Privacy Policy

Release Date: January 6, 2023

Effective Date: January 6, 2023

Introduction

Beijing LLVision Technology Co., Ltd. and its affiliates (referred to as "LLVision" or "we") attach great importance to your personal information and strive to protect the security and reliability of your personal information. We are committed to maintaining your trust and adhere to principles such as the principle of consistency between rights and responsibilities, clear objectives, choice and consent, minimum necessity, ensuring security, subject participation, openness and transparency, among others, to protect your personal information. Additionally, we use powerful encryption technology to ensure the security of your personal information and have established strict policies to manage all data.

This Privacy Policy ("this Policy") applies to all products and services provided by LLVision, including but not limited to our current mobile applications (apps) developed for Android and iOS systems, collectively referred to as "Translatable App," LLVision-related WeChat public accounts, Translatable website (https://www.llvision.com/), other products or services provided to you, as well as continuously innovated and developed products and services. If you allow us to share information with third parties, you will also be bound by the terms of service and privacy policies of those third parties.

Before accessing or using the products or services provided by LLVision, please carefully read and thoroughly understand the provisions of this Policy regarding how we collect, use, store, share, transfer, or publicly disclose your relevant personal information. Pay special attention to the terms marked in bold, and only use LLVision's products and services after fully understanding, agreeing, and accepting this Policy. If you or your guardian do not agree to any part of this Policy, you should immediately stop using or accessing our products and services. If you have any questions, comments, or suggestions regarding the content of this Policy, you can contact us through the various contact methods provided in Article 10 of this Policy.

Definitions

  1. Personal Information (from GB/T 35273-2020 "Information Security Technology - Personal Information Security Specification"): Refers to various information recorded in electronic or other forms that can identify the personal identity of a natural person independently or in combination with other information or reflect specific activities of a natural person. Personal information includes but is not limited to the individual's name, date of birth, identification number, personal biometric information, address, phone number, etc. For the avoidance of doubt, personal information includes but is not limited to personal sensitive information. The specific types of personal information we collect are described in the following text.

  2. Personal Sensitive Information (from GB/T 35273-2020 "Information Security Technology - Personal Information Security Specification"): Refers to personal information that, once leaked, provided illegally or abused, may harm personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment, etc. Personal sensitive information includes but is not limited to personal financial information, personal health and physiological information, personal biometric information, personal identification information, as well as communication records and content, contact lists, trajectory, precise positioning information, internet browsing records, and other information. The specific types of personal sensitive information we collect are described in the following text.

  3. Device: Device refers to the device used to access the Translatable App and other products and services provided by LLVision, such as smart glasses, laptops, tablets, or smartphones.

  4. Unique Device Identifier: Unique device identifier (exclusive ID or UUID) refers to a string of characters embedded in a device by the manufacturer, which can uniquely identify the corresponding device (IMEI number for mobile devices). Unique device identifiers have various purposes, including providing advertisements when cookies cannot be used.

  5. IP Address: Each device connected to the Internet is assigned a number known as an Internet Protocol (IP) address. These numbers are usually assigned based on geographical regions. IP addresses are typically used to identify the location of a device when connected to the Internet.

  6. SSL: SSL (Secure Socket Layer), also known as Secure Sockets Layer, is a security protocol implemented on the transmission communication protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which achieve the effect of information confidentiality through the use of public key and symmetric key technologies.

  7. Anonymization: Anonymization refers to the technical processing of personal information, making it impossible to identify or associate with the data subject, and the processed information cannot be restored.

  8. De-identification: De-identification refers to the technical processing of personal information, making it impossible to identify or associate with the data subject without additional information.

