Update date: [8] month [20] day of [2024]

Effective Date: [August] [15], [2024]

GemNearby products and/or services are provided by Shenzhen Zhangxun Technology Co., Ltd. (registered address and contact address: 2602 Jinzhan Jewelry Plaza, No. 20 Shuibei 1st Road, Shuibei Community, Cuizhu Street, Luohu District, Shenzhen) and its affiliated company (hereinafter referred to as "us") as co-processors. We provide network-based marketing services for gemstone merchants through GemNearby App, GemNearby website (https://GemNearby.com/) and through other client ends (hereinafter collectively referred to as "GemNearby products and/or services" or "GemNearby"), and are committed to helping users (hereinafter referred to as "you") expand their contacts in the gemstone industry.

As an operator of GemNearby products and/or services, we are well aware of the importance of personal information to you. We have formulated the GemNearby Privacy Policy (hereinafter referred to as "this policy") in accordance with the cyber security law of the People's Republic of China, the personal information protection law of the People's Republic of China, the data security law of the People's Republic of China, and the provisions on the scope of necessary personal information for common types of mobile internet applications. Your trust is very important to us, we promise to take appropriate security measures in accordance with the requirements of laws and regulations, and try our best to protect your personal information security controllable.

Before using GemNearby products and/or services, please be sure to read and thoroughly understand this policy, and start using the relevant products or services after confirming that you fully understand and agree. We will introduce to you how we handle personal information in different scenarios through this Privacy Policy. When you log in or use GemNearby, we will process relevant information for the implementation of the functions and services you choose to use, or to comply with laws and regulations. In addition to the information required for the implementation of the basic functions and services of GemNearby products and/or services, and the information required by laws and regulations, you can reject our processing of other information, but this may lead to our inability to provide the corresponding GemNearby products and/or services. We will explain the relevant situation item by item in this policy. The key content of your personal information rights and interests has been marked in bold. At the same time, for personal sensitive information, we use "bold italics" to write special reminders. We hope you will pay special attention when reading. The implementation methods of your personal information rights include but are not limited to accessing or correcting, deleting, deleting accounts, rejecting pushes, and getting timely responses to ensure your implementation of control over your personal information.

We have formulated this Privacy Policy and specifically remind: We hope that you will carefully read and understand this Privacy Policy before using GemNearby and related services in order to make appropriate choices. By clicking Agree, you indicate that you have fully understood and agreed to this policy. We will process your personal information strictly in accordance with this policy and your consent. If you do not agree to this policy, you should stop using GemNearby products and/or services. If you have any questions, comments or suggestions about the content of this policy, please contact us in time through the contact information provided in Section 10 of this policy.

The first part, Definition

GemNearby, GemNearby products and/or services: refers to the products and/or services provided to users by various product carriers such as the client end application (App) labeled "GemNearby" and the official website (https://GemNearby.com/) of GemNearby, which are legally owned and operated by Shenzhen Zhangxun Technology Co., Ltd. and its affiliates.

GemNearby Service Provider: Shenzhen Zhangxun Technology Co., Ltd. and affiliated companies are the network and software technology service providers of GemNearby.

Affiliated company: Affiliated company refers to Shenzhen Palm Search Technology Co., Ltd. and other units or collective names that have a related relationship with Shenzhen Palm Search Technology Co., Ltd. "Affiliated relationship" refers to any subject (including individuals, companies, partnerships, organizations or any other entities), that is, the subject directly or indirectly controlled by it, or the subject directly or indirectly controlled by the same subject. The aforementioned "control" refers to, through voting rights, contracts or other means, directly or indirectly have the right to instruct or instruct others to instruct the management and decisions of the relevant subject or other relationships that in fact constitute actual control.

Personal information refers to all kinds of information related to an identified or identifiable natural person recorded electronically or otherwise, including but not limited to the natural person's name, date of birth, identification document number, personal biometric information, address, telephone number, excluding information after annonymization.

Sensitive personal information refers to personal information that, once leaked or illegally used, could easily violate the personal dignity of natural persons or endanger personal and property safety, including biometrics, religious beliefs, specific identities, medical and health care, financial accounts, and whereabouts, as well as personal information of minors under the age of 14.

Log information: refers to your operation time and IP address information when using GemNearby.

Device information: refers to the device parameters and system information (device type, device model, operating system) when you use GemNearby.

