DOORM

DOORMAI

Version Update Date: February 21, 2024

Version Number: 2024 v1

Important Notice

Your trust is very important to us. We deeply understand the significance of personal information and will take appropriate security measures in accordance with legal regulations to protect your personal information as securely and controllably as possible. Therefore, the service provider of DOORM (or referred to as “we”) has developed this “Privacy Policy” (hereinafter referred to as “this policy/this privacy policy”) and reminds you:
This policy applies to all products and services provided by our platform. When you visit our platform, use the services provided by our platform, and access our platform websites, servers, and/or log in to related clients without separate privacy policies, this privacy policy will apply. If we and our affiliates (as defined in the definition section) use DOORM’s products or services in their products or services but do not have a separate privacy policy, this policy will also apply to those products or services.

It is important to note that this policy does not apply to services provided to you by other third parties. The privacy policy applicable to services provided by third parties to you will be the privacy policy described by them. Before using any of DOORM’s products or services, please carefully read and fully understand this policy, especially the terms marked in bold/bold underline. You should focus on reading these terms and only use the services after confirming that you fully understand and agree to them. If you have any questions, comments, or suggestions regarding the contents of this policy, you can contact us through various contact methods provided by DOORM.

Part One: Definitions

Personal Information: Refers to various types of information recorded electronically or otherwise that can identify a specific individual or reflect the activities of a specific individual, either alone or in combination with other information.

Personal Sensitive Information: Includes identity card numbers, personal biometric information, bank or other financial account information, property information, travel trajectory, transaction information, personal information of children aged 14 or below (inclusive). Sensitive information in this policy will be highlighted in bold and underlined.

Personal Information Deletion: Refers to the action of removing personal information from systems involved in daily business functions, making it non-retrievable and inaccessible.

Our Platform: Includes DOORM (with domain name doorm.ai), DOORM video open platform, and our content service platforms for internet TV businesses (including platforms cooperating with internet TV broadcasting control organizations and content licensees, as well as those cooperating with smart TV manufacturers), and related clients such as DOORM APP (including but not limited to mobile, PC, large screen apps, APKs, SDKs, APIs, etc.). If products or services from our affiliates (as defined in the definition section) use products or services provided by our platform (such as logging in using DOORM platform accounts) but do not have separate privacy policies, this policy will also apply to such products or services.

We (“Our”): The operator of the platform providing internet audio and video content services. The operator of DOORM and DOORM’s client applications (DOORM APP) is DOORM AI PTE. LTD.

Our Platform Services: Refers to various forms of services provided by us through the internet, including but not limited to our platform website, clients (including APP, APK, SDK, API formats), for content distribution, online information transmission, internet TV services, etc., as well as future technologies or new service forms that may emerge.

Our Platform Rules: Includes all rules, user service agreements, interpretations, announcements, and other content already published or to be published on all our platform websites, as well as various rules, implementation details, product descriptions, and announcements published on platform channels, event pages, help centers, etc.

Affiliated Companies: Refers to the affiliated companies of DOORM AI PTE. LTD., disclosed in its latest company annual report.

Part Two: Privacy Policy

This Privacy Policy will help you understand the following content:

Important Notice

Part One: Definitions

Part Two: Privacy Policy

1. How we collect and use your information

2. How we use cookies and similar technologies

3. How we share, transfer, and disclose information

4. How we store information

5. How we protect your personal information

6. Protection of minors

7. How you can manage your information

8. Revisions and updates of this privacy policy

9. How to contact us

1. How we collect and use your information

When you use our products/services, we may need to collect and use your personal information under the following two circumstances:

1. To achieve the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide this information, you will not be able to use our products and/or services normally;

2. To provide additional functions of our products and/or services, you can choose to authorize us to collect and use additional information. If you refuse to provide this, you will not be able to use the relevant additional functions or achieve the intended functionality, but it will not affect the basic functionality of our products and/or services.

You understand and agree:

1. We are committed to providing diverse products and services to meet your needs. As the variety of products and services we provide is extensive, and different users select different products/services, the types and scope of personal information collected and used will differ accordingly. Please refer to the specific functionality of the product/service;

2. In order to bring you a better product and service experience, we are continuously working to improve our technology. As a result, we may occasionally introduce new or optimized features that may require the collection and use of new personal information or changes in the purpose or manner of using personal information. In this regard, we will separately explain to you the purpose, scope, and usage methods of the corresponding information through updates to this policy, pop-ups, internal messages, etc., and provide you with a way to voluntarily agree, and collect and use it only after obtaining your explicit consent. If you have any questions, opinions, or suggestions during this process, you can contact us through various contact methods provided by DOORM, and we will respond to you as soon as possible.