Contents

  1. How We Collect and Use Your Personal Information

  2. What Information We Collect

  3. How We Use Cookies and Similar Technologies

  4. How We Share, Transfer, and Disclose Your Personal Information

  5. How We Store Your Personal Information

  6. How We Protect the Security of Your Personal Information

  7. How You Can Exercise Your Rights Regarding Your Personal Information

  8. How We Protect the Personal Information of Children

  9. How We Update This Policy

  10. How to Contact Us

  11. Dispute Resolution

1. How We Collect and Use Your Personal Information

Due to the wide range of products and services we provide, we will collect and use your personal information based on the specific scope of services and different functionalities, following the principles of legality, legitimacy, and necessity. You understand and agree that, for the purpose of continuously improving products and services, we may periodically introduce optimized features that may increase or change the scope, purpose, and methods of collecting and using personal information. In this regard, we will provide you with explicit explanations and options to agree or disagree through the update of this Policy, pop-ups, or in-app messages. You have the right to refuse to agree to this Policy (including updates); however, you acknowledge and understand that if you refuse to provide your personal information, or if you refuse our collection and processing of your personal information when it is necessary for the current or updated services or functionalities, we may be unable to provide you with the current or updated services and functionalities, or may not achieve the intended service effects. However, the basic functions you previously used will not be affected.

The main sources of personal information we collect and use from you are: information you provide to LLVision, information we obtain during your use of Translatable App and other products and services provided by LLVision, and information shared by third parties.

2. What Information We Collect

Below, we will inform you of the types of necessary personal information required for each function and prompt you to authorize the permissions when using specific functional scenarios.

(1) Assisting You in Registering and Maintaining Your Account

1. Basic Account Creation

  • When you create an account on Translatable App and/or other products and services provided by LLVision, you need to provide your phone number and set a password within the Translatable App and/or other products and services provided by LLVision. Please note that the matching results of your phone number and verification code are considered your personal sensitive information. We collect this type of information based on the relevant requirements of laws and regulations. If you refuse to provide this information, it may prevent you from registering an account and using the relevant product functions, so please consider carefully before deciding whether to provide it.

2. Profile Maintenance and Account Recovery

  • To maintain your account's basic information and enhance your service experience, you can choose to fill in your personal profile, including your avatar, nickname, birthday, gender, etc. If you choose not to provide this information, it will not affect your use of basic service functions.

  • If you lose your account or it is stolen, you can reset your password through phone verification. If you are unable to reset it through phone verification, you can contact customer service to reset your password. However, during this process, we may require you to provide information such as your frequently used login locations, devices, registration time and city information, registered phone number, and previously used passwords to verify your identity.

(2) Providing Translator and Handwriting Pad Services You can use our provided basic functions, which mainly include translation of voices from different distances and providing a handwriting pad service. To ensure the realization of the above functions and fulfill our network system operation security obligations, we will collect necessary device information from you, assign a unique device identifier to you, and record your operational information based on this identifier, which will be saved in the form of log files. In addition, during your use, we may request access to your storage permissions to record your log information, cache content, etc.

(3) Providing Real-time Voice-to-Text Conversion Services When using the voice dictation, voice transcription, translation, and other services provided by Translatable App and/or other LLVision products and services, we collect and view the voice content you input to achieve the necessary functionality. At the same time, we collect, view, or delete the text information after voice transcription to understand your needs and provide real-time processing and feedback to you. Please be aware that although your voice and text content may contain personal information about you or others, we do not identify individuals based on the content of the personal information involved. We only use string extraction for technical analysis to achieve the voice-to-text function. If you refuse to input the aforementioned information or refuse our collection, viewing, or deletion of the voice content and text information you input, you will be unable to use the complete service mentioned above.

(4) Assisting You in Participating in Platform Operations and Interactive Activities If you participate in operational and interactive activities provided by Translatable App or other products or services provided by LLVision, such as check-ins and surveys, you may need to voluntarily submit the necessary information for participating in the activities. Regarding how such operational activities collect and use your personal information, you can refer to the information collection and usage prompts on the respective H5 pages (including but not limited to feedback, health questionnaires, and operational activity pages).

