APUS Security Privacy Policy

1.Overview

APUS Security (this “Product”) is a security product developed, operated and managed by Qilin Hesheng Network Technology Co., Ltd. (“APUS” “We” or “us”). We fully respect and protect users’ personal privacy. While providing you with quality services, we will collect, use, disclose, store and protect your personal data in accordance with this Privacy Policy (the “Policy”).

We will explain how we process your personal data in this Policy and how you may access and control your personal data.

Please completely read and fully understand this Policy before using this Product. If you have any questions about this Policy, or have any complaints or suggestions, please contact us via the methods as described in this Policy. This policy will help you understand the followings:

How We Collect and Use Your Personal Data

ŸHow We Use Cookie and Similar Technologies

ŸHow We Share, Transfer and Disclose Your Personal Data

ŸProcess Your Personal Data Using Third Party Services

ŸHow We Protect Your Personal Data

How You Access and Control Your Personal Data

ŸHow We Process the Minor’s Data

ŸHow Your Personal Data Is Transferred Globally

ŸContact Us

ŸUpdate of Privacy Policy

2.How We Collect and Use Your Personal Data

We may collect your personal data as follows while we are providing services. These data is critical for us to realize various functions of this Product. We will use these data to help us develop and improve our products to provide better services. We will use your personal data in strict compliance with the purposes set forth in this Policy. We will inform you in advance and obtain your consent before we use these data for any other purposes than set forth in this Policy or we use the personal data collected for specific purposes for other purposes.

2.1. Category and purpose of your personal data we collect

This Product is a full functionality security product with rich content and services. We will collect different categories of your personal data in different scenarios according to various product features, and will use these data to realize such product features.

2.1.1. Pre-activation service

In order to strictly comply with the laws and policies of the relevant countries or regions, we need to use pre-activation services to know your country or region. During pre-activation, we will send your IP address, country code (MCC), mobile phone language, system version and other information to our server. This information is only used to know your country or region, thus providing you with agreements and services that comply with that country or region. This information will be deleted within a short period of time after knowing your country or region, and will not be permanently saved.

2.1.2. Anti-Virus

In order to provide a safe mobile usage environment, we build the Anti-Virus system through Quick Scan, Full Scan , Real Time Protect, False Positives Mark, Virus Database Updates and Virus Sample functions; When you start Quick Scan, Full Scan and enable Real Time Protect, we’ll read and collect information of applications you installed both in phone and SD card and file information or file storage information of installed applications. Then we can kill virus with our cloud antivirus engine and local antivirus engine.

In order to modify malicious application information marked with no false positives, we’ll read and collect information including application information, application file information you installed both in phone and SD card and virus information as well as input content , and upload them to the server.

In order to build up virus database, we’ll collect virus database sample file information and upload it to the server.

In order to upgrade the virus database manually or automatically for latest virus killing, we’ll read your WIFI status and current virus database information and then compare different versions.

2.1.3. Junk Files

We’ll read the application information、file storage information、application cache and multimedia file information installed both in your mobile and SD card, to help you clear junk files including system cache, ads unload residue, empty folders, useless installation packages, temporary files, other files, pictures, audios and videos etc. In this way, we can clear junk files and release more space by scanning and cleaning. Further more, if deeper cleaning is needed, we can also provide you better cleaning effect with auxiliary functions. We’ll also collect the application list and SD card catalog information in your mobile and SD card in the meanwhile for a continues optimized scanning speed and cleaning effect.

2.1.4. Memory Boost

In order to close background process for space release and mobile efficiency enhancement, we’ll read the application information, file storage information, application cache and multimedia file information installed both in your mobile and SD card when you start Memory Boost function, and release more memory space by scanning and shutting down apps. Again, we can also provide you better boost effect with auxiliary function if you try our Super Mobile Booster. We’ll also collect the application list and SD card catalog information in your mobile and SD card in the meanwhile for a continues optimized scanning speed and boost effect.