Unless otherwise agreed, the definitions used in this policy shall have the same meaning as those in the GemNearby Service Agreement.

Part II Privacy Policy

This policy will help you understand the following:

How we collect and use personal information

How we entrust, share, transfer and publicly disclose personal information

III. How do we store personal information?

How we protect personal information security

V. How do you manage your personal information?

How do we handle information about minors?

Privacy Policy applicable range

Revisions and Updates to the Privacy Policy

Nine, how to contact us

Dispute Resolution

How we collect and use personal information

We will follow the principles of legitimacy, legality and necessity, and collect and use personal information that you voluntarily provide during the use of the service or arising from the use of GemNearby for the following purposes described in this policy. If we want to use your personal information for other purposes not specified in this policy, or use the collected information for other purposes based on specific purposes, we will inform you in a reasonable manner and obtain your consent again.

If you have questions about the concepts in the following, please refer to Part 1 of this Policy Definitions and delineations.

When you use GemNearby products and/or services, we need/may need to collect and use your personal information, including the following two:

For the implementation of the basic business functions of providing you with GemNearby products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use GemNearby products and/or services normally;

For the implementation of the extended business functions of providing you with GemNearby products and/or services, you can choose to authorize us to collect and use the information. If you refuse to provide it, you will not be able to use the relevant extended business functions normally or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic business functions of GemNearby products and/or services.

Since the products and/or services we provide to you are constantly updated, if a product or service is not described in the foregoing and collects your information, we will separately explain the content of information collection to you through page prompts, interactive processes, website announcements, etc., to obtain your individual consent. This description forms part of this policy, and this information is subject to the provisions of this policy.

(1) The basic business functions and required information involved in GemNearby's products and/or services

GemNearby's basic function service is "Gem Industry Merchant Network", and the necessary personal information under this function is "registered user mobile phone number".

1. Registration and login GemNearby

We provide you with services through GemNearby products and/or services. To use our services, you need to create an account with your mobile phone number to become a registered user. When you register and log in to your GemNearby account, we will verify your identity by sending the verification code or you pre-fill the password. If you refuse to provide your mobile number, you will not be able to register or use other functions.

Unless otherwise specified, the products and/or services of all related versions of GemNearby use a unified account service, and the related versions include but are not limited to the "GemNearby" APP and other versions launched by us.

You can use your GemNearby account to conveniently log in and use each associated version of GemNearby to use the corresponding version of the service or function. In order to provide a consistent service experience in each associated version of GemNearby, we use the SDK or related technologies to sync up the accounts and content in the GemNearby APP and associated versions, including: sync up your authorized information.

2. Content browsing

As you browse GemNearby content, we will record your usage. If you don't have a login account, you will no longer be able to use GemNearby. If you logged in, we will record your actions through your GemNearby account.

3. Information release

You can post text, pictures, voice and video messages on GemNearby, and we will ask you to authorize the camera, voice and photo album according to the type of information you post. If you reject the authorization, you will not be able to use the functions of shooting and publishing relevant class information, but it will not affect your use of other functions of GemNearby.

Your avatar, nickname and other information will be displayed in the content you publish. You can click on your avatar when publishing content to choose whether to display your profile page nickname and avatar, or your nickname and avatar, and whether to display company and job information for content publishing. If you choose to display the nickname and avatar of your profile page, other users can browse your profile page and contact you in-app by clicking on your avatar when browsing the content you publish.

4. Gem industry network interaction

In order to facilitate the merchant's understanding of you and help you understand more efficient and valuable procurement and marketing information based on the network of contacts, you need to improve the intention of brand categories and other information.

If you do not provide this information, you may not be able to use the relevant functions, but it will not affect your normal use of other functions and services.

(2) Extended business functions and required information related to GemNearby's products and/or services

When you actively use the following functions, we will collect the listed information. If you refuse to provide the following information, it will not affect your normal use of the basic business functions of GemNearby products and/or services, but we cannot provide you with the corresponding specific products and/or services.

1. Public profile page

We will generate your GemNearby profile page according to the information you filled in when registering. You can enter the profile page by clicking on the avatar or user name through "I" according to your own needs, and fill in and modify the profile page information according to the page prompts, including your avatar, name, region, and intended brand category.

