User Personal Information and Privacy Protection Policy

Updated date: November 3, 2022 Effective Date: November 3, 2022

Thank you for using our platform.

This User Privacy Policy (hereinafter referred to as this "Policy") will help you understand the following:

Collection and Use of Your Personal Information;

Commissioned Processing, Sharing, Transfer, and Public Disclosure of Your Personal Information;

Use of Cookies or Similar Technologies;

Storage and Protection of Your Personal Information;

Your Rights;

Protection of Minors

Scope of Application of this Policy

Changes to this Policy;

Contacting Us.

This Privacy Policy applies to various services, software (including "YUI System", "YVR Cinema", "YVR GO", "Streaming Assistant", "User Guide", etc.) and applications (including "YVR Assistant", "YVR Wireless Display Assistant", "Streaming Assistant", etc.) and services (including the release and display of information, pictures, articles, comments, links, etc.) provided through the YVR distribution platform, but not applicable to products or services provided by third parties (hereinafter referred to collectively as the "Third Party Services"). Before choosing to use Third Party Services, you should fully understand the product features and privacy protection policy of the Third Party Services. This Policy is applicable to our processing of your personal information based on your authorization before the issuance of this Policy. If you do not agree to this Policy, please cease using our services. By continuing to use our products and/or services, you acknowledge that you agree to be bound by this Policy. However, your disagreement with this Policy will not affect the personal information previously processed under your authorization.

We hereby remind you to read, understand, and agree to this Policy and the relevant supplementary documents before using this platform. Please carefully read and fully understand the content of each clause, especially the exemption or limitation of liability clauses and clauses excluding or limiting your rights, as well as the separate agreement on the subscription to or use of a service of the platform. You are not entitled to use any service of the platform, unless you have read and accepted all the terms and conditions contained herein. By registering an account with the platform, logging on to the platform, or using any other service provided by the platform, you acknowledge that you have read and agreed to all the content of this Policy.

I. Definitions

1."Company" means Shanghai YVR Technology Co., Ltd. and its affiliates (hereinafter referred to as "YVR"). "Platform" means the platform developed, designed, and operated by the Company that offers a series of services to users.

2."User" or "you" means the natural person who has successfully registered with the platform and uses relevant services of the platform (hereinafter referred to as the "Services").

3."Personal information" refers to any information recorded electronically or otherwise that can be used alone or in combination with other information to identify a specific natural person or reflect activities of a specific natural person, including but not limited to name, date of birth, ID number, home address, communication and contact information, account password, property status, whereabouts, and trails. "Personal sensitive information" includes ID number, personal biometric information, bank account numbers, communication records and content, property information, credit information, whereabouts and trails, accommodation information, health and physiological information, and transaction information.

4."Device" means a device that can be used to access our products and/or services, such as the desktop computer, laptop, tablet, or smartphone.

5."Cookie" means a small file containing a string of characters that is sent and stored on your computer, mobile device, or other devices (generally encrypted) when you log on to and use a website or other network content. Similar technologies are other technologies used for similar purposes as cookies, such as web beacons, proxies, and embedded scripts.

6."Payment service provider" means a company or institution that operates the payment channel connected by YVR to the platform, such as Alipay or WeChat Pay.

7."Data" means the data contained in content and services, including the information related to game preferences, game progress, and the time spent on games, and information about the device used, including the operating system, device settings, unique device ID, and crash data.

8."Partner" means a third party that provides content and services on the YVR platform, including the payment service provider, telecommunications service provider, and licensor.

9."De-identification" means the process in which personal information is processed technically to make it impossible to identify or associate with the subject of personal information without resorting to additional information.

10."Anonymization" means the process in which personal information is processed technically so that it cannot identify or be associated with the subject of personal information, and the processed information cannot be recovered. Information generated by the anonymization process of personal information shall no longer be personal information.

11."Processed data" means the data for which reasonable security measures, such as encryption, de-identification, or anonymization techniques, have been taken to ensure the data security and the privacy of the data subject.

II. Collection and Use of Your Personal Information

We collect certain personal information of you based on the principles of legality, legitimacy, and necessity during your use of the following services, to provide you with services, guarantee the security of your account, improve our service quality, and comply with applicable national laws and regulations and regulatory requirements.

1. Registration and logon

(1) When you register with the platform, you need to provide the device information that is used to verify your identity and determine the optimal way of displaying information to you. If you refuse to provide such information, you may not be able to normally use our services.