2.1.5. WiFi Security

In order to ensure your WiFi environment safety, we’ll read your network connection information (eg. WiFi connection status, encryption type, WiFi network connection status, SSID , etc.) and complete WiFi security detection through WiFi information analysis, ARP attack detection, DNS detection ,middleman attack detection ,Portal authentication ,etc.

2.1.6. WhatsApp Cleaner, Facebook Cleaner

In order to clear cache, ads, pictures, audios ,videos and other files in specified applications like WhatsApp and Facebook, we’ll read the application information, file storage information, application cache and multimedia file information installed both in your mobile and SD card , and clear specified application by scanning and shutting down specified apps. We’ll also collect the application list and SD card catalog information in your mobile and SD card in the meanwhile for a continues optimized scanning speed and cleaning effect.

2.1.7. CPU Clooler

In order to lower the temperature of CPU, we’ll read your mobile CPU temperature, installed application information in both mobile and SD card as well as running application information, and cool down CPU by shutting down running applications and reduce mobile memory usage. We’ll also collect the application list and SD card catalog information in your mobile and SD card in the meanwhile for a continues optimized cooling effect.

2.1.8. Bttery Saver

In order to prolong the standby time of mobile battery, we’ll read app information installed in your phone and SD card, running application information and self-starting application information. Meanwhile, we can completely shut down process with auxiliary function to avoid app self-staring and get a better power saving result. We’ll also collect the application list and SD card catalog information in your mobile and SD card for a continues optimized power saving result.

2.1.9. Safe Browser

In order to provide you with a safe web browsing environment, we build the whole safe browsing function through browsing webpage, bookmark, searching, download management, privacy protection, ads blocking, voice search and other functions.

We provide you with book mark function to help you browse webpage easily and save your favorite webpage . When you add bookmark, we’ll save the webpage link address, title, favicon and time information to local. When you want to visit the website again, you can open it directly from bookmark list without entering the site address again. Besides, we also provide you with bookmark delete function so that you can delete bookmarks one by one or at one time as needed.

Download management function allows you download several files at the same time, manage download process of each file, switch specified target download folder, quick search or delete downloaded files and self-start pending download task paused due to network issue. In order to realize these functions, we’ll save your download status information, eg waiting for download, suspended download, network interrupt and others, and decide whether to continue with download based on there information. We’ll read your SD card catalog list so that we can switch file download folders. What’s more, we’ll save download file information and download start time and end time to help you search or delete downloaded files quickly. We also provide delete download task function so that you can delete download tasks one by one or at one time as needed.

We provide you with voice search function if your phone support voice recognition. We support the voice recognition program that arouses the system to recognize your voice from the system’s voice recognition program and convert it into text to return to us, then we search for the text through the search function. We will not apply for permission in the whole process, nor will we collect and store any data related to your voice.

In order to show and recommend related searching results, we’ll read and collect your web information, cache, cookie, location, system language, clipboard URL and other information.

You can lock to protect your privacy. We need to access your security gestures and security questions and save them. You can check your privacy when unlocked.

2.1.10. Risk Reminder

In order to provide you with security related information, we’ll read your country and language data to show you relevant security information in your area.

2.1.11. Call Blocker

In order to help you block specified numbers and identify whether a strange call is harassment call, we need to read your call log, contacts, call status, tag information on strange calls and messages as well as other information. When you use the identify(display) strange call function, we’ll upload your call log to the server to request the classification of the number to display. To continuously improve harassment call database, we’ll upload your tag information of strange calls to the server. You can check and turn off upload tag information function in setting page of Call Blocker at any time to protect your privacy.

2.1.12. Cloud service

We provide you with a wealth of features and services through cloud service interfaces, such as memory boost, junk files, app lock, antivirus, safe browsing, and product updates. In order to ensure the operation of cloud services, we need to collect some necessary data, including: application information such as application package name, application version, and application installation time; system information such as country code, system language, and system time zone; screen resolution and other devices Information; network information such as operators.

