Privacy Policy

Welcome to use the services provided by NebulaBuds! Jimmy Cat Company (referred to in this agreement as Shanghai Jimmy Cat Technology Co., Ltd. and its affiliated companies, hereinafter also referred to as "we") attaches great importance to the protection of your privacy and personal information. NebulaBuds Privacy Policy (hereinafter referred to as "this Agreement") applies to your use of NebulaBuds services in different ways, including the NebulaBuds official website, multiple application versions including NebulaBuds for iOS and Android, and smart devices equipped with NebulaBuds.

You can use NebulaBuds to achieve device connection, on-site recording, simultaneous interpretation, face-to-face translation, AI music, AI chat, and AI assistant (hereinafter collectively referred to as "NebulaBuds products or services"). We will only process the personal information necessary for you to use our products or services.

This Agreement is intended to help you understand what personal information we collect, why we collect it, what we do with it and how we protect it. We will collect and use your personal information in accordance with the Privacy Policy, but will not collect all of your personal information in a mandatory manner just because you authorize and agree to this agreement. We will strictly comply with legal and regulatory requirements and obtain your separate consent in specific circumstances. In addition to this agreement, we may also explain to you our rules for processing your personal information through product page notifications, pop-up prompts, information push, etc. The processing of personal information corresponding to specific business functions will be subject to specific rules. Specific rules have the same effect as this Agreement.

Unless otherwise provided by laws and administrative regulations, you have the right to know and decide how we process your personal information, and you have the right to restrict or refuse us or other parties from processing your personal information; at the same time, you have the right to request We explain the personal information processing rules we provide to you. Please read and understand this agreement carefully before using NebulaBuds related products and services in order to make appropriate choices.

This agreement will help you understand the following:

1. Information we collect and corresponding purposes of use

2. How we use cookies and similar technologies

3. How we share, transfer and publicly disclose your personal information

4. How we store and protect your personal information

5. Your rights

6. How we process personal information of minors

7. How to update this agreement

8. How to contact us

We are well aware of the importance of personal information to you, and we also know that providing effective protection of your information is the cornerstone of the healthy and sustainable development of our business. Thank you for your use and trust in NebulaBuds! We are committed to maintaining your trust in us and abide by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of least adequate use, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. . We solemnly promise that we will take appropriate security protection measures to protect your personal information in accordance with mature security standards in the industry. , we will take corresponding security protection measures to protect your personal information in accordance with the mature security standards of the industry.

1. Information we collect and corresponding purposes of use

We will collect and use your personal information in accordance with the principles of lawfulness, legitimacy and necessity. Specifically, we collect and process your personal information to provide you with corresponding business functions . In the corresponding function, if you provide other people's personal information, please ensure that you have obtained authorization from the relevant subject. We reserve the right to verify the legal source of such personal information at any time.

You need to provide us with personal information for us to implement the basic business functions of NebulaBuds. The information necessary to realize basic business functions is necessary personal information. If you refuse to provide these necessary personal information, we will not be able to provide you with the basic business functions and corresponding services. In addition to basic business functions, you may choose to provide us with some personal information so that we can implement the expanded business functions of NebulaBuds. We will inform you of the purpose of use and process this personal information based on your authorization or consent or necessary to achieve the expanded business functions you choose. Your refusal to provide such expanded business function information will not affect your use of our basic business functions. However, if you refuse to provide the personal information necessary to realize the expanded business functions, we will not be able to provide you with the expanded business functions.

To facilitate your understanding, we list the business functions we provide, the purposes of processing and the personal information required as follows:

1.1. Register and log in to your account

You can create a NebulaBuds account through your mobile phone number, and you can complete your account information. When registering and logging in to your NebulaBuds account, you need to provide us with your mobile phone number .

You can choose whether to log in to NebulaBuds through the "one-click login" method. If you choose this login method, the operator will process your mobile phone number information.

1.2. Search and browse

In order to fulfill network security obligations and Internet information content management responsibilities stipulated in laws and regulations, and to display more relevant content to you that may be of interest to you, our servers will automatically record your activity information in accordance with the law, including the following:

The search keyword information you entered

Your browsing history, your favorites, posts, followings, comments, likes and other operational behavior records

Your content on-demand behavior record

your device information

Your other log information

We may also use the aforementioned information to provide you with more convenient search and information flow services and to continuously improve NebulaBuds products and services. For this purpose, we may also use mechanisms such as browser web storage (including HTML5) and application data caching to collect and store information on your device locally.