(5) Providing Additional Services for Your Permission Requests To adapt the product to different hardware devices, ensure the safety of the operating environment, identify abnormal account status, and improve user experience, we may request the following device permissions from you for the additional services we provide. We will only collect your personal information when you use the relevant functions.

  1. Device Information: Depending on your specific operations during the installation and use of Translatable App and/or other products and services provided by LLVision, we will receive and record relevant information about the device you use (including device model, device MAC address, operating system version, device settings, mobile device identification code, network device information, necessary mobile application list information, software and hardware, device environment information, gyroscope sensor, accelerometer sensor) and location-related information (including GPS precise location authorized by you, WLAN access points and base station sensor information).

  2. Log Information: When you use our website or client-provided products or services, we will automatically collect detailed usage information and save it as network logs. Log information includes your IP address, WIFI network, telecommunications network, language used, access date and time, etc.

  3. Album and Storage Permissions: In order to facilitate your sharing and saving of videos and pictures, with your consent, we may access your phone's album and storage permissions. After granting access to the album and storage permissions, your conversation records can be automatically saved locally.

  4. Microphone Permission: With the microphone permission enabled, you can record videos, perform voice recognition, and translate text. Even if you have granted microphone permission, the microphone will remain turned off by default and will only capture voice information when you actively click on the microphone icon or record audio within the app. The voice information we collect is used solely for speech-to-text recognition to provide language training functionality and to optimize and improve the user experience based on the collected voice information.

  5. Information Push and Display: We may collect and use information related to the software and hardware features of your device and device environment, including but not limited to the International Mobile Equipment Identity (IMEI), network device address (MAC), device model, and system

(6) Special Statement on the Collection and Use of Your Personal Information

If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing such personal information to us. If it involves the personal information of children, you must obtain explicit consent from the corresponding guardian before publishing it. In such cases, the guardian has the right to contact us through the methods provided in Article 10 of this Policy and request the correction or deletion of the content related to the personal information of children.

  1. If we use the information for purposes not specified in this Policy or use information collected for specific purposes for other purposes, we will obtain your prior consent.

  2. You understand and acknowledge that we cannot access or use personal information that you provide to external third parties (excluding LLVision affiliated companies) or personal information collected by external third parties through unconventional means (such as maliciously interfering with the data of their series of apps). If we need to indirectly collect (such as sharing, etc.) your personal information from third parties due to business development needs, we will explicitly request the third party to collect personal information with your consent in written form, inform you of the shared information, and obtain your prior confirmation when personal sensitive information is involved. We will also require the third party to commit to the legality and compliance of the personal information sources. If the third party violates the law, we will explicitly request them to assume corresponding legal responsibilities. At the same time, our professional security team will strengthen the security of personal information (including reporting sensitive information, encrypting sensitive information storage, access control). We will use protection measures and measures for indirectly obtained personal information that are no less than those for our own user's personal information.

  3. Exceptions to obtaining authorization and consent You fully understand and agree that we may collect and use your personal information without your authorization and consent in the following circumstances:

    a. It is directly related to our fulfillment of legal obligations as required by laws and regulations.

    b. It is directly related to national security and defense.

    c. It is directly related to public safety, public health, and major public interests.

    d. It is directly related to criminal investigations, prosecutions, trials, and enforcement of judgments.

    e. It is necessary to protect the vital interests of you or other individuals, but it is difficult to obtain your consent.

    f. The personal information involved is voluntarily disclosed by you to the public.

    g. It is collected from legally disclosed information, including legal news reports and government information disclosure channels.

    h. It is necessary for the conclusion and performance of a contract at your request.

    i. It is necessary for the safe and stable operation of the provided products and/or services, such as identifying and handling malfunctions of the products and/or services.

    j. The personal information controller is a news organization, and it is necessary for legitimate news reporting. k. The personal information controller is an academic research institution, and it is necessary for statistics or academic research in the public interest. When providing research or descriptive results externally, the personal information contained in the results will be de-identified.

    l. Other circumstances as stipulated by laws and regulations.

