"كود نيمز(Codenames)" Privacy Policy

Dofm (hereinafter referred to as "this APP") is operated by Fundots Ltd. (hereinafter referred to as "this company", "we"), and specific product services will be provided by qualified service providers.

Privacy is an important right of every individual, and this company attaches great importance to the protection of user personal information and privacy. Before you (hereinafter referred to as "user", "you") use this APP, please read and fully understand this Privacy Policy (hereinafter referred to as "this Privacy Policy", "this policy"). Through this Privacy Policy, we explain to you how we collect, use, store, share, and transfer this information when you use this APP, as well as how we provide you with access, update, delete, and protect this information. If you are a minor under the age of 18, you should ensure that your guardian reads and agrees to this policy before you use this APP and provide us with your personal information.

If you have any questions, opinions, or suggestions, please contact us through the following contact information:

Email: fundots1@gamil.com

[Special Note]

In order to better protect your personal information, please read and fully understand this policy before using this APP. Once you use or continue to use this APP, it means that you agree to us processing your relevant information in accordance with this policy. Once you agree to provide your personal information, we will process your personal information for the purposes and in the manner described in this policy. The purpose of using your personal information is for the relevant functions of this APP. You have the right to refuse to provide us with personal information, but refusing to collect and use this information may affect your use of relevant functions.

Table of Contents

1. How We Collect and Use Your Personal Information

2. How We Use Cookie Technology

3. How We Share, Transfer, and Publicly Disclose Your Personal Information

4. How We Store and Protect Your Personal Information

5. How You Manage Your Personal Information

6. How We Protect the Personal Information of Minors

7. About This Policy

8. How to Contact Us

1. How We Collect and Use Your Personal Information

Personal information refers to various information recorded electronically or by other means that can identify a specific natural person individually or in combination with other information, or reflect the specific activities of a specific natural person. The personal information mentioned in this privacy policy includes: network identity information (IP address, etc.), personal common device information (including hardware model, device MAC address, software list, operating system type, software list, information describing the basic situation of personal common devices such as unique device identification code (such as IMEI/android ID/IDFA, etc.)).

Personal sensitive information refers to personal information that, once leaked, illegally provided, or abused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment, etc. It mainly includes: network identity information (IP address, etc.), other information (web browsing record information, etc.).

We will only collect and use your personal information for the following purposes in accordance with this policy:

(1) Circumstances in which you need to authorize us to collect and use your personal information

1. Obtaining the necessary functions of this APP

(1) Service information display

In order to quickly find the business you need and provide you with better services, we may collect device information (including device name and model, device identification code, operating system and application version, resolution, service provider network ID, network identity information (IP address, etc.), personal common device information (including hardware model, software list, MAC address, operating system type, unique device identification code (such as IMEI/Android ID/IDFA), etc.) when the application is started or running in the background, in order to provide you with services. We will also use the above personal information to continuously improve and optimize the above functions.

(2) List of information collected and used for product business functions

When you agree to this policy and start using this APP, you need to provide network identity information (IP address, etc.), personal common device information (including hardware model, software list, MAC address, operating system type, unique device identification code (such as IMEI/Android ID/IDFA)).

(3) To ensure the secure operation of the software and services, prevent unauthorized access to your personal information, and more accurately prevent fraud and protect account security

We may collect device information (including device name and model, device identification code, operating system and application version, resolution, service provider network ID, network identity information (IP address, etc.), personal common device information (including hardware model, software list, MAC address, operating system type, unique device identification code (such as IMEI/Android ID/IDFA), etc.) when the application is started, in order to provide you with services.

2. Requires your separate authorization and consent

When we want to use the information for other purposes not specified in this policy, we will seek your prior consent. When we want to use the information collected for specific purposes for other purposes, we will seek your prior consent.

3. Scenarios for collecting personal information

We will collect the following information that you actively provide when using this APP, as well as the information generated during your use of this APP's functions or services through automated means. You can provide feedback on your personal information management, query, correction, download, deletion, and other needs through the following content and contact information disclosed in the privacy policy.

