FaceLink Privacy Policy

Updated: February 18, 2022
Effective: March 10, 2022

Introduction


  This privacy policy applies to products or services provided by Shenzhen Dinghefeng Technology Co., Ltd. (hereinafter referred to as "we" or "Dinghefeng") and its extended functionalities (hereinafter referred to as "FaceLink"), including Heylink Audio APP, mini-programs, and various products and services offered as new forms emerge due to technological development. If a particular product provided by us has its own privacy policy or specific agreements within its user service agreement, then the privacy policy of that product shall prevail. For content not covered by the product’s privacy policy and user agreement, this policy shall apply. If the products or services of our affiliated companies use the products or services provided by Dinghefeng but do not have a separate privacy policy, then this privacy policy also applies to those products or services.
  Please read the "FaceLink Privacy Policy" carefully, (especially the bold content) and ensure you understand our rules regarding the handling of your personal information. If you have any questions during the reading, you can consult us through the contact information in the "Heylink Audio Privacy Policy".

Main Text:


  Welcome to use Heylink Audio products and services! We highly value user privacy and personal information protection. When you use our products or services, we may collect and use your relevant information. We hope to explain through the "Heylink Audio Privacy Policy" ("this Privacy Policy") how we collect, use, store, share, and transfer this information when you use our products or services, as well as how we provide ways for you to access, update, delete, and protect this information. This Privacy Policy is closely related to the Dinghefeng service you use and the various business functions included in the service (hereinafter collectively referred to as "our products" or "services"). We hope you read carefully before using our products or services and confirm that you have fully understood the contents stated in this Privacy Policy, and make choices you deem appropriate according to the guidance of this Privacy Policy. We try to express the relevant terms involved in this Privacy Policy in a concise and straightforward manner to help you understand better.
  FaceLink supports sharing your data with third parties to obtain more professional services. Please read the privacy policy of the third-party software carefully before enabling the service. In addition, we will obtain your authorization again before sharing data.
  After you exit the "FaceLink" application, the app will still access the phone sensors to obtain step count data and connect to the network to complete data synchronization, message reception, device software updates, and log upload services.
  Your FaceLink information contains sensitive personal information, which we will upload to the Dinghefeng server only after you explicitly agree in the application. Your aforementioned data will be stored within the territory of the People's Republic of China.

1. Service Content

1.1 This application is a Bluetooth headset product service APP, which can realize hardware connections, obtain company product information, and other series of services. All illegal and pornographic content is strictly prohibited within the APP. Violators of the community operation norms will be banned.
1.2 The specific content of this application's services is provided by the creators of the application based on actual situations.
1.3 Unless otherwise explicitly stipulated in this registration and service agreement, new products, features, and services launched by this application are subject to this registration and service agreement.
1.4 This application only provides relevant network services. Other related equipment (such as personal computers, mobile phones, and other devices related to accessing the Internet or mobile networks) and the costs associated (such as telephone and internet fees for accessing the internet, and mobile fees for using the mobile network) are to be borne by the user.
1.5 When you use our services, we will call the device's gyroscope, accelerometer, and gravity sensor to identify and determine the state of your device.
1.6 When you use our services, we will use Umeng SDK to collect your personal information. The specific information is as follows:

    Platform Name: Umeng
    SDK Used: Umeng SDK
    Service Type: Data Statistics and Analysis
    Type of Personal Information Collected: Device Information (clipboard information/device serial number/AndroidID/IMEI/MAC/Android/ID/IDFA/OpenUDID/GUID/SIM card IMSI/geographical location, etc.)
    Privacy Policy Link: https://www.umeng.com/page/policy

1.7 When you use our services, we will use AMap SDK to collect your personal information. The specific information is as follows:

    Platform Name: AMap
    SDK Used: AMap SDK
    Service Type: Map Services
    Type of Personal Information Collected: Device Information (clipboard information/device serial number/AndroidID/IMEI/MAC/Android/ID/IDFA/OpenUDID/GUID/SIM card IMSI/geographical location, etc.)
    Privacy Policy Link: https://cache.amap.com/h5/h5/publish/238/index.html

