before it is transferred and subject to another privacy policy. If there is any change in the collection and processing of personal information agreed in this policy, the company or organization will re-seek your authorization and consent.

(iii) Public disclosure of data

We will comply with relevant laws and regulations and keep your personal information confidential. We will not publicly disclose your personal information unless we have obtained your explicit consent or authorization, or as required by law. However, we will disclose your personal information to the competent authorities based on laws, legal procedures, lawsuits or mandatory requirements of government authorities. However, we guarantee that in the event of the above-mentioned circumstances, we will require the party requesting disclosure to produce corresponding valid legal documents, and at the same time use reasonable efforts to take security measures that comply with laws and industry standards for the disclosed information.

(iv) Exceptions to the authorization of consent for sharing, transfer and public disclosure of personal information

According to provisions of laws and regulations, we can share, transfer and publicly disclose your personal information without your authorization under the following circumstances:

1. Necessary for the conclusion and performance of a contract to which an individual is a party, or for the implementation of human resources management in accordance with the labor rules and regulations established according to the law and the collective contract signed following the law;

2. Necessary for the implementation of legal duties or obligations;

3. Necessary in response to a public health emergency or critical situation for protecting the life and property of a natural person;

4. Handing personal information within a reasonable scope to carry out acts such as news reporting, opinion monitoring for public interests;

5. Handing personal information that has been voluntarily disclosed by individuals or legally disclosed by the public within reasonable scope in accordance with laws and regulations;

6. Other situations stipulated by laws and regulations.

You fully understand and agree that the sharing or transfer of anonymized personal information that the data recipient cannot recover and re-identify the personal information subject, is not an external sharing, transfer or public disclosure of personal information, and the storage and processing of such data will not require further notice to you and your consent.

VI. Protecting system of data storage and personal information

(i) Data retention period

We will use security measures to store data for a minimum period of not less than six months in strict accordance with laws and regulations, and delete or anonymize the data within a reasonable period after the purposes of service have been fulfilled unless an extension of retention period is required or permitted by law.

(ii) Technological measures and data security measures

The security of your personal information is important to us. We will strictly comply with relevant laws and regulations and take reasonable and feasible security measures recognized by the industry to protect data from unauthorized access, modification, disclosure or destruction. These measures include an internal review of our data collection, storage and processing practices and security measures (including putting in place appropriate encryption and physical security measures to prevent unauthorized access to the systems where we store personal data).

We strive to protect the security of your personal information by implementing a variety of physical, electronic, and managerial security measures that comply with industry standards. We actively establish a data classification and grading system, data security management standards, and data security development specifications to manage and regulate the storage and use of personal information, and ensure that personal information unrelated to the services we provide is not collected. In addition, in the case of information exchange with relevant third parties, we protect your privacy through security measures such as safe house and federated learning.

We restrict access to your personal information to those employees, contractors and agents of YOYI who need to know such personal information in order to process it on our behalf. These persons are bound by confidentiality obligations, and if they fail to comply with these obligations, they will be subject to appropriate penalties, including termination of contract and criminal prosecution. 

(iii) Security certification

We have passed the Level 3 information security protection certification of the Ministry of Public Security, as well as ISO 27001 certification, and have established a good coordination and communication mechanism with regulatory agencies and third-party evaluation agencies to resist and deal with various information security threats promptly, providing all-round protection for your information security.

(iv) Security incidence response

We will do our best to ensure the security of any information you provide, but please understand that due to the limitations of technology and the existence of various malicious means in the Internet, information is not guaranteed 1oo% secure. You may need to be aware that there may be problems with the systems and communication networks you use to access our services due to factors beyond our control. 

In order to prevent the occurrence of security accidents, we have formulated a proper early warning mechanism and emergency plan. In the unfortunate event of a personal information security incident, we will, following the requirements of laws and regulations, promptly inform you of the basic situation and impact of the security incident, the measures we have taken or will take to deal with it, suggestions for you to prevent and reduce risks on your own, and remedial measures for you, and immediately activate the emergency plan to minimize the loss. We will inform you of the relevant circumstances of the incident by telephone, push notification, etc., and if it is difficult to inform users one by one, we will make an announcement reasonably and effectively. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities, and closely cooperate with the work of government.

(v) Your understanding and assistance 

We will do our best to ensure the security of any information you provide. But please understand that due to the limitations of technology and risk prevention, even though we have maximized security measures, information is not guaranteed 100% secure. You may need to be aware that there may be problems with the systems and communication networks you use to access our services due to factors beyond our control. We ask you to protect your data and provide it to others only when necessary.

VIII. Other

(i) How we handle the personal information of minors 

YOYI's products or services are primarily intended for adults. If you are a minor under the age of 18, you should obtain the consent of your guardian before using YOYI's products or services. For the collection of minors' personal information with parental consent, we will only use or publicly disclose this information when permitted by law, with the explicit consent of the guardian, or when it is necessary to protect the child. For the personal information of children under the age of 14 that may be involved, in addition to complying with the provisions of this policy on users' personal information, we will also uphold the principles of legitimate necessity, informed consent, clear purpose, security and lawful use, strictly follow the requirements of the Provisions on the Protection of Children's Personal Information and other laws and regulations to store, use and disclose children's personal information, and protect the legitimate rights of children and their guardians with respect to the relevant children's personal information.

If we become aware that we have collected personal information of minors without first obtaining verifiable consent from the guardian, we will endeavor to delete the relevant data as quickly as possible.

If you are a guardian of a minor, when you have questions about the information processing of the minor under your guardianship, or you have facts to prove that the minor has used YOYI’s products or services without guardians’ consent, please send an email to marketing@yoyi.com.cn

(ii) Cross-border transfer of data

Data collected and generated in our operations in the People’s Republic of China will be stored in China in accordance with provisions of laws and regulations and it will not be transferred outside China

(iii) Announcement and information we sent to you

We would send announcements related to service to you when necessary( e.g., when we suspend a service due to system maintenance). You may not be able to cancel these service-related and not promotionally-natural announcements.

(iv) Contact us

If you have any questions, comments or suggestions, please contact us, the specific contact information see “Contact us” on our websites and we will reply to you within 15 working days. If you are not satisfied with our reply, especially if you believe that our personal information processing has harmed your legitimate rights and interests, you may also file a complaint or report to the regulatory authorities such as the Cyberspace Administration, the Public Security Ministry, and the Administration for Market Regulation, or file a lawsuit with a court of competent jurisdiction.