Here is the English version of the Privacy Policy. The content and structure remain unchanged, only translated into English:

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title: Privacy Policy
date: 2025-03-04

Privacy Policy

Release Date: 2025-03-04 Effective Date: 2025-03-04

As the provider of the Cloud Phone SDK, Minical International Limited (hereinafter referred to as “Minical” or “we”) greatly respects and is committed to protecting the security of your personal information.

The Cloud Phone SDK product and/or services referred to in this privacy statement include providing SDK software packages and API services for developers to integrate and access cloud phone services.

The Cloud Phone SDK provides developers with a quick way to access a comprehensive cloud phone technology solution. By calling the client-side SDK interfaces, developers can implement various cloud phone-related business scenarios.

After developers integrate the Cloud Phone SDK into their developed and/or operated applications and products (including APPs, mini-programs, web pages, etc., collectively referred to as “applications” or “developer applications”), the Cloud Phone SDK may collect and process data of end users (hereinafter referred to as “you”).

We hope that through this Privacy Policy, we can clearly, accurately, and completely explain to you how we collect, process, and protect all the information you provide when using developer applications that have integrated the Cloud Phone SDK.

This Privacy Policy will help you understand the following:

I. How We Collect and Use Personal Information

(1) To assist developers in providing corresponding functions and services to end users

When you use a developer application that has integrated the Cloud Phone SDK, the Cloud Phone SDK will collect the following information programmatically on behalf of the developer:

SDK Name	Function Type	Type of Personal Information	Purpose
Cloud Phone SDK	【Necessary Information】 (Basic information required for your cooperation with Minical)	Personal device information: Device brand, device model, operating system, OS API version, system language, screen resolution, user agent, CPU information (frequency, model, architecture) IP address Application information: Application distribution channel, application package name	Data streaming service, identifying application product service characteristics
	【Optional Information】	Sensor information: Accelerometer, magnetometer, gyroscope, gravity sensor Personal location information: Wi-Fi network name, latitude and longitude Other information: Access to camera, microphone, clipboard	Sensor information (with user consent) for simulating phone functions and local experience behavior, etc. Personal location and other information for data streaming services

We will not require you to actively submit personal information. The information we collect cannot individually identify a specific natural person, and due to the technical characteristics of this SDK, it is objectively unable to obtain any information that can individually identify a specific natural person during operation.

Cloud Phone SDK Permission List:

SDK Name	Permission Name	Permission Function	Usage Scenarios and Purposes
Android SDK	CAMERA (Camera)	Read/write storage permission	Complete audio/video publishing, sync cloud phone and local device data
	MICROPHONE (Microphone)
	READ_EXTERNAL_STORAGE (Read external storage)
	WRITE_EXTERNAL_STORAGE (Write external storage)
	ACCESS_FINE_LOCATION (Access precise location)		Enable cloud phone to simulate local location
	ACCESS_COARSE_LOCATION (Access coarse location)		Enable cloud phone to simulate local location

(2) To ensure service security, optimize and improve services

To assist developers in providing the above functions and services to end users, and to more accurately locate and resolve issues encountered by developers and end users when using the VMOSCloud Cloud Phone SDK products and services, improve and optimize the user experience on both the developer and end-user sides, enhance the security of the VMOSCloud Cloud Phone SDK services, prevent, detect, and investigate fraud, security risks, illegal or prohibited activities in violation of our agreements, policies, or rules, and to protect the legitimate rights and interests of developers, end users, us, our affiliates, partners, and the public, we will collect end users’ device information, location information, log information, and other information related to the login environment.

(3) Anonymization of personal information

Without publicly disclosing or providing end users’ personal information to external parties, Minical has the right to mine, analyze, and utilize user databases that have been anonymized (including for commercial purposes), and has the right to conduct statistics on product/service usage and share anonymized statistical information with the public/third parties.

(4) Exceptions where prior authorization and consent are not required

Click to view exceptions where authorization and consent are not required

Please note that in the following circumstances, collection and use of personal information do not require prior authorization and consent from the end user:

• Directly related to national security or national defense security;
• Necessary for the conclusion or performance of a contract in which the individual is a party;
• Necessary for fulfilling statutory duties or legal obligations;
• Directly related to public security, public health, or major public interests (e.g., responding to public health emergencies or protecting natural persons’ life, health, and property in emergency situations);
• Directly related to criminal investigation, prosecution, trial, and execution of judgments;
• Necessary to protect the life, property, or other major legitimate rights and interests of the individual or other persons when it is difficult to obtain consent;
• Processing publicly disclosed personal information by the individual or otherwise lawfully made public within a reasonable scope (e.g., legitimate news reporting, government information disclosure, etc.);
• Other circumstances stipulated by laws and administrative regulations.

We will seek your prior consent when we intend to use the information for purposes not stated in this Privacy Policy.

II. How We Share, Transfer, and Publicly Disclose Personal Information

(1) Sharing

Unless we obtain your prior separate consent or it falls under other circumstances stipulated by laws and regulations, we will not share your personal information with any third party other than Minical, except for information that has been processed so that specific individuals cannot be identified and cannot be restored.