You can apply for GemNearby authentication. After we review the authentication materials you provide, we will complete the authentication of the corresponding identity experience for you. The authentication mark and verification information will be publicly displayed on your profile page.

The profile page information you fill in and your certification mark and verification information will be publicly displayed on your GemNearby homepage.

2. Add friends

You can add friends by browsing under the "Home" page.

When you add or remove friends from GemNearby, we create/adjust your friend list. You can view and manage your friend list in "Address Book".

3. User interaction

When you interact with other users, in order to maintain the stability of the service, we may collect your interaction information and your avatar, profile page nickname and verification information.

If you visit another user's profile page and browse other users' content, we will record your interactions.

4. In-app screening

To provide you with search functionality (including contacts), we use the nationality and intended brand categories you provide to us.

5. Identity authentication

When you apply for GemNearby authentication (including identity authentication, merchant authentication, and other authentication types we add from time to time), we will collect your personal information in the following scenarios.

In order to verify your real-name identity, we will collect your name and identity documents (including identification card number/Hong Kong, Macao and Taiwan pass/passport number) based on your individual consent. At the same time, to confirm that the aforementioned information you upload is your own information, we will also perform facial recognition based on your individual consent. For details on processing face information, please refer to the "GemNearby integration's third-party SDK directory". If you have any objection to the result of machine moderation, you can also choose to contact human customer service to complete the authentication by proactively providing a photo of your ID.

We will protect your personal information to the greatest extent possible. If you do not provide this information, we will not be able to provide relevant services, but it will not affect your normal use of other functions and services.

You understand and agree that, based on your individual consent, when you apply for certification as a merchant, when you have been certified as a merchant and the company questions your certification identity or when GemNearby regularly evaluates the certification account, in order to verify whether your certification application is true and valid, we may provide your mobile phone number and/or business email address to the company you applied for certification under the premise of data encryption to verify whether your information is included in its employee information database. If the verification result is no, GemNearby has the right to ask you to further provide certification application materials or reject all or part of the certification services for you.

6. Ensure operational safety

In order to ensure the safe operation of software and services, the quality and efficiency of operation, we will collect your device type, device model, operating system and device network environment information (IP address), software version number. To prevent malicious programs and ensure the quality and efficiency of operation, we will also collect software crashes, operation logs, performance data and application sources. We may also use your account info, mobile number, device information, service log information and information that our affiliates and partners can share when authorized by you or in accordance with the law to judge account security, conduct identity authentication, detect and prevent security incidents.

7. Information you or other users comment and post

You or other users may provide or post information related to you or other users when using our services (including articles, events, comments or pictures, videos posted by you or other users). When you provide or post information about other users to us, please ensure that you have obtained legal authorization.

8. Customer service communication

If you apply to the customer service center to change the bound mobile phone number, you may need to provide us with the original registered mobile number, the new bound mobile phone number and related information. If you refuse to provide this information, we will not be able to provide you with the service, but it will not affect your use of other functions of GemNearby products and/or services.

When you contact us for help through customer service channels, in order to help you solve problems and improve the quality of service, we may collect and save your name, identification card number, company, job information, contact information to verify your identity information, as well as your communication/call records with us and related content (including account information, inquiry information, other information you provide to prove relevant facts, or contact information you leave).

9. Information obtained from third-party partners

In order to analyze the need for statistical metrics such as application addition, activation, retention, and performance, based on your individual consent, we may obtain information generated or shared by you when using third-party partner services, including device information and operation behavior log information. Please read the user agreement or Privacy Policy of third-party partner services carefully. In addition, we will strictly abide by relevant laws and regulations, and require third-party to guarantee the legality of the information it provides.

Third-party login: When you use the third-party applet login GemNearby (including WeChat login GemNearby), with your authorization, we will obtain your third-party nickname, avatar, and region information from the third-party. Please be aware that we will not share your personal information with these developers and operators without your individual consent. When you use the applet, the applet may use the relevant system permissions authorized by you, and you can withdraw such authorization in the corresponding applet. For details on the types of personal information collected by our partners and the purpose of collection, please refer to the "Third-party SDK Catalog of GemNearby integration".

10, message notification

You acknowledge and agree that we may send you one or more types of notifications at the same time through the contact information (such as phone number, email) you provide in the process of using the product and/or service, such as message notification, identity authentication, security verification, user experience research. But please rest assured that if you do not want to accept this information, you can unsubscribe according to the instructions in the text message, email or phone call.

