【Zhilian Unlimited (Hainan) Technology Co., Ltd.】(hereinafter referred to as "we") understands the importance of personal information to you. We value user privacy policies and strictly comply with relevant laws and regulations. Before using our products or services, please read and understand this Privacy Policy carefully. Use related products or services only after full understanding and consent. This application respects and protects the personal privacy of all users. To provide you with more accurate and better services, this application will use and disclose your personal information in accordance with this Privacy Policy. Unless otherwise specified in this Privacy Policy, this application will not disclose this information to the public or provide it to third parties without your prior permission. Once you click Agree, Confirm, or continue using our products or services, it means you accept and recognize the updated content of this policy.

I. Scope of Application

1. This application strictly prohibits users from posting inappropriate information such as nudity, pornography, and profanity. We review posted content, and any inappropriate information found will result in disabling all permissions and account suspension.

II. How We Collect and Use Your Personal Information

Personal information refers to any information recorded electronically or otherwise that can identify a specific natural person alone or in combination with other information, or reflect the activities of a specific natural person.

We only collect and use your personal information for the purposes stated below in this policy, and obtain your relevant information from third parties. If we intend to use your personal information for purposes not stated in this policy, or use information collected for specific purposes for other purposes, we will inform you in a reasonable manner and obtain your consent again before use.

We may collect, store, and use the following information related to you. You must agree to the "User Service Agreement" and this policy to use all content of Palm bada. If you do not provide relevant information, you can still use basic functions, but you will not be able to use related additional functions or achieve the functional effects we intend.

(A) Situations where you must authorize us to collect and use your personal information:

1. Registration/Login

When registering and logging into your Palm bada account, you need to provide us with your mobile phone number, operating system, and software version number. We will verify your identity by sending SMS verification codes. Your mobile phone number is your default username.

2. Scan to Log In

When you use Palm bada to scan and log into the management backend, we need to access your system's camera function. This information is collected to obtain QR code information for quick login. If you do not provide this information, you may not be able to use the scan function.

3. Make Phone Calls

When you contact us, we may save your communication/call records and content or contact information to contact you or help solve problems, or record relevant solutions and results.

4. Access Control Management

When connecting door locks and gateways, we need to access your Bluetooth information and WiFi information. This information is collected to connect and control door locks and gateways. If you do not provide this information, you may not be able to use access control management functions.

5. Post Information

When editing information and pasting content, we need to access your clipboard to read or write the contained content.

(B) During your use of Palm bada services, we access your permissions to provide services, optimize our services, and protect your account security. Specific information collection rules are as follows:

1. We need to access your GPS location permission for functions including but not limited to:

When using access control management functions, to quickly search and bind nearby gateways and door lock devices.

2. We need to access your camera permission for functions including but not limited to:

When scanning to log into the management backend, providing quick scanning and recognition of login codes;

When posting information, providing the function to take photos and upload accompanying images.

3. We need to access your read/write file permissions for functions including but not limited to:

When posting information, providing the function to directly select accompanying images from the album for upload;

When Palm bada detects that a version upgrade is needed within the APP, this permission is required to store the latest version installation package.

4. We need to access your Bluetooth permission for functions including but not limited to:

When using access control management functions, to quickly search and pair nearby gateways and door lock devices.

5. We need to access your WiFi and network permissions for functions including but not limited to:

Ensuring smooth network information access during APP use and normal functionality in the current network environment.

6. Others

You can view the status of your access permissions in the system settings regarding Palm bada application permissions and decide to enable or disable these permissions. Enabling these permissions means you authorize us to collect and use this personal information to achieve the above functions. Disabling these permissions means you cancel this authorization, and we will no longer collect or use this personal information, nor can we provide you with the corresponding functions. Your decision to disable permissions will not affect the processing of personal information previously based on your authorization.