1.3. Provide you with intelligent voice services

When you activate the NebulaBuds program, we will automatically receive and record audio, video and other related information (including appropriate environmental parameters, such as noise indicators) generated during your interaction with the device terminal to provide you with services. Please note that if the wake-up function of the program is turned on, NebulaBuds will be woken up when she receives a wake-up action, and we will only collect voice information after receiving a wake-up action. If you refuse us to collect the above information, please turn off the information collection function of your device or do not wake up the device, but this will also result in you being unable to obtain relevant services.

In order to provide you with voice recognition and conversation functions, we need to collect the voice information and device identifiers you input . If you do not provide this type of information, you will not be able to perform voice recognition and text input through NebulaBuds.

When you use the intelligent voice interaction function of NebulaBuds, you can interact with NebulaBuds through voice input. At this time, we will ask you to authorize microphone permission and collect your voice information (only for text processing). After processing, we will delete it immediately without retaining it. We will automatically receive and record the text conversation information converted from speech during your interaction with NebulaBuds, and use this information to output content to you to provide human-computer interaction services. At the same time, we will store the aforementioned text conversation information for your subsequent query. If you refuse us to collect and process the aforementioned personal information, please enter the aforementioned information carefully, but this may affect your normal use of the aforementioned functions.

1.4. Complete payment

When you use the payment function, we will collect the payment method, order information, and payment content information you set. You can choose the payment channels provided by third-party payment institutions (including WeChat Pay, Alipay, Apple Pay, VISA and other payment channels). Payment Services. The payment behavior itself does not collect your personal information, but we need to share your order number and transaction amount information with these payment institutions in order for them to confirm your payment instructions and complete the payment.

1.5. Smart device connection and control

We collect your device information to provide more adapted services (such as message push services) for different device terminals. At the same time, we will sense the information of other devices equipped with NebulaBuds under the same WiFi in order to realize the interconnection of the devices, so that the NebulaBuds services you use between different devices can be seamlessly connected and you can enjoy personalized services across terminals.

In order to ensure that we provide you with normal services, we will collect your mobile phone's MAC address, smart device's MAC address, device Bluetooth MAC address, WiFi MAC address, and network card MAC address in the background to enable you to connect safely. Manage smart devices and Bluetooth devices. In addition, in the background, we will also collect your IMEI information for statistical daily activity data.

When you use the [on-site recording, simultaneous interpretation, and face-to-face translation] functions of smart headphones, we will apply for access to the microphone and recording permissions to collect your voice input content for the purpose of speech-to-text, recording, and translation. For your voice input content, we will encrypt the transmission and processing, and delete it immediately after the purpose of use is achieved to ensure that the data is safe and not used for other purposes.

1.6. New service and function operation and customer service processing

NebulaBuds will launch operational activities for newly launched services and functions from time to time. If the launch of a new service requires processing your personal information or applying for device system permissions without your prior authorization and consent, we will obtain your consent separately. Among them, If the processing of sensitive personal information is involved, we will obtain your separate consent.

If you participate in relevant operational activities, we may collect your identity information, contact information, and transaction account information through the operational activity interface in order to contact you and issue operational rewards to you. If you do not participate in relevant operational activities, you do not need to provide the aforementioned information.

In order to ensure the quality of calls and ensure that disputes are properly resolved, we may save records of your communication with us, including call records , information you provide related to your dispute resolution, and the contact information you use or provide.

1.7. Message notification

Please be aware and agree that we may send multiple types of notifications to one or more of the contact information (such as contact number) you provide when using the products and/or services during our operations. Used for user message notification, identity verification, security verification, user experience research, etc. In addition, we may also provide you with commercial information such as services, functions or activities that may be of interest to you by text message or phone call. If you do not want to accept this information, you can unsubscribe through the unsubscribe method provided in the mobile phone text message. Subscription, or you can contact us directly to unsubscribe.

1.8. Ensure service security, optimize and improve service purposes

When you use NebulaBuds, in order to ensure your normal use of NebulaBuds services, more accurately locate and solve the problems you encounter when using NebulaBuds services, improve and optimize the service experience of NebulaBuds, protect the security of your account, and prevent, detect and investigate fraud. , endanger safety, illegal or violate the agreement, policy or rules with us. In order to protect the legitimate rights and interests of you, us or our affiliates, partners and the public, we will collect your device information, location information , logs information and other information related to the login environment.

Please understand that when you switch NebulaBuds from the device screen to running in the background of the device, due to some device models and system reasons, the information collection behavior generated by your previous use of NebulaBuds related functions may not be stopped immediately, resulting in a short-term Background information collection behavior.