2.1.13. Service quality measurement

In order to measure the quality of service of a product and thus provide you with better services experience and other new services, we will collect the following information during your use of the service, and the information obtained will only be used for this purpose.

Activation information: application information including application package name, application version, and application installation time; system information such as Android ID, country code, system language, system version, system time zone, and Google service version; screen resolution, mobile phone brand, mobile phone model, etc.; Network card information and other devices information; network types, operators and other network information.

Usage information: application information including application package name, application version, and application installation time; system information such as country code, system language, and system time zone; screen resolution and other device information.

2.1.14. Provide stable services

In order to provide you with a stable service, we will collect the following related information for locating, analyzing ,and improving problems in the event of product. And the information is only used for this purpose.

Crash information: When our product crashes, you can choose whether to upload crash information. Then we will get the uploaded crash information, including application name, application version, application installation time, application signature and other application information; country code, system language, system time zone, memory information and other system information; screen resolution, mobile phone brand, horizontal screens, vertical screens and other information; crash process name, crash time, system non-sensitive log at crash, and crash log of this application.

Feedback: If you have any questions or suggestions about this policy, you can give us feedback through the product’s feedback function. We will get your feedback, including email address, feedback content, mobile phone brand, mobile phone model, system version and other information.

2.1.15. Anti-Fraud and Anti-Cheating

To prevent fraud and cheating, in order to ensure the normal operation of our business that provide you with better services and ecological environment, we need to obtain some necessary data, including: application package name, application version, application installation time, application signature and other applications Information; Android ID, country code, startup time, system time, memory information, system version, power, volume information, Bluetooth information, SIM card status and identification information, storage information and other system information; screen resolution, mobile brand, mobile phone Type, sensor information, camera information, CPU information, GPU information and other device information; location information, headset pluggable information, application installation and use information, screen unlocking information, Wi-Fi list information, network information and other user use information. The information obtained is used only for this purpose and is stored on the server as a pseudonym.

2.2. Your personal data we obtain from a third party

For now, we do not obtain your personal data from any third party. If certain services may require your personal data from a third party, we will notify you in advance and obtain your consent.

2.3. What permissions do we use to get your data

• Read phone status and identity

This permission is used to acquire a unique ID of each device, and we will then apply a non-invertible encryption on the data. It does not include any personal identity information.

Read the contents of USB storage

Used in our junk files cleaning feature to scan junk from device’s hard drive.

Modify or delete the contents of USB storage
Used in our junk files cleaning feature to remove junk from device’s hard drive.

Find accounts on the device

Used to check if user has logged in to Google Play, and provide the corresponding installation and download services.

Read Google service configuration

Used to retrieve anonymous advertising ID so as to provide high-accuracy advertising recommendation service.

Full network access.

Used to achieve network-based services, e.g. performing version update notification. GPRS traffic may be needed.

Check network connections

Used in our smart settings and quick access function to check network connections.

Modify network connectivity

Used in our smart settings and quick access function in notification bar to turn on/off cellular data.

Check Wi-Fi connections

Used in our smart settings and quick access function to check Wi-Fi connection.

Access Bluetooth settings
Used in our smart settings, turning on/off Bluetooth connection.

Close other apps

Used to close apps running in background with 1-Tap Acceleration and Professional AntiVirus.

Retrieve running apps
Used to check running apps with 1-Tap Acceleration and Professional AntiVirus.

Run at startup
Used to wake cleaning and app lock services at device startup.

Draw over other apps
Used to provide floating window feature as well as displaying windows over other apps when using memory boost feature.

Read sync settings
Used to provide battery saver feature, checking sync status to save power; Used to support app lock feature, to retrieve forgotten password through email.

Toggle sync on and off

Used to support battery saver feature to toggle on/off sync.

