Version: 1

Publication date of this privacy statement: February 3, 2024

Effective date of this privacy statement: February 3, 2024

Contact number: (0755) 8652-0569

Contact email: developer@datatower.ai

Registered address: A03, Vanke Cloud City Design Commune, Xingke Road, Xili Community, Xili Street, Nanshan District, Shenzhen

Common work address: A03, Vanke Cloud City Design Commune, Xingke Road, Xili Community, Xili Street, Nanshan District, Shenzhen

Introduction

Shenzhen Potato Information Technology Co., Ltd. (hereinafter referred to as "we") has always attached great importance to the protection of personal information. When developers use the SDK and other data import tools we provide, we will collect, use, store, share, transfer, and publicly disclose the personal information of end users of developers in accordance with the relevant provisions in this "DataTower.ai SDK Privacy Statement" (hereinafter referred to as "this Privacy Statement") and other relevant legal texts within the territory of the People's Republic of China (excluding Hong Kong, Macao Special Administrative Region and Taiwan Region of China for the purpose of this Privacy Statement).

This privacy statement is closely related to the use of our services by developers (hereinafter referred to as "you") and end users. We recommend that you and your end users carefully read and understand all the contents of this privacy statement, especially to ensure that they are fully aware of and fully understand the meaning of the bold font content and the corresponding legal consequences. Based on this, you and your end users can make appropriate choices. If you choose to use our services, you should agree and ensure that your users have also agreed to this privacy statement . We will abide by the following principles to protect your end users' personal information: legal, legitimate, necessary and good faith principles, with clear and reasonable purposes, clear and reasonable and directly related principles, minimum necessary principles, open and transparent principles, quality assurance principles, responsible and safeguard personal information security principles, etc. At the same time, we strive to use easy-to-understand and concise language expression, and for the provisions in this privacy statement that have a significant relationship with the rights and interests of your end users, use bold words to mark them to remind your end users to pay attention . If you end users have any questions, comments or suggestions about the content of this privacy statement, you end users can consult us through the contact information set forth in this privacy statement. If you still do not agree to the terms of this statement on the basis of your full understanding of this statement, it is recommended that you immediately stop accessing and using the products and/or services provided by the DataTower.ai SDK (hereinafter referred to as "DT SDK").

This privacy statement will help you understand the following:

How we collect and use your end users personal information

II. How we use cookies and similar technologies

How we share, transfer and publicly disclose your end users personal information

How we store and protect your end users personal information

Rights of your end users

Agreement on Juvenile personal information

How to update and revise this privacy statement

How to contact us

1、How we collect and use your end users personal information

Personal information refers to various information related to identified or identifiable natural persons recorded electronically or in other ways, excluding information processed anonymization.

Sensitive data is once leaked or illegally used, it is easy to cause the personal dignity of natural persons to be infringed or personal and property safety to be endangered personal information, including biometric identification, religious beliefs, specific identities, medical health, financial accounts, whereabouts and other information, and personal information of minors under the age of 14 .

During your use of products and/or services integrated with the DT SDK, we will collect information generated by your end users due to the use of the service and actively provided by your end users when using the service in accordance with the principles of legality, propriety, necessity, and good faith, and collect personal information lawfully collected from third parties in accordance with laws and regulations or your end users' consent, in order to understand the performance and usage of your application on different end point devices, platforms, or application distribution channels, provide you with analysis services, and output analysis results. The specific situation is as follows:

SDK Name	Types of personal information	Personal information field And content	Personal information processing purposes	Involving sensitive permissions
DT SDK	Device information	Device attribute information (Android ID/OAID/IDFV/IDFA), Device information (network information, device brand/model, system information)	User identification	Device information permission
	Location information	Location information, country/region, city for IP address resolution	User behavior analysis	No
	Unique application number	Application unique identifier, application process, application name, and application version number	User behavior analysis	No

You can disable or turn off the collection of some personal information by switching on and off. If you perform such operations, we will no longer collect the corresponding personal information involved. In addition, under the Private Deployment mode, the personal information of the aforementioned end users is collected and used by you through data tools. We cannot access such information, and you are fully responsible for the collection, use, storage, and other processing of such information.

You should disclose the collection of your end users personal information in the privacy statement of your application and ensure that you have obtained the consent of your end users in accordance with legal requirements; for the avoidance of doubt, the consent here includes the consent of end users to us collecting and using their personal information to provide you with products and/or services integrated with the DT SDK.