1.9. Other additional services provided to you

1.9.1. Additional functions based on location information

When you use the location-based related services provided by NebulaBuds, we may collect and process your device information, location information , and network identity information so that you can use the following related services without manually entering your geographical coordinates. Location information includes precise location information obtained through GPS information, WLAN access points, Bluetooth, base stations and other sensor information , as well as rough geographical location information obtained through IP addresses or other network information. When you use the following functions, we will request authorization of precise geographical location permissions. If you refuse to authorize precise geographical location permissions, we will not provide you with the above services based on precise location information. We will only use IP addresses or other network information to provide you with the above services. Corresponding city and/or district and county information and rough location information inferred based on other network location information provide you with services. Please understand that the IP address information we use has been de-identified. Data analysis and speculation only correspond to specific codes that cannot be directly associated with your identity, and will not be associated with your real information.

When you use the device adding function, in order to ensure that devices nearby you can be discovered through Bluetooth, we will collect your location information.

You can stop our collection of your precise location information by canceling the system's authorization for NebulaBuds to access your precise location information at any time. After that, you may not be able to use the above-mentioned related services or functions based on precise location information, or you may not be able to achieve the above-mentioned purposes based on precise location information. The intended effect of related services provided by precise location information. But this will not affect your normal use of other business functions of NebulaBuds that are not based on precise location information.

1.9.2. Microphone-based additional services:

When you use NebulaBuds products or services, you can turn on the microphone permission to record. We will collect your recording content and process the voice content based on functional purposes. Among them, for voice messages and home radio functions, we will also collect the identifier of the receiving device to achieve the purpose of transmitting and playing voice messages to the NebulaBuds you specify.

1.10. Indirect collection of information

In order to jointly provide you with products/services or improve the quality and personalization of products and services, or for reasonable needs such as considering the safety of products and services, we may obtain information from the Jimmy Cat Platform in accordance with the provisions of laws and regulations or based on your valid authorization. Receive your personal information and other information from , affiliated companies, partners and other trusted third-party suppliers. We will ask the personal information provider to explain the source of personal information in advance and confirm the legality of the source of personal information. At the same time, we will understand the scope of authorization and consent the personal information provider has obtained for the processing of personal information, such as necessary to conduct business. If the personal information processing activities carried out exceed the scope of the authorized consent obtained, we will obtain your express consent before processing the personal information, or obtain your express consent through the personal information provider.

1.11. Exceptions to prior authorization and consent

Please note: In the following situations, the collection and use of personal information does not require your prior authorization and consent:

Directly related to national security and national defense security;

Necessary for the conclusion and performance of a contract to which the individual is a party;

Necessary to perform legal duties or legal obligations;

In response to public health emergencies, or when necessary to protect the life, health and property safety of natural persons;

Directly related to criminal investigation, prosecution, trial and judgment execution;

To protect your or other individuals' life, property and other major legitimate rights and interests but it is difficult to obtain your consent;

Collect personal information that you have disclosed to the public on your own or that has been legally disclosed by others within a reasonable scope in accordance with laws and regulations;

Collect your personal information from legally publicly disclosed information within a reasonable scope in accordance with laws and regulations, such as legal news reports, government information disclosure and other channels;

Implement news reporting, public opinion supervision and other activities for the public interest, and process personal information within a reasonable scope;

When it is necessary for an academic research institution to conduct statistical or academic research based on public interests, and when providing externally the results of academic research or descriptions, the personal information contained in the results will be de-identified;

Other situations specified by laws and regulations.

1.12. Anonymization of personal information

On the premise of not publicly disclosing or providing your personal information to the outside world, Jimmy Cat Company has the right to mine, analyze and utilize the anonymized user database (including commercial use), and has the right to make statistics on the use of products/services. and share anonymized statistical information with the public/third parties.

1.13. Device permission call

In the process of providing services, in order to ensure that you can use product functions normally, we will apply to the system for the following system device permissions of your device. We will ask for your consent before applying. You can choose to "allow" or "forbid" permission application. After your authorization, we will open the relevant permissions. You can cancel the authorization in the system at any time. Your cancellation of authorization will cause you to be unable to use relevant business functions, but it will not cause you to be unable to use other business functions.

