WELLFIT Privacy Policy

Update date of this Privacy Policy: November 28, 2022

Effective date of this Privacy Policy: November 28, 2022

The main contents of this update are: more clarity on the purpose of collecting users' personal information; additional ways to notify updates to this policy.

User Agreement

Tips Terms

WELLFIT is a product provided by WELLFIT Health & Fitness Co., Ltd. (hereinafter referred to as "us"). We are aware of the importance of personal information to you, and we will take appropriate security measures to protect your personal information in accordance with legal requirements. Considering this, we have established this WELLFIT Privacy Policy (hereinafter referred to as "this Policy") and would like to remind you that:

1. Please check the box to confirm your consent to this Policy when you use the WELLFIT service, we will not collect any private information from you until you agree. If you agree to this Policy and use WELLFIT, we will collect, store, use, disclose and protect your personal information in accordance with this Policy. We hope to clearly introduce the handling method of your personal information to you through this Policy. 2. According to the relevant laws and regulations, the provider of network products and services that have the function of collecting user information shall expressly notify its users and obtain their consent. Through this Policy, we hereby inform you of the purpose, manner and scope of collecting and using your personal information, the channels for inquiring and correcting information, and the impact of refusing to provide information. 3. This Policy does not apply to services provided to you by other third parties, for example, when a third-party on our platform relies on our platform to provide services to you (such as third-party payment channels), the personal information you provide to the-third party does not apply to this Policy, and we are not responsible for the use of information provided by you by any third party, unless expressly provided by law. 4. Please read and understand this Policy carefully before using WELLFIT products or services, and use the relevant products or services after confirming your full understanding and agreement. By using any of the services provided by WELLFIT, you consent to the lawful collection, use and protection of your personal information in accordance with this Policy. If you have any questions, comments or suggestions regarding the content of this Policy, you may contact us at uswellfit@gmail.com.

This Privacy Policy section will help you understand the following:

I. How we collect your information. II. How we use information. III. The shared information or public information you posted. IV. How we share, transfer, and disclose information. V. How we store information. VI. How we protect the security of your personal information. VII. Protection of minors. VIII. How you manage your information. IX. How your personal information is transferred globally. X. Revisions and updates to this privacy policy. XI. Scope of application

I. How we collect your information

To provide you with better services such as display or playback of text, images and audiovisual content, we will collect the following information about you according to the services you use.

(i) Information you provide to us

We collect information about the services you use and how you use them, such as when you watch a video on the WELLFIT App, when you access our advertising services, or when you view our ads and content. Such information includes:

1.1 Information You Provide

(1) Information that you provide to us when you register for an account or use our Services that can be used to personally identify a user, such as name, gender, birth date, weight, height, email address, telephone number, ID number, address, communication records, or other data by which we can legitimately find such information through a link. This information is used primarily to establish your account for your normal use of the WELLFIT APP, and to display relevant personal data in the Software according to your settings. You have the right to refuse to provide such information to us, but refusal to provide such information will prevent you from establishing an account and using the WELLFIT APP properly.

(2) Information that you share with other parties through our Services and information that you upload, submit, store, send or receive when using our Services.

1.2 Information We Obtain

We collect information about the Services you use and how you use them, such as information that may be generated by your use of the WELLFIT APP, participation in WELLFIT courses, and training programs. Such information includes:

a¡¢ Device Information: During your use of our services (including basic services), including in the background, we collect information about your device to provide you with services such as device mapping and securing your transactions and system operations (basic services). We receive and record information about your device, such as your device model, operating system version information, device settings, mobile device version, device identification number (ANDROID ID), screen rating, device environment and other hardware and software characteristics, information about the location of the device, such as IP address, GPS location and sensor information such as WLAN access points, Bluetooth and base stations that can provide relevant information. If you refuse to grant us the appropriate permissions during installation and/or use, we will not record the corresponding information.