Additionally, according to relevant laws, regulations, and national standards, we may collect and use your relevant personal information without seeking your authorization and consent in the following circumstances:

1) Related to our fulfillment of legal obligations;

2) Directly related to national security and national defense security;

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

4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;

5) Necessary to protect your or others' life, property, and other major legitimate rights and interests, but difficult to obtain consent from the person;

6) The personal information involved is disclosed to the public by yourself;

7) Collected from legally publicly disclosed information, such as legal news reports, government information disclosure, etc.;

8) Necessary to maintain the safe and stable operation of the provided products or services, such as discovering and handling product or service failures;

9) For news units and necessary for conducting legal news reporting;

10) For academic research institutions, necessary for conducting statistical or academic research in the public interest, and when disclosing results, de-identifying the personal information contained in the results.

Special note:

1) The products and services we provide to you are constantly updated and developed. If business needs require collecting and using personal information beyond the above scope, we will update this privacy policy and inform you of the specific circumstances of information collection and use through pop-ups, page prompts, website announcements, etc., and obtain your consent.

2) Currently, Palm bada will not actively obtain your personal information from third parties. If in the future, for business development needs, Palm bada indirectly obtains your personal information from third parties, we will inform you of the source, type, and scope of use of the personal information before obtaining it and obtain your explicit consent.

3) For information generated by processing collected personal information that can identify your personal identity alone or in combination with other information, or reflect your personal activities, our processing follows the scope of authorization and consent obtained when collecting personal information.

You have the right to withdraw your authorization for personal information

As mentioned above, some functions of our products and services require obtaining relevant permissions on your device. You can withdraw (or stop) continued authorization for this permission at any time after authorization. For example, you can disable authorization for your phone album through "Settings - Privacy - Photos" on your mobile device. You can also permanently withdraw all authorizations for us to continue collecting your personal information by canceling your account. After you withdraw authorization, we cannot continue to provide you with the specific functions and/or services corresponding to the withdrawn authorization.

III. How We Share, Transfer, and Publicly Disclose Your Personal Information

(A) Sharing

We will not share your personal information with any other company, organization, or individual, except in the following cases:

1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

2. We may share your personal information externally in accordance with legal provisions or mandatory requirements of government authorities.

3. Sharing with affiliated companies: Your personal information may be shared with our affiliated companies. We will only share necessary personal information, and it is bound by the purposes stated in this privacy policy. If affiliated companies need to change the purpose of processing personal information, they will seek your authorization and consent again.

4. Sharing with authorized partners: Only to achieve the purposes stated in this privacy policy, some of our services will be provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. For example, companies we hire to provide third-party data statistics and analysis services may need to collect and access personal data for data statistics and analysis. In this case, these companies must comply with our data privacy and security requirements. We will only share your personal information for legal, legitimate, necessary, specific, and explicit purposes, and only share personal information necessary to provide the service.

For companies, organizations, and individuals with whom we share personal information, we sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.

(B) Entrusted Processing

To ensure the stable operation and functional implementation of our APP, and to enable you to use and enjoy more services and functions, our application embeds SDKs or similar applications from authorized partners. We may entrust authorized partners to process your personal information so that authorized partners can provide you with certain services or perform functions on our behalf. We will conduct strict security checks on the application programming interfaces (APIs) and software development kits (SDKs) that obtain relevant information from authorized partners. We only entrust them to process your information for the legal, legitimate, necessary, specific, and explicit purposes stated in this policy. Authorized partners can only access the information necessary for them to perform their duties, and we will require them through agreements not to use this information for any other purpose beyond the entrusted scope. If authorized partners use your information for purposes not entrusted by us, they will separately obtain your consent.

The third-party SDKs we access mainly serve your and other users' needs. Therefore, when meeting new service requirements and changing business functions, we may adjust the third-party SDKs we access. We will promptly disclose the latest situation of accessing third-party SDKs to you in this statement. Third-party SDKs may change the types of personal data they process due to version upgrades, policy adjustments, etc. Please refer to their official statements for details. Special reminder: If your privacy is leaked or property is damaged due to changes in the actual types of personal information obtained by third parties, we do not bear any legal responsibility.