Business Scenario Purpose of Collection Collection Method Personal Information Fields
Network and operational security protection Security protection of networks, operations, and systems, prevention of phishing website fraud and Trojan viruses, and ensuring network security in accordance with legal requirements APP collection/user input Software version number, operation/use/service log, sensor information, device identification information (a string of characters that the device manufacturer enters into the device to identify it, Android such as IMEI, Android ID, OAID, IMSI, ICCID, GAID, MEID, DEVICEID, iOS such as IDFV, IDFA, the term "device identification information" as used in this list refers to the same as the definition in this list), hardware serial number, hardware model, software list, operating system type, network identity information, MAC address, gid
Browsing, searching, and bookmarking Ensure normal use of services and functions by users APP collection/user input Device hardware information, operating system settings information, network information, operator information, WLAN information, device identification information
Issues and suggestions Feedback on opinions or suggestions generated during the use of services APP collection/user input Content you actively upload (such as text, images, or videos), device identification information, application information, contact information (phone number or email address)
Obtaining device ID For customer service communication and problem localization User actively copies to clipboard Device identification information, IMEI

4. Sensor information

We will access the accelerometer and proximity sensor data of your device to identify the orientation of your device screen and adapt the display for your device model.

(II) Circumstances where your authorization is not required to collect and use your personal information

In the following circumstances, we may collect and use certain necessary personal information without obtaining your authorization and consent, in accordance with relevant laws, regulations, regulatory requirements, and national standards:

(1) Related to our fulfillment of legal obligations;

(2) Directly related to national security and defense security;

(3) Directly related to public safety, public health, and significant public interests;

(4) Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;

(5) Necessary for the protection of your or other individuals' vital interests, but it is difficult to obtain your consent;

(6) The personal information involved is voluntarily disclosed by you to the public;

(7) Necessary for the conclusion and performance of contracts between you and us;

(8) Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosures, and other channels;

(9) Necessary for the security and stable operation of our services, such as discovering and handling service failures;

(10) Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosures, and other channels;

(11) Necessary for the conduct of statistics or academic research in the public interest, and the results of the research or descriptions provided to the public are de-identified;

(12) Other circumstances as stipulated by laws and regulations.

(III) Circumstances where you can choose whether to authorize us to collect and use your personal information

To improve user experience and make this APP more user-friendly, we may need you to enable access permissions to your device's location (location information), camera (camera), photo library (photo gallery), and microphone, in order to collect and use the information involved in these functions. You can find the application details in the settings, click to enter the permission view to find the status of these permissions, and decide to enable or disable these permissions at any time. Please note that by enabling these permissions, you authorize us to collect and use these personal information to achieve the above-mentioned functions. By disabling permissions, you cancel these authorizations, and we will no longer collect and use these personal information, nor can we provide you with the corresponding functions associated with these authorizations. Your decision to disable permissions will not affect the processing of personal information based on your previous authorizations.

(IV) Rules for the use of your personal information

1. We will use the collected personal information in accordance with the provisions of this Privacy Policy and for the purpose of implementing our service functions. When we use your personal information for other purposes not specified in this policy, we will seek your authorization and consent in advance.

2. After collecting your personal information, we will de-identify the information, and the de-identified information will be unable to identify the subject. Please note that in this case, we have the right to use the de-identified information. Without disclosing your personal information, we can analyze and commercially utilize the de-identified user database.

3. Please note that when you use our services, unless you delete or refuse our collection through system settings, you will continue to authorize us to use your personal information during the period of using our services.

4. We will statistically analyze the use of our services and may share these statistics with the public or third parties to demonstrate the overall usage trends of our services. However, these statistics do not contain any of your personally identifiable information.

5. In the event of a merger, acquisition, or bankruptcy liquidation that may involve the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy.

II. How We Use Cookie Technology

To ensure the normal operation of the website or APP, we store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, the website or APP can store your preference data. We will not use cookies for any purposes other than those described in this policy. You can manage or delete cookies according to your preferences. For more details, please refer to AboutCookies.org. You can clear all cookies stored on your computer, and most web browsers have the function to block cookies. However, if you do so, you need to change your user settings every time you visit our website or APP.

III. How we share, transfer, and publicly disclose your personal information

(I) Sharing

1. We will not share your personal information with any company, organization, or individual, except in the following circumstances:

(1) Obtaining your explicit authorization or consent: After obtaining your explicit consent, we will share your personal information with other parties;

(2) Sharing in statutory circumstances: Sharing your personal information is necessary in accordance with applicable laws, regulations, legal procedures, litigation/arbitration, government orders, and regulatory requirements;

(3) Necessary for the protection of your or public interests: Providing your personal information to third parties is necessary to protect your or public interests, property, or safety, within the scope permitted or required by law;

(4) Necessary for the protection of national security, public safety, and the vital interests of yourself and others;

(5) Personal information that is voluntarily disclosed by you or obtained from other legitimate public channels.