(2) When you register or log on to your account, you may need to provide your mobile phone number, name, email address, etc. We will send you an SMS verification code to verify your identity. If you refuse to provide such information, you may not be able to normally use part of our services.

2. Product view, search, use, and other services

(1) When you use the view, search, matching, and recommendation services, we collect your location information (your current geographical location), so as to recommend you services suitable in your region. If you refuse to provide such information, you can disable location services, and we will cease collection of such information. You may therefore be unable to use part of our services related to location information, but this will not affect your use of other services we provide.

(2) We collect information about your physical features, environment, movements, and measurements when you use our products and services. For example, when you set up the guardian system to alert you when you approach a boundary, we collect information about the play area that you have defined; and when you enable the hand tracking feature, we collect technical information like your estimated hand size and hand movement data to enable this feature.

(3) Device attributes and device operation: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins. Information about operations and behaviors performed on the device, such as whether a window is placed in the foreground or background, or mouse movements (which can help distinguish humans from bots).

(4) Data from device settings and device signals: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos, bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.

(5) Unique identifiers, device IDs, and other identifiers: such as identifiers from games, apps, or accounts you use, and family device IDs (or other identifiers unique to the Company's products associated with the same device or account).

(6) We may collect and retain, or authorize our third-party partners to collect and retain, your personal information, including your real name, identity information, location information, mobile phone number, your direct relative's name, and contact information.

(7) We will also collect information about you from third parties, including third-party apps, developers, and other online content providers, as well as marketing partners that provide information to us.

(8) Information about risk features generated by technical means such as risk control rules and machine learning: Such feature information is automatically generated through desensitization processing of the following information: information about your operations on the platform, the mobile device information we obtain under your authorization (including but not limited to device hardware information, device ID information, call information, and contact information), and all information we obtain from third parties under your authorization. If you refuse to provide all information, you may not be able to use services related to such information, but it will not affect your use of other services we provide.

(9) We may also collect your mobile phone number and transfer it to our partners of the services, so that the partners can generate your account information and complete the services for you. To provide such services, we may need to obtain your separate consent. If you withhold your consent, you may not be able to normally use the services.

(10) When you purchase related digital content on our products, we collect information about the transaction, including your payment information, purchase activity, delivery information, and contact information, so that we can provide you with product shipping and delivery services; we and the third-party payment channel may collect your payment card number, opening bank, card type, cardholder's name, ID number, and mobile phone number provided to the bank, so that you can pay for your products. If you refuse to provide all information, you may not be able to use such services, but it will not affect your use of other services we provide.

(11) When you publish relevant information, share information or communicate with us or other users on our products, we may collect and store the relevant interaction records and information, such as the publishing date.

(12) Information about your interaction with our products, such as information about the people, games, content, apps, features, or other experiences you interact with, including information collected through or from content provided by our third-party partners. For example, we collect information about in-app purchases you have made in a game provided by a third-party developer.

(13) Information about how you access our products: including information about the type of device you're using (such as a headset, PC, TV, mobile device, or other smart devices), its configuration (such as your operating system and graphics processing unit), your browser, IP address, and your device's performance.

(14) Certain identifiers that are unique to you. These identifiers include device and other identifiers, such as those from games and apps you use.

(15) When you use an online multi-user app, your public posts and other information you provide (including avatar, in-app profile information, and in-app status) will be visible to all people. Such public posts and information may be collected, reproduced, recorded, live broadcast, shared on or off our products, or submitted to us for purposes of reporting illegal acts or cracking down on harmful acts, by other users.

3. Security management

When you use a service we provide, to guarantee the secure and stable operations of the service, prevent and control risks, and improve the service, our server will automatically collect the type of service you use, the way you use the service, the type of your device, IP address, device software versions, device ID, device identifier, log information, and Internet access records.

The above separate device information or log information is not sufficient to identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person or use such non-personal information in conjunction with personal information, we will anonymize or de-identify such information, except where we obtain your special authorization or it is otherwise specified by law.

4. Personalized service

Based on your information we legally collect when providing certain services, we may reasonably provide you with personalized content and display and recommend personalized services to you by SMS message or email according to the mobile phone number or email address you provide, or by site message. If you refuse to use this service, you can disable such feature, and we will cease the provision of this service, but this will not affect your use of other services we provide.