3. How We Use Cookies and Similar Technologies

To provide you with a more convenient browsing experience, when you use our products and services, we may identify your identity through small data files. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively referred to as "Cookies"). We may use cookies to collect some of your personal information, including your login information and your browsing habits on the website. We collect your login information through cookies to protect the security of your information and account, detect cheating, hacking, and fraudulent activities related to our products and services; simplify repetitive operations (such as registration and login), avoid unnecessary server loads, improve service efficiency, and save resources and energy; improve our products and services. We collect information about your browsing habits on the website to facilitate your viewing of usage history, understand how you use our services, and improve the user experience of our products and services, providing reference data for the development of new products or features.

In addition, web pages may often contain electronic images (referred to as "pixel GIF files" or "web beacons"). The use of web beacons can help websites calculate the number of users browsing web pages or access certain cookies. We may collect information about your web browsing activities through web beacons, such as the page addresses you visit, the addresses of the referring pages you previously visited, the time you spend on the page, your browsing environment, and display settings.

Please understand that some of our services can only be implemented through the use of cookies. If your browser or browser add-ons allow it, you can open the browser's settings options, select privacy settings, enable "Do Not Track" or disable cookies, so that your data will not be tracked by us. However, you may not be able to use our related products and services properly or obtain the best service experience through our products and services, and it may also have an impact on the protection of your information and account security.

For detailed information about cookies and instructions on how to set your browser to accept, delete, or disable cookies, please refer to www.allaboutcookies.org.

4. How We Share, Transfer, and Disclose Your Personal Information

(1) Sharing

Except in the following circumstances, we will not share your personal information with any other third party.

Sharing with your explicit consent, authorization, or proactive selection.

  1. Sharing based on legal requirements. We may share your personal information with external parties in accordance with legal and regulatory requirements, litigation and dispute resolution needs, or requests made by administrative and judicial authorities in accordance with the law.

  2. Sharing with affiliated companies. To facilitate us jointly providing services to you based on associated accounts and to protect the personal and property safety of LLVision's affiliated companies or other users or the public, your personal information may be shared with our affiliated companies after obtaining your authorized consent. We will only share the necessary personal information (such as sharing your necessary personal information with affiliated companies to facilitate your use of their products or services).

  3. Sharing with authorized partners. You authorize and agree that we may entrust authorized partners to provide certain services to you or act on our behalf to perform functions. We will only share your information for legitimate, lawful, necessary, specific, and explicit purposes stated in this Policy. Before sharing data, we will assess the data security capabilities and data sharing risks of the authorized partners and bind them through agreements to ensure that they can only access the information necessary to perform their duties, and we will not use your personal information for any other purposes. If the authorized partners use your personal information beyond the shared purposes, we will require them to obtain your explicit consent.

    Currently, our authorized partners include the following types:

  • Authorized partners providing advertising monitoring, data statistics, and data analysis services. In order to maintain/improve our products and services, provide better content to you, and facilitate advertising reach rate and effectiveness statistics and billing, we may access designated partners that provide such services to analyze your use of our services and optimize advertising delivery.

  • Suppliers, service providers, and other partners. We share some personal information with suppliers, service providers, and other partners that support our business to provide technical infrastructure services, analyze user usage patterns, facilitate convenient payment, or conduct academic research and surveys, bug or crash statistics, and improve login experiences.

  • Rest assured that we will not share personal information that can be used to identify or contact you with authorized partners without your explicit consent. We will de-identify personal information that can identify your identity so that authorized partners cannot recognize your specific identity.