When you use NebulaBuds APP, our invocation of mobile phone system privacy permissions is as follows:

Device permissions Business functions Permission authorization method Can it be closed
Access phone status User device identification ensures users' normal use of message push services and improves the efficiency and accuracy of message push services. A pop-up window asks when the user opens the App for the first time yes
Location Address management Pop-up window asking when user performs location-related business for the first time yes
microphone Live recording, simultaneous interpretation, face-to-face translation, AI chat Pop-up window asking when using voice-related functions for the first time yes
wireless network Network connections for various business functions A pop-up window asks when the user opens the App for the first time yes
Bluetooth Device addition; device connection; device settings A pop-up window will appear when the user uses the relevant function for the first time. yes
notify Send notification message A pop-up window asks when the user opens the App for the first time yes
IDFA Improve and optimize service experience; advertising recommendations; protect the security of your account A pop-up window asks when the user opens the App for the first time yes

In different devices, the permission display and closing methods may be different. For details, please refer to the instructions or guidelines of the device and system developers.

1.14. Other purposes that you otherwise agree to

When we want to use information for other purposes not specified in this agreement, we will ask for your consent in advance. When we want to use the information collected for a specific purpose for other purposes, we will ask for your consent in advance.

2. How we use cookies and similar technologies

Cookies and Anonymous Identifier Tools . Cookies are a mechanism that supports server-side (or script) storage and retrieval of information on the client. When you use NebulaBuds products or services, we will send one or more Cookies or anonymous identifiers to your device. When you interact with the NebulaBuds service, we allow cookies or anonymous identifiers to be sent to the Jimmy Cat Company server. Cookies usually contain an identifier, the site name, and some numbers and characters. Using Cookie technology, Jimmy Cat can understand your usage habits, remember your preferences, save you the step of entering repeated information, provide you with more thoughtful personalized services, or help you determine the security of your account. Cookies can also help us count traffic information and analyze page design and advertising effectiveness.

We will not use Cookies for any purpose other than those stated in this Agreement. You can manage or delete cookies according to your preferences. See AboutCookies.org for details. You can clear all cookies saved on your computer, and most web browsers have the function to block cookies. But if you do this, you will need to personally change the user settings every time you visit our website, but you may not be able to log in or use the services or functions provided by Jimmy Cat Company that rely on cookies because of such modifications.

You can clear your cookies and limit Jimmy Cat's use of cookies through [My]-[Settings]-[Clear Cache].

3. How we share, transfer, publicly disclose, entrust the processing of your personal information and the third parties connected to it

Some of our services will be provided by authorized partners. Only to achieve the purposes stated in this agreement, we may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and we will only share the personal information necessary to provide services. Unless otherwise authorized by you or otherwise required by laws and regulations, our partners have no right to use the shared personal information for any other purpose.

3.1. Sharing

Unless you have separately agreed in advance or comply with other laws and regulations, we will not share your personal information with third parties other than Jimmy Cat Company, unless the processing cannot identify a specific individual 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 take confidentiality and security measures to handle personal information in accordance with the law.

We may share your personal information with the following third parties under the following circumstances:

3.1.1. Third-party product or service providers.

NebulaBuds is connected to a wealth of third-party services (including third-party applets). When you use third-party services connected to NebulaBuds, you may be required to submit your personal information. We will provide your personal information to third parties that provide services to you based on your valid authorization or when necessary to enter into and perform a contract to which the individual is a party. Regarding how third-party services specifically collect and use your personal information, we recommend that you refer to the relevant service agreements and privacy policies of the third-party services .

When you participate in marketing activities or service content provided by a third party, you may be required to provide your account nickname, avatar, name, contact information and other information based on service needs. We will provide you with marketing activities or services with your separate consent or through a third party. When necessary for service content, your personal information will be shared with third parties to ensure that the third party can smoothly provide you with services or cash rewards to you in a timely manner. If you refuse to share when it is necessary to provide you with marketing activities or service content, the third party will not be able to provide you with services or refuse your participation.

3.1.2 Third parties with whom you actively choose to share personal information

You can use the sharing function of NebulaBuds to share information content, search results, etc. that interest you with Jimmy Cat friends, QQ friends, WeChat friends, and Weibo friends. Please fully consider the creditworthiness of the information recipient before using third-party services or sharing functions, and we recommend that you check the personal information processing rules (such as privacy policies) of the social network or third-party service provider you use to understand how they handle it. Processing of your information for informed decision-making.

3.2. Transfer

We will not transfer your personal information to any company, organization or individual other than Jimmy Cat Company, except in the following circumstances:

Obtain your express authorization or consent in advance;

To meet the requirements of laws, regulations, legal procedures or mandatory government requirements or judicial rulings;

If we or our affiliates are involved in a transaction such as a merger, spin-off, liquidation, acquisition or sale of assets or business, and if personal information is transferred, we will ensure the confidentiality of such information at the time of transfer and inform you of the recipient's information. Name or name and contact details. At the same time, we will require the transferee to adopt the same or higher standards and requirements as this policy for processing and protection, otherwise we will require the transferee to seek your consent again. In addition, we will anonymize or destroy personal information that does not have a data recipient.

