Dear Customer,

Thank you for using the products and services provided by Toptechalliance Device Co., Ltd (hereinafter referred to as “Toptechalliance”, “we”, “us”, or “our”) and its global affiliates. To ensure that you can be updated with and reserve control over your privacy and personal data, please carefully read the Privacy and Personal Data Protection Policy (hereinafter referred to as this “Policy”).

This policy describes your data subject rights and how we process your personal data. Unless a specific privacy policy or statement exists, this Policy will apply to all products and services offered by Toptechalliance, as well as to Toptechalliance’s websites that display or link to this Policy (e.g., www.hiToptechalliance.com, developer.hiToptechalliance.com). The products and services mentioned in this Policy may vary depending on your software version, device model, or location. For details about the data process for specific products or services, refer to the corresponding agreements, policies, or statements.

Toptechalliance respects your privacy. We will process your personal data under the principles of lawfulness and fairness, and the minimum necessary standard. We will protect your privacy and personal information in strict compliance with this policy and legal or regulatory requirements, as well as proven industry security standards.

This Policy describes:

1. What Data Do We Collect About You

2. Why We Process Your Personal Data

3. How We Share, Transfer, or Disclose Your Personal Data

4. How We Control Your Personal Data Independently or Jointly with Third Parties

5. How You Control Your Personal Data

6. How We Protect Your Personal Data

7. Protection of Minors

8. How We Manage Cookies and Similar Technologies

9. How We Store Your Personal Data

10. Contact Us

11. How We update This Policy

1. What Data Do We Collect About You

1.1.1 When you register your account related to our products and services, you will be asked to provide necessary personal data, such as your name, gender, email, and cell phone number. When you log in to your Toptechalliance account for online shopping, software downloading, and service purchasing, we will ask you to provide necessary personal data, such as your name, email, cell phone number, order information, delivery address, and payment method.

1.1.2 When you participate in our online or offline events or contact us for information or feedback, you will be asked to provide necessary personal data, such as your name, email address, shipping address, cell phone number, or other contact information.

1.2 Personal data obtained by us when providing services to you
We will collect your device information, and how you and your device interact with Toptechalliance products and services, including:

1.2.1 Device and app information: Device name, device identifier, device activation time, hardware model, hardware system version, app version, software identifier, and device and app settings (such as region, language, time zone, and font).

1.2.2 Mobile network information: Public Land Mobile Network (PLMN) provider ID, geographical location (cell ID of the area where the device is located), and Internet protocol (IP) address.

1.2.3 Log information: When you use our services or view content provided by us, we will automatically collect certain information and record it in logs, such as the time of access, access count, IP address accessed, and event information (such as error, crash, restart, and upgrade).

1.2.4 Location information (applicable only to specific functions): When you access certain location-based services (such as the search, navigation, or weather query service), we will collect, use, and process your device’s approximate or precise location information, which is obtained using GPS, Wi-Fi hotspot, and service provider’s network ID. You can revoke the corresponding permission from the system settings on your device to reject sharing your location information.

1.3 Personal data provided by third parties

Where permitted by law, we may also collect your personal data from third parties. Such information may include:

1.3.1 We may obtain your personal data, such as your name, cell phone number, or shipping address, from other individuals, such as your friends and family, when they purchase products for you on the Toptechalliance Store.

1.3.2 We will also obtain information about you from public and commercial sources, including third-party social media platforms, such as when you log in to our websites using a social media app.

1.3.3 For risk management purposes, we may engage our providers to confirm your device identifier, device type information, and network information when you perform high-risk operations, such as creating an Toptechalliance account.

1.4 Non-identifiable personal data

Non-identifiable personal data is information that cannot be used to identify or determine the identity of a specific individual, such as statistics on website operations and service inquiries. Toptechalliance collects such information to understand how users use our products and services and improve the quality of our services based on such information. Toptechalliance may, in its sole discretion, collect, use, disclose, and transfer non-identifiable personal data for other purposes. We will endeavor to segregate your personal data from non-identifiable personal data and ensure that the two types of information are used separately.

2. Why We Process Your Personal Data

We will process your personal data only for clear, explicit, and specific purposes. If personal data collected is not used for purposes directly or reasonably associated with the explicit purpose described in this Policy, we will ask for your consent.

Your personal data will be used for us to:

2.1 Contract with you or provide products or services to you, such as purchasing Toptechalliance’s personal and household products or activating the one you have purchased, registering for an Toptechalliance account, and handling your inquiries and requests.