We will push your friend's messages to you through the system notification of your device, and you can choose to turn off the notification function of GemNearby in your device.

(3) The system permissions called by GemnearbyApp

In order to provide you with GemNearby products and/or services, we may need to use the system permissions in your device to collect relevant personal information. This section will summarize all the system permissions we use to facilitate a more systematic, complete and transparent presentation to you. You can choose whether to authorize us to use the relevant permissions of your device.

iOS operating system application access list

This content is temporarily unavailable outside of Feishu Docs

Android operating system application access list

This content is temporarily unavailable outside of Feishu Docs

(4) Other legitimate reasons other than consent accidents

According to relevant laws and regulations, in the following circumstances, we may collect and use some necessary personal information without your authorization and consent:

1. It is necessary for the conclusion and performance of a contract to which the individual is a party.

2. Necessary for the performance of statutory duties or obligations.

3. It is necessary to respond to public health emergencies or to protect the lives, health and property of natural persons in emergencies.

4. Carry out acts such as coverage and public opinion supervision for the public interest, and process personal information within a reasonable range;

5. In accordance with the provisions of the Personal Information Protection Law of the People's Republic of China, handle personal information disclosed by individuals or other personal information that has been lawfully disclosed within a reasonable range.

6. Directly related to national security and national defense security.

7. Those directly related to public safety, public health, and major public interests.

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

9. It is in a position to safeguard the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain their authorization and consent.

10. The personal information involved is disclosed to the public by the subject of personal information.

11. Collecting personal information from legally disclosed information, such as legal coverage, government information disclosure and other channels;

12. It is necessary to maintain the safe and stable operation of the products or services provided, such as detecting and dealing with product or service failures.

13. Other circumstances stipulated by laws and administrative regulations.

Please understand that the functions and services we provide to you are constantly updated and developed. If a certain function or service is not in the foregoing description and collects your information, we will explain the content, scope and purpose of information collection to you separately through page prompts, etc., to obtain your individual consent. This description forms part of this policy, and the newly collected information is subject to the provisions of this policy.

How we entrust, share, transfer and publicly disclose personal information

(A) entrusted processing

In order to provide you with better and better quality products and/or services, certain features may be provided by our service partners (such as our third-party service providers, contractors, agents, etc.), and we will entrust our service partners to process certain of your personal information on our behalf.

We will sign confidentiality agreements or DPA (data processing agreements) with companies, organizations and individuals who accept our trust to process your personal information, clarifying the responsibilities, processing items and processing purposes of both parties, and requiring them to process personal information only in accordance with our requirements, this policy and relevant confidentiality and security measures.

At present, our commissioned partners include the following types:

1. Security

We attach great importance to account, service and content safety. In order to protect the account and property security of you and other users, so that you and our legitimate rights and interests are protected from illegal infringement, we and affiliated parties or service providers may collect your device information, account number, company, position and log information.

2, push notification

In order to use the end point model adaptability push notification function with you, we may share the phone model, version and related device information (including device identifier, device parameters and system information, device network environment information) with end point device manufacturers and third-party service providers (Huawei, Xiaomi, OPPO, VIVO, Meizu, etc.) through SDK and other technologies.

3, real name authentication audit service

When you perform real name authentication, based on your individual consent, we will share your facial recognition information, personal identification card information, and company name information with the third-party audit service provider (Tencent Cloud) to complete the authority identification.

4. Information audit services

When you perform the information release function, based on your individual consent, we will share the information you publish with the third-party review service provider (Tencent Cloud) to complete the information review service.

5. Cloud data as a Service

In order to improve the performance of the image processing, audio & video transcoding service, we may share the relevant image, audio & video information you publish with the designated partner (Tencent Cloud) who provides the service.

6. Marketing gift delivery

If you participate in GemNearby's marketing activities and win relevant gifts, we will share your name, mobile number and mailing address with the logistics service provider (SF Express) in order to send the gift to you; if you refuse to provide this information, we will not be able to send you the gift.

(2) Sharing

In order to provide you with related services of GemNearby, ensure the stable operation of GemNearby and other reasonable purposes, we may share your personal information with other personal information processors under certain circumstances and obtain your individual consent. For third-parties with whom we share personal information, we will evaluate the legality, legitimacy and necessity of collecting information, investigate their data security environment, and require them to process personal information in accordance with the requirements of this policy and applicable data protection laws. At the same time, we will agree with authorized partners to strict data protection measures, so that they handle your personal information in accordance with relevant confidentiality and security measures.