b¡¢ Log Information oA. Device or software information, such as configuration information provided by your mobile device, web browser or other program used to access our Services, your IP address and the version and device identifier used by your mobile device; oB. Information searched or viewed while using our Services, such as web search terms you use, URL addresses of social media pages you visit, and other information and information you view or request while using our Services. other information and content details that you view or request when using our Services;

c¡¢ IP Addresses oA. Information about the mobile applications (APP) and other software you have used, and information about how you have used such mobile apps and software; oB. Information about your communications through our Services, such as the accounts you have communicated with, and the time, data and duration of communications; oC. Information contained in content you share through our Services (metadata), such as the shared photos or videos taken or uploaded by date, time or location, etc.

d¡¢Video, pictures, game software, etc. in the device. To provide you with a full range of sports experience, after receiving your authorization our server will extract the video, pictures, software name, version number, etc. from your device and upload it to the server for comparison through encryption, which is used to match the display function corresponding to the video, pictures, software.

e¡¢Camera. Except as otherwise agreed in this Agreement, the camera on your device is an essential tool to ensure that you can view the movement from multiple angles. If you disable the camera feature, you may not be able to use some of our products or services, or may not achieve optimal results or have limited access during use. We will not use the camera to capture your personal photos, unless authorized by you or you upload, submit, post, we will not actively capture your device pictures, video information.

f¡¢Location information. You can authorize to enable the device location function and use our location-based services, of course, you can also stop our collection of your geographic location information at any time by turning off the location function.

g¡¢Address Book. If you want to track your friends' use of WELLFIT App, you can apply for WELLFIT App related functions, we will upload and save your application list according to your authorization, and upload and save the cell phone numbers of your contacts in your address book in an encrypted way, and provide you with special services by matching with the information in the server.

h¡¢Bluetooth. If you want to synchronize the information recorded in your existing hardware devices (including speed, distance, steps, pace, speed, resistance, pedaling frequency, heart rate, exercise data, weight, BMI and other personal information and personal body data that you have agreed to upload) to the WELLFIT App, you can do so by enabling the Bluetooth function. If you refuse to do so, you will only be unable to use this function, but it will not affect your normal use of other functions of WELLFIT. At the same time, you can cancel this permission at any time by setting the relevant function. However, when you cancel the authorization, we will no longer collect the information and can no longer provide you with the above-mentioned services; but unless you delete your information in accordance with the law, your cancellation will not affect the processing and storage of information based on your previous authorization.

i¡¢Storage permission setting.

We will collect the album information in storage with your separate consent to this authorization so that you can change your avatar, as well as post photo dynamics, and in case of abnormalities, reproduce the problem, write and read the logs and other functions. We will only collect the corresponding information when you use the corresponding function. The names may vary on different systems, such as files and media. If you turn off the storage permission, you may not be able to use the function, but it will not affect your basic use.

j¡¢Information from third parties

In some cases permitted by law, we may obtain your personal information from third parties. For example:

● For the purpose of security and fraud prevention, verify your information (such as telephone number) through legal sources for specific accounts, financial transactions and other services under your authorization;

● We may also obtain certain information from third-party social networking services, such as your accounts, nicknames in third-party social networks (e.g., when you log in to the WELLFIT App Service using your social networking account).

k¡¢Non-Personal Information

We may also collect other information that cannot be identified to a specific individual and is not personal information under applicable local law, such as statistical data generated when you use a specific service, such as anonymous device-related information, daily activity events, page access events, page access duration events, session events; network monitoring data such as request duration, number of requests and false requests; and app crash events. This information is collected for the purpose of improving the services we provide to you. The type and amount of information collected depends on how you use our products or services.

We may collect information such as unique device identifiers, device models, system version numbers, and other information related to your activities on our websites or mobile applications. We may aggregate this information to help us provide more useful information to our customers about which parts of our websites, products or services are of most interest to them. Aggregated data is considered non-personal information for the purposes of this Privacy Policy. If we use non-personal information in combination with personal information, such information will be treated as personal information for the duration of the combined use.