1.1 How we use your end users personal information

In order to comply with national laws, regulations and regulatory requirements, provide functions and services to your end users and improve the quality of functions and services, we will use your end users' information in the following situations:

Achieve the purposes described in this privacy statement "how we collect personal information from your end users";
Report to relevant departments in accordance with laws, regulations or regulatory requirements.

1.2 Device permission invocation instructions

If end users need to turn off the function permissions (such as device information permissions, etc.) that are enabled for the use of certain specific functions mentioned above, most mobile devices will support this requirement of end users. For specific methods, please refer to or contact the service provider or manufacturer of the mobile device. Please note that if a user enables any permission, it means that we authorize us to collect and use relevant information to provide corresponding services. Once end users close any permission, it means that the user cancels the authorization. We will no longer collect and use relevant information based on the corresponding permission, nor can we provide the corresponding service .

1.2.1 Android SDK Product Permission Description

To ensure the normal deployment of supporting customer data collection, the Android platform's SDK requires the following system permissions:

Permissions	Purpose	Whether it is necessary to
INTERNET	Allow Apps to Send Statistical Data	Required permission, SDK needs this permission to send event tracking data
ACCESS_NETWORK_STATE & ACCESS_WIFI_STATE	Allow applications to detect network status	Permission is required, the SDK will choose whether to send data based on the network status
READ_PHONE_STATE	Allow applications to obtain device IMEI.	Optional permissions will be used when collecting operator-related attributes

1.2.2 iOS SDK Product Permission Description

To support the proper deployment of customer data collection, the SDK of the iOS platform requires the following system permissions:

Permissions	Purpose	Whether it is necessary to
Network (specialized for Chinese server)	Allows apps to send data	Required permissions, SDK to send event tracking data requires this permission
IDFA	Allow applications to obtain IDFA.	Optional permissions, This permission will be used when using in-app promotion

1.3 Exceptions with consent

According to relevant laws and regulations, in the following circumstances, we may lawfully collect and use your end users' personal information without the consent of your end users:

Related to fulfilling obligations stipulated by laws and regulations.
Directly related to national security and national defense security.
Directly related to public safety, public health, and major public interests.
Directly related to criminal investigation, prosecution, trial, and judgment execution.
For the purpose of safeguarding your or your end users' significant legal rights and interests such as life and property, but it is difficult to obtain your consent.
The personal information involved is disclosed to the public by you or your end users;
Necessary to enter into and perform the contract at your or your end users request;
Collect your or your end users' personal information from legally disclosed information, such as from legal coverage, government information disclosure and other channels;
Other circumstances stipulated by laws and regulations.

1.4 Change of purpose of collecting and using personal information

With the development of our business, our functions and services may be adjusted and changed. In principle, when a new function or service is related to the function or service we currently provide, the personal information collected and used will be related to the original processing purpose. In scenarios that are not related to the original processing purpose, we will collect and use your end users' personal information again and obtain your consent. You should inform your end users and obtain their consent.

2、 How we use cookies and similar technologies

2.1 Cookie

When end users use products and/or services integrated with the DT SDK through various devices, including but not limited to mobile end points, to ensure the normal operation of the system, we will store small data files called cookies on the end users' devices. Cookies usually include identifiers, site names, and some numbers and characters. The main function of cookies is to provide more thoughtful personalized services to end users and allow users to set specific service options. We will not use cookies for any purpose other than those described in this privacy statement. You end users can manage or delete cookies according to your preferences. You end users can clear all cookies saved on your computer, and most web browsers have a function to block cookies. However, if you end users do so, you will need to personally change customer settings every time you visit our website , but end users may not be able to log in or use services or features provided by developers that rely on cookies because of such modifications.

2.2 Do Not Track

Many web browsers have a Do Not Track function, which allows you to send Do Not Track requests to websites. Currently, major internet standards organizations have not established relevant policies to regulate how websites should respond to such requests. However, if your end users' browsers have enabled Do Not Track, then all of our websites will respect your end users' choices.

3、How we share, transfer and publicly disclose your end users personal information

When end users use products and/or services integrated with the DT SDK, the information collected through the DT SDK is stored in the DataTower.ai cluster purchased by the developer (including Private Deployment and SaaS versions). We have no right to access user personal data and do not involve the sharing, transfer, or public disclosure of end users' personal information.

4、How we store and protect your end users personal information

4.1 Storage of personal information

The end users personal information collected by developers is stored on the DataTower.ai cluster and its associated servers purchased by them. Developers should strictly store personal information in accordance with laws and regulations (such as storing personal information collected in China in China) .
When end users use products and/or services integrated with DT SDK, the DataTower.ai cluster purchased by the developer and its associated servers are responsible for storing end users' personal information. Developers should store information in accordance with legal requirements, and please ensure that the personal information of end users is deleted or anonymized after the retention period exceeds.