At present, our partners involved in information sharing include the following types:

1. Payment

The payment function is provided to you by the third-party payment institution that cooperates with us. Based on your individual consent, the third-party payment institution may need to collect your name, bank card type and card number, valid period and mobile number. bank account number, valid period and mobile number, these information are necessary information for the payment function. Refusing to provide it will prevent you from using the function, but will not affect the normal use of other functions. Third-party payment institutions include Yibao Technology Co., Ltd. (referred to as "Yibao Pay"), Alipay, WeChat Pay to provide services to you. When you pay with GemNearby, the aforementioned third-party payment institutions will collect your relevant information to provide you with payment services in accordance with laws and regulations. For further information on the Privacy Policy of the payment function, you can further consult the relevant Privacy Policy of Alipay and WeChat Pay.

2. Gem industry network

To help you find your gem industry contacts, with your individual consent, we will share your name, location, and brand category preferences with merchants so that merchants can contact you and sell.

Please note that GemNearby may choose to use some of its partners or change partners at different times, so the partners in the list may be adjusted. The third-party SDK may change the data processing type due to its version upgrade, policy adjustment, etc. Please refer to its official instructions.

(III) Transfer

In principle, we will not transfer control of your personal information to other companies, organizations or individuals. In the event of a merger, acquisition or asset transfer, your personal information may be transferred as a result. Before the above change occurs, we will inform you of the recipient's name or name and contact information, and require the information recipient to continue to protect your personal information in accordance with the security standards required by this policy, otherwise we will require the information recipient to obtain your consent.

(4) publicly disclosed

We will not disclose your personal information publicly except with your individual consent.

Special Note: In the process of using GemNearby, the personal information you actively share and share is not restricted by this policy (such as reposting content to other Internet platforms). You should note that any information you share can be read, collected and used by any third-party. Please carefully consider the content you post and disseminate through GemNearby and the information that may refer to you personally. You fully understand that when you make a self-disclosure, as long as you do not delete your publicly posted information, the information may remain in the public domain; in some cases, even if you delete your publicly posted information, such information may still be independently cached, copied or stored by other users or third-parties not associated with and controlled by GemNearby, or saved in the public domain by other users or third-parties. For example, when you forward your published information on GemNearby to other Internet platforms, the platform will independently display, cache or save your forwarded content, and other Internet users will also forward and save your answers, and the corresponding page will not be controlled by GemNearby.

(5) Sharing, transferring or publicly disclosing personal information without prior consent

In the following circumstances, we may share, transfer, or publicly disclose personal information without your prior authorization:

1. Relevant to our fulfillment of legal obligations;

2. Directly related to national security and national defense security.

3. Those directly related to public safety, public health, and major public interests.

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

5. To safeguard your or other individuals' significant legitimate rights and interests in life and property, but it is difficult to obtain my authorization and consent.

6. Personal information that you disclose to the public by yourself.

(7) Collecting personal information from legally disclosed information, such as legal coverage and government information disclosure channels.

III. How do we store personal information?

(1) Where the information is stored

We store your personal information collected and generated during our operations in the People's Republic of China in accordance with laws and regulations.

(2) Period of information storage

We will take reasonable and feasible measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purpose stated in this policy, unless there is a mandatory retention requirement by law. The E-commerce Law of the People's Republic of China requires that product and service information and transaction information be kept for not less than three years from the date of completion of the transaction. The Cyber Security Law of the People's Republic of China requires that technical measures be taken to monitor and record network operation state and cyber security incidents, and to keep relevant network logs for not less than six months in accordance with regulations. Our criteria for judging the aforementioned period include:

(1) Complete the transaction purposes related to you, maintain corresponding transaction and business records, and respond to your possible inquiries or complaints.

(2) To ensure the safety and quality of the services we provide to you.

(3) Whether you agree to a longer retention period;

(4) Whether there is any other special agreement on the retention period.

After your personal information exceeds the retention period, we will delete or annonymize your personal information as required by applicable law.