1.8 When you use our services, we will use iFLYTEK SDK to collect your personal information. The specific information is as follows:

    Platform Name: iFLYTEK
    SDK Used: iFLYTEK SDK
    Service Type: Voice Services
    Type of Personal Information Collected: Device Information (clipboard information/device serial number/AndroidID/IMEI/MAC/Android/ID/IDFA/OpenUDID/GUID/SIM card IMSI/geographical location, etc.)
    Privacy Policy Link: https://www.xfyun.cn/doc/policy/privacy.html#%E4%B8%80%E3%80%81%E5%AE%9A%E4%B9%89%E4%B8%8E%E8%A7%A3%E9%87%8A

2. How We Collect and Use Your Personal Information

  Personal information is various information related to an identified or identifiable natural person recorded electronically or by other means, excluding information after anonymization. Sensitive personal information, which if leaked or used unlawfully, could easily harm the dignity, personal safety, or property safety of a natural person, includes biometric, religious beliefs, specific identity, medical health, financial account, whereabouts, etc., as well as personal information of minors under fourteen years of age.
  We will follow the principles of legitimacy, legality, and necessity. For the purposes outlined in this policy, we collect and use your personal information that you provide actively or generate during the use of our products or services, as well as personal information about you from third parties. If we want to use your personal information for purposes not stated in this policy, or for other purposes than for which it was collected, we will inform you in a reasonable manner and obtain your consent again before use.
  When you use our products/services, we need/may need to collect and use the following types of your personal information:
(1) To provide you with the basic functionalities of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide such information, you will not be able to use our products and/or services properly;
(2) To provide you with additional functionalities of our products and/or services, you can choose to agree or disagree with our collection and use of information. If you refuse to provide, you will not be able to use the related additional functionalities properly or achieve the effects we intend, but it will not affect your use of our basic functionalities.
We especially remind you: We are committed to creating a variety of products and services to meet your needs. Since we offer many types of products and services, and the specific range of products/services chosen by different users varies, the basic/additional functionalities and corresponding types and scope of personal information collected and used will differ. Please refer to the specific product/service functionalities.

3. The specific functionalities we will provide for you include:

(I) Log in to the APP
To create and log into an APP account, you need to provide your mobile number for SMS verification code login or to create a username and password. Not logging in or creating an account may affect your use of the APP for connecting headphones.
(II) APP Connection to Dinghefeng Products
1. Bluetooth Permission
Bluetooth permission is a basic permission for the APP. Only with this permission can the APP search and connect to Heylink Audio Bluetooth products. We promise that Bluetooth permission is only used for functions related to this APP and not for other purposes.
2. Location Permission
Location permission is also a basic permission for the APP. The mobile system requires the APP to have location permission to search for nearby Bluetooth products, and only with this permission can the APP find nearby Heylink Audio Bluetooth products. We promise that location permission is only used for functions related to this APP and not for other purposes.
3. Background Location Permission
Background location permission is not essential. It is used to search for nearby Heylink Audio Bluetooth products after adding APP widgets on Android phones. We promise that background location permission is only used for functions related to this APP and not for other purposes.
4. Synchronize Server Data
(1) Network Access Permission
Network access permission is a basic permission for the APP, used for account login, loading discovery pages, downloading Heylink Audio product information (product pictures, models, and manuals). We promise that network access permission is only used for functions related to this APP and not for other purposes.
(2) Data Read/Write Permission
Data read/write permission is a basic permission for the APP, used for creating local databases to record server cache data, cache network images, and read the local gallery (for customizing the background of the music playback interface, it reads local gallery content). We promise that data read/write permission is only used for functions related to this APP and not for other purposes.
5. Sensor Permission
User actively opens a webpage, supports the webpage to obtain sensor data, supports webpage sensor functions, and this permission is collected by Tencent SDK.
6. Camera Permission
Camera permission is not essential, used for adding FaceLink Bluetooth products on Android phones. We promise that camera permission is only used for functions related to this APP and not for other purposes.
7. Read Contacts
Reading contacts is also not essential, used for sharing FaceLink Bluetooth products on Android phones. We promise that reading contacts permission is only used for functions related to this APP and not for other purposes.
8. Device Information
To identify your device and prevent malicious software and cheating, to improve service security, and ensure operational quality and efficiency, we will collect your device information (including IMEI, device serial number, OAID, MEID, Android ID, IMSI, GUID, MAC address, SIM card serial number), installed APP information, or running process information.
9. Storage Permission
To enable junk cleaning and running acceleration functions, we will request your storage permission to access external storage information (SD card data), used to check the phone's CPU, memory, and SD card conditions.
10. Storage Permission
When you share or receive shared information, you need to access your clipboard locally, read the contained passwords, share codes, links, etc., to realize functions or services like jumping, sharing, activity linkage, etc.