5. Improvement of services

Subject to applicable laws and regulations, we may use the information we collect through certain services for other services we provide upon your separate consent, for purposes of delivering better services to you, improving our services, or for other purposes to which you have consented. For example, we use this information to:

(1) Provide you with hardware, content, games, apps, and other experiences;

(2) Enable certain features, such as hand tracking and voice services;

(3) Enable user-to-user communications and other related services;

(4) Notify you of updates to our products; and customize your experiences on our products based on your activities (including the content, games, apps, and other experiences you interact with), other online services you use, and other information we collect, and show you content that is most relevant to you;

(5) Solicit and analyze input and feedback about our products; conduct and learn from research about the ways in which people use our products;

(6) Improve services offered by others, such as third parties that offer content, games, apps and other experiences on our products; and improve and develop our features, such as voice services and hand tracking. For voice services, we analyze and examine your voice commands using human and machine processes to improve, train, and troubleshoot our speech recognition systems. For hand tracking, we collect technical information like hand tracking quality, the amount of time it takes to detect your hands, and the number of pinches you make to improve and troubleshoot this feature.

6. Others

In accordance with applicable laws and regulations and national standards, we may legally collect and use your personal information without your consent if such information is:

(1) Related to the performance of our obligations specified by laws and regulations;

(2) Directly related to national security or national defense security;

(3) Directly related to public safety, public health, or major public interests;

(4) Directly related to criminal investigation, prosecution, trial, execution of judgment, etc.;

(5) For the purpose of safeguarding the life, property, and other significant legitimate rights and interests of you or other individuals, but it is difficult to obtain your consent;

(6) Disclosed to the public by you;

(7) Collected from the information lawfully disclosed to the public through such lawful channels as news coverage and government information disclosure;

(8) Necessary to sign and perform contracts according to your requirements;

(9) Necessary to maintain the secure and stable operation of the services we provide, such as discovering and handling the failure of our services; or

(10) Under other circumstances as specified by laws and regulations.

7. Prompts

Third-party entities may provide services to you through the platform. When you enter the service pages operated by third-party entities, please note that the relevant services are provided by the third-party entities. If the third-party entities collect information from you, we suggest that you carefully review the privacy policy or agreement of the third-party entities.

When we use your personal information for other purposes not stated in this Policy, or use the information we collect for a particular purpose for other purposes, we will obtain your consent in advance. We will also use the aforesaid personal information of you for the purpose of continuously improving and optimizing the aforesaid features.

III. Use of Cookies or Similar Technologies

1. We or our third-party partners may obtain and use your information through cookies or similar technologies, and store such information as log information.

2. Cookies help us provide users with an easy-to-use and personalized web experience. A cookie is a small amount of data sent from the server to your browser and then stored on your computer's hard drive. We use cookies to benefit our users. Cookies help us determine the pages and content you have viewed, the time you spend on platform-specific services and the platform services you choose.

3. Cookies enable us to serve you better and faster, and to make your experience on the platform more personalized. However, you should be able to control whether and how cookies are accepted by your browser. Please refer to the file attached to your browser for more information in this regard.

4. We and our third-party partners may collect and use your information through cookies or similar technologies, and store such information.

5. We may use cookies or similar technologies for the following purposes:

(1) To remember your identity. For example, cookies or similar technologies help us identify you as our registered user, or save your preferences or other information you provide to us;

(2) To analyze your use of our services. We can use cookies or similar technologies to understand what activities you conduct in the platform services or which services are the most popular;

(3) To optimize advertisements. Cookies or similar technologies help us deliver advertisements relevant to you based on your information instead of general advertisements.

When we use cookies or similar technologies for the foregoing purposes, we may summarize and provide the non-personally identifiable information collected through cookies or similar technologies to advertisers and other partners to analyze how you and other users use the platform services and for advertising services.

6. The platform services may have cookies or similar technologies placed by advertisers and other partners. These cookies or similar technologies may collect non-personally identifiable information related to you for analyzing how users use such services, sending you advertisements that may be of interest to you, or evaluating the effect of advertising services. The collection and use of such information by these third-party cookies or similar technologies are not governed by this Policy, but are governed by their own personal information protection statement, and we assume no responsibility for these third-party cookies or similar technologies.

7. You can reject or manage cookies or similar technologies through your browser settings or user selection mechanism. However, please note that if you disable cookies or similar technologies, we may not be able to provide you with the best service experience, and you may not be able to normally use certain services. At the same time, you will still receive advertisements, but the relevance of these advertisements to you will decrease.

1. Commissioned processing

Certain specific modules or features in our services may be provided by third-party service providers. For example, we hire service providers to assist us in providing customer support. We sign a strict non-disclosure agreement with companies, organizations, and individuals who are commissioned to process personal information on our behalf, and require them to process personal information according to our requirements, this Policy, and any other related confidentiality and security measures.

