Privacy Policy for OTA System Update Service

Introduction

This Privacy Policy is formulated by Shenzhen Huanle Technology Co., Ltd. (hereinafter referred to as “the Company”, “we” or “us”) to explain how our OTA system update product (the “Service”) collects, uses, stores, shares and protects your personal information when providing device system detection, version updates, firmware upgrades and performance optimisation, and to describe the rights you enjoy.

Please read and fully understand this Policy before using the Service. By enabling or using the Service, you acknowledge that you have read, understood and agreed to all terms of this Policy. If you do not agree with any part of it, please stop using the Service immediately.

1. Information We Collect

To keep the OTA update service running, match upgrade resources accurately, fix system vulnerabilities, troubleshoot device faults and safeguard update security, we strictly follow the principle of minimum necessity and collect and use only the information necessary for the Service. Information is collected either locally on the device or passively on the server side, as detailed below:

1. Unique device identifiers and basic hardware information: device model, unique device identifier (Device ID / IMEI / MAC address), hardware serial number, hardware parameters, device configuration and manufacturer information — used to identify your device accurately and match the dedicated firmware and installation package, thereby avoiding compatibility errors during updates.
2. System version and update configuration information: current system version, firmware version, kernel version, installed module versions, your update preferences (automatic / scheduled / manual update) and update switch settings — used to determine update requirements and push compatible versions.
3. Update service and device diagnostic logs: update detection records, download progress and status, installation logs, failure codes, system diagnostic logs, module update records and service interaction logs — used to troubleshoot update anomalies, fix vulnerabilities and keep the update process secure and stable.
4. Network and access information: connection type, mobile carrier, network access status, network node information and network environment parameters — used solely to ensure stable download of update files and to support resumable transfers, preventing failures caused by network anomalies.
5. Server-side statistical and diagnostic data: to continuously improve service stability and resolve common issues across devices, our servers automatically collect anonymised update statistics, service access requests, feature usage rates and crash diagnostics. Such data is de-identified and anonymised and cannot be linked to any individual user, and is used only for product analysis and service optimisation.
6. Firmware and module verification information: update package checksums, firmware compatibility verification data and module update verification logs — used to verify update file integrity, prevent malicious firmware injection and safeguard device update security.

2. How We Use Your Information

The information we collect is used only for the following lawful, legitimate and necessary purposes, and will not be used for any unauthorised commercial or other purpose:

1. Matching the system update package and firmware resources that fit your device, and pushing compliant and compatible version updates;
2. Detecting device system status, troubleshooting update anomalies and faults, and completing fixes and service optimisation;
3. Compiling service operation statistics to optimise the update process, improve download and installation stability, and continuously enhance product experience;
4. Complying with applicable laws, regulations and regulatory requirements, including compliant data retention and industry filings.

3. Storage and Protection of Information

1. Retention period: We retain your device information and service logs only for the period necessary for the Service. When the update service ends or the information is no longer necessary, the data will be automatically de-identified or deleted. Where laws and regulations require mandatory retention, we will retain it strictly for the statutory period.
2. Storage method: Relevant information is stored in encrypted form on compliant servers, protected by multiple technical and organisational measures including hierarchical access control, data masking and full-process security auditing, so as to fully protect the security of your device information.
3. Security safeguards: We continuously improve our security mechanisms to prevent leakage, tampering, loss and misuse of data. If a personal information security incident occurs or may occur, we will activate our emergency plan in accordance with the law and fulfil our notification and reporting obligations in a timely manner.

4. Sharing, Transfer and Disclosure

We do not sell, rent or share your personal information with any third party. We will not provide your information to any third party without your prior explicit authorisation, except in the following statutory circumstances:

1. Where disclosure is required by laws and regulations, or by judicial or administrative authorities in accordance with statutory procedures;
2. Where disclosure is necessary in an emergency to protect the life or property of you or other users, or to safeguard public interests;
3. Where you have voluntarily and explicitly authorised a legitimate third-party service scenario.

In the above circumstances, we will strictly require the recipient to observe confidentiality obligations and data processing restrictions, and to use the relevant information only within the authorised scope.

5. Your Rights

You enjoy the following rights regarding your device-related information: the right to know, the right to access and copy, the right to rectification, the right to deletion and the right to withdraw authorisation.

1. You may view the information collection and use rules of the Service at any time in your device settings or the APP settings page;
2. You may stop further information collection by turning off automatic OTA updates or disabling the update detection permission;
3. To access, copy, correct or delete device service data retained by us, you may submit a request through the in-product customer service or our official contact channel, and we will handle it promptly after verifying your identity;
4. You may withdraw any authorisation you have granted at any time. After withdrawal, we will stop collecting and using the corresponding information (withdrawal does not affect processing already carried out on the basis of the authorisation before withdrawal).

6. Protection of Minors

The Service is open to users of all ages. If you are a minor (in particular a child under the age of 14), please read this Policy and use the Service under the guidance and supervision of a guardian. We do not proactively collect sensitive personal information of minors; if such information is collected inadvertently, we will delete it completely at the earliest opportunity.

7. Updates to This Policy

We may revise this Privacy Policy from time to time in response to product iteration, business adjustments, and changes in laws and regulatory requirements. After an update, we will proactively notify you through in-APP pop-ups, page announcements or similar means. The updated Policy takes effect on the date of publication. Where the update involves material changes such as the scope of information collected or the purposes of use, we will obtain your explicit consent again. Your continued use of the Service constitutes acceptance of all updated terms.

8. Contact Us

If you have any questions, suggestions or complaints regarding this Privacy Policy, please contact us through our official customer service channel. We will verify, handle and respond to your request in a timely manner.