For registered users to use WELLFIT to download content, you need to authorize access to your stored information (i.e., you need to agree to modify/delete SD card contents, read external storage access). If you are not authorized, you will be prompted to grant authorization through a pop-up window, and after obtaining your authorization, you may download videos, audio, pictures, copy text, etc. from WELLFIT. If you are not authorized, you will not be able to use the relevant functions.

 (ii) Information that is automatically collected during your use of the service

1¡¢ In order to provide and optimize the services you need, we will receive and record information related to your browser and equipment on your computer, mobile device, etc., according to the specific permissions granted by you in the installation and use of the software, which include: browsing, searching, playing content functions, the personal information collected is basic device information (including device model, operating system type and version number, screen density and resolution, the International Mobile Equipment Identification Number (IMEI/IDFA), network device hardware address (MAC/IMSI/Android Id). Device location (including location information obtained through gps, wifi signal access points and base station sensor information), log information (including your search query content, browsing history, playback history, playback duration, IP address) device installation list, network type. The correlation between the information collected from your various devices to maintain a consistent service we can provide to you on those devices. Such information is collected to provide you with services that better match your preferences or habits using recommendation techniques, and to alert you to network traffic usage. In the event that you share or receive information that is shared, we may access your clipboard to read passwords, share codes, linked features or services to help facilitate your content sharing. To ensure operational security, we collect information about installed applications or running processes, information about the running list of applications, the usage and frequency of programs, cases where applications do not work properly, performance data, and application sources. Please note that device information, log information, etc. alone is information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person or use it in combination with personal information, such non-personal information will be treated as personal information during the period of combined use, and we will anonymize and de-identify such personal information unless we obtain your authorization or unless otherwise required by law or regulation. The above information is necessary for us to provide you with the corresponding functions on our platform.

2¡¢If you upload graphics, audio or video to WELLFIT, the information contained in the content itself, including the date, time and location of the shared photo or video taken or uploaded, will be used for the purpose of providing you with the information on our Platform. If you do not need to upload videos on our platform, you do not need to provide the above information.

3¡¢If you use WELLFIT's user services, the contact information you provide and your communication with our customer service staff will be collected and used by us to contact you and help you solve your problem, or to record the solution and outcome of the problem.

4¡¢If you upload graphics, audio or video to WELLFIT, the information contained in the content itself, including the date, time and location of the shared photo or video taken or uploaded, will be used for the purpose of providing you with the information on our Platform. If you do not need to upload videos on our platform, you do not need to provide the above information.

(iii) Information collected through indirect access

1¡¢ Information about your use of our affiliates' and our partners' products and services, and your interaction with our products and services.

2¡¢ In order to provide you with better and better services, or to jointly provide services to you, or for the purpose of preventing Internet fraud, we may cooperate with third parties or reach cooperation in other ways, and our affiliates and partners will share your personal information with us or we will share it with each other within the scope of cooperation and in accordance with the provisions of the law and the agreement with you.

3¡¢When you use the above services through our products or services, you authorize us to receive, aggregate and analyze your personal information or transaction information from our affiliates that we confirm to be legal in origin or that you authorize to agree with them to provide to us according to the actual business and cooperation needs. We promise that we have confirmed the legitimacy of the source of the above personal information.

(iv) Information collected using technologies such as cookies

Cookies: To make your access experience easier, when you visit our Platform website or use the services provided by our Platform, we may identify you through small data files to help you save the step of repeatedly entering your registration information or to help determine the security of your account. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively, "Cookies"). Please understand that some of our services are only available with "cookies". You may modify your acceptance of cookies or refuse our cookies if your browser or browser add-on allows, but this action may, in some cases, affect your ability to safely access our Platform-related websites and use the services offered on our Platform.