How we protect personal information security

Technical measures and data security measures

In order to protect your information security, we have taken reasonable and feasible security measures (such as SSL/TLS encrypted transmission, encrypted storage, annonymization, etc.) to protect your information and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information.

(2) Safety certification

We guarantee the security of the entire system from multiple dimensions such as organization building, system design, personnel management, and product technology.

(III) Guarantee of the terms of the cooperation agreement

Before we collect your personal information indirectly from a third-party, we will explicitly require the third-party to collect and process your personal information in writing (e.g. cooperation agreement, commitment letter) after obtaining your express consent, and require the third-party to make a commitment to the legality and compliance of the source of personal information. If the third-party violates the law, we will explicitly require the other party to bear the corresponding legal responsibility.

Before we share your personal information with our business partners, we obtain your individual consent and strictly require the partners to assume information protection obligations and responsibilities. To this end, we will require the partners to sign a DPA (data processing agreement) before cooperation or set out the terms of data protection in the cooperation agreement signed by both parties. The agreement strictly stipulates that the partners' confidentiality obligations to user information, including the storage, use and circulation of information, should meet our control requirements and accept our review, supervision and audit. Once there is any violation, we will require the other party to bear the corresponding legal responsibility.

(Iv) Security incidents

After an unfortunate personal information security incident occurs, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the handling measures we have taken or will take, the suggestions you can take to prevent and reduce risks, and the remedial measures for you. We will inform you of the relevant situation of the incident by email, letter, phone, push notification, etc. When it is difficult to inform the personal information subject one by one, we will take a reasonable and valid way to issue an announcement.

At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of laws and regulations and regulatory authorities.

The Internet is not an absolutely safe environment. We strongly recommend that you use a secure system and communication network when integrating services. Please use complex passwords to help us ensure the security of your account. We will do our best to ensure the security of any information you send us. Please properly protect your personal information and provide it to others only when necessary. If you find that your personal information, especially your account or password, has been leaked, please contact GemNearby customer service immediately in the manner described in Section 10 of this policy, so that we can take corresponding measures according to your application.

V. How do you manage your personal information?

We will use all appropriate technical means to ensure that you can access, update and correct your registration information or other personal information provided when using our services. You have the following rights with respect to your personal information:

(1) Inquire about your personal information

You can log in to GemnearbyApp, click on your avatar/name on the "I" page in the lower right corner, enter the personal information preview page, and inquire about your personal information.

If you wish to inquire about your other personal information or encounter difficulties in exercising the above rights, you may contact us in the manner described in section 10 of this policy.

(2) Correcting and supplementing your personal information

You can login to GemnearbyApp, click on your avatar/name on the "I" page in the lower right corner, enter the personal information preview page, and click "Edit" to correct and supplement your personal business card information.

If you wish to update or supplement your other personal information, or encounter difficulties in exercising the above rights, you may contact us in the manner described in section 10 of this policy.

(3) Delete your information

You can log in to GemnearbyApp, click on your avatar/name on the "I" page in the lower right corner, enter the personal information preview page, click "Edit", and enter the personal information Edit Page to delete some of your personal information, such as the brand category;

If you wish to delete your other personal information or encounter difficulties in exercising the above rights, you can contact us through the means described in Section 10 of this policy, and we will respond to your request promptly after verifying your identity, except as otherwise provided by laws and regulations or as otherwise agreed in this policy.

In the following circumstances, you may request the deletion of personal information to us through the means described in Section 10 of this policy, unless the personal information has been annonymized or otherwise provided by laws and regulations:

1. If our handling of personal information violates laws and regulations;

2, if our processing purposes have been implemented, cannot be implemented or is no longer necessary for the implementation of processing purposes;

3. You withdraw your authorization;

4, if you no longer use our products and/or services, or you actively delete account;

5. Other circumstances stipulated by laws and regulations.

If we decide to respond to your request for deletion, we will also notify the subjects who have obtained your personal information from us as much as possible and require them to delete it in a timely manner (unless otherwise provided by laws and regulations, or these subjects have independently obtained your authorization).

When you or we assist you in deleting the relevant information, due to applicable laws and security technologies, we may not be able to delete the corresponding information from the backup system immediately. We will only store it for no other purpose until the backup update is deleted or the information is annonymized. During this period, we will not carry out processing other than storage and take necessary security measures.