Install shortcuts
Used to create shortcuts on other launcher’s home that users may continue to use Professional AntiVirus services。

Measure app storage space

Used in our apps management feature, retrieving the amount of storage used by other apps.

Uninstall shortcuts
Remove app shortcuts on other launchers.

Receive data from Internet

Allows programs to receive data from internet in order to provide immediate content updates.

Read, modify or delete contents on SD card

Allows apps to read and modify contents in SD card as user instructions.

Read or modify system settings

Used to support battery saver feature to control and adjust vibration, screen rotation and screen brightness, and we may use this permission to read device’s default input method.

Use of system-level dialog

Used for confirmation process in feature settings.

Retrieve recently used applications

When providing app lock feature, this permission is needed to monitor the app that is currently displayed on the platform.

Use of Accessibility Service

To improve phone performance even further and keep users away from malicious Websites , this app needs to retrieve window content of apps such as Settings ,third-party browsers etc and sometimes perform actions on behalf of users ,but no information will be uploaded . With accessibility service , this app can find and click “force stop” button in application details page to stop an specific app , also “clear system cache” button in storage settings to free up storage and "app standby " button in development settings to frezze apps. This app may retrive url in browsers to check if it is safe to visit while Websites protection is on. Users don’t have to worry about their privacy , because we will never ever upload any of those information.

Delete system’s cache

Used to provide junk files cleaning feature with removing system’s cache data.

Information Automatically Collected Through the Service.

We automatically collect information about you when you use the Service. If you access the Service through a mobile device, we may be able to identify the general location of your mobile device. We will collect information including, but not limited to: your mobile device’s brand, model, operating system, resolution, screen size, system version, Bluetooth settings, internet connection, RAM, history, the apps(including application details) you have installed, the apps you have running in the background, mobile device’s Android Advertising ID, along with your account activation time, content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, URLs you have visited, notifications that have appeared on your mobile device, your IP address, your mobile country code, and your identity. We will also request access to your photos, media and files, your device’s camera and microphone, your Wi-Fi connection information and your device ID and call information. You may be able to limit the amount of information collected from your device (phone, or tablet) with us by adjusting your mobile device’s settings. We may upload the above stated information to our own server for the purpose of making sure that our app’s functionalities can run as expected, like anti-virus and cache cleaner. We do not, in any way, share this information with any other parties.

Had you enjoyed our service and provided with us your account, password or other personal information, we will only use such information for our own service in accordance with the purpose we committed in this policy. If you disclose any your Google account information, we will only visit your Google account with your consent, and the usage of such information shall be subject to this policy.

Directory names on sdcard

We collect the encoded directory names to identify if it can be delete safely. None of the directory names will be exposed to anyone or any institution.

SMS, contact and account information

(1) Read your contauls
Used to display contact name of missed calls or SMS on lock screen. No contact identified information will be collected.

(2) Send and view SMS
Used in messaging service in Smart Locker, including receive, reply. No Message content will be collected.

(3) Read call log
Used in phone call service in Smart Locker, including display phone number and time of missed calls, and users can spontaneously change status of missed calls. No calls information will be collected.

(4) Information you give us

Android Advertising ID

The advertising identifier is required for providing advertisements, but it will not be associated with any persistent device identifier (for example: SSAID, MAC address, IMEI, etc.)

3. How We Use Cookie and Similar Technologies

Cookie is a small piece of text sent to a browser by a website visited by a user. It helps the browser to record user access information, such as preferred language and other settings. In this way, users will have an easier and more practical experience when they visit the same website the next time. Cookie play a vital role. Without cookie, the user’s experience of Internet will be greatly reduced, and some website features or services may not even work properly. We use cookies to provide you with a complete web browsing service. We do not collect cookie information ourselves. Please note that the websites you visit may use cookie to store your preferences, settings, login status, etc. For example, when you visit a webpage that has a login function for the first time, you need to enter a user name and password to log in. After logging in, the website will record your login status, When you switch different pages under the site, you do not need to re-enter the user name and password, you can directly browse the content of the web page. Websites may use cookie to recommend advertisements. For example, some websites use cookie to record websites that you click on to prevent you from seeing duplicate advertisements. We provide the ability to disable and delete cookies. You can disable or delete cookies.