II. How we use information

Personal information is collected for the purpose of providing you with products or services and to ensure that we comply with applicable relevant laws, regulations and other regulatory documents. We may use the above collected information for the following purposes:

(1) To provide, process, maintain, improve, and develop our products or services to you, such as delivery, verification, after-sales, customer support, and advertising;

(2) For identity verification, customer service, security prevention, fraud monitoring, archiving and backup purposes in connection with our provision of services and to ensure the security of the products and services we provide to you;

(3) For internal purposes, such as data analysis, research and development of statistical information related to the use of our products or services in order to better improve our products or services;

(4) To help us design new services and improve our existing services;

(5) To provide you with system, event, and community message pushes that are relevant to you;

(6) To perform software verification and upgrade services;

(7) To provide specific services in response to special requests from users that require information to be provided to our affiliates, third parties or other users;

(8) Other situations that do not violate any mandatory laws and regulations;

(9) To involve you in surveys about our products and services;

(10) To store and maintain information about you for the purposes of our business operations (such as business statistics) or to meet legal obligations;

(11) For other purposes with your consent.

More detailed examples of how we use your information (which may include your personal information) are as follows:

(1) When you register as an WELLFIT user, we collect your cell phone number, nickname, and avatar, which are used to help you complete your registration and protect the security of your account. Cell phone numbers are sensitive personal information and are collected to meet the real name requirements of relevant laws and regulations, if you refuse to provide them, you may not be able to use our services normally. In addition, you can choose to fill in information such as gender, birthday, height and weight according to your own needs.

(2) We will request access to your Bluetooth permission when you use the relevant hardware devices to participate in running, rope skipping, hula hooping and other equipment sports to realize the WELLFIT App to control the device on/stop, speed, incline, and to synchronize the relevant information of the device, including the hardware information such as the brand and model of the device, as well as the speed, distance, step count, step frequency, speed, resistance, pedaling frequency, heart rate and other sports data that you have agreed to upload.

(3) We will collect your height, weight, waist circumference, BMI and other body data information when you use our smart training plan function, which is used to assess your health condition and recommend a scientific exercise plan for you. We will not disclose the above information and body data to any third party without your permission.

(4) We will collect your device MAC address, unique device identification code, device model number and other information to identify your user identity when you use our products and services. To protect your normal use of our services, maintain the normal operation of our services, improve and optimize our service experience and protect your account security, we also collect your IP address, operating system, mode, type and status of access to the network, operation logs, service logs, and other personal information necessary to provide services to you. We use this information to make comprehensive determinations about your account, account risk and transaction risk, identity verification, customer service, detection and prevention of security incidents, archiving and backup purposes, and to take necessary record-keeping, audit, analysis, and disposal measures in accordance with the law. Once we detect the existence or suspected existence of account security risks, we will apply the relevant information for security verification and risk elimination to ensure the security of the products and services we provide to you, to protect your rights and interests from being infringed. At the same time, in case of account or system security problems, we will collect such information to optimize our products and services.

III. Shared or Public Information Posted by You

You can post content, establish connections and share with each other through our services. When you post content through our Services, your avatar, username, gender, age, height, weight, topics you participate in, number of followers, and number of fans may be visible to other WELLFIT users or visitors. Personal information may be disclosed when you use WELLFIT to browse, post content, post comments and communicate. Please protect your personal information and only provide and display your information to others when necessary. If you become aware that your personal information has been compromised, especially if your account or password has been compromised, please contact our platform website customer service immediately to take appropriate action. Public information refers to any information you share publicly, such as the content you post, comments you make, your avatar, nickname, user name, etc. Please note that the content and information you share when using our services may involve your personal sensitive information. Please consider more carefully whether to disclose or even publicly share relevant personal sensitive information when using our services.

IV. How we share, transfer, and disclose information

(i) Sharing and Disclosure

We will not share your personal information with any other third-party, except for the following cases:

1¡¢ Share with your explicit consent or authorization or if you choose to do so on your own initiative. We may share your personal information with other companies, organizations and individuals after obtaining your authorization or explicit consent. For example, if we entrust a third-party to provide products or services to you (e.g., in the case of user events, raffle prize delivery, or points redemption for prizes), we will share the above information with the third-party with your consent, and if you refuse to provide such information, we will not be able to complete the relevant delivery service. We will only share your sensitive personal information if you choose to consent. We may publicly disclose your personal information with your explicit consent or based on your voluntary choice.