To help you become our registered user and member, and to provide you with audio and video content display or playback, on-demand services, and better, superior, and more personalized services, we will collect the following information based on the services you use:

(1) Account Creation and Registration

1. Basic account creation

When you create an account on our platform to become our member and to enable us to provide you with member services, you need to provide (1) phone number; and create (2) username and (3) password.

When you log in using a third-party platform account (WeChat account, Weibo account, QQ account, Google account), if you decide to bind a DOORM account, after your account binding authorization, the third-party platform will synchronize some information to us, such as phone number, avatar, nickname, or ID.

2. Basic profile maintenance & identity verification

[Basic information maintenance] When using our platform, to maintain your basic information and improve your service experience, you need to choose to fill in and/or complete the necessary information, which may include your email address, gender, location, avatar, nickname, birthday, personal introduction, etc. Not providing this information will not affect your use of the core functions of our platform and client.

[Identity verification] If you lose your account, we will provide three ways to verify your identity. After identity verification, you can reset your password, such as resetting your password after mobile identity verification, or resetting your password through customer service. During this process, you need to provide some information to verify your identity. When retrieving your password, we may need you to provide frequent login locations and devices for verification.

(2) Uploading or posting information and videos

If you choose to upload videos or photos, post bullet comments, comments, or messages in the community, in addition to creating and registering an account, you may also need to provide the following information:

1. Necessary identity information

a. For users who frequently or in bulk upload spam advertisements, spam videos, or violate content, in order to ensure content security, avoid suspicious upload accounts from disturbing our platform users and audience, and purify the online space, our platform may require the aforementioned users to upload ID card number, ID card, and a photo of themselves with the ID card for additional information collection and verification. If a user refuses to provide this information, our platform has the right to temporarily close the upload requirements of such users.

b. Please note that according to the requirements of national regulatory authorities, DOORM accounts registered overseas need to fully implement real-name system. Therefore, we may require these users to provide some information based on the requirements of regulatory authorities. These accounts and related information can only be opened for uploading videos and publishing videos after approval by the national regulatory authorities.

2. Posting information, comments, etc.

The content information you provide when using our services (including but not limited to comments, follow-ups, bullet comments, community content, etc.). For example, the information you post on our platform, forums, planets, and communities.

The above information is necessary for you to upload, post videos, photos, and information on our platform. If you do not need to upload or post on our platform, you do not need to provide the above information. Not providing the above information does not affect your use of the core functions of our platform.

3. Establishing contacts and sharing information

You can establish contacts and share with each other through our services. When you create communication, transactions, or content sharing through our services, you can choose the objects to communicate, transact, or share with, and they can see your membership level, nickname, etc., communication information, or shared content, etc.

When using our platform and platform services for video storage services, distribution services, on-demand consumption services, viewing, posting comments, and bullet comments, it may involve disclosing your personal information and others’ personal information, which may include sensitive information. Please protect your personal information properly, only provide or display your information to others when necessary; without the permission of others, you should not illegally disclose others’ personal information or privacy. Please consider more carefully whether to disclose or even publicly share relevant personal information when using our services. If you find that your personal information is leaked or the content you provide involves others’ personal information or privacy, especially if your account or password is leaked, please contact our platform website customer service immediately and take appropriate measures.

Public information refers to any information you publicly share, such as comments, bullet comments, follow-ups, your avatar, nickname, username, photos, videos, etc.

Please note that the content and information you share when using our services may involve your sensitive personal information. If it includes others’ personal information, please make sure you have obtained their legal authorization. Please consider more carefully whether to disclose or even publicly share relevant sensitive personal information when using our services.

(3) Your participation in operational and interactive activities

If you participate in operational and interactive activities on our platform, such as lotteries, quizzes, quizzes, surveys, you may need to actively submit relevant information. For example, when cashing out red envelopes received from specific activities, redeeming prizes, paying taxes to tax authorities, you may need to submit ID information. If prizes or activity gifts need to be shipped, you also need to provide address information.

(4) Providing content recommendation display for you

In order to provide you with better content recommendation display, optimize search results, understand the adaptability of products to different hardware devices, ensure the safety of the operating environment, identify abnormal account statuses, etc., we will collect information about how you use our products or services and associate this information. This information includes:

1. Device information: We will receive and record device-related information you use based on specific operations granted during software installation and/or use (such as device model, operating system version, device settings, mobile device identification code, network device information, necessary mobile application list information, etc., software and hardware device, device environment information), device location-related information (including your authorized GPS location and WLAN access points and base stations and other sensor information).

2. Log information: When you use the products or services provided by our website or client, we will automatically collect detailed usage information about our services as network log records. This includes your search and browsing history, follow-ups, playback records, visit volume, playback duration, IP address, WLAN network, telecommunications operator network, language used, visit date and time.