4. How We Share Information Externally

(I) Sharing
We do not share your personal information with companies, organizations, and individuals outside of FaceLink service providers, except in the following cases:
1. Sharing necessary for fulfilling legal obligations: We may share your personal information as necessary for compliance with laws and regulations, for litigation, dispute resolution, or at the request of administrative or judicial authorities, and other necessary for the fulfillment of legal obligations;
2. Sharing with your consent: After obtaining your explicit consent, we will share your personal information with other parties;
3. Sharing necessary for the establishment or performance of a contract to which you are a party: When you purchase goods or services through the Dinghefeng official mall platform, we will share necessary information related to the transaction in your order with the relevant goods or service providers, to fulfill your transaction, delivery, and after-sales service requirements;
4. Sharing within affiliated companies: To facilitate our provision of certain services together with our affiliated companies, based on Dinghefeng platform accounts, to provide products and services, identify abnormal member accounts, protect the personal and property safety of Dinghefeng official mall, affiliated companies, or other users or the public from infringement, your personal information may be shared with our affiliated companies and/or their designated service providers. We only share necessary personal information, subject to the purposes stated in this policy. If we share your sensitive personal information or affiliated companies change the purpose of use and processing of personal information, we will seek your authorization and consent again. Please note that information you voluntarily share or publicly share when using our services may involve your or others' personal information or even sensitive personal information. Please consider carefully and make decisions.
(II) Storage Security
1. Data Protection Technical Measures
We have adopted industry-standard, reasonably feasible security measures to protect your information and prevent unauthorized access, public disclosure, use, modification, damage, or loss of personal information. For example, we use encryption technology to enhance the security of personal information, data exchanged between your browser and the server is encrypted and protected by the SSL protocol, and we provide HTTPS protocol for secure browsing; we use trusted mechanisms to prevent malicious attacks on personal information; we deploy access control mechanisms to ensure only authorized personnel can access personal information. Currently, our important information systems have passed level three or above assessments for network security level protection.
2. Data Protection Management Organizational Measures
We have established an industry-leading data security management system centered on data, covering data lifecycle, including organizational construction, system design, personnel management, and product technology dimensions to enhance the security of personal information. We have set up a dedicated department for personal information protection and designated personnel responsible for child personal information protection. We continuously strengthen employees' awareness of the importance of protecting personal information through training courses and exams.
3. Response to Personal Information Security Incidents
If our physical, technical, or management protective facilities are compromised, leading to unauthorized access, public disclosure, tampering, or destruction of information, and thereby damaging your legitimate rights and interests, we will promptly initiate emergency plans, take reasonable and necessary measures to minimize the impact on your personal information. In the event of a personal information security incident, we will inform you of the basic situation and possible impact of the security incident, measures we have taken or will take, suggestions for you to independently prevent and reduce the risk, and remedies for you, as required by laws and regulations. We will inform you via text message, phone call, push notification, and other reasonable channels. If it's difficult to inform each individual, we will take reasonable and effective methods to make announcements. At the same time, we will report the handling of personal information security incidents as required by regulatory authorities.
4. Prevention of Account Security Risks
When using Dinghefeng official mall services for online transactions, you inevitably need to disclose your personal information, such as contact information or postal address, to the transaction counterpart or potential transaction counterpart. Additionally, you can establish communication, exchange information, or analyze content with third parties through our services. Please protect your personal information properly, provide it to others only when necessary, and avoid careless disclosure through shared documents to prevent information theft.