    Third-party SDK List The products and services we provide may include third-party SDKs or similar applications. When you use such services provided by third parties on our platform, you agree that they will directly collect and process your information (such as in the form of embedded code, plugins, etc.). Currently, the following third-party SDK services are included in the Translate App:

    SDK Name: iFlytek SDK (Speech Recognition) Service Type: Speech synthesis, speech assessment, camera, photo album, microphone, device storage Third-party Institution: iFlytek Co., Ltd. Privacy Policy Website: https://www.xfyun.cn/doc/policy/privacy.html

    SDK Name: Authing Service Type: User management system - phone number, date of birth, gender, and other personal information Third-party Institution: Beijing Steam Memory Technology Co., Ltd. Privacy Policy Website: https://www.authing.co/privacy-policy.html

    SDK Name: Umeng SDK Service Type: Data collection and management, business monitoring Types of collected personal information: Device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI/ICCID/geolocation, etc.) Third-party Institution: Beijing Rui Xun Ling Tong Technology Co., Ltd. Privacy Policy Link: https://www.umeng.com/page/policy

    The aforementioned collection and processing of information by third parties are subject to the privacy terms of those third parties and are not covered by this policy. To maximize the security of your information, we recommend that you review the privacy terms of any third-party SDK services before using them. To protect your legitimate rights and interests, if you find any risks associated with such SDKs or similar applications, we recommend that you immediately terminate the relevant operations and promptly contact us.

(2) Transfer

We will not transfer your personal information to any company, organization, or individual unless under the following circumstances:

  1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.

  2. In the event of a reorganization, merger, division, acquisition, asset sale, bankruptcy liquidation, or similar circumstances involving LLVision and its affiliated companies, if it involves the transfer of personal information, we will require the transferee to handle and protect the information in the same or higher standards and requirements as stated in this policy. Otherwise, we will require the transferee to seek your consent again.

(3) Public Disclosure

Public disclosure refers to the act of publishing information to the public or unspecified individuals. In addition to necessary disclosures for purposes such as punishment notices for violating accounts, fraud activities, or displaying desensitized information when announcing winners, we will not publicly disclose your personal information. If there is a reasonable justification for the need for public disclosure, we will inform you of the purpose and types of information to be disclosed (including the content of personal sensitive information if applicable) before obtaining your authorized consent for public disclosure, except as otherwise provided by laws and regulations or as otherwise specified in this policy.

For public disclosure of your personal information, we will carefully review its legitimacy, reasonableness, and legality as soon as we receive the disclosure request. We will implement the strictest personal information security protection measures and methods to protect it during and after the disclosure.

(4) Exceptions to Obtaining Prior Consent for Sharing, Transfer, and Public Disclosure of Personal Information

In accordance with relevant laws and regulations, please fully understand and agree that we may share, transfer, or publicly disclose your personal information without obtaining your prior consent in the following circumstances:

  • It is directly related to national security and defense.

  • It is directly related to public safety, public health, and major public interests.

  • It is directly related to criminal investigations, prosecutions, trials, and enforcement of judgments.

  • It is necessary to protect the vital interests of you or other individuals, but it is difficult to obtain your consent.

  • It is personal information voluntarily disclosed by you to the public.

  • It is collected from legally disclosed information, including legal news reports and government information disclosure channels.

  • It is necessary to fulfill other obligations as required by laws and regulations, such as facilitating online intellectual property dispute resolution.

According to legal provisions, when sharing or transferring personal information is processed by technical measures that make it impossible for the data recipient to restore and re-identify specific personal identities, we will not separately notify you or seek your consent again.


5. How We Store Your Personal Information

(1) Storage Location

The personal information we collect and generate during our operation within the territory of the People's Republic of China is stored within China, except in the following circumstances:

  1. When there are explicit provisions in laws and regulations.

  2. If we need to transfer your personal information overseas for the purpose of providing you with certain services or functions, we will obtain your explicit authorization and strictly comply with applicable laws and regulations.

In the above cases, we will ensure sufficient protection of your personal information in accordance with this policy.

(2) Storage Period

We will only retain your personal information for the shortest period necessary to achieve the purposes stated in this policy, unless there is a mandatory retention requirement in laws and regulations. The criteria we use to determine the above retention period mainly include the following, with the longer one prevailing:

  1. Completing the purposes of the relevant services related to you, maintaining corresponding service and business records, and responding to your inquiries or complaints.