Please understand that individual device information, log information, etc., are information that cannot identify specific natural persons. If we combine this type of non-personal information with other information to identify specific natural persons, or use it in combination with personal information, during the period of combined use, this type of non-personal information will be considered as personal information. Unless you authorize or there are other legal regulations, we will anonymize and de-identify this type of personal information.

In order to provide you with more convenient, more personalized information display, search, and push services, we will extract your preference features based on your device information and service log information, and generate indirect user portraits based on feature tags for display, information push, and possible commercial advertisements.

We strive to protect your browsing experience. If you do not want to receive commercial advertisements from us, you can unsubscribe or close through SMS prompts or other methods we provide. When you open the recommended page in the hotspot, you can click the drop-down button of each video to independently choose to close the content and preferred categories recommended by us.

In addition, we will also use your above information to continuously improve and optimize the above functions.

In order to enhance your experience, we may use new technologies other than server-client transmission technology to improve information transmission efficiency and enhance user experience; for this purpose, we may use your terminal device information and content access information.

(5) Providing VIP membership or subscription services

To complete VIP membership fee payment, we will record your payment method and fund account to achieve original path refunds, activity red envelope withdrawals, cancellation of continuous monthly services, etc. We will share your order payment-related information, order security-related device information, and other necessary information required by anti-money laundering laws with other third-party payment companies through embedding third-party payment software development kits (SDK) in the application based on the payment institution and payment method you choose. At the same time, we will record and display your account’s order information, including purchasing membership, single video on-demand, subscribing to comics, purchasing virtual currency and props, etc.

(6) Customer service and dispute resolution

To provide you with customer service, we will record the contact information and communication/call records and content you provide to help you solve problems, or record the solutions and results of related issues.

To confirm transaction status and provide you with VIP membership after-sales and dispute resolution services, we will collect your transaction and payment information related to transactions based on the payment institution and payment method you choose, such as transaction certificates and charge certificates for IAP payments on the IOS side.

（7）Security Features

Risk Identification: We may use your personal information to prevent, detect, and investigate fraud, security threats, illegal or violations of agreements, policies, or rules with us or our affiliates, such as abnormal member account activities, multiple logins, unusual traffic, frequent refund requests, or low-price transfer of membership cards, in order to protect you, other users, or the legitimate rights and interests of us or our affiliates.
To enhance the security of your use of our services and those provided by our affiliated companies and partners, ensure the security of the operating environment and identify abnormal member account statuses, protect your or other users’ or the public’s personal and property safety from infringement, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, and other security risks, more accurately identify violations of laws and regulations or DOORM platform-related agreement rules, we embed application security SDK developed by our affiliated companies in the application to collect your device information, service log information, and may use or integrate your account information, transaction information, payment information, device information, relevant network logs, and information shared by our affiliated companies or partners with your authorization or in accordance with the law to comprehensively assess the risks of your account and transactions, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

（8）Providing Other Additional Services

To provide you with more convenient, higher-quality, personalized products and/or services, and strive to enhance your experience, we may collect and use your personal information in the following additional services we provide to you. If you do not provide this information, it will not affect your use of basic services such as browsing, searching, and purchasing on our platform, but you may not be able to enjoy the user experience brought by these additional services. These additional services include:

1. Camera-based Additional Services: You can use this function after granting camera permission. We access your camera to allow you to use the camera for QR code scanning, taking photos, and videos, for user login, directly shooting and uploading videos, photos for UGC-related functions, displaying corresponding content on our platform, and in specific scenarios where you authorize QR code payments, participate in activities, etc., which you are clearly aware of. It is worth noting that to enrich your user experience, our client on some Apple devices in eye protection mode will use TrueDepth APIs to obtain the position of your face in the world coordinate system through camera permission, for real-time calculation of the position where your eyes are looking at the device screen and apply it to interactive feedback. We will not store or share this information with third parties, and it is only used for the aforementioned interactive feedback. Additionally, you can turn off this function at any time, and turning off the function will immediately stop the call to the TrueDepth APIs interface and cease data collection.

2. Album (Photo/Video Library) Access and Upload Services:You can use this function after granting album permission to upload your photos/images/videos and locally cached audiovisual files, ensuring that local photos and videos can be uploaded to DOORM for functions such as changing avatars, posting and sharing comments, posts, saving activity sharing QR codes, or proving the issues you encounter when communicating with customer service. We may use the photos/images you upload to identify the activity links or video service links you need to participate in, or use the comments containing the photos/images you uploaded. To meet your needs for sharing links to friends, activity discounts, etc., we may read the most recently saved image link addresses on your device.

3. Microphone-based Voice Technology Related Services:You can use this function after granting microphone permission to search for your favorite movies, TV shows, programs, etc., by voice, post video posts in the app, and interact with customer service or chatbots by voice. Please note that even if you have agreed to grant microphone permission, we will only use the microphone to collect voice information when you actively click on the microphone icon in the client or record a video.