3.3. Public disclosure

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

Obtain your separate consent;

Based on laws, regulations, legal procedures, litigation or mandatory requirements of government authorities.

When announcing penalties for illegal accounts and violations, we will disclose relevant account information, which will inevitably include account-related certification information and violations.

3.4. Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information

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

Directly related to national security and national defense security;

Necessary for the conclusion and performance of a contract to which the individual is a party;

Necessary to perform legal duties or legal obligations;

Directly related to public safety, public health, and major public interests. For example: in response to public health emergencies, or when necessary to protect the life, health and property safety of natural persons;

Directly related to criminal investigation, prosecution, trial and judgment execution;

To protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals but it is difficult to obtain the consent of the individual;

In accordance with the provisions of laws and regulations, we will process personal information that has been disclosed by individuals or has been legally disclosed by others within a reasonable scope, such as legal news reports, government information disclosure and other channels.

Situations otherwise provided for by laws and administrative regulations.

3.5. The third-party software development kit (SDK) we have access to

In order to adapt to the use of NebulaBuds and third-party platform services on different mobile devices, to achieve your mobile device identity authentication, mobile device security, receive information push, log in to third-party platform accounts, share information through third-party platforms and payment security], NebulaBuds Integrated third-party SDK. The above-mentioned third-party SDK providers include mobile phone equipment manufacturers, social platforms, communication operators and third-party payment institutions. Some third-party SDKs may call your device permissions and obtain your relevant information so that you can use corresponding functions normally on different mobile devices or third-party platforms. The type of device permissions called by different third-party SDKs and the information obtained may be different, which may include obtaining your location, reading/writing your external memory card, reading your phone status and identity, viewing WLAN connections, and retrieving current data. Running apps/Bluetooth information. Regarding the specific types of device permissions called by the third-party SDK, and how to collect and use your personal information, we recommend that you refer to the relevant service agreement and privacy policy of the third-party SDK. If you want to know more about the third-party SDK we have connected, please read the third-party SDK information .

3.6 Entrusted processing and joint processing

In order to better serve you, we may entrust third-party partners to process your personal information. We will only entrust third-party partners to process your information for legal, legitimate, necessary, specific, and clear purposes. We will strictly limit the purpose of information processing by the trustee and require the trustee to adopt adequate data security measures. If a third-party partner uses your information for purposes not entrusted by us, it will obtain your consent separately. The authorized partners we entrust include advertising and analysis service authorized partners. We will entrust these partners to process information related to advertising delivery, advertising effectiveness, and advertising reach rate while complying with industry-accepted security technologies. Among them, in order to identify the advertising click effect on the smart device, we may provide the advertising partners with the IMEI and OAID of the mobile phone equipped with the NebulaBuds APP bound to the device in an encrypted manner. Without your valid authorization, we will not entrust information that can directly identify you to third-party partners for processing. If you actively leave your contact information, address information and other personal information for a specific third-party partner to contact you, they will directly process your personal information.

In joint processing scenarios, we will also sign relevant agreements with our partners that comply with legal and regulatory requirements and fulfill relevant personal information protection obligations.

4. How we store and protect your personal information

4.1. Storage period

We will keep your personal information for the period required to provide services, but laws and regulations have other provisions on the retention period. You agree to retain it for a longer period, to ensure the safety and quality of the service, to achieve the purpose of dispute resolution, and it is technically difficult to achieve Under other circumstances, after the aforementioned retention period expires, we will extend the retention period in accordance with the law, the contract, or within a reasonable scope.

After the retention period has expired, we will delete or anonymize your personal information in accordance with legal requirements.

4.2. Save region

In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. If your personal information may be transferred to overseas jurisdictions in the country/region where you use products or services, or be accessed from these jurisdictions, we will strictly fulfill our obligations under laws and regulations and obtain your information in advance in accordance with legal requirements. Agree individually . Such jurisdictions may have different or no data protection laws. In such cases, we will transfer your personal information in accordance with the current laws of China and will ensure that your personal information receives adequate and equal protection within the territory of the People's Republic of China. For example, we may ask for your consent to the cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfer.

4.3. Security measures

We will collect, use, store and transmit user information based on the "minimization" principle, and inform you of the purpose and scope of use of relevant information through the user agreement and privacy policy.