The third-party SDKs currently accessed by the App are listed as follows:

Umeng Analytics SDK

Purpose: Conduct internal data analysis and research, provide statistical analysis services

Personal information fields collected: Device MAC address, unique device identifier (IMEI/android ID/IDFA/OPENUDID/DRIVEID/OAID/GUID/ICCID), SIM card IMSI information

Privacy protection statement: https://www.umeng.com/page/policy

(C) Transfer

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

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

2. In the event of merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy; otherwise, we will require the company or organization to re-seek your authorization and consent.

(D) Public Disclosure

We will only publicly disclose your personal information in the following cases:

1. After obtaining your explicit consent;

2. Disclosure based on law: In the case of legal, legal proceedings, litigation, or mandatory requirements from government authorities, we may publicly disclose your personal information.

IV. How We Retain, Store, and Protect Your Personal Information

We only retain your information for the period necessary for the purposes stated in this Privacy Policy and the time limit required by laws and regulations. Information collected and generated during our operations within the People's Republic of China is stored within China. We will take the following measures to protect your information:

1. Data security technical measures

We adopt security protection measures that meet industry standards, including establishing reasonable system specifications and security technologies to prevent your information from being accessed, used, or modified without authorization, and to avoid data damage or loss. Network services adopt various encryption technologies. For example, in some services, we will use encryption technologies (such as SSL) to protect your information, encrypt your information for storage, and isolate it using isolation technology.

When using information, such as information display and information association calculation, we use various data desensitization technologies to enhance security during use. We adopt strict data access permission control and multi-factor identity authentication technology to protect information and prevent data from being used improperly.

2. Other security measures we take to protect information

We manage and regulate the storage and use of information by establishing a data classification and grading system, data security management specifications, and data security development specifications.

We conduct comprehensive security control of data through information contact confidentiality agreements, monitoring, and audit mechanisms.

Strengthen security awareness. We also hold security and privacy protection training courses to strengthen employees' awareness of the importance of protecting information.

3. We only allow our employees and partners who need to know this information to access your information, and we have set strict access permission control and monitoring mechanisms for this purpose. We also require all personnel who may come into contact with your information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or termination of cooperation with us.

4. We will take all reasonably feasible measures to ensure that irrelevant information is not collected.

5. The Internet is not an absolutely secure environment, and communication methods such as email, instant messaging, social software, or other service software cannot determine whether they are fully encrypted. We recommend that you use complex passwords when using such tools and pay attention to protecting your information security.

6. The Internet environment is not 100% secure. We will endeavor to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are breached, resulting in unauthorized access, public disclosure, tampering, or destruction of information, causing damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.

7. Security incident handling

When communicating with third parties or purchasing goods and services through our services, you will inevitably disclose your information to the counterparty or potential counterparty, such as contact information or postal address. Please protect your information properly and only provide it to others when necessary.

To deal with possible risks such as information leakage, damage, and loss, we have formulated multiple systems, clarifying the classification and grading standards for security incidents and security vulnerabilities and corresponding handling procedures. We have also established a dedicated emergency response team for security incidents. In accordance with security incident handling specifications, we will initiate security plans for different security incidents, carry out loss stopping, analysis, positioning, formulate remedial measures, and trace and combat them jointly with relevant departments.

In the unfortunate event of an information security incident, we will inform you in accordance with legal requirements: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks independently, and remedial measures for you. We will also promptly inform you of the incident-related situation by email, letter, phone, push notification, etc. If it is difficult to inform each information subject individually, we will adopt reasonable and effective methods to issue announcements. At the same time, we will actively report the handling of information security incidents to regulatory authorities as required.

Please understand that due to technical limitations and limitations in risk prevention, even though we have strengthened security measures as much as possible, we cannot always guarantee 100% security of information. You need to understand that the systems and communication networks you use to access our services may have problems due to circumstances beyond our control.

V. How to Manage Your Information

1. Access, update, and delete

We encourage you to update and modify your information to make it more accurate and effective. You can access your information through our services and modify, supplement, and delete it yourself or require us to do so according to the management method of the corresponding information. We will take appropriate technical means to ensure that you can access, update, and correct your information or other information provided when using our services as much as possible.