For companies, organizations, and individuals with whom we share personal information, we will investigate their data security environment, sign strict confidentiality agreements with them, and require them to process personal information in accordance with our instructions, this Privacy Policy, and other relevant confidentiality and security measures.

1. With your authorization and consent, we may share the following personal information in the circumstances below:

   To achieve the purposes stated in this Privacy Policy, certain services are provided by authorized partners. We may share certain personal information of end users with partners to provide better customer service and user experience. We will only share end users’ personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only share information related to the provision of services. Our partners have no right to use the shared personal information for any other purpose.

   Currently, our authorized partners include the following types:

• (1) Service platforms or service providers. Various VMOSCloud products integrate rich third-party services. When end users choose to use these third-party services, they authorize us to provide relevant information to third-party service platforms or providers so they can provide services based on such information.
• (2) Software/hardware/system service providers. When third-party software/hardware/system products or services are combined with Minical’s products or services to provide services to end users, upon user authorization, we will provide necessary personal information to such third-party providers to enable service usage or to analyze product/service usage and improve user experience.

2. We will investigate the data security environment of companies, organizations, and individuals with whom we share personal information, sign strict confidentiality agreements, and require them to process personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

3. In the event of merger, division, liquidation, asset or business acquisition or sale involving us or our affiliates, end users’ personal information may be transferred as part of such transaction. We will ensure the confidentiality of such information during transfer and make our best efforts to ensure that the new entity holding the personal information continues to be bound by this Privacy Policy; otherwise, we will require the new entity to obtain fresh consent from end users.

(2) Transfer

We will not transfer end users’ personal information to any company, organization, or individual outside of our affiliates, except in the following cases:

• Prior explicit authorization or consent from the end user;
• Compliance with requirements of laws and regulations, legal procedures, or mandatory government or judicial orders;
• In case of merger, division, liquidation, asset or business acquisition or sale involving us or our affiliates, personal information may be transferred as part of the transaction. We will ensure confidentiality during transfer and strive to ensure the new holder continues to be bound by this Privacy Policy; otherwise we will require fresh consent.

(3) Public Disclosure

We will only publicly disclose end users’ personal information in the following circumstances:

• With the end user’s separate consent;
• When required by laws and regulations, legal procedures, litigation, or mandatory demands from government authorities.

(4) Exceptions to prior authorization and consent for sharing, transfer, and public disclosure

Click to view exceptions

In the following circumstances, sharing, transferring, or publicly disclosing personal information does not require prior authorization and consent from the end user:

• Directly related to national security or national defense security;
• Necessary for concluding or performing a contract in which the individual is a party;
• Directly related to public security, public health, or major public interests (e.g., responding to public health emergencies or protecting life, health, and property in emergencies);
• Directly related to criminal investigation, prosecution, trial, and execution of judgments;
• Necessary to protect the life, property, or other major legitimate rights and interests of the individual or others when it is difficult to obtain consent;
• Processing personal information lawfully made public by the individual or otherwise legally public within a reasonable scope (e.g., legitimate news reporting, government information disclosure, etc.);
• Other circumstances stipulated by laws and administrative regulations.

III. How We Store and Protect Personal Information

We attach great importance to information security and follow strict security standards, using industry-standard security protection measures to safeguard the information you provide, and employing various reasonable technical, operational, and managerial security measures to protect the collected information from unauthorized access, disclosure, use, modification, damage, or loss.

(1) Location of information storage

In accordance with the provisions of laws and regulations, we store personal information collected and generated within the territory of the People’s Republic of China. Currently, we do not transmit the above information overseas. If a developer transmits such information overseas, the developer shall fulfill the relevant compliance obligations.

(2) Storage period

We retain your information only for the period necessary to provide services to the developer. After the agreed storage period expires or upon receiving corresponding instructions from the developer, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations.

(3) Security measures

1. We attach great importance to the security of user information and will make reasonable efforts to adopt security measures (both technical and managerial) to protect your information from improper use, unauthorized access, disclosure, modification, damage, loss, or leakage.
2. We use encryption technologies and anonymization not lower than industry standards, along with reasonable and feasible security mechanisms to prevent malicious attacks on your information.
3. We have established dedicated security departments, security management systems, and data security processes to safeguard your information. We implement strict data usage and access controls to ensure only authorized personnel can access your information and conduct regular security audits of data and technology.
4. Although we have taken the above reasonable and effective measures and complied with legally required standards, due to technical limitations and various potential malicious means in the internet industry, we cannot guarantee 100% security of information even with our best efforts. We will do our utmost to ensure the security of the information you provide. You acknowledge and understand that the systems and communication networks you use to access our services may experience issues beyond our control. Therefore, we strongly recommend that you take active measures to protect your information security, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account passwords to others.
5. We will establish emergency response plans and immediately activate them in the event of a user information security incident (e.g., leakage or loss), striving to prevent expansion of the impact and consequences. Once a user information security incident occurs, we will inform you in accordance with legal requirements in a timely manner about: the basic situation of the incident and possible impacts, measures we have taken or will take, suggestions for you to prevent and mitigate risks, remedial measures for you, etc. We will notify you through push notifications, emails, letters, SMS, or other reasonable and effective methods (announcements when individual notification is difficult). We will also report the handling of the user information security incident to the relevant regulatory authorities as required.
6. We particularly remind you that the user information protection measures provided in this Privacy Policy apply only to this service. Once you leave pages related to this service and browse or use other websites, products, services, or content resources, we have no ability or obligation to protect any information you submit outside of this service, regardless of whether such access is based on links or guidance from this service.