4. Calendar-based Services:After granting us permission to read/write to your calendar, we can access your calendar to help you schedule live broadcasts and program broadcasts and remind you.

5. Contact Permission:When you intend to share videos or activity links from our platform with your friends, you need to grant us contact permission to send video playback addresses or activity link addresses to your friends via SMS or social networks.

6. Location Permission:You can grant us location permission to access information about nearby places, such as information about nearby dining places, movie theaters, and other local services.

7. Phone Status Permission:To ensure the security of your account and usage, you need to authorize us to read the device identification code.

8. Floating Window Permission:To enable you to use the picture-in-picture function and receive notification messages, DOORMAPP will request your floating window permission.

9. Instructions for Using the get_accounts Permission:DOORM has registered an application account on the Android system. By utilizing the Android system’s account synchronization mechanism, when the application account registered by DOORM receives system notifications, it will automatically launch your DOORMAPP, which will improve the efficiency of PUSH message delivery when the application is active, ensuring that important information reaches your mobile device. Currently, this permission is required for Android versions 5.1 and below, and not required for Android 5.1 and above; This permission is only supported on Android 8.0 and below, and not supported on Android 8.0 and above. DOORM currently does not use this permission to obtain any user information.

10. Instructions for Using oaid and idfa Data Permissions:When advertisers place programmatic advertising on the DOORM platform, in order to confirm the effectiveness of the advertising, our platform needs to provide oaid and idfa data to advertising agencies and programmatic advertising platforms. Users need to grant permission to enable the use of these two data fields, which are used to generate IDs for advertising tracking. Users theoretically have the ability to disable, reset, or update these two data fields.

You understand and agree that the aforementioned additional services may requireyou to enableaccess to your camera, album, microphone, calendar, location, and/or phone status on your device to collect and use the information related to these permissions.

If you wish to revoke or cancel a permission setting for DOORMAPP, please go to DOORMAPP—My—Settings—Privacy—System Permissions, and disable or revoke the permissions you have granted. You can also go to your mobile device (Android) settings—Privacy—Permission Management, search for the DOORM application, and review the permissions you have granted. If you need to revoke a permission, click on the deny or disable option; On iOS devices, you can go to Settings—Privacy—Select specific permissions—click on DOORMAPP to revoke or disable specific permissions. Please note that some permissions are necessary for the normal operation of DOORMAPP, and disabling them may affect the functionality of certain features of the app.

If you cannot find the option to disable permissions on your app due to an update, you will need to go to your device settings to disable permissions for DOORMAPP. Please note that enabling any permission means that you authorize us to collect and use relevant personal information to provide corresponding services to you. Once you disable a permission, it means that you revoke the authorization, and we will no longer collect and use the relevant personal information based on that permission, nor can we provide the services corresponding to that permission. However, your decision to disable permissions will not affect the information collected and used based on your previous authorization.

（9）Providing Technical Integration Support

When you use mini-programs on our platform, we may need to obtain necessary personal information (such as device information, operational behavior log information) from mini-program developers and technical service providers (such as DOORM mini-program platform operators) to provide technical support for integration purposes. When you use mini-program services through our platform, your information will be subject to the privacy policy of the mini-program developer and technical service provider. We recommend that you read and understand the relevant agreements before accepting the services.

If you bind your DOORM account to a Shangduiyuan account, you can directly log in to Shangduiyuan Touch Edition and Shangduiyuan mini-programs (referred to as “mini-programs” or H5) in DOORMAPP; All behaviors, behavior data, and transaction data generated in the mini-programs and H5 pages where you log in with your Shangduiyuan account belong to the developer of the mini-programs (such as Shangduiyuan), and DOORM only provides information display entrances and display services; To ensure the security of your operations and data in these mini-programs and H5 pages, please do not share your DOORM account and the Shangduiyuan account bound to DOORM with others. If you share your DOORM account with a third party, resulting in orders and consumption in the aforementioned mini-programs and H5 pages, causing you losses, you will be responsible for them.

（10）Other

1. If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing this personal information to us. If it involves personal information of children, you must obtain the consent of the corresponding guardian before publishing it. In the event of the above, the guardian has the right to contact us through the methods specified in Article 9 of this policy to request correction or deletion of content containing personal information of children.

2. If we use information for purposes not specified in this policy, or use information collected for specific purposes for other purposes, or proactively obtain your personal information from third parties, we will obtain your consent in advance.