4.2 Protection measures for personal information

We have implemented industry-standard security measures to protect your end users' personal information from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonable and feasible measures to protect your end users' personal information. For example, we will use encryption technology to ensure the confidentiality of data; we will use trusted protection mechanisms to prevent malicious attacks on data; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information.
Our data security capabilities: We have used security measures that comply with industry standards to protect the personal information of your end users, and to prevent unauthorized access, public disclosure, use, modification, damage, or loss of data as much as possible. We will take all reasonable and feasible measures to protect the personal information of your end users.
The Internet is not an absolutely secure environment, and we will do our best to ensure the security of any information you send to us. At the same time, please ensure that you and your end users keep your account, login password, and other identity elements properly.
In the event of a personal information security incident, we will promptly inform you of the relevant situation by email, letter, phone, push notification, etc. in accordance with the requirements of laws and regulations, or take reasonable and effective measures to publish announcements. If we inform you of the relevant situation of the incident, you should promptly inform your end users. At the same time, we will also report the handling of personal information security incidents in accordance with laws and regulations.

5、Your rights

As our customer, you have a direct contractual relationship with us, which is different from the indirect relationship between us and your end users. You should promise to provide your end users with an easy-to-operate user rights implementation mechanism and explain to your users how to exercise their legal rights to personal information. Based on different relationships and in accordance with relevant Chinese laws and regulations, we will take different measures as much as possible to protect your end users' right to manage information, as follows:

5.1 Customers who directly use our products or services

In view of the developer's direct obligation to respond to users' requests for personal information, the developer should: provide and clarify the functions and ways for users to access, copy, modify, delete personal information, withdraw consent, transfer personal information, restrict personal information processing, obtain copies of personal information, and cancel accounts based on the actual situation of integrating the DT SDK.

5.2 Users who have installed applications that use our products or services

As end users are not our direct users and there is no direct interaction interface between them and the DT SDK, in order to ensure the realization of your rights, we have requested third-party developers to promise to provide user rights realization functions and methods that are easy to operate. If you need to access, copy, modify, delete their related personal information, withdraw consent, restrict personal information processing, obtain copies of personal information, and cancel your account, you can achieve your personal information needs through the above functions provided by third-party developers.

6、Agreement on Juvenile personal information

We attach great importance to the protection of information of underage users. DT SDK products and/or services are mainly aimed at enterprises and adults. We have asked developers to ensure that the users of the products and/or services are individuals aged 18 or above. If you are a Juvenile under the age of 18, you should ensure that your guardian accompanies you to read and agree to this statement before using products and/or services integrated with DT SDK and providing your personal information.

If your application provides services to children under the age of 14 (hereinafter referred to as "children"), you should inform the parents or guardians of the child's personal information processing in accordance with laws and regulations, and obtain the consent of the parents or guardians.

If you find that we have processed children's personal information without their knowledge or prior consent from verifiable parents or other guardians, you can contact us in a timely manner, and we will try to delete it in a timely manner after discovery. If we discover the above situation ourselves, we will also delete it in a timely manner, except as otherwise provided by laws and regulations.

7、How to update and revise this privacy statement

We reserve the right to update this statement in a timely manner. Without your affirmative consent, we will not change the rights you are entitled to under this statement. If this statement is updated due to DT SDK functions and other reasons, we will notify you through website announcements and other means so that you can be informed of any changes made to this statement in a timely manner.

If you are a third-party developer, when there are significant changes in the handling of end users' personal information in this updated statement, you should update the Privacy Policy in a timely manner and inform the App and other end users through pop-ups and other means. If end users do not agree to accept the modified Privacy Policy, please stop using the products and/or services of the DT SDK. If end users continue to use products and/or services integrated with the DT SDK, they are deemed to have accepted our modifications to the relevant terms of this statement.

8、How to contact us

If you have any questions, comments or suggestions about this Privacy Statement, you can contact us at:

Contact address: A03, Vanke Cloud City Design Commune, Xingke Road, Xili Community, Xili Street, Nanshan District, Shenzhen

Contact email: developer@datatower.ai

Under normal circumstances, we will respond within 15 working days.

If you are not satisfied with our response, especially our personal information processing behavior has damaged your legitimate rights and interests, you can report to the relevant government departments.

隐私与安全