(4) Altering the scope of authorization or withdrawing authorization

Please be aware that in order for you to use GemNearby products and/or services normally, you need to provide us with some basic personal information. If you wish to withdraw the relevant permissions you previously agreed to open, you can follow the prompts of your device's own operating system.

If you do not want to receive message notifications on the GemnearbyApp page, you can reject receiving message notifications when installing the app for the first time, or you can follow the prompts of your device's own operating system.

Please understand that specific business functions and services will require your information to complete. When you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous processing of personal information based on your consent or authorization.

(5) delete account your account

You can delete account in the following ways:

1. Login GemnearbyApp client end, through "I" - "Settings" - "cancel account" commit account deletion application;

2, login GemnearbyApp choose to contact customer service, ask for help, help you apply to delete account your account.

After you voluntarily cancel your account, we will stop providing you with products or services, delete your personal information as required by applicable laws, or make it annonymized, except as otherwise stipulated by laws, regulations or regulatory authorities for the storage time of user information.

(6) Respond to your request

For the implementation of the user rights under this policy, or if you have any questions, complaints, comments or suggestions about your data subject rights, you can contact us through the contact information provided in this policy. For security, we may need you to provide corresponding means to prove your identity and the legitimacy of the request. We will complete the identity verification and processing response within 15 working days after receiving your feedback. 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 as appropriate. For those requests that are unprovoked repetition, require excessive technical means, pose risks to the legitimate rights and interests of others, or are very impractical, we may reject them.

We may not respond to your request based on this Article 6 under the following circumstances:

1. Relevant to our fulfillment of our obligations under laws and regulations;

2. Directly related to national security and national defense security.

3. Those directly related to public safety, public health, and major public interests.

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

5. There is sufficient evidence to demonstrate that you have subjective malice or abuse of power.

6. To safeguard your or other individuals' life, property and other major legitimate rights and interests, but it is difficult to obtain my authorization and consent;

7. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations.

8. Involving trade secrets.

How do we handle information about minors?

GemNearby products and/or services are primarily aimed at adults. GemNearby takes the protection of minors' personal information very seriously. Our products, websites and services are primarily aimed at adults. We do not knowingly collect minors' personal information. If you find that we have unintentionally collected minors' personal information, please notify us immediately and we will try to delete the relevant data as soon as possible.

Privacy Policy applicable range

(1) All GemNearby products and/or services are subject to this policy.

(2) Some services have their own specific Privacy Policy, which more specifically explains how we handle your information in the service. If there is any inconsistency between this policy and the Privacy Policy of the specific service, please refer to the Privacy Policy.

(3) Please note that this policy is not applicable to services provided by other companies or individuals. Your use of third-party services is subject to its Privacy Policy (not this policy), and you need to read its policy carefully.

Revisions and Updates to the Privacy Policy

Without your affirmative consent, we will not limit your rights under this policy.

(2) For major changes (including but not limited to major changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used), we will also provide more prominent notice. In this case, if you continue to use our services, you agree to be bound by the revised policy. Major changes include but are not limited to:

1. Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used.

2. We have undergone major changes in ownership structure, organizational structure, etc. Such as business adjustments, bankruptcy mergers and acquisitions caused by owner changes, etc.;

3. Changes in the main objects of personal information sharing, transfer or public disclosure;

4. Significant changes have taken place in your rights to participate in the processing of personal information and in the way you exercise them.

5. Changes in our responsible department, contact information and complaint channels for handling personal information security;

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

Nine, how to contact us

If you have any questions, comments or suggestions about the content of this policy, or you think your personal information may be leaked, you can contact us through [I --- Online Customer Service] in GemnearbyApp. The registered address of Shenzhen Zhangxun Technology Co., Ltd. is 2602, Jinzhan Jewelry Plaza, No. 20, Shuibei 1st Road, Shuibei Community, Cuizhu Street, Luohu District, Shenzhen. We will complete the verification and processing within 15 working days.

Dispute Resolution

The delineation and dispute resolution of this policy shall be governed by the laws of the Chinese mainland. Any disputes arising from this policy and our handling of your personal information shall first be settled through friendly negotiation; if the negotiation fails, you can commit the dispute or dispute to the jurisdiction of the people's court with jurisdiction where Shenzhen Zhangxun Technology Co., Ltd is located. If you believe that our personal information processing has damaged your legitimate rights and interests, you can also report to the relevant government departments.