You understand and agree that we may collect and use your personal information without your authorization in the following cases, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, or information requests:

(1) Related to national security and national defense;

(2) Related to public safety, public health, and major public interests;

(3) Related to criminal investigation, prosecution, trial, and execution of judgments in judicial or administrative law enforcement;

(4) Necessary to protect your or other individuals’ lives, property, and other major legitimate rights and interests, but it is difficult to obtain your consent;

(5) Personal information that you voluntarily disclose to the public;

(6) Collection of personal information from legally disclosed information, such as legal news reports, government information disclosure, etc.

(7) Necessary for signing and fulfilling relevant agreements or other written documents with you;

(8) Necessary for the safe and stable operation of the products and/or services we provide, such as discovering and handling product and/or service failures;

(9) Necessary for legitimate news reporting;

(10) Necessary for academic research institutions to conduct statistics or academic research based on public interests, and when providing academic research or describing the results, the personal information contained in the results will be de-identified;

(11) Other circumstances as stipulated by laws and regulations.

Please be informed that according to applicable laws, if weprocess personal information using technical measures and other necessary measures to make the data recipient unable to re-identify specific individuals and cannot be restored,or we may de-identify the collected information for research, statistical analysis, and prediction, to improve the content and layout of our platform and services, provide support for business decisions, and improve our products and services (including using anonymous data for machine learning or model algorithm training), we will comply with the requirements of relevant laws and regulations.

4. If we cease the operation of our platform products or services, we will promptly cease the collection of your personal information, notify you of the cessation of operation through individual delivery or announcements, and delete or anonymize the personal information related to the closed business that we hold.

II. How We Use Cookies and Similar Technologies

（1）Cookies

To ensure the normal operation of the website, provide you with a more relaxed browsing experience, and recommend content that may interest you, we store cookies, Flash cookies, or other local storage provided by browsers or associated applications on your computer or mobile device (collectively referred to as “Cookies”). With cookies, websites can store your preferences or data such as items in your shopping cart.

If your browser or browser add-ons allow, you can modify the acceptance level of cookies or reject our cookies. For more details, please refer to AboutCookies.org. However, if you do so, it may affect your secure access to our website in some cases, and you may need to change your user settings each time you visit our website.

(2) Cookie and Similar Technologies

In addition to cookies, we also use other similar technologies on our website, such as website beacons and pixel tags. For example, the emails we send to you may contain links to our website content. If you click on these links, we will track this click to help us understand your product or service preferences in order to improve customer service experience proactively. Website beacons are typically transparent images embedded in websites or emails. With the help of pixel tags in emails, we can know if the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

ETag (entity tag) is an HTTP protocol header transmitted between internet browsers and servers that can replace cookies. ETag can help us avoid unnecessary server loads, improve service efficiency, save resources and energy. At the same time, we may use ETag to record your identity so that we can better understand and improve our products or services. Most browsers provide users with the function to clear browser cache data, and you can perform the corresponding data clearing operation in the browser settings. However, please note that if ETag is disabled, you may not be able to enjoy the best product or service experience.

Three, How We Share, Transfer, and Disclose Information

(1) Sharing and Disclosure

Except for the following circumstances, we will not share your personal information with any other third parties.

Sharing with your explicit consent or authorization or in cases where you actively choose to share. After obtaining your authorization or explicit consent, we will share your personal information with other companies, organizations, and individuals. For example, if we entrust a third party to provide you with products or services (such as user activities, prize delivery for sweepstakes, prize redemption), we will share the above information with the third party after obtaining your consent. If you refuse to provide such information, we will not be able to complete the relevant delivery service. We will only share your personal sensitive information if you choose to agree. With your explicit consent or based on your active choice, we may publicly disclose your personal information.

Sharing and disclosure in legal circumstances. We may share your personal information with external parties in accordance with legal requirements, litigation dispute resolution needs, or requests made by administrative or judicial authorities. For example, if we determine that you have violated laws or regulations or seriously violated the rules of our platform, or to protect the personal and property safety of users of our platform website and its affiliated companies or the public from harm, we may disclose your personal information about you based on legal requirements or the rules of our platform after obtaining your consent, including relevant violations and measures taken by our platform against you. For example, if you or your account uploads illegal videos or videos that violate the rules and seriously violate the rules of our platform, violate laws and regulations and/or violate public order and good customs, causing significant social impact and reputation damage to our platform, we may disclose your information and punishment situation.

Sharing your personal information with our affiliated companies. Sharing between affiliated companies: In order to facilitate us to provide services to you based on affiliated accounts, recommend information that you may be interested in, identify abnormal member account activities, protect the personal and property safety of our affiliated companies or other users or the public from harm, your personal information may be shared with our affiliated companies. We will only share necessary personal information (for example, to facilitate you to use our account to log in and use products or services of our affiliated companies, we will share your necessary personal information with affiliated companies), and be bound by the purposes stated in this privacy policy. If we share your personal sensitive information or affiliated companies change the use and processing purposes of personal information, we will seek your authorization consent again.

