Privacy Policy

Last Updated: August 5, 2024

Effective Date: August 5, 2024

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This Privacy Policy (hereinafter referred to as “this Policy”) aims to clearly explain to you how the software operator (hereinafter referred to as the “Operator” or “we”) collects, uses, stores, shares, and deletes your relevant data and information during your use of this software and related online services. As an internet technology team that values user privacy and end-to-end encryption security, we are deeply aware of the importance of personal data to you, and we strictly comply with the fundamental privacy protection principles of major global jurisdictions.

Please read carefully and fully understand this Policy before you start using this software. Once you click to confirm, complete registration, or continue to use this software, it means that you have fully acknowledged and agreed to the entire content of this Policy.

I. Scope of Information Collection

To provide you with secure, stable, and compliant local encryption and cloud synchronization services, we only collect the following information within the necessary scope:

1.1 No Direct Personally Identifiable Information: During the account registration and creation phases, this software does not collect your email address, phone number, real name, or any other direct personal identity information. The system will randomly generate a unique username for you, and you only need to set a login password to complete the registration. Upon successful registration, the locally generated “Recovery Key” is the sole proof of your account ownership.

1.2 Region and Location Determination Information: To fulfill regionalized billing contracts and technical compliance obligations of specific jurisdictions, the system determines the approximate administrative jurisdiction from which you are currently accessing.

This determination is achieved solely by the server during request interactions through the transient verification of coarse-grained network identifiers (such as IP addresses) in memory. The platform does not acquire precise GPS location data, never persistently stores your IP address in any database, and does not perform any identity profiling correlation, ensuring zero privacy retention at the technical level.

1.3 Automatically Collected Technical Data: While you are running the software, the system automatically collects the following technical characteristic information to ensure the normal operation of core services:

• Device Internet Protocol (IP) address (used solely for the transient in-memory verification and secure handshake described in Section 1.2 of this Policy; the platform does not persistently store it);

• Basic cookies used to maintain user login status and session security;

• Client software crash logs and exception diagnostic data.

  1.4 Regional Consistency Verification Features: The system automatically checks and compares device environment characteristics, such as the user’s current operating system language (OS Language) and system time zone (Time Zone), to verify whether the device environment matches the region of the subscription package purchased by the user, which is used to prevent cross-region cheating.

II. Purposes of Information Use

Our purposes for collecting and processing the aforementioned non-PII technical data are explicit and limited, mainly including the following aspects:

2.1 Regionalized Billing Verification: Since our paid packages utilize a region-based pricing (Region-Based Pricing) mechanism, we need to know the general geographical location of the user. Under normal circumstances, verification is precise to the country level; in special jurisdictions or customs-isolated zones (for example: Hong Kong, Macau, Isle of Man, Jersey, Guernsey, Faroe Islands, etc.), verification will be refined to that specific micro-region to ensure billing compliance and correct tax rate clearing.

2.2 Core Business Maintenance and Risk Control: The relevant technical data is used solely for account authentication, handshakes for multi-terminal data synchronization protocols, secure software update notifications, platform security defense risk control (such as combating malicious network attacks, cracking, and fraudulent ordering), and performing baseline technical troubleshooting. We will never use this data for user profiling, targeted advertising delivery, or sell it to any undisclosed third party for profit.

III. Data Localization and Escrow Disclosure

3.1 Highly Localized Hosting Architecture: To strictly align with the legal compliance requirements of sovereign states, the platform adopts a highly localized and nation-specific key escrow and data sharding mechanism at the technical level. Data and judicial assistance key pairs across different regions are independent and isolated from one another.

3.2 Consolidated Disclosure for Special Micro-Jurisdictions: Based on international judicial conventions and the distribution of underlying infrastructure, the compliance and legal affairs of certain specific micro-countries or offshore jurisdictions will be lawfully consolidated into their de facto core judicially associated countries for centralized processing. For example: users whose account location is the Isle of Man, Jersey, or Guernsey will use the compliance configuration data of the United Kingdom. Similarly, other comparable overseas territories or offshore regions will be governed under the legal frameworks of their de facto sovereign states or core judicially associated countries.

IV. Protection of Minors

We attach great importance to the protection of minors’ personal data. This software primarily provides services to adults. If you are a minor (under the age of 18 or the legal age of majority in your jurisdiction), you must obtain the explicit consent and permission of your legal guardian (parents or other legal guardians) before installing and using this software.

Given the decentralized and anonymous technical nature of this software, the external sharing functions of the software’s shared community are open only to adult users; minors are prohibited from using such features even with guardian consent. If we discover that we have inadvertently collected unencrypted technical data from a minor without obtaining guardian consent, we will immediately execute a physical erasure.