2¡¢ Sharing and disclosure in statutory circumstances. We may share your personal information in accordance with laws and regulations, the need for litigation dispute resolution, or as required by law by administrative or judicial authorities. For example, if you violate laws and regulations or seriously violate the rules of the relevant agreement of our platform, or to protect the personal and property safety of users of our platform website and its affiliates or the public from infringement, we may disclose personal information about you in accordance with laws and regulations or the rules of the relevant agreement of our platform, including the relevant violations and the measures that our platform has taken against you. For example, if you or the account you use uploads illegal content that seriously violates our platform rules, breaks laws and regulations and/or violates public order and morals, causing significant social impact and causing reputational damage to our platform, we may publicly disclose your information and penalties. (The type of sensitive personal information that may be included in the public disclosure and the security measures to be taken should be described here)

3¡¢ Your personal information may be shared with our affiliates for us to jointly provide services to you based on our affiliated accounts (e.g., through technical cooperation with third parties via SDKs, APIs) and to protect the personal and property of our affiliates or other users or the public from infringement. We will only share personal information that is necessary (e.g., we may share your personal information with our affiliates if necessary to enable you to log in with our account and use our affiliates' products or services) and is subject to the purposes stated in this Privacy Policy. If we share your sensitive personal information or if our affiliates change the purposes for which personal information is used and processed, we will again seek your authorized consent.

4¡¢Sharing with authorized partners. We may engage authorized partners to provide certain services to you or perform functions on our behalf, and we will only share your information for lawful, legitimate, necessary, specific, and explicit purposes, and authorized partners will only have access to the information needed to perform their duties and will not use this information for any other purpose.

Our authorized partners currently include the following types:

£¨1£©Authorized partners in the advertising and analytics services category. We will not share your personally identifiable information (information that identifies you, such as a cell phone number, by which you can be contacted or identified) with partners that provide advertising and analytics services unless we have your permission to do so. We will only provide non-personally identifiable statistical information to these partners to help them understand their audiences or customers. Limited by the technical capabilities based on cooperation, depending on the hardware facilities you use, some partners may have access to your device model, operating system type and version number, screen density and resolution, international mobile device identification number (IMEI/IDFA), network device hardware address (MAC/IMSI/Android Id) and other device information. However, we will require our partners to protect the information technically and not to use it for any illegal purpose.£¨2£©Vendors, service providers and other partners. We send information to suppliers, service providers and other partners (such as hardware manufacturers, telecommunications carriers, etc.) that support our business by providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, facilitating payments, or conducting academic research and surveys. For companies, organizations and individuals with whom we share personal information, we enter into strict data protection agreements requiring them to handle personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures. If we share your personal sensitive information or authorize our partners to change the purpose of use and processing of personal information, we will again seek your authorized consent.£¨3£©Third-party SDK-type service providers: Our products may include third party SDKs or other similar applications. By using such third-party services on our platform, you agree that your information will be collected and processed directly by them (e.g. in the form of embedded code, plug-ins, etc.). Please refer to the WELLFIT Third Party Information Data Sharing for details of the third-party SDK services currently included in our products. The aforementioned service providers collect and process information in accordance with their own privacy policy, which does not apply to this policy. To maximize the security of your information, we recommend that you review the privacy policy of any third-party SDK service before using it. To protect your legitimate rights and interests, if you find that such SDK or other similar applications are at risk, we recommend that you immediately terminate the relevant operations and contact us in a timely manner.