To make it easier for you to open web pages, we provide web page caching. We allow websites you visit to store some web page data, such as web page pictures and other information. When you visit the site next time, the site will directly read the saved data for display, thereby to open the webpage faste. The cache will expire due to expiration or manual removal. We will not upload any cached content.

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

We will share with or transfer or disclose your personal data to a third party with your consent or explicit instructions. In addition, to improve the quality of our service, we may also share with or transfer or disclose your personal data to a third party under the following circumstances.

4.1. Subsidiary Products

We may share your personal data with our subsidiary products to provide a more consistent experience and better service. We guarantee that our subsidiary products will treat your personal data in accordance with the purposes and requirements shown in this Policy. We will obtain your prior consent again if our subsidiary products wish to use your personal data for purposes other than those set forth in this Policy.

4.2. Affiliated Company

We may share your personal data with our affiliated companies and will ensure their processing of your personal data is in compliance with the purposes and requirements of this Policy. We will obtain your prior consent again if affiliated companies intend to use your personal data for other purposes than set forth in this Policy.

4.3. Third party service provider

We may engage third party service providers to provide specific services. Third party service providers may collect data when providing services, and we will ensure that they follow our instructions, follow the purposes and requirements set out in this policy to process your personal data, and take appropriate confidentiality and security measures to safeguard data security.

4.3.1. Local Anti-virus

In order to provide you with better antivirus function, both cloud killing and local killing are available at the same time when you scan the virus. The local virus engine is provided by the third party service provider: Antiy; It may access and collect your device information, installed application information, file information, virus information, and virus database version to complete virus detection, analysis and killing.

4.3.2. Attribution of installation channel

In order to attribution of installation channel and provide you with better services, we use the services of a third party service provider. The service needs to obtain your information including: application package name, application version, application installation time, system version, Android ID, country information, mobile phone language information, mobile phone brand, mobile phone model. The information obtained is only used for this purpose.

4.3.3 Visiting a Web Page

In order to realize the function of browsing the webpage, we will request the content of the webpage according to the webpage link address you provided, and then display the content of the webpage returned by the server. In this process, website may collect your relevant data，such as user agent, cookies, browsing track and so on. In addition, to implement special functions in certain web pages, the website may use the browser to apply for the location of your address or mobile phone file information, for example: pictures that need to be uploaded to the avatar, and microphone information. After you authorize it, the website can display related functions.

4.3.4. Attribution of installation channel

In order to attribution of installation channel and provide you with better services, we use the services of a third party service provider. The service needs to obtain your information including: application package name, application version, application installation time and other applications Information; Android ID, country code , language, system version and other system information;  power, charging type, sensor information, mobile brand, mobile phone Type, network information, CPU information and other device information. The information obtained is only used for this purpose.

4.3.5. Anti-fraud and Anti-Cheat

In order to prevent fraud and prevent cheating, and to provide you with better services and better ecological environment, we use Digital Union’s services. The service needs to obtain your information including: application package name, application time information, application version number, installation path, application size and other application information; CPU, screen resolution, total memory information and other hardware general information; country code, start-up time, system time and other system information; mobile phone brand, mobile phone model, memory, CPU and other equipment hardware information. The information obtained is only used for this purpose.

4.4 Share of your personal data as required by law

Subject to compliance with this Policy, we may be required to share or disclose your personal data under certain circumstances, such as in accordance with laws and regulations, and compulsory requirements of government orders; to safeguard the legitimate rights and interests of yours, ours, and third parties; and to prevent or deal with fraud, secure or technical problems.