We take information security very seriously. We have established a dedicated team responsible for the development and application of various security technologies and procedures. We will conduct security background reviews for security management leaders and personnel in key security positions. We have established a complete information security management system and internal security incident handling mechanism. wait. We will take appropriate security measures and technical means that comply with industry standards to store and protect your personal information to prevent your information from being lost, unauthorized access, public disclosure, use, damage, loss or leakage. We will take all reasonably feasible measures to protect your personal information. We will use encryption technology to ensure the confidentiality of data; we will use trusted protection mechanisms to prevent data from malicious attacks.

We will conduct data security awareness training and security capability training and assessment for employees to strengthen their understanding of the importance of protecting personal information. We will conduct identity authentication and authority control for employees who handle personal information, and will sign confidentiality agreements with employees and partners who come into contact with your personal information to clarify job responsibilities and codes of conduct to ensure that only authorized personnel can access personal information. If there is a violation of the confidentiality agreement, the cooperative relationship with Jimmy Cat Company will be immediately terminated , and relevant legal responsibilities will be held. Personnel who have access to personal information will also be required to keep confidentiality when they leave their jobs.

We remind you that the Internet is not an absolutely secure environment. When you interact with other users about your geographical location or whereabouts information through third-party social software, email, text messages, etc. embedded in NebulaBuds, you are not sure whether the third-party software will affect the information. Whether the transmission is fully encrypted, please pay attention to ensure the security of your personal information .

We also ask you to understand that due to technological limitations and rapid development in the Internet industry, as well as various possible malicious attack methods, even if we do our best to strengthen security measures, we cannot always guarantee 100% security of information. Please understand that the systems and communication networks you use when using our products and/or services may have security issues in other links beyond our control .

4.4. Security incident notification

We will formulate contingency plans for network security incidents to promptly deal with security risks such as system vulnerabilities, computer viruses, network attacks, and network intrusions. When an incident that endangers network security occurs, we will immediately activate the contingency plan, take corresponding remedial measures, and follow Requires reporting to relevant authorities.

The leakage, damage, and loss of personal information are serious security incidents at the company level. We will be responsible for regularly organizing working group members to conduct security plan drills to prevent such security incidents from occurring. If something unfortunate happens, we will activate the emergency plan with the highest priority and form an emergency response team to trace the cause and reduce losses in the shortest possible time.

After an unfortunate personal information security incident occurs, we will promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take, and the risks you can prevent and reduce on your own in accordance with the requirements of laws and regulations. Suggestions, remedies for you, etc. We will promptly inform you of the incident-related information through site notifications, SMS notifications, phone calls, emails and other contact methods you have reserved. When it is difficult to inform you one by one, we will issue announcements in a reasonable and effective manner. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities. Please understand that according to laws and regulations, if the measures we take can effectively avoid harm caused by information leakage, tampering, and loss, we may choose not to notify you of the personal information security incident unless the regulatory authorities require notification to you.

5. Your rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights over your personal information. If you have questions or claims about the exercise of your rights, you can also contact us through [8. How to Contact Contact us via:

5.1. Right of access

In principle, you can check your personal information in the following ways:

Account information: Visit [My] - [Settings] - [Account Management] to access or edit the personal profile information in your account.

5.2. Right of correction and addition

When you find that the personal information we process about you is incorrect or incomplete, you have the right to correct the incorrect or incomplete information after your identity has been verified and the correction does not affect the objectivity and accuracy of the information. To correct or supplement the information, you can make corrections or supplements by yourself in NebulaBuds through [My] - [Settings] - [Jimmy Cat Account Management], or submit your correction or supplement application to us through feedback and error reporting. .

5.3. Right to erasure

You can make a request to us to delete personal information under the following circumstances:

If we process your personal information in violation of laws, regulations or agreements with you;

If our processing purposes have been fulfilled, cannot be fulfilled or are no longer necessary to fulfill the processing purposes;

If we stop providing products or services, or the storage period has expired;

If you withdraw your consent;

Other situations stipulated by laws and administrative regulations.

When you delete information from our services, we may not delete the corresponding information in the backup system immediately, but we will delete the information when the backup is updated. Please know and understand that if the retention period stipulated in laws, administrative regulations or described in this agreement has not expired, or it is technically difficult to delete personal information, we will stop processing other than storing and taking necessary security protection measures. .

5.4. Withdrawal of consent

Each business function requires some basic personal information to be completed. You may give or withdraw your consent at any time for the collection and use of additional personal information.

You can visit [My] - [Settings] - [Account Management] - [Authorization Management] to unbind the Jimmy Cat account from the third-party account.

You can directly turn off system permissions such as storage, location information, camera, microphone, camera, address book, etc. in the device system, change the scope of consent, or withdraw your authorization.