5¡¢Assist in handling disputes. If the content published by you causes infringement to a third-party, the party complaining, judicial agencies or administrative law enforcement agencies to request the disclosure of information, we will provide the above-mentioned agencies with the contact information of the complained user and other necessary information, as appropriate, to facilitate the settlement of the dispute. Our platform will only bear the corresponding legal responsibility if the law clearly stipulates it.

(ii) Transfer

We will not transfer your personal information to any company, organization or individual, except for 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 a merger, acquisition or bankruptcy liquidation situation of our platform service provider, or other situations involving merger, acquisition or bankruptcy liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy. Otherwise, we will require the company, organization and individual to seek your authorized consent again.

(iii) Exceptions to Prior Authorized Consent for Sharing, Transferring, and Disclosure of Personal Information

Your prior authorized consent is not required for sharing, transferring, or publicly disclosing your personal information in the following cases:

1£©related to national security or national defense security; 2) related to public safety, public health, or significant public interest; 3) related to crime investigation, prosecution, trial, and judgment enforcement; 4) for the purpose of safeguarding your or other individuals' life, property, and other significant legitimate rights and interests but where it is difficult to obtain your consent; 5) personal information that you disclose to the public on your own; 6) from information that is lawfully and publicly disclosed personal information collected, such as legitimate news reports, government information disclosure and other channels. According to the law, sharing or transferring personal information that has been de-identified and ensuring that the recipient of the data cannot recover and re-identify the subject of the personal information is not an act of sharing, transferring or publicly disclosing personal information to the public, and there will be no need to separately notify you and obtain your consent for the storage and processing of such data.

If you do not agree that we provide your personal information to a third-party in accordance with the above terms, please stop using our platform services immediately.

(iv) Sharing of Information to Implement Functions or Services

You understand and agree that we may share de-identified personal information with our affiliates and third parties when you use the functions provided by them in WELLFIT or when software service providers, smart device providers, system service providers and we jointly provide you with related services. However, we are committed to sharing your necessary personal information only for legitimate, lawful, necessary, specific and explicit purposes. We will also use reasonable efforts to ensure that relevant affiliates and third-party providers comply with the privacy laws used in your jurisdiction.

When you use the following services provided by third parties on our platform, you agree that your information will be collected and processed directly by them:

(1) Push Service: When you use our products or services, Huawei Push, Xiaomi Push and Aurora Push will access your device status and identity and obtain your IMEI, IMSI information for pushing down notification bar messages (such as exercise reminders, training plan class reminders, etc.). This information is necessary for the push function, and refusal to provide it will prevent you from using the function, but will not affect other functions but normal use.

(2) One-click Login Service: If you register or login to WELLFIT with one click, Tencent WeChat will perform device identification service on you by accessing your device status and identity to facilitate your quick registration or login. This information is necessary for one-click login, and refusal to provide it will result in your inability to use the function, but will not affect the normal use of other login methods.

(3) Payment function: If you use Alipay or WeChat, the third-party payment institution may obtain your device status and identity to ensure transaction security and achieve transaction purpose. This information is necessary for the payment function, and refusal to provide it will result in your inability to use the function, but will not affect the normal use of other login methods.

(4) Statistical Service: When you use our products, to ensure the stability of the products and collect crash information, we will detect them through the statistical SDK. The Shence SDK will collect your crash logs, unique device identifiers, software usage and click records, and geographic location information.

(5) Sharing Service: When you use our products, you can share your movement information to the third-party platform through the sharing SDK (WeChat), which will collect your device MAC address, unique device is identification code.

V. How We Store Information

The information and data we collect about you will be stored on servers controlled, used, and leased by us and/or our affiliates, and we will maintain strict confidentiality and access control over the information we collect about you. Such information and data may be transferred to, accessed, stored and displayed in your country, region or location where we collect the information and data. Please see Section 10 for rules regarding the storage and cross-border transfer of your personal information.

Data Retention Period: We will take reasonably practicable steps to avoid collecting irrelevant personal information. In general, we will keep your personal information for three years. The above retention period is the minimum period necessary to achieve the purposes described in this policy, unless you agree to an extended retention period or are permitted by law. After the retention period expires, we will delete or anonymize your personal information.