2. Examples of sharing personal information involving embedded third-party code and plugin transmission:

Umeng+ SDK

  • Purpose: Data analysis
  • Usage scenario: User statistics such as user acquisition and retention
  • Third-party name: Beijing RuiXunLingTong Technology Co., Ltd., Umeng Tongxin (Beijing) Technology Co., Ltd., Zhejiang Alibaba Cloud Computing Co., Ltd., Beijing Diyuanxin Internet Data Technology Co., Ltd., etc.
  • Personal information involved: Device MAC address, unique device identifier (IMEI/android ID/IDFA/OPENUDID/GUID/SIM card IMSI information/ICCID)
  • Third-party official website: https://www.umeng.com
  • Privacy policy: https://developer.umeng.com/docs/147377/detail/209997
  • Information collection method: Collected by the SDK

(II) Transfer

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

(1) Obtaining your explicit consent;

(2) Required to provide in accordance with applicable laws, regulations, industry regulations, legal procedures, litigation/arbitration, government orders, and regulatory requirements;

(3) Necessary for the protection of national security, public safety, and the vital interests of yourself and others;

(4) Personal information that is voluntarily disclosed by you or obtained from other legitimate public channels.

In the event of a merger, acquisition, or bankruptcy liquidation, which may involve the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy. If any changes occur in the collection and processing of personal information specified in this policy, the company or organization will seek your authorization and consent again.

(III) Public Disclosure

We will not disclose your personal information publicly unless we obtain your explicit consent. However, in cases where it is required by law, legal proceedings, litigation, or mandatory requirements from government authorities, we may disclose your personal information to authorized agencies or the public in order to protect national security, public safety, and the significant legitimate rights and interests of you and others. In such cases, we ensure that the requesting party must provide corresponding valid legal documents, and we will take security measures that comply with legal and industry standards to protect the disclosed information.

IV. How We Store and Protect Your Personal Information

(I) Storage of Your Personal Information

1. Your personal information will be stored entirely within the territory of the People's Republic of China, including the servers of this APP and third-party servers, or servers commissioned by this APP institution. We will take reasonable and feasible measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period required to achieve the purposes stated in this policy, unless there is a mandatory retention requirement under the law. For example, the "People's Republic of China E-commerce Law" requires that information about goods and services and transaction information be retained for a period not less than three years from the date of completion of the transaction. The criteria we use to determine the aforementioned period include:

(1) Completion of transaction objectives related to you, maintenance of relevant transaction and business records, and response to possible inquiries or complaints;

(2) Ensuring the security and quality of services we provide to you;

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

(4) Any other special agreements regarding retention periods.

Please note that once your personal information exceeds the retention period, we will delete your personal information or anonymize it in accordance with applicable laws and requirements. In addition, after you cancel your account, we will stop providing products and services to you, and upon your request, we will delete your personal information or anonymize it, except as otherwise provided by laws and regulations.

2. The personal information we collect and generate in our operation within the territory of the People's Republic of China is stored within China. In some scenarios, it is necessary to transfer your personal information overseas:

(1) Applicable laws have clear provisions;

(2) We have obtained your explicit authorization;

(3) You engage in personal voluntary activities such as cross-border transactions through the internet.

In the above cases, we will ensure that your personal information receives sufficient protection in accordance with this Privacy Policy.

If you use cross-border transaction services and need to transfer your personal information overseas to complete the transaction, we will separately obtain your authorized consent and require the recipient to handle this personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

This APP's network services use encryption technologies such as transport layer security protocols to provide browsing services through methods such as HTTPS, ensuring the security of user data during transmission.

This APP uses encryption technology to encrypt and store users' personal information and isolates it using isolation techniques.

In the use of personal information, such as personal information display and personal information correlation calculations, we will use various data desensitization techniques, including content replacement, SHA256, and FPE, to enhance the security of personal information in use.

2. We only allow employees and partners of our app and affiliated entities who need to know this information to access personal information, and we have established strict access control and monitoring mechanisms for this purpose. We also require all personnel who may have access to your personal information to fulfill their confidentiality obligations. Failure to fulfill these obligations may result in legal liability or suspension of cooperation with our app.

3. We will take all reasonable and feasible measures to ensure that unrelated personal information is not collected. We will only retain your personal information for the period required to achieve the purposes stated in this policy, unless the retention period needs to be extended or permitted by law.

