Chinese Roaming Privacy Policy

Last Updated: May 30, 2024

This Privacy Policy applies to EU users and users from other regions worldwide. Please read carefully and ensure you understand all contents of this policy.

I. Introduction and Data Controller Information

Chinese Roaming [Changsha Zhongyu Network Technology Co., Ltd.] (hereinafter referred to as "we" or "us") recognizes the importance of personal information to you. We will take appropriate protection measures in accordance with legal requirements to protect your personal information security.

II. Scope of Application

This policy applies to:

Mainland China users (under Personal Information Protection Law)
EU users (under GDPR)
Users from other regions (following local privacy regulations)

III. Information We Collect and Use

3.1 Basic Information Collection

Device Information: device model, operating system version, device settings, application software list
Log Information: operation time, operation type, IP address
Service Records: usage records, learning data, preference settings
Payment Information: transaction records (if applicable)

3.2 Purposes of Information Use

Providing core service functions
Improving products and services
Ensuring account security
Customer support services
Fulfilling legal obligations

IV. Legal Basis for Processing (for EU Users)

Under GDPR, we process your personal data based on the following legal grounds:

Contractual Necessity: to provide services you request
Legal Obligation: to comply with applicable laws and regulations
Your Explicit Consent: when processing requires your consent
Legitimate Interests: for reasonable purposes such as service improvement and fraud prevention

V. Data Storage and Transfer

5.1 Data Storage Location

We primarily store and process data within mainland China. For EU users' data, we ensure:

Implementation of Standard Contractual Clauses for cross-border transfers
Implementation of adequate data protection measures
Compliance with GDPR requirements on data transfers

5.2 Data Retention Period

We retain your personal data only for:

The duration of account existence
The period necessary for service provision
The period required by laws and regulations

VI. Your Rights

You have the following rights:

Right of Access: to obtain your personal data we hold
Right to Rectification: to request correction of inaccurate personal data
Right to Erasure: to request deletion of personal data in specific circumstances

VII. Special Provisions for Minors Protection

As our services are directed at children:

Parental consent required for users under 13 (under 16 in EU)
Special data protection measures implemented
Limited scope of information collection from minors
Transparency in information usage

VIII. Security Measures

We protect your data through:

Data encryption in transit and at rest
Access control and authentication mechanisms
Regular security assessments
Staff training and confidentiality agreements

IX. Cookies and Similar Technologies

We use cookies and similar technologies for:

Essential cookies: ensuring basic website functionality
Analytics cookies: improving user experience
You can control cookies through browser settings

X. Policy Updates

We may update this Privacy Policy. Updates will be published in the APP and take effect 7 days later. Significant changes will be specially notified.

XI. Contact Us

For any questions, please contact:

Email: service@manyfish.top
Address: Room 1826, Tuhong Building, 1250 Xiangxiang North Road Section 3, Yuelu District, Changsha, Hunan Province

Changsha Zhongyu Network Technology Co., Ltd.
May 30, 2024