If we decide to discontinue the operation of our platform services, we will stop continuing to collect your personal information after the relevant services have ceased operation. We will deliver the notice of discontinuation of operation to you in the form of announcement, and we will delete or anonymize your personal information that we already hold.

VI. How We Protect the Security of Your Personal Information

To ensure the security of your personal information collected by us, we are committed to strive to achieve a reasonable level of security, and specific security measures and security capabilities are stated as follows:

(i) Technical protection: To protect the security of your information, we strive to adopt various reasonable physical, electronic and administrative security measures that meet industry standards to protect your information from leakage, destruction or loss, including but not limited to SSL, encrypted storage of information, and data center access control. We will use encryption technology to enhance the security of personal information; use trusted protection mechanisms to prevent malicious attacks on personal information; and deploy access control mechanisms to make every effort to ensure that only authorized personnel have access to personal information. (ii) Security system assurance: We have an industry-advanced data security management system that is data-centered and revolves around the data lifecycle, and improves the security of the entire system in multiple dimensions, including organizational construction, system design, personnel management, and product technology. (iii) Personnel security management: We also adopt strict management for employees or outsourced personnel who may have access to your information, including but not limited to different authority control according to the position, signing confidentiality agreements with them, monitoring their operation and other measures. We will provide appropriate security measures to protect your information according to the existing technology and provide reasonable security, and we will try our best to make sure that your information will not be leaked, destroyed or lost. We will conduct training courses on security and privacy protection to enhance employees' awareness of the importance of protecting personal information. (iv) Sensitive information and password protection tips: a) Personal sensitive information protection note: The information you voluntarily share or even publicly share when using our services may involve your or others' personal information or even personal sensitive information, such as your avatar image upload, for example, if you choose to upload images containing personal information when commenting, posting, or posting pop-ups. Please consider more carefully whether to share or even publicly share relevant information when using our services. b) Please use a complex password or a dynamic verification code to help us ensure the security of your account. We will try our best to ensure the security of any information you send us. If our physical, technical or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, tampering or destruction of information, resulting in damage to your legal rights and interests, we will bear the corresponding legal responsibility. c) Your account is protected by security features, please keep your account and password information safe. We will ensure that your information is not lost, misused or altered through security measures such as backing up to other servers and encrypting your password. Notwithstanding the aforementioned security measures, please understand that there are no "perfect security measures" on the information network. (v) Information disclosure tips and password breach handling: Please note that the Internet is not an absolutely secure environment. When using certain services on our platform, you will inevitably have to disclose your personal information, such as bank account information, contact information or postal address, to counterparties or potential counterparties. Please protect your personal information and provide it to others only when necessary. If you find that your personal information has been compromised, especially your account and password, please contact our customer service immediately so that we can take appropriate measures. (vi) Information security incident handling: After the occurrence of personal information security events, we will inform you by mail, letter, telephone, push notification and other means in accordance with the requirements of laws and regulations: the basic situation of the security event and the possible impact, the disposal measures we have taken or will take, the recommendations you can independently prevent and reduce the risk, the remedial measures for you, etc. When it is difficult to inform the subject of personal information one by one, we will take reasonable and effective ways to publish announcements, and will also report the disposition of personal information security events in accordance with the requirements of regulatory authorities.

VII. Protection of Minors

We take the protection of personal information of minors seriously. If you are a minor, we recommend that you ask your guardian to read this Privacy Policy carefully and to use our Services or provide us with information with your guardian's consent, and to use our Services in " Teen Mode".

In addition, in order to better protect the privacy rights of minors, WELLFIT reminds you to be cautious about posting or forwarding content that involves the privacy of minors, and WELLFIT will report any information involving minors that violates the law to the network information and public security departments as appropriate.