  2. Ensuring the security and quality of the services we provide to you.

  3. Whether you agree to a longer retention period.

  4. Other special agreements regarding the retention period. After the retention period for your personal information has expired, we will delete or anonymize your personal information in accordance with applicable laws and regulations.

(3) Deletion and Anonymization

If we decide to cease the operation of the Can Translate app and/or the products and services provided by LLVision Technology, we will stop collecting your personal information after the relevant services cease operation. We will notify you of the cessation of operation by way of announcement. For the personal information we already hold, we will delete or anonymize it unless otherwise required by laws and regulations. If it involves the personal information of children, we will take necessary and reasonable measures to promptly inform the guardians of the children of the cessation of operation.

6. How We Protect the Security of Your Personal Information

To ensure the security of your information, we will use industry-standard security measures to protect the personal information you provide to us, so that your information will not be disclosed, destroyed, or lost. These measures include but are not limited to SSL, encrypted storage of information, and access control to data centers. We also have strict management in place for employees or outsourced personnel who may access your information. This includes different permission controls based on job positions, signing confidentiality agreements, monitoring their operations, and other measures. We will provide appropriate security measures based on existing technologies to protect your information and make every effort to prevent leaks, damages, or losses of your information.

The information you voluntarily share or publicly disclose when using our services may involve personal information or even sensitive personal information of yourself or others, such as profile pictures you upload or pictures containing personal information that you choose to share. Please exercise caution and consider whether it is necessary to share or publicly disclose such information when using our services.

Your accounts have security protection features. Please properly safeguard your account and password information. We will ensure the security of your information by backing up to other servers and encrypting user passwords, among other security measures, to prevent loss, abuse, and tampering.

We have designated a person responsible for the protection of personal information, who is responsible for handling various matters related to user personal information in relation to the Can Translate app and other products and services provided by LianLian Technology. This includes planning and formulating the company's privacy policy, reviewing user agreements for various products, supervising the working principles and information processing mechanisms of various products, and more. We have established an access control mechanism to ensure that only authorized personnel can access personal information.

The server systems where we store user personal information are secured and fortified operating systems. We conduct audits and monitoring of server operations. If we discover security issues with external server operating systems, we will promptly upgrade the server security to ensure the security of all our server systems and applications.

We regularly provide training on personal information protection laws and regulations to our employees to enhance their awareness of protecting user privacy.

We have established an information security incident response plan and allocated sufficient resources to ensure the implementation of the emergency plan. We conduct training and emergency drills on the plan every year. If our physical, technical, or managerial protection measures are unfortunately compromised, we will promptly activate the emergency plan, prevent the escalation of security incidents, report to the competent national authorities in accordance with laws and regulations, and promptly inform you of the basic information, potential impacts, measures already taken, or measures to be taken regarding the security incident through reasonable and effective means such as notifications and announcements.

However, please be aware that the internet is not an absolutely secure environment. Despite the aforementioned security measures, please understand that there is no "perfect security measure" on the internet. Therefore, please safeguard your personal information properly and only provide it to others when necessary. If you discover that your personal information has been leaked, especially if your account and password have been compromised, please contact us immediately so that we can take appropriate measures.

7. How You Can Exercise Your Rights

Regarding Your Personal Information We provide convenient methods for you to access, correct, delete, and withdraw your consent to your account information and other personal information provided when using our services, so that you have the ability to protect your privacy and security. Your rights include:

(1) Access to Your Personal Information

You have the right to access your personal information, subject to exceptions provided by laws and regulations. You can access your personal information through the following methods:

  • If you wish to access or edit your personal profile in your account or change your registered phone number, you can perform such operations through the "Settings" - "Personal Information" section in the Can Translate app. For example, you can add, modify, or delete your avatar, nickname, gender, and other basic information, as well as check and modify your account binding status. If you want to change your account password, you can do so through the "Settings" - "Account Security" section in the Can Translate app.