Sharing with authorized partners. We may entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share your information for legitimate, lawful, necessary, specific, and explicit purposes stated in this privacy policy, and authorized partners can only access the information needed to perform their duties and may not use this information for any other purpose.

Currently, our authorized partners include the following types:

(1) Authorized partners providing advertising monitoring, data statistics, and data analysis services. To maintain/improve our products/services and provide you with better content, we may access designated partner advertising alliances, iResearch, and our affiliated company Umeng to read your device identification number and network-related information for analyzing your use of our services and optimizing ad delivery.

Except for the situations where you have given permission, we will not share your personal identity information (information that can identify you, such as name or email address, which can be used to contact you or identify you) with partners providing advertising and analysis services. We will entrust these partners to handle information related to advertising coverage and effectiveness, but will not provide your personal identity information, or we will de-identify this information so that it does not identify you personally. These partners may combine this information with other data lawfully obtained to perform the advertising services or decision recommendations we have commissioned.

(2) Suppliers, service providers, and other partners. We will send information to suppliers, service providers, and other partners supporting our business (such as internet TV broadcast control licensees, content licensees, hardware manufacturers, telecommunications operators, etc.), including technical infrastructure services we entrust, analyzing the usage of our services, measuring the effectiveness of advertisements and services, providing customer service, facilitating payments, or conducting academic research and surveys.

(3) SDK usage. To ensure the stable operation and function realization of our client, allowing you to use and enjoy more services and functions, our applications may embed authorized partner SDKs or similar applications,click to viewwe access authorized partner SDKs.
We will conduct strict security checks on the application programming interfaces (APIs) and software development kits (SDKs) that authorized partners use to obtain information and agree with authorized partners on strict data protection measures to handle personal information in accordance with this policy and any other relevant confidentiality and security measures.

Assisting in resolving disputes. If you are an eligible intellectual property complainant and have filed a complaint, at the request of the complained party, disclosure to the complained party is necessary for both parties to handle potential rights disputes. Only by sharing your information can we provide the services you need or handle disputes or conflicts with others. For example, if a video content created by you on our platform is accused of intellectual property infringement or content violation, if any of the parties to the complaint, judicial agencies, or law enforcement agencies request information disclosure, we will provide the contact information of the complained user to facilitate the resolution of the dispute. Our platform only assumes legal responsibilities in cases where the law clearly stipulates.

(2) Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

1. Transfer with explicit consent: With your explicit consent, we will transfer your personal information to other parties;

2. In the event of a merger, acquisition, or bankruptcy liquidation of our platform service provider, or other situations involving mergers, acquisitions, or bankruptcy liquidation, if it involves the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy, otherwise we will require the company, organization, and individual to seek your authorization consent again.

(3) Exceptions to obtaining prior authorization consent for sharing, transferring, and disclosing personal information

In the following situations, sharing, transferring, and publicly disclosing your personal information does not require obtaining your prior authorization consent:

1. Related to national security and national defense;

2. Related to public safety, public health, and major public interests;

3. Related to criminal investigation, prosecution, trial, and execution of judgments;

4. For the purpose of protecting the vital interests of you or other individuals’ life, property, etc., but it is difficult to obtain your consent;

5. Personal information that you voluntarily disclose to the public;

6. Collecting personal information from legally public disclosures, such as lawful news reports, government information disclosures, and other channels;

7. Related to our fulfillment of legal obligations.

According to legal regulations, sharing and transferring de-identified personal information, and ensuring that the data recipient cannot recover and re-identify the personal information subject, does not constitute sharing, transferring, and publicly disclosing personal information. For such data, we do not need to notify you separately and obtain your consent.

If you do not agree to provide your personal information to third parties according to the above terms, please stop using our platform services immediately.

Four, How We Store Information

(1) Location of Information Storage:

Personal information collected and generated by us in operation within the Republic of Singapore is stored in Singapore, except for the following circumstances:

1. Clear legal regulations;

2. Obtaining your explicit authorization;

In the above situations, we will ensure that your personal information is adequately protected in accordance with this privacy policy.

(2) Information Storage Period:

We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless there is a mandatory retention requirement under the law. The criteria we use to determine the above period include:

1. Completing the service purposes related to you, maintaining corresponding service and business records, responding to your possible inquiries or complaints;

2. Ensuring the security and quality of the services we provide to you;

3. Whether you agree to a longer retention period;

4. Whether there are other special agreements on retention periods.

After the expiration of the retention period of your personal information, we will delete your personal information in accordance with the requirements of applicable laws or anonymize it.

(3) Deletion and Anonymization of Information

When this platform service decides to cease operation, we will stop collecting your personal information after the relevant service ceases operation. We will notify you of the cessation of operation through announcements. Your personal information that we already hold will be deleted or anonymized. In the case of children’s personal information, we will promptly inform the guardians of children of the cessation of operation.