When accessing, updating, correcting, and deleting the aforementioned information, we may require you to verify your identity to ensure information security.

2. Public and sharing

Many of our services allow you to publicly share your relevant information not only with your social network but also with all users using the service. For example, information you upload or post in our services, your responses to information uploaded or posted by others, uploading or publishing your personal information in public areas visible to non-specific users via email or within our services, including location data and log information related to this information. As long as you do not delete the information you have made public or shared, the relevant information may remain in the public domain; even if you delete shared information, the relevant information may still be independently cached, copied, or stored by other users or third parties not controlled by us, or saved by other users or such third parties in the public domain. If you disclose information through the above channels, resulting in the leakage of your information, we are not responsible. Therefore, we remind and ask you to carefully consider whether to make your information public or shared through the above channels.

3. Cancellation

Under the conditions stipulated in the service agreement of our individual services and relevant national laws and regulations, your service account may be canceled or deleted. After the account is canceled or deleted, all service materials and data related to the account under the individual service will be deleted or processed in accordance with the service agreement of the individual service.

4. Tips on sensitive information

Certain information may be considered sensitive due to its particularity, such as your race, religion, personal health and medical information, as well as identity documents, personal biometric information, property information, travel trajectory, minors' information, etc.

Please note that the content and information you provide, upload, or post in our services (such as photos or information about your social activities) may reveal your sensitive information. You need to carefully consider whether to disclose your sensitive information using our services.

You agree that your sensitive information will be processed for the purposes and methods described in this Privacy Policy.

5. Personal information subject account cancellation

You can use the cancellation function in the product or contact us to submit an application for cancellation. Steps to cancel your account in the app: [Me - About Us - Account Cancellation] Submit an account cancellation application.

After canceling the account, we will stop providing you with products or services and, at your request, delete or anonymize your personal information, unless otherwise stipulated by laws and regulations.

VI. Use of Cookies

1. If you do not refuse to accept cookies, this application will set or access cookies on your computer to enable you to log in or use platform services or functions that rely on cookies. This application uses cookies to provide you with more thoughtful personalized services.

2. You have the right to choose to accept or refuse cookies. You can refuse to accept cookies by modifying your browser settings. However, if you choose to refuse cookies, you may not be able to log in or use the network services or functions of this application that rely on cookies.

3. The relevant information obtained through the cookies set by this application will be subject to this policy.

VII. How Your Personal Information is Transferred Globally

In principle, personal information collected and generated within the territory of the People's Republic of China during our operations will be stored within China.

Since we provide products or services through resources and servers distributed globally, this means that after obtaining your authorization and consent, your personal information may be transferred to jurisdictions outside the country/region where you use the product or service, or accessed from these jurisdictions.

Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information receives protection within the territory of the People's Republic of China that is sufficiently equivalent. For example, we will request your consent for cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfer.

If cross-border data transmission is indeed necessary, we will clearly inform you separately (including the purpose of data export, recipient, method and scope of use, content of use, security measures, security risks, etc.) and obtain your authorization and consent. We will ensure that the data recipient has sufficient data protection capabilities to protect your personal information.

VIII. Changes to this Privacy Policy

If we decide to change the privacy policy, we will publish these changes in this policy and in places we deem appropriate so that you can understand how we collect project information.

Please properly protect your account information. If you find that your account information has been leaked, especially if the username and password of this application have been leaked, please contact the administrator of this application immediately so that this application can take corresponding measures.

IX. How to Contact Us

1. If you have any questions, comments, or suggestions about this privacy policy, please contact us in the following ways:

Email: 【BadaVipService@gmail.com】

Generally, we will reply within 15 working days;

X. Dispute Resolution

The interpretation and dispute resolution of this Privacy Policy shall be governed by the laws of Mainland China. Any disputes arising from this Privacy Policy and our handling of your personal information shall be resolved through friendly negotiation. If negotiation fails, you may file a lawsuit with a competent court in Hainan Province.

Zhilian Unlimited (Hainan) Technology Co., Ltd.

The latest update time of this policy is: September 8, 2025