2. Sharing

(1) We will not share, transfer, or publicly disclose your personal information, except under the following circumstances:

1) We share the information we collect with vendors, service providers, research institutions, and other partners, who work at our direction to support our products (such as hosting our products, fulfilling orders, facilitating payments, analyzing the way people use our products, processing credit card payments, providing customer service, or sending electronic communications for us). For example, we share recordings and transcripts of your voice interactions with vendors and service providers who assist us in improving, training, and troubleshooting our speech recognition systems.
2) We share information with our affiliates, depending on which services you use, for the purpose of strengthening user security, data security, product reputation, etc.
3) The personal information is related to performance by the personal information controller of the obligations specified by laws and regulations.
4) The personal information is directly related to national security or national defense security.
5) The personal information is directly related to public safety, public health, or major public interests.
6) The personal information is directly related to criminal investigation, prosecution, trial, execution of judgment, etc.
7) For the purpose of safeguarding the life, property, and other significant legitimate rights and interests of you or other individuals but where it is difficult to obtain your consent.
8) The personal information is disclosed to the public by you.
9) We are required by the competent regulatory authority to disclose the personal information.
10) The personal information is collected from the information disclosed through legitimate public channels, such as lawful news reports or information disclosure by governments.

(2) We may share your personal information with our affiliates. However, we will only share necessary personal information, subject to the terms and conditions of this Policy.

(3) We may share your personal information with our partners and other third parties (such as service platforms or service providers, and software and hardware/system service providers) only to the extent necessary to guarantee the smooth provision of services to you. We will only share your personal information for legal, legitimate, necessary, specific, and explicit purposes, subject to the terms and conditions of this Policy. Our partners have no right to use the shared personal information for any other purposes.

3. Transfer

We will not transfer your personal information to any companies, organizations, or individuals, except under the following circumstances:

(1) We have obtained your explicit consent in advance.

(2) In the event of asset transfer, acquisition, merger, restructuring, or bankruptcy liquidation where personal information transfer is involved, we will inform you of the relevant situation, and require that the new company or organization holding your personal information be bound by this Policy. If your personal information is used for other purposes, we will require that the company or organization solicit your explicit consent again.

(3) It is justified in order to comply with compulsory requirements of laws and regulations, legal procedures, litigation, or competent governmental authorities.

4. Public disclosure

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

(1) We have obtained your explicit consent in advance.

(2) It is justified in order to comply with compulsory requirements of laws and regulations, legal procedures, litigation, or competent governmental authorities.

V. Storage and Protection of Your Personal Information

1. Retention time

(1) Generally, we retain your personal information only for the minimum period necessary to fulfill purposes described in this Policy, unless it is otherwise specified by laws and regulations or we have obtained your separate consent. We will delete or anonymize your personal information upon expiration of the aforesaid retention period.

(2) We store data that identifies you until it is no longer necessary to provide our products or your account is deleted, whichever comes first, unless retention of the data for a longer period is justified in order to comply with law or record keeping obligations, respond to a legal request, prevent harm, or improve user security, data security, and product reputation. This is determined on a case-by-case basis, depending on things like the nature of the data, why it is collected and processed, and relevant legal, product reputation, or operational retention needs. For example, we retain certain purchase information for accounting and tax purposes even after you have deleted your account.

2. Storage location

Your information will be stored within the territory of the People's Republic of China. If cross-border transfer of your personal information is required, we will separately solicit your authorization or consent and strictly comply with applicable laws and regulations.

3. Security protection

We provide security guarantees for your information, to protect the information against loss, improper use, unauthorized access, or disclosure.

(1) We protect your personal information in strict compliance with laws and regulations.

(2) We will use reasonable security measures to guarantee information security. For example, we protect your personal information by anonymization, de-identification, or other means.

(3) After obtaining your full authorization, we will encrypt your personal information before collecting and storing such information.

(4) We have established a special management system, process, and organization to ensure information security. For example, we strictly limit the scope of people who can access information, require them to comply with confidentiality obligations, and conduct audits on them.

(5) We take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will retain your personal information only for the period necessary to fulfill the purposes stated in this Policy, unless a longer retention period is required or permitted by law.

(6) The Internet environment is not completely secure. Please use a complicated password to help us secure your account.