After you withdraw your consent, we will no longer be able to provide you with the services corresponding to your withdrawal of consent, and we will no longer use your corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your consent.

5.5. Right of cancellation

You can log out of your account in NebulaBuds through the following path: [My] - [Settings] - [Jimmy Cat Account Management] - [Account Logout].

    Once you log out of your Jimmy Cat account, you will not be able to use the services of Jimmy Cat's full range of user products, so please operate with caution. In order to protect your or others' legitimate rights and interests, we will determine whether to support your cancellation request based on your use of Jimmy Cat Company products. Unless otherwise provided by laws and regulations, after canceling your account, we will stop providing products and services to you, and delete your personal information according to your request.

5.6. Right of reproduction and portability

You have the right to copy the personal information we have collected about you. Under the conditions stipulated by laws and regulations, and in compliance with the instructions and conditions stipulated by the national cyberspace department, if technically feasible, you may also ask us to transfer your personal information to other entities designated by you.

5.7. The right to be notified in advance of the discontinuation of operations of products and services.

NebulaBuds is willing to accompany you all the time. If NebulaBuds products cease operation due to special reasons, we will notify you within a reasonable period on the main page of the product or service or on the site, or by sending you an email or other appropriate method to reach you. We will stop collecting your personal information and delete or anonymize your collected personal information in accordance with legal provisions.

5.8. Right to an explanation

You have the right to request an explanation of our personal information processing rules. You can contact us through the contact information in Section 8.

5.9. Display and control of personalized content and advertising

5.9.1. Display and control of personalized content

To facilitate you to control the personalized information you wish to receive, you can dynamically adjust your interests and preferences through the following paths, and we will push relevant personalized content to you based on your choices.

If you do not want to receive relevant personalized content pushed to you based on your interests and preferences, you can choose to turn on or off personalized recommendations through the [My] - [About] - [Personalized Recommendation Settings] switch. When you choose to turn off personalized content recommendation, you will not be able to enjoy the personalized recommendation service. We will show you content based on non-personalized factors such as content popularity. You may see content that you are not interested in or even like. Your usage Experience may be affected.

5.9.2. Display and control of personalized advertising

We may collect and use advertising identification information that complies with national or industry group standards. This identification is generated based on non-sensitive personal information such as device model and system configuration to provide you with more personalized information while protecting your privacy and service security. advertising to enable you to enjoy more convenient services. After we launch this function, we will also provide you with the closing function and inform you of the closing path. If you do not want us to use advertising identification information for the above purposes, you can choose to close it at any time. After closing, we will no longer obtain and process the Internet advertising identifier.

If you do not want to receive relevant personalized ads that we push to you based on your interests and preferences, you can choose to turn on or off personalized recommendations and turn off personalized ad recommendations through the [My] - [About] - [Personalized Recommendation Settings] switch. . When you choose to turn off personalized ad recommendations, the number of ads you see will not be reduced, and you will not be able to enjoy personalized recommendation services. We will show you ads based on non-personalized factors such as content popularity. You may see that you Ads that you are not interested in or even dislike may affect your experience.

5.10. Exceptions to the exercise of rights

We may not be able to respond to your requests for access, correction and addition, deletion, copying and portability, information, and decision-making under the following circumstances:

Directly related to national security and national defense security;

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

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

We have sufficient evidence to show that you have subjective malice or abused your rights (for example, your request will endanger public safety and the legitimate rights and interests of others, or your request exceeds the scope that can be covered by general technical means and commercial costs);

Responding to the personal information subject's request will cause serious damage to your or other individuals' or organizations' legitimate rights and interests;

Involving trade secrets;

Situations otherwise provided for by laws and administrative regulations.

5.11. How to respond to your rights request

For security reasons, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. Once verified, we will respond within fifteen working days.

In principle, we do not charge fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the circumstances. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, require the development of new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical.

6. How we process personal information of minors

Jimmy Cat Company attaches great importance to the protection of minors’ information.

Our products and services are primarily intended for adults. We will only process the personal information of minors as permitted by laws and regulations and with the consent of parents or other guardians.

If you are a minor under the age of 14, before using NebulaBuds products and services, you should ask your parents or other guardians to read it carefully, or read this agreement carefully together under the supervision and guidance of your parents or other guardians. "Jimmy Cat Children's Personal Information Protection Statement" and use our products and services or provide information to us with the consent of your parents or other guardians .

If we discover that we have collected personal information from minors under the age of 14 without first obtaining verifiable parental or other guardian consent, we will take steps to delete the relevant information as soon as possible. If at any time the guardian has reason to believe that we have collected the personal information of minors without the guardian's consent, please contact us at nebulabuds@palmzen.cn and we will take steps to delete the relevant data as soon as possible.