  • If you are unable to access your personal information through the above methods, you can contact us through the contact information provided in Article 10 of this policy. We will respond to your access request and verify your user identity within fifteen working days.

(2) Correction or Supplement of Your Personal Information

If you discover that the personal information we process about you is incorrect, incomplete, or outdated, you have the right to request us to make corrections or supplements. You can make correction or supplement requests through the methods specified in "(1) Access to Your Personal Information".

If you encounter difficulties in exercising the aforementioned rights or if it is currently not possible to provide you with online self-correction or modification services, we will verify your identity and make corrections or modifications to incorrect or incomplete information, as long as it does not affect the objectivity and accuracy of the information. In specific situations, especially in the case of data errors, you can submit your correction or modification request to us through the contact information provided in Article 10 of this policy, requesting us to correct or modify your data, unless otherwise provided by laws and regulations. However, for security and identification purposes, you may not be able to modify certain initial registration information submitted during registration.

(3) Deletion of Your Personal Information

For certain personal information, you can request its deletion by contacting us through the contact information provided in Article 10 of this policy. Please note that once your personal information is deleted, we will delete or anonymize such information unless otherwise provided by laws and regulations.

You can request the deletion of personal information in the following circumstances, except when it has been anonymized or there are other provisions in laws and regulations:

  1. If our processing of personal information violates laws and regulations.

  2. If we collect and use your personal information without obtaining your consent.

  3. If our processing of personal information violates the agreements with you.

  4. If you no longer use our products or services, or if you voluntarily cancel your account.

  5. If we no longer provide products or services to you.

If we decide to respond to your deletion request, we will also notify the third parties who obtained your personal information from us and request them to delete it in a timely manner, unless otherwise provided by laws and regulations or unless these third parties have obtained your independent authorization.

After you delete information from the products and services we provide, we may not immediately delete the corresponding information from the backup systems, but we will delete such information when the backups are updated.

(4) Right to Withdraw Your Consent to Personal Information

Certain functions of the products and services we provide require the relevant permissions of your device (such as location, camera, microphone, etc., as specified in Article 2 of this policy). You can withdraw (or stop) your ongoing authorization to such permissions at any time. After you update the Can Translate app version and other products and services provided by LLVision Technology, we will not change the permission status you previously set without your explicit consent. For example, you can disable the authorization for access to your phone album by going to "Settings - Privacy - Photos" on your mobile device. You can also withdraw your consent for us to collect your personal information by canceling your account. Please note that once you withdraw your consent, we will no longer be able to provide you with the specific functions and services corresponding to the withdrawn consent. However, your decision to withdraw consent will not affect the processing of personal information based on your previous consent.

(5) Account Cancellation

You can cancel your previously registered account at any time. You can do this by accessing the "Settings" - "Account Security" - "Cancellation" section in the Can Translate app and following the instructions to cancel your account.

If you are unable to cancel your account through the above method, you can contact us through the contact information provided in Article 10 of this policy to request the cancellation of your account. After verifying your identity within fifteen working days, we will release your phone number, effectively canceling your account.

Once you voluntarily cancel your account, we will cease to provide products or services to you. We will delete your personal information in accordance with applicable laws and regulations or anonymize it, unless otherwise provided by laws and regulations.

(6) Disabling Push Notifications

You can choose whether to receive information push notifications through the "Settings - Notifications" option on your mobile device.

(7) Complaints

You have the right to file a complaint regarding the processing of your personal information by contacting us through the contact information provided in Article 10 of this policy. We will respond to your complaint within fifteen working days from the date of receipt. If you are not satisfied with our response, especially if our handling of personal information has harmed your legitimate rights and interests, you may also file a complaint or report with regulatory authorities such as the cyberspace administration, public security bureau, and industrial and commercial bureau, or file a lawsuit with a competent court. However, we hope that you will first contact us regarding the relevant issues.