Five, How We Protect Your Personal Information Security

To ensure the security of the personal information we collect, we promise to strive for a reasonable level of security. The specific security measures and capabilities are stated as follows:

(1) Technical Security Protection: To safeguard your information security, we strive to adopt various reasonable physical, electronic, and managerial security measures that comply with industry standards to protect your information, ensuring that your information will not be leaked, damaged, or lost, including but not limited to SSL, information encryption storage, and data center access control. We will use encryption technology to enhance the security of personal information; we will use trusted protection mechanisms to prevent personal information from malicious attacks; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information.

(2) Security System Guarantee:We have an advanced data security management system centered around data lifecycle, covering organization building, system design, personnel management, product technology, and other aspects to enhance the overall system security from multiple dimensions. Currently, to enhance the security of your use of our services and those provided by our affiliated companies and partners, protect your or other users’ or the public’s personal and property safety from infringement, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, and other security risks, more accurately identify violations of laws and regulations or our platform’s relevant agreements and rules, our platform has implemented a level protection system. Currently, our important information systems have undergone level three or above evaluation of network security protection and ISO27001 certification.

(3) Personnel Security Management:We have implemented strict management of employees or outsourced personnel who may come into contact with your information, including but not limited to different permission controls based on job positions, signing confidentiality agreements with them, monitoring their operations, etc. We will provide corresponding security measures to protect your information according to existing technology, provide reasonable security guarantees, and make every effort to ensure that your information is not leaked, damaged, or lost. We will hold security and privacy protection training courses to enhance employees’ awareness of the importance of protecting personal information.

(4) Protection Tips for Sensitive Information and Passwords:

a) Protection of Personal Sensitive Information:The information you voluntarily share or publicly share when using our services may involve personal information or even sensitive personal information, such as uploading your avatar picture, such as choosing to upload pictures containing personal information when commenting, posting, or sending bullet screens. Please consider more carefully whether to share or publicly share relevant information when using our services.

b) Please use complex passwords,to assist us in ensuring the security of your account. We will do our best to ensure the security of any information you send to us. If our physical, technical, or managerial protection facilities are compromised, leading to unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.

c) Your account has security protection functions,please keep your account and password information safe. We will ensure that your information is not lost, abused, or altered by backing up to other servers, encrypting user passwords, and other security measures. Despite the aforementioned security measures, please understand that there are no “perfect security measures” on the information network.

(5) Information Disclosure Tips and Password Leakage Handling: Please note that the Internet is not an absolutely secure environment. Please protect your personal information properly and only provide it to others when necessary. If you find that your personal information has been leaked, especially if your account and password have been leaked, please contact our customer service immediately so that we can take appropriate measures.

(6) Handling of Information Security Incidents:In the event of a personal information security incident, we will inform you in accordance with legal requirements: the basic situation of the security incident and possible impacts, the disposal measures we have taken or will take, suggestions for you to prevent and reduce risks, and remedial measures for you. We will inform you of the event-related information through emails, phone calls, push notifications, etc. If it is difficult to inform each individual information subject, we will announce it in a reasonable and effective manner. At the same time, we will also report the disposal of personal information security incidents to regulatory authorities as required.

(7) Security of Children’s Personal Information:We strictly set access permissions for children’s personal information, adopt the principle of minimum necessary authorization for employees who may come into contact with children’s personal information, and take technical measures to record and control the behavior of employees handling children’s information to prevent illegal copying and downloading of children’s personal information.

We have formulated an emergency plan for children’s personal information security incidents, regularly organize internal personnel for emergency response training and drills, so that they can understand their duties and emergency response strategies and procedures. In the event of a children’s personal information security incident, we will promptly inform children and their guardians in accordance with legal requirements: the basic situation of the security incident and possible impacts, the disposal measures we have taken or will take, suggestions for children and their guardians to prevent and reduce risks, and remedial measures for children and their guardians. We will promptly inform children and their guardians of the event-related information through APP push notifications, emails, text messages, etc. If it is difficult to inform each individual, we will announce relevant warning information in a reasonable and effective manner. At the same time, we will also proactively report to regulatory authorities the disposal of children’s personal information security incidents. If the legitimate rights and interests of children and their guardians are damaged, we will bear corresponding legal responsibilities.

Six, Protection of Minors

We attach great importance to the protection of personal information of minors. If you are a minor, we ask you to have your parents or other guardians carefully read this privacy policy and use our services or provide information to us with the consent of your parents or other guardians.

We have products or services specifically designed for children under 14 years old, product or service features specifically for children, or products or services that require users to input age information or other information that can identify the user’s age.