7. Revision of Privacy Policy

Our privacy policy may change.

We will not reduce your rights under this Agreement without your explicit consent. We will post any changes to this Agreement on this page.

For major changes, we will notify you on the main exposure page of the product or service, an in-site letter, or send you an email or other appropriate method to reach you . If you do not agree to these changes, please stop using NebulaBuds products and services immediately.

Major changes referred to in this Agreement include but are not limited to:

Significant changes to our service model. Such as the purpose of processing personal information, types of personal information processed, how personal information is used, etc.;

We have undergone significant changes in our ownership structure, organizational structure and other aspects. Such as changes in owners caused by business adjustments, bankruptcy mergers, etc.;

The main objects to whom personal information is provided, transferred or publicly disclosed change;

There are significant changes in your rights to participate in the processing of personal information and how to exercise them;

When our responsible department, contact information and complaint channels for handling personal information security change;

When the personal information security impact assessment report indicates that there is a high risk.

8. How to contact us

The growth of NebulaBuds cannot be separated from the joint efforts of user experts from all parties. We are very grateful for your contribution to NebulaBuds data updates and usage feedback.

You can contact us by sending an email to nebulabuds@palmzen.cn .

In order to ensure that we handle your problem efficiently and provide you with timely feedback, you are required to submit proof of identity, valid contact information, written request and relevant evidence. We will verify your identity and process your request.

Attached: Explanation of terms

Personal information refers to various information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information. Personal information includes name, date of birth, ID number, personal biometric information, address, communication contact information, communication records and content, account password, property information, credit information, whereabouts, accommodation information, health and physiological information, transactions information etc.

Sensitive personal information refers to personal information that, once leaked or illegally used, could easily cause the dignity of a natural person to be infringed or the personal and property safety to be endangered, including biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts and other information , and personal information of minors under the age of fourteen.

Device means a device that can be used to use Jimmy Cat products and/or services, such as a desktop device, tablet or smartphone.

Device information may include device attribute information of the terminal device you use to install and run NebulaBuds SDK (such as hardware model, operating system version and system status, device configuration, International Mobile Equipment Identity code IMEI, International Mobile Subscriber Identity Code IMSI, network equipment Hardware address MAC, advertising identifier IDFA, vendor identifier IDFV, mobile device identification code MEID, anonymous device identifier OAID, integrated circuit card identification code ICCID, Android ID, hardware serial number and other device identifiers), device connection information ( For example, browser type, telecom operator, language used, WIFI information) and device status information (such as device application installation list).

Log information refers to our server automatically recording the requests you make when accessing NebulaBuds, such as your IP address, browser type and language used, hardware device information, operating system version, network operator information, The date, time, and duration of your access to the service and other information you provide, form or retain when using our products or services.

Cookies refer to a mechanism that supports server-side (or script) storage and retrieval of information on the client, extending Web-based client/server applications by adding simple, persistent client state. The server sends a status message while returning the HTTP object to the client, and the client saves it. The status information describes the valid URL range in this status. Thereafter, any HTTP request within this range initiated by the client will return the current value of the status information from the client to the server. This status information is called a cookie.

Location information refers to precise location information obtained through GPS information, WLAN access points, Bluetooth, base stations and other sensor information. It also includes rough geographical location information obtained through IP addresses or other network information.

De-identification is the process by which personal data are processed in such a way that they cannot be identified as a specific natural person without the aid of additional information.

Anonymization refers to the process of technical processing of personal information so that the subject of personal information cannot be identified and the processed information cannot be restored. Information obtained after personal information has been anonymized does not belong to personal information.

Jimmy Cat Platform refers to the specialized channels or platform services of Jimmy Cat Company.

Affiliated companies refer to the individual or collective name of Shanghai Jimmy Cat Technology Co., Ltd., the operator of NebulaBuds, and other companies with related relationships. "Affiliated relationship" means any entity (including an individual, company, partnership, organization or any other entity) that is directly or indirectly controlled by it, or a entity that directly or indirectly controls it, or is directly or indirectly related to it. Subjects controlled by the same subject. The aforementioned "control" refers to having the power, directly or indirectly, to give instructions on the management and decision-making of relevant entities or to oblige others to give instructions through holding voting rights, contracts or other means, or other relationships that in fact constitute actual control.

Thank you again for your trust and use of NebulaBuds!

Shanghai Jimmy Cat Technology Co., Ltd.

April 22, 2024