(8) Responding to Your Requests

To ensure security, you may need to provide a written request or other means to prove your identity. We may request you to verify your identity before processing your request.

We generally do not charge a fee for your reasonable requests. However, for repeated requests beyond a reasonable limit, we may charge a certain cost. We may also refuse requests that are repetitive without cause, require excessive technical means (such as the development of new systems or fundamental changes to current management), pose risks to the legitimate rights and interests of others, or are highly impractical.

In addition, we may not be able to respond to your requests in the following situations:

  • Those related to our fulfillment of legal obligations.

  • Those directly related to national security and defense.

  • Those directly related to public safety, public health, and significant public interests.

  • Those directly related to criminal investigation, prosecution, trial, and execution of judgments.

  • Those where we have sufficient evidence to demonstrate subjective malice or abuse of rights by the subject of personal information.

  • Those that are difficult to obtain consent for but are necessary to protect your or other individuals' vital interests such as life and property.

  • Those that would cause significant harm to your or other individuals' legitimate rights and interests.

  • Those involving trade secrets.

  • Other circumstances as provided by laws and regulations.

(8) How We Handle Personal Information of Minors

We attach great importance to the protection of personal information of minors. Our products and services are primarily aimed at adults, and we do not intentionally collect personal information of individuals defined as minors under relevant laws and regulations. If you are a parent or guardian of a minor and you become aware that the minor under your guardianship has used our services without your authorization and consent, please contact us through the contact information provided in this statement. If we discover that we have collected personal information of a minor without prior verifiable parental consent, we will promptly delete the relevant data.

(9) How We Update This Policy

We may modify or update this policy from time to time. After the modification or update, we will announce the revised content on relevant pages or through other appropriate means. If you do not agree to the modified policy, please immediately stop using the Can Translate app and/or other products and services provided by us. If you continue to access or use the Can Translate app and/or other products and services after the modification of this policy, it indicates that you agree to be bound by the updated privacy policy and related policies.

Without your explicit consent, we will not limit your rights as stipulated in this policy. For significant changes, we will also provide more prominent notices (including announcements, notifications, or pop-up windows) as appropriate.

Significant changes referred to in this policy include, but are not limited to:

  1. Significant changes in our service mode, such as the purpose of personal information processing, types of personal information processed, and methods of using personal information.

  2. Significant changes in our control, such as changes in ownership due to mergers or reorganizations.

  3. Major changes in the main entities with whom we share, transfer, or publicly disclose personal information.

  4. Significant changes in your rights to participate in the processing of personal information and how to exercise them.

  5. Changes in the department responsible for the security of personal information, contact information, and complaint channels when handling personal information security impact assessments.

  6. Personal information security impact assessment reports indicating high risks.

It is important to note that this policy does not apply to other third-party services provided to you. For example, services provided by third parties linked through the Can Translate app. While we make reasonable efforts to urge these third parties to protect your personal information, you understand that these services are independently provided to you by third parties, and they will be responsible for the processing of your personal information in accordance with their own privacy policies or user agreements.

(10) How to Contact Us

If you have any questions or suggestions regarding this policy or your personal information in the process of using the Can Translate app and/or other products and services provided by us, you can contact us through the following methods: Customer service phone: +86-400-0525-102 for online consultations. Email: service@llvision.com. Mailing address: 3rd Floor, B12C, Hengtong International Business Park, No. 10 Jiuxianqiao Road, Chaoyang District, Beijing, Postal Code: 100123.

We will promptly verify the requester's identity and review the relevant issues, and respond to you within fifteen working days after verifying your user identity.

(11) Dispute Resolution

Any disputes or controversies between users and LianLian Technology arising from this policy shall first be resolved through friendly consultation. If the consultation fails, the user hereby agrees to submit the dispute or controversy to the people's court with jurisdiction at the domicile of LianLian Technology for litigation resolution.