5. Policy Updates

In our continuous efforts to provide you with a better product and service experience, we are constantly improving our products, services, and technology. When there are changes in new services and business processes, we may update our privacy policy to inform you of the specific changes. However, without your explicit consent, we will not restrict your rights as provided by this policy.
For significant changes, we will also provide more prominent notifications (including notifications through the official Dinghe Feng Mall or pop-up prompts).
Significant changes referred to in this policy include but are not limited to:
1. Significant changes in the business model of the product, such as the purpose of processing personal information, types of personal information processed, and the way personal information is used;
2. Substantial changes in privacy policy due to business adjustments, transactions, or mergers, where the new entity receiving personal information changes the original processing purposes and methods;
3. Significant changes in the main recipients of personal information sharing or public disclosure;
4. Significant changes in the rights of users regarding their personal information and how they are exercised;
5. Changes in the contact information of the person responsible for personal information protection and the channels for filing complaints;
6. When the impact assessment report on personal information protection indicates that the product has a significant impact on individual rights.

6. Account Cancellation

6.1 If you need to cancel your account, you must meet the following conditions simultaneously:
(a) No unusual logins have occurred in the last 1 month for the account;
(b) The account has not been reported or complained about;
(c) There are no unused rights in the account. If you still have unused rights, the cancellation request will be considered as your voluntary abandonment of the corresponding rights;
(d) You completely waive the right to retain or recover such data;
(e) Account cancellation does not involve any ongoing complaints, disputes, lawsuits, regulatory investigations, etc., and there are no current risks related to litigation or regulatory actions;
(f) There are no other circumstances in which legal obligations that should be fulfilled according to laws and regulations have not been fulfilled.
The account cancellation process is as follows: Login to the FaceLink APP - My - Settings - Account and Security - Account Cancellation; Before you cancel your account, we will verify your account information. You understand and agree that canceling your account is irreversible;
6.2 Consequences of Account Cancellation
You understand and agree that after completing the account cancellation process, there will be consequences including but not limited to the following:
(a) You will be unable to perform any privileged operations with that account;
(b) You will not be able to log in to the FaceLink APP account with that account again;
(c) After cancellation, we will clear your data, and you will not be able to retrieve all the information and data you have stored or used under that account;
(d) Other consequences that may harm your rights or cause you losses;

7. How to Contact Us

To better protect your personal information, we have a dedicated department for network security and personal information protection. If you have any questions or suggestions about this policy or your personal information while using Xuncheng Intelligent products, please contact us through the following methods:
Contact Email: dhf_sz@163.com
Contact Address: Block A6-20, Building A, No. 108 Lijia Road, Henggang Community, Henggang Street, Longgang District, Shenzhen City

8. Protection of Minors

We attach great importance to the protection of personal information of minors. If you are under 18 years of age, we will not process your personal information without the consent of you or your guardian. If you are the guardian of a minor, when you have questions about the personal information of the minor you are supervising, please contact us through the contact information in Section 10. In particular, if you are a child under 14 years of age, we have also prepared a "Children's Privacy Protection Statement" for you. Children and their guardians should carefully read the "Children's Privacy Protection Statement" before using Tencent App Market services for children under 14 years of age. We will only process the personal information of children under 14 years of age with the consent of their guardian in accordance with the "Children's Privacy Protection Statement".