2.2 Provide you with a better service experience, invite you to participate in online and offline activities, or collect your requirements for products, such as providing you with personalized user experience and content, and inviting you to participate in promotional activities.

2.3 Push related messages and important notifications to you, such as sending you notifications about OS or application updates and installations.

2.4 Protect the security of our products and services, such as implementing and improving our loss prevention and anti-fraud programs for security purposes.

2.5 Fulfill relevant internal purposes, such as business audits and business data analysis and statistics to improve our product or service experience.

2.6 Achieve other lawful and practical purposes with your consent.

3. How We Share, Transfer, or Disclose Your Personal Data

3.1 We need to share your personal data with third-party service providers or our affiliates when using their services in certain scenarios, examples include providing technical support for Toptechalliance products, contacting you on our behalf via hotline or email, or handling your requests. We will appropriately review the personal data protection capabilities of the recipient of personal data, sign strict confidentiality agreements or personal data processing clauses with the third-parties, and require them to take adequate organizational or technical measures to protect your privacy and personal data.

3.2 We may transfer your personal data to third parties after seeking and obtaining your explicit consent. In the event of acquisition, merger, reorganization, bankruptcy, or other change that involves the transfer of personal data, we will inform you of the situation and require the party receiving the personal data to be bound by this Policy.

3.3 We may disclose your personal data after seeking your explicit consent, in accordance with the law, or for other legitimate reasons, such as when required by the regulatory authority.

3.4 We may also share, transfer, or disclose your data in other legally applicable scenarios or otherwise authorized by you.

4. How We Control Your Personal Data Independently or Jointly with Third Parties

When your personal data is under the control of us and third parties, we will work with the third party to determine the security requirements for personal data, as well as our respective responsibilities and obligations, and update you accordingly. For example, when you purchase products released by developers in AppGallery, we will share necessary information with developers to complete the transaction.

When your personal data is under the sole control of a third party, please carefully read its third-party privacy and personal data protection policies and determine whether to accept the services. For example, links in Toptechalliance products and services may redirect you to third-party websites, products, and services, which are provided for your convenience only. We cannot control the privacy and data protection policies of third parties who, therefore, are not subject to this Policy.
Your personal data may be shared with our affiliates in compliance with laws and regulations, and this Policy.

In addition, we will share your personal data with third parties to the extent permitted by law or with your consent.

5. How You Control Your Personal Data

5.1 Access, Correct and Delete: You reserve the right to access, correct, and delete your personal data in accordance with applicable laws. To protect your privacy and personal data security, we will verify your identity and provide feedback to you to the extent permitted by law. We may reject unreasonable requests, such as repeated or unrealistic requests, or requests that may infringe upon others’ rights or interests.

5.2 Withdraw Consent: Within the scope permitted by applicable laws, you may withdraw your prior consent at any time. If you withdraw your consent, we will not be able to continue to provide you with the services for which you have withdrawn your consent, and we will stop collecting your personal data. This does not affect the processing of your personal data prior to the withdrawal of consent.

5.3 Delete Account: You can delete your Toptechalliance ID linked with your Toptechalliance products and services at any time. After your Toptechalliance ID is deleted, we will stop providing related products and services. Your relevant personal data will be deleted or anonymized unless otherwise specified by laws.

6. How We Protect Your Personal Data

We take your personal data and privacy seriously, and are committed to protecting your privacy and personal data in accordance with established industry security standards. For this purpose, we take the following measures:

6.1 We take all reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We will retain your personal data for the minimum period required to fulfill the purposes described in this Statement, unless the retention period is extended as necessary or permitted by law.

6.2 We will use encryption technology to ensure the confidentiality of data transmission and storage. We will use a trusted protection mechanism to protect data and data storage servers against malicious attacks.

6.3 We will deploy an access control mechanism to ensure that only authorized personnel can access personal data. In addition, we will control the number of authorized personnel according to the business needs and personnel levels and manage their access permissions in a hierarchical way. All personal data access is recorded in logs and periodically reviewed by the administrator.

6.4 We strictly select business partners and service providers and incorporate personal data protection requirements into commercial contracts, audits, and appraisal activities.

6.5 We will organize security and privacy protection training courses, tests, and publicity activities to enhance employees’ awareness of the importance of protecting personal data.

In a word, we are highly committed to protecting your privacy and personal data. In spite of this, no security measures are completely infallible, and no products and services, websites, data transmission, computer systems, or network connections are absolutely secure.