(7) In the event of a personal information security incident (information leakage, destruction, or loss), we will, in accordance with the requirements of laws and regulations, inform you of the basic information and possible impact of the security incident, the measures we have taken or will take, suggestions for risk prevention and reduction on your part, and remedial measures for you. We will promptly inform you of the relevant situation of the incident by site message, SMS, telephone, email, or other contact means you provided. When it is difficult to inform the subjects of personal information one by one, we will publish an announcement in a reasonable and effective manner. At the same time, we will voluntarily report the handling of the personal information security incident in accordance with the requirements of regulatory authorities.

VI. Your Rights

We do our best to protect your exercise of the following rights to your personal information in accordance with applicable laws and regulations. Your rights include:

1. Right to access personal information. You have the right to access your personal information, except as otherwise specified by laws and regulations. You can access and manage your personal information through the official customer service hotline.

2. Right to correct personal information. You can access and manage your personal information through the official customer service hotline when you need to correct your personal information or when you find that we have processed your personal information incorrectly.

3. Right to delete personal information. You can delete your personal information you upload. You may also make a request for deletion of personal information under any of the following circumstances:

(1) We handle your personal information in violation of laws and regulations.

(2) We collect and use your personal information without obtaining your consent.

(3) We handle your personal information in violation of the agreement with you.

(4) You no longer use our products or services, or you have canceled your account.

(5) We will no longer provide you with products or services.

If we decide to respond to your deletion request, we will also notify entities that have received your personal information from us, requiring them to promptly delete such personal information, unless it is otherwise specified by laws and regulations or these entities have obtained your separate authorization.

When you delete your personal information from our services, we may not immediately delete the relevant information from the backup system, but we will delete it when updating our backups.

4. Right to cancel personal account. You can cancel your personal information.

If you want to cancel your account, you can click [Me] > [Account & Security] > [Account Cancelation] on YVR Assistant, and then proceed as prompted.

After you voluntarily cancel your account, we will cease to provide you with, and you will no longer be able to access, the content and services, your account, game information associated with your account, and other services that you could previously access through your account. In addition, your personal information will become irretrievable or inaccessible or be deleted and/or anonymized, unless otherwise provided by applicable laws, regulations, rules, normative documents, or government policies or orders.

We would like to remind you that you should be prudent when choosing to cancel your account, as the cancellation of your account will affect your normal use of or access to the content and services or will bring inconveniences to your subsequent use of or access to the platform. Once your account has been canceled, it cannot be restored, so please back up all information and data related to your account before you do so. We shall not be responsible for any adverse impact on you arising from your request to cancel your account.

We will review and respond to your account cancellation request within seven working days after receiving it, to avoid canceling your account due to errors, such as loss of your account password or hacking. We will respond to your accounting settlement and other requests you made before sending the account cancellation request in such period. The personal information associated with your account will be deleted after the cancellation of your account.

5. Right to withdraw your consent or authorization. You can withdraw your consent or authorization through the official customer service hotline. After you withdraw your consent or authorization, we will not be able to continue to provide you with the corresponding services, and will no longer process your relevant personal information. However, your withdrawal of the consent or authorization will not affect information previously processed under your authorization.

VII. Protection of Minors

We attach great importance to the protection of personal information of minors. In accordance with applicable laws and regulations, if you are a minor under the age of 18, you should obtain the consent of your parent or statutory guardian before using our services, or use our services accompanied by your parent or statutory guardian. If you are a minor's guardian, when you have any questions about the personal information of your minor, please contact us.

XIII. Scope of Application of this Policy

This Policy is applicable to all our services. However, certain services have their own specific privacy guidelines/statements which explain in more detail how we process your information in the services. In the event of any inconsistency between this Policy and the specific privacy guidelines/statements, the latter shall prevail. In addition, this Policy is an integral part of the User Service Agreement signed by you when registering with the platform.

IX. Changes to this Policy

We may make changes to this Policy as appropriate. We will publish the updated text of this Policy in a prominent position on the platform page.

If such changes result in a substantial reduction of your rights under this Policy, we will notify you by displaying prompts in a prominent position on the page, sending you a site message, message, or SMS message, or otherwise, before the changes become effective. If you disagree with such changes, please cease using our services. By continuing using our services, you agree to be bound by the revised Policy.

X. Contacting Us

If you have any questions, opinions, or suggestions about this Policy, please contact us in the following ways:

Official customer service hotline:400-618-1160

Contact address:上海市松江区漕淞路1号3号楼8F

Post code:201620

We will review your questions as soon as possible, and respond to you within thirty days after verifying your user identity.