V. Account Cancellation and Data Erasure Mechanism

You have absolute control over your own account and synchronized data. We provide you with a transparent and convenient channel for personal data removal:

5.1 Self-Service Cancellation Entrance

Both in the mobile application (App) of this software and on the User Center page of the web version, a prominent “Cancel Account” functional entrance is provided. You have the right to initiate a request to cancel your account and delete all cloud-based personal data at any time through this entrance or through official public technical support channels.

5.2 Response and Complete Erasure Cycle Under Normal Circumstances

5.2.1 Within 30 days from the date we receive your formal cancellation or deletion request, we will respond and execute the deletion operation, immediately cease providing synchronization services to you, and logically delete your User-Generated Content (UGC) synchronized data hosted in the cloud.

5.2.2 Subject to the natural cyclic overwriting period of cloud server backups and redundant disaster recovery logs, the relevant fully encrypted data blocks you once generated will be completely overwritten, shredded, and irreversibly physically cleared from all physical backup media and disaster recovery storage of the platform within a maximum of 90 days.

5.2.3 To comply with applicable financial, taxation, auditing, and anti-money laundering statutory obligations, the order number, payment status, baseline compliance logs associated with the transaction, and relevant decentralized data blocks necessary for handling billing disputes/refund transactions will remain encrypted and archived within the statutory minimum retention period (or dispute resolution window).

5.3 Response and Complete Erasure Cycle When Unable to Log In

When a user is permanently unable to log in to their account due to reasons such as losing the account Recovery Key, and needs to apply for termination of paid services and a refund through the original payment method, they can initiate an application to customer service on the official website by providing the original proof of payment (such as a third-party payment order number or bank debit statement). Given the specific nature of anonymous accounts, to prevent malicious third parties from falsely applying for refunds and causing assets to be maliciously destroyed, the Operator will enter a waiting period of up to 180 days upon receiving such an application, after which the refund will be processed. During this period, logging into the account just once will cancel and terminate the refund process. Once the refund is completed, the User-Generated Content (UGC) synchronized data hosted in the cloud for this account will be permanently cleared, while locally stored data will remain unaffected.

VI. Business Transfer and Reorganization

As our business continues to develop, the operating entity of this software may undergo strategic adjustments in the future. If this software or related platforms involve a name change, merger (Merger), acquisition (Acquisition), bankruptcy liquidation, significant asset transfer, or change of the operating entity, your basic technical account information and cloud-encrypted data blocks, as part of the overall business assets, may be transferred to the new receiving entity. In regards to this, we make the following strict statutory obligation commitments to you:

• Continuity of Security Obligations: The new operating entity receiving the assets must unconditionally continue to accept and perform all privacy commitments and compliance constraints under this Privacy Policy, and continue to undertake the highest level of technical security obligations, such as end-to-end encryption and the non-alteration of local private key ownership.
• Mandatory Public Notice Period: Prior to the occurrence of the aforementioned entity change or asset transfer, we will issue a formal announcement to all users at least 30 days in advance via in-app persistent pop-ups, official Twitter/announcement channels, or in-app system notifications, clearly disclosing the basic information of the new entity.
• Absolute User Choice: Within the 30-day public notice period published in the announcement, users enjoy an absolute right of refusal. If you are unwilling to accept the management of the new operating entity, you have the right to cancel your account, download and export all your local assets, or completely delete all your fully encrypted data blocks in the cloud through the aforementioned cancellation process at any time.

VII. Third-Party Services and SDK Disclosure

To achieve secure cross-border settlements, global network acceleration, high-availability underlying storage, and efficient system crash rate monitoring, this software integrates certain industry-leading third-party service providers and Software Development Kits (SDKs). The data processing by these third-party service providers is governed by their respective privacy policies, disclosed specifically as follows:

Third-Party Service Provider / SDK Name	Use Case and Processing Purpose	Official Privacy Policy Link
Stripe	Provides global credit card and compliant multi-currency online payment clearing and settlement services.	Stripe Privacy Policy
Cloudflare	Provides sitewide Anycast network acceleration, anti-DDoS attack defense, static asset distribution, and full-link encrypted gateways.	Cloudflare Privacy Policy
UpCloud	As a high-availability and high-performance Infrastructure as a Service (IaaS) provider, hosts and runs partial encrypted cloud servers and fully isolated cloud storage.	Please refer to the UpCloud Legal Center on the official UpCloud website.
Crash Logs Analytics SDK	Used to automatically capture stack trace errors when the application crashes or deadlocks, allowing engineers to quickly fix faults. Contains no user business content.	Executed in accordance with native underlying error feedback mechanisms of device platforms (e.g., Apple/Google developer diagnostic protocols).

VIII. Miscellaneous

We reserve the right to modify this Policy at any time. When material or substantive changes occur to this Policy, we will notify you through prominent means such as in-app notices. Your continued use of the services after changes take effect shall be deemed as your acceptance of the updated Policy.