4. Our app may contain links to other websites or apps. We remind you that our app cannot make any commitments or guarantees regarding the privacy protection measures of other websites or apps. However, our app's pages have significant "our app" marks, and you can judge whether to jump to external links based on this.

5. The internet is not a completely secure environment, and it is not possible to determine whether communication methods such as email, instant messaging, and social software with other users are completely encrypted. We recommend that you use complex passwords when using such tools and pay attention to protecting the security of your personal information.

6. The internet environment is not 100% secure, but we will do our best to ensure or guarantee the security of any information you send to us.

7. In the event of a personal information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks, and remedies for you, in accordance with the requirements of laws and regulations. We will also inform you of the event-related information through email, letter, phone call, push notification, etc. If it is difficult to inform each individual data subject one by one, we will adopt reasonable and effective methods to make announcements. At the same time, we will actively report to the regulatory authorities the disposal of personal information security incidents as required.

V. How You Can Manage Your Personal Information

Our app attaches great importance to your attention to personal information and makes every effort to protect your rights to access, correct, delete, and withdraw consent to your personal information, so that you have the ability to fully protect your privacy and security. Your rights include:

1. Accessing and correcting your personal information

You have the right to access and correct your personal information, except as otherwise provided by laws and regulations.

2. Deleting your personal information

Information that you can directly clear or delete on our service pages;

3. Changing the scope of your authorized consent or withdrawing your consent

You can change the scope of your authorized consent or withdraw your consent by deleting information, disabling device functions, and adjusting privacy settings on our app website, app, or software. You can also withdraw your consent by canceling your account, which revokes our authority to collect your personal information.

Please understand that each business function requires some basic personal information to be completed. When you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the revoked consent or authorization, and we will no longer process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect the processing of personal information carried out based on your previous consent.

4. Responding to your requests

To ensure security, we may require you to provide a written request or prove your identity in other ways. We will respond to your request within 30 days after receiving your feedback and verifying your identity. For reasonable requests, we will generally not charge a fee, but for multiple repetitive requests or requests that exceed reasonable limits, we may charge a certain cost. We may refuse requests that are repetitive without cause, require excessive technical means (such as the need to develop a new system or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as requests involving information stored on backup tapes).

In the following situations, we will be unable to respond to your requests as required by laws and regulations:

(1) Relating to national security and national defense security;

(2) Relating to public security, public health, and significant public interests;

(3) Relating to criminal investigation, prosecution, trial, and execution of judgments;

(4) There is sufficient evidence to indicate that you have subjective malice or abuse of rights;

(5) Responding to your request would cause serious harm to your or others' legitimate rights and interests;

(6) Involving trade secrets.

VI. How We Protect the Personal Information of Minors

1. Our app attaches great importance to the protection of personal information of minors. If you are under 18 years of age, you should obtain written consent from your parent or legal guardian before using our services. Our app protects the personal information of minors in accordance with relevant national laws and regulations.

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2. In the case of collecting personal information of minors with the consent of parents or legal guardians, we will only use or disclose this information when permitted by law, with explicit consent from parents or guardians, or when it is necessary to protect the minors.

3. If we find that we have collected personal information of minors without obtaining verifiable consent from parents or legal guardians in advance, we will strive to delete the relevant data as soon as possible.

4. If you are a child under 14 years of age, in addition to protecting the personal information of minors in accordance with this policy, we will also protect the personal information of children under 14 years of age in accordance with the "Regulations on the Protection of Children's Personal Information on the Internet" and other relevant regulations.

VII. About This Policy

1. Our privacy policy may change. However, without your explicit consent, we will not reduce the rights you are entitled to under this privacy policy. When this policy is changed, we will display the updated policy in advance on our app through announcements, pop-ups, or other appropriate means. Without your consent, we will not restrict the relevant rights you should enjoy according to the policy.

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2. Please note that we will only collect, use, process, and store your personal information in accordance with the updated policy after obtaining your consent. You can choose to disagree, and we will provide you with the function to browse as a "visitor," but this may result in your inability to fully use the services of our app.

3. The final interpretation and modification rights of the provisions of this policy belong to Fundots Ltd.

VIII. How to Contact Us

Company Name: Fundots Ltd.

Email: fundots1@gamil.com

If you have any questions, comments, or suggestions regarding this privacy policy, please contact us using the following methods:

Last Updated: April 1, 2024

Effective Date: April 1, 2024