If any personal data security incidents occur, we will notify you, pursuant to relevant legal and regulatory requirements, of the basic information about the security incident and its possible impact, measures that we have taken or will take, suggestions about active defense and risk mitigation, and remedial measures. The notification may take the form of an email, text message, push notification, etc. If it is difficult to notify data subjects one by one, we will take appropriate and effective measures to release a Security Notice. In addition, we will also report the handling status of personal data security incidents as required by supervisory authorities.

7. Protection of Minors

Minors refer to natural persons under the age of 18 unless under this Policy, unless otherwise stipulated by applicable laws. We will protect the privacy and personal data of minors in strict compliance with laws and established practices in the industry. We will only process minors’ data by law and with the explicit consent from their legal guardians.

If you find that we are not processing the personal data of minors according to the above standards, please refer to the “Contact Us” section to notify us.

8. How We Manage Cookies and Similar Technologies

Our websites, mobile apps, online services, emails, and advertisements may use local storage technologies such as cookies, pixel tags, and website beacons.

8.1 Cookies
A cookie is a text-only file stored on computers or mobile devices by network servers. The content of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. Cookies usually contain identifiers, site names, and some numbers and characters.

Cookies are sometimes stored on computers or mobile devices to improve user experience, including:

8.1.1 Login and Verification: With cookies, you can be re-directed from one webpage to another without re-logging on each page, when you log in to our websites with Toptechalliance ID.

8.1.2 Store Your Preferences and Settings: With cookies, our websites are able to save settings, such as the language, font size, and other browsing preferences, and items in your shopping cart on your computers or mobile devices.

8.1.3 Interest-Based Advertising: With cookies, we are able to collect information about your online activities, discover your interests, and deliver to you the most relevant advertisements.

8.1.4 Statistical Analysis: With cookies, we can collect information about your use of our websites and other apps, either for a single visit (using a session cookie) or for repeated visits (using a persistent cookie).

We will not use cookies for any purposes not stated in this Policy. You can manage or delete cookies at your own preference. You can clear all cookies stored on your computer, and most web browsers can be configured to block cookies.

However, if you do clear cookies, you will need to manually change your settings the next time you visit our websites. In addition, blocking cookies may affect your use of all or some features of certain services, which require the use of cookies to function properly.

8.2 Web Beacons and Pixel Tags
In addition to cookies, we and some third parties may also use web beacons and pixel tags on websites. A web beacon is usually an electronic graphic image embedded into a website or email to identify your device cookies when you browse the website or email. Pixel tags allow us to send emails in a way that is readable to you and find out whether an email is opened.

We and some third parties use these technologies for various purposes, including analyzing service usage (together with cookies) and providing more satisfactory content and advertisements to you. For example, when you receive an email from Toptechalliance, it may contain a click-through URL which links to an Toptechalliance web page. If you click the URL, we will track your visit to understand your preferences for products and services and improve customer services. You can unsubscribe from our mailing list at any time if you do not want to be tracked in this manner.

8.3 Other Local Storage
We and some third parties may apply other local storage technologies, for example, local shared object (also called “flash cookie”) and HTML5 local storage, in certain products and services. Similar to cookies, these technologies store information in your device and can record some information about your activities and preferences.

9. How We Store Your Personal Data

We will retain your personal data for no longer than is necessary for the purposes defined in this Statement, and delete or anonymize your personal data after the retention period expires.

Your personal data may be transferred outside of your country or region, as our products and services are provided by service providers worldwide. Although privacy and personal data protection laws and practices vary between countries/regions, we will take corresponding measures to provide the same level protection to your privacy and personal data. For instance, the personal information of data subjects stored in the EU will be governed by standard contractual clauses when the information is transferred to countries or territories that are not recognized by EU but provide the same level of data protection, or we will implement security measures such as data anonymity before the transfers.

10. Contact Us

We have a department (or specialists) dedicated to personal information protection. If you have any questions, comments, or suggestions regarding your personal information, contact us via visiting the Privacy Questions page.
We will reply as soon as possible. If you think that our data processing has infringed upon your legal rights and interests, you have the right to file a complaint with or report to the corresponding regulatory authority.

11. How We Update This Policy

We will update or modify this Policy at our discretion. We will notify you of any changes that may affect your rights and interests under this Policy by posting our notice at a prominent position on the Toptechalliance official website or sending an email to you.