VIII. How You Manage Your Information

We provide convenient ways for you to access, correct and delete your account information or other personal information you provide when using our services, as required by the Network Security Law of the People's Republic of China. You can access and manage your personal information in the following ways.

(i) Access to your personal information

You have the right to access your personal information, subject to any exceptions provided by law or regulation. You can access your personal information by yourself in the following ways:

You can view your personal information through "My". Edit your personal information through "Edit Profile" and "Settings" to edit and manage your personal information.

(ii) Correction or addition of your personal information

When you find that we have incorrectly processed your personal information, you have the right to ask us to make corrections or additions. You may request corrections or additions in the manner specified in "(i) Access to your personal information".

(iii) Deletion of your personal information

You may delete some of your personal information in the manner specified in "(i) Access to your personal information".

After you delete some of your information, we will retain your personal data for as long as necessary to fulfill the purposes described in this policy, unless an extension of the retention period is required or permitted by law. You may also choose to cancel your account, after which we will cease providing products and services based on that account and will delete or anonymize the corresponding personal data about you, if not specifically required by law to do so.

(iv) Change the scope of your authorized consent

Each business function requires some basic personal information to be completed. In addition, you may give or withdraw your consent for the collection and use of additional personal information in the "Settings" section or by contacting our platform customer service.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out based on your authorization.

(V) Cancellation of accounts by personal information subjects

If you need to cancel your account, you can contact our platform customer service by clicking on the Contact Customer Service button in the upper right corner of the home page and personal center. After verifying the user's identity, customer service will release the user's cell phone and email address to achieve the effect of cancellation.

Once your personal account in the platform is cancelled, we will delete or anonymize your information and account information, which cannot be restored. Please think well before you cancel your account as this will prevent you from using the full range of WELLFIT App products or services, and from accessing and retrieving historical information and records.

(vi) Constraint information system automatic decision making

We may make decisions based solely on automated non-human decision-making mechanisms in some business functions, including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will provide a method of appeal without infringing on our platform's trade secrets or other users' rights and interests, or the public interest.

(vii) Responding to your request above

For security purposes, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity first before processing your request.

We will respond within 15 days. If you are not satisfied with our response, you may also initiate a complaint through our platform customer service.

In principle, we do not charge for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a cost fee as appropriate. We may reject requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical.

In the following cases, we will not be able to respond to your request in accordance with the requirements of laws and regulations: 1) if it is related to national security or national defense security; 2) if it is related to public safety, public health, or significant public interest; 3) if it is related to crime investigation, prosecution, trial, and enforcement of judgments; 4) if there is sufficient evidence of subjective malice or abuse of rights by the subject of personal information; 5) if responding to your request would result in your or other individuals or organizations to suffer serious damage to their legitimate rights and interests; 6) involving commercial secrets.

IX. How your personal information is transferred globally

Personal information collected and generated in our operations in the People's Republic of China is stored in the territory of China, except in the following cases: 1) when explicitly provided for by laws and regulations; 2) when explicitly authorized by you; for the above cases, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy.

X. Revisions and updates to this Privacy Policy

We may modify and update this Privacy Policy from time to time by posting notices in the WELLFIT App, etc. You can check the latest version of the Privacy Policy by visiting the WELLFIT App. For major changes, we will provide you with a formal notice (including, for certain services, an email notice describing the changes to our Privacy Policy). In such cases, by continuing to use our Services, you agree to be bound the revised Privacy Policy of our Platform.

XI. Scope of application

1. Our Privacy Policy applies to all services provided by the WELLFIT Platform, including services provided on the WELLFIT App and "www.uswellfit.com", but does not include services with separate privacy policies (such as products and services provided by third parties). 2. Our privacy policy does not apply to products and services provided by third parties, such as those provided by third parties on the WELLFIT App and "www.uswellfit.com", and other websites linked to our services, which are governed by separate privacy policies, please refer to the corresponding policies separately. Our privacy policy does not cover the information handling policies of other companies and organizations that advertise our services and may use our cookies or other log information to place and use advertisements.