If we identify you as a child user, we will notify your parents or other guardians and request their consent to the rules for collecting and using children’s personal information.For cases where children’s personal information is collected with the consent of parents or other guardians to use our products or services, we will only use, share, transfer, or disclose this information when permitted by laws and regulations, with the explicit consent of parents or guardians, or when necessary to protect the rights and interests of minors.

If you are the parent or guardian of a child, please pay attention to whether the child you are supervising is using our services with your authorized consent. If you have any questions about the personal information of the child you are supervising, please contact us through the contact information provided in Section Nine.

Seven, How to Manage Your Information

According to the requirements of the “Network Security Law of the Republic of Singapore,” we provide convenient methods for you to access, correct, and delete your account information or other personal information provided when using our services. You can access and manage your personal information in the following ways:

(1) Access Your Personal Information

You have the right to access your personal information, except for exceptions stipulated by laws and regulations. You can access your personal information by yourself through the following methods:

Account Information—If you wish to access or edit your personal basic information and payment information in your account, change your password, add security information, or close your account, you can log in to your account and perform such operations through “Account Management”; for example, you can log in to the PC or APP “My Account” to query, modify your personal information, privacy settings, security settings, and modify your personal registration information.

(2) Correct or Supplement Your Personal Information

When you find errors in the personal information we process about you, you have the right to request corrections or supplements. You can submit correction or supplement requests through the methods listed in “Access Your Personal Information.”

(3) Delete Your Personal Information

You can delete some of your personal information through the methods listed in “Access Your Personal Information.”

You can request the deletion of personal information from us in the following situations:

1. If our processing of personal information violates laws and regulations;

2. If we collect and use your personal information without your explicit consent;

3. If our processing of personal information seriously violates our agreement with you;

4. If you no longer use our products or services, or you voluntarily cancel your account;

5. If we permanently stop providing products or services to you

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete it as soon as possible, unless otherwise provided by laws and regulations, or these entities have obtained your independent authorization.

After you delete information from our services, we may not immediately delete the corresponding information from the backup system, but will delete this information when the backup is updated.

(4) Change the Scope of Your Authorized Consent

Each business function requires some basic personal information to be completed. In addition to this, for the collection and use of additional personal information, you can set or revoke your authorized consent in my account management or contact our platform customer service.

After you revoke your consent, we will no longer process the corresponding personal information. However, your decision to revoke consent will not affect the personal information processing conducted based on your authorization before.

(5) Account Cancellation by the Data Subject

Currently, we have implemented technical means to allow you to submit an account cancellation application on the “Cancel Account” page by yourself (for example, on the DOORM APP on your mobile phone, go to “My-Settings-Security Center-Cancel Account,” on the PC side, go to the DOORM homepage, My-Account Settings-Security Settings-Account Cancellation). If you need to cancel, you can also contact our platform customer service. After verifying the user’s identity, the customer service will release the user’s phone number and email after the user’s account is canceled.

After you voluntarily cancel your account, we will stop providing products or services to you, delete your personal information according to the requirements of applicable laws, or anonymize it. If you have uploaded videos on our platform before canceling your account, if you do not want the related videos to continue to be disseminated on our platform, please delete them yourself. If you choose not to delete them, it will be deemed that you agree to continue authorizing our platform to disseminate such videos on the information network. If you choose not to delete the videos you uploaded, after you cancel your account, the personal information of the uploader in those videos displayed on our platform will be anonymized or desensitized.

(6) Restrict Information System Automated Decision-Making

In some business functions, we may make decisions solely based on non-human automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will provide an appeal method without infringing on our platform’s trade secrets or other users’ rights and social public interests.

(7) Unsubscribe

If you receive video content and product or service information push notifications that you did not actively search for or browse and do not wish to receive such information, you can unsubscribe through the original path, for example, you can directly reply with the relevant unsubscribe command to SMS push notifications, or for continuous monthly membership services, you can call customer service to provide feedback and cancel your continuous monthly service.

(8) Responding to Your Requests

For security reasons, you may need to provide a written request or other proof of your identity. We may first ask you to verify your identity before processing your request.

Eight, Revision and Update of This Privacy Policy

We have the right to modify the privacy policy and notify you through announcements on our platform or other appropriate means before the revision takes effect. In such cases, if you continue to use our services, it means that you agree to be bound by the revised privacy policy of our platform.

Without your explicit consent, we will not restrict your rights under this privacy policy. We will publish any changes and updates to the privacy policy on a dedicated DOORM link. For significant changes, we will also provide more prominent notifications (including notifications through announcements on our platform or even pop-up prompts to you).

Nine, Contact Us

We have established a dedicated personal information protection team and a person in charge of personal information protection. If you have any questions, complaints, or suggestions regarding this privacy policy or personal information protection matters, you can contact us through the following methods:

Send your questions to service@doorm.ai