IV. How We Handle Minors’ Personal Information

Minical places great importance on the protection of minors’ information.

The products and services of VMOSCloud Cloud Phone SDK are primarily intended for adults. If you are a minor under the age of 14, please carefully read the developer application’s privacy policy and this Privacy Policy together with your parents or other guardians before using any developer application that has integrated VMOSCloud Cloud Phone SDK, and use the application or provide personal information only with the consent of your guardian.

If we discover that we have collected a minor’s personal information without verifiable parental consent, we will take steps to delete the relevant information as soon as possible.

If at any time a guardian believes we have collected a minor’s personal information without guardian consent, please contact us through official channels, and we will take steps to delete the relevant data as soon as possible.

V. Your Rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we will make every effort to coordinate, support, and safeguard the following rights of end users regarding their personal information:

(1) Right to access, correct and supplement, copy, and cancel account

Since end users use the VMOSCloud Cloud Phone SDK service through developer applications without registering/logging into a Minical account, in order to ensure your rights to access, correct, supplement, copy your personal information, and cancel your developer application account, we require developers in this Privacy Policy and other agreements to promise to provide convenient implementation methods. If you wish to access, correct, supplement, copy your personal information, or cancel your developer application account, please do so through the methods provided by the developer. If the developer fails to provide such methods as promised, you may contact us through the channel in Section VII “How to Contact Us”, and we will make every effort to coordinate, support, and safeguard the realization of the above rights.

(2) Right to deletion

To safeguard your right to delete personal information, we require developers in this Privacy Policy and other agreements to promise to provide convenient implementation methods. If you wish to delete your personal information, please do so through the methods provided by the developer. If the developer fails to provide such methods as promised, you may contact us through the channel in Section VII to request deletion of personal information in the following circumstances:

• If we process your personal information in violation of laws and regulations or our agreement with you;
• If the processing purpose has been achieved, cannot be achieved, or is no longer necessary;
• If we cease to provide products or services, or the retention period has expired;
• If you withdraw consent;
• Other circumstances stipulated by laws and administrative regulations.

After you delete information from our service, we may not immediately delete corresponding information from backup systems, but we will delete it when the backup is updated. Please understand that if the legally required or policy-stated retention period has not expired, or deletion is technically difficult, we will cease processing except for storage and necessary security protection measures.

(3) Right to withdraw consent

Some basic personal information is required to complete each business function. For the collection and use of additional personal information, you may grant or withdraw your authorization and consent at any time.

You can directly disable the device system permissions mentioned in this Privacy Policy in your device settings, or change the scope of consent or withdraw authorization through other authorization settings provided by the developer application (if applicable). After you withdraw consent, we will no longer be able to provide the corresponding services related to the withdrawn consent and will cease using the relevant personal information. However, withdrawal of consent does not affect previous personal information processing activities based on your consent.

(4) Right to data portability

To safeguard your right to transfer personal information, we require developers in this Privacy Policy and other agreements to promise to provide convenient implementation methods. If you wish to transfer your personal information, please do so through the methods provided by the developer. If the developer fails to provide such methods as promised, you may contact us through the channel in Section VII, and we will make every effort to coordinate, support, and safeguard the realization of this right. Under conditions stipulated by laws and regulations and in compliance with instructions and requirements from the national cyberspace authority, if technically feasible, you may also request us to transfer your personal information to another entity designated by you.

(5) Right to be informed in advance of product/service discontinuation

VMOSCloud Cloud Phone SDK hopes to always accompany developers and end users. If the product must cease operation due to special reasons, we will notify developers and end users within a reasonable period through the main product/service page, in-app messages, email, or other appropriate means that can reach them, and we will stop collecting end users’ personal information. We will delete or anonymize collected personal information in accordance with the law.

(6) Right to obtain explanation

You have the right to request an explanation of our personal information processing rules. You may contact us through the channel in Section VII “How to Contact Us”.

VI. How This Privacy Policy Is Updated

(1) To provide better services to developers and users, this service will be updated from time to time. We will revise this Privacy Policy as appropriate, and such revisions will form part of this Privacy Policy and have the same legal effect.

(2) After this Privacy Policy is updated, we will publish the updated version on the relevant pages of this service so that you can learn about the latest version in a timely manner. Your continued use of the service constitutes your acceptance of all the contents of the revised Privacy Policy. However, if the updated content requires us to collect additional personal information from you, we will seek your consent again in a prominent manner.

VII. How to Contact Us

If you have any questions, comments, or suggestions regarding the content of this Privacy Policy, you may contact us by sending an email to start@vmoscloud.com. We will reply within 15 working days (“Reply Period”).

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This is the complete English translation with all original content preserved.