4.5 Change of organization and existing status of our company

For any change of the organization or existing status of our company (such as restructuring, merger or bankruptcy), your personal data may be transferred to the company entity after change or our affiliated company (the “Data Transferee”). The Data Transferee will continue to be bound by this Policy.

5.Process Your Personal Data Using Third Party Services

The Product may contain a hyperlink directing to third party products or services, such as a hyperlink to another website. You may click the hyperlinks in this Product to access third party products or services. Meanwhile, we may also embed third party links in this Product and you may click these links to access or use third party products or services on the interface of this Product. We hereby remind you that when you access or use third party products or services via the above methods whereby your personal data will be obtained by such third party products or services, the privacy policies of such third party products or services will apply to such personal data.

In addition, we may use the third party interface to improve product function. For example, search module will request search engine interface based on the keyword input by user and obtain the search suggestions and keyword related webpage contents.

6.How We Store and Protect Your Personal Data

6.1. Security protection of personal data

We are committed to protecting your personal data. We have adopted all possible security technologies and procedures to protect your personal data against unauthorized access, use, revision, damage, destruction or disclosure. These security measures mainly include the following:

a） Your personal data is stored in the computer systems located in a controlled site with security measures such as encryption.

b） Only APUS employees who have the necessity to process relevant data for the purpose of product operation are authorized to access your personal data and such employees are required to comply with strict confidentiality obligations.

c） We are constantly striving to ensure the security of your personal data, and we adopt encryption technologies during data transmission to prevent your information against unauthorized access, use, revision, damage, destruction or disclosure.

d） We are more prudential when we transmit and store special categories of your personal data and adopt encryption technologies and other security measures to ensure data security.

In case of personal data security incident, according to the requirements of relevant laws and regulations, we will promptly inform you via push notification, announcement, etc. the basic situations and possible influence of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc. We will timely deal with system vulnerabilities, cyber-attacks, virus intrusion, and other security risks.

6.2. Personal data storage term

We will store your personal data for the necessary period for data collection and processing purposes. Beyond the above-mentioned period, we will delete or anonymize personal data.

The related data read through Anti-Virus, Memory Boost, Junk Files, Facebook Clean, Whatsapp Clean, Wifi Security, CPU Cooling, Battery Saver, Risk Reminder, Safe Browsing functions are for recording mobile using status continually(eg, real time monitor function in antivirus, strange WiFi detect function in WiFi security)and optimizing operating speed of related functions. We save data to the local with storage period the same as lifecycle of software and promise never upload data to the server. You can even clear related data in software management under system setting at any time.

The data collected from above functions, including app information installed in mobile and SD card, app file information and virus information, are used for products continuous improvement (eg, False Positives Mark in antivirus, close background app process by default in booster function ) and will be saved in the server for a long time. You can tell us the actions you need to do with data by clicking side bar>settings>personal data centert>manage more data. We’ll delete and anonymize personal data. If you want to know more about the data we collected, please consult us by sending email to mailbox at the page bottom.

The access records, application execution logs, and application debug logs of the cloud service are stored on the server for a short period of time, typically 7 days. If this period expires, we will delete or anonymize the data.

Application usage data is pseudo-persistently stored on the server for data analysis. You can access, edit or delete your data in the manner described in section 7. : How to Access and Control Your Personal Data.

After you cancel your account, we may not be able to delete your personal data immediately due to technical reasons; however, we will delete it during the next system update, and we undertake not to process your personal data during the period between cancellation of your account and the next system update.

7.How You Access and Control Your Personal Data

7.1. Access and revise your personal data

You can access and edit your personal data onlie in APUS user information center.

7.2. Change of your authorization scope

You may select on the page of APUS User Information Center to change your authorization scope for us to process your personal data. Please be minded that since all functions of the Product need certain basic personal data for normal operation, certain functions of the Product may not operate normally when you withdraw your consent to processing of some personal data.

When we receive your withdrawal of consent, we will no longer process your corresponding personal data.

7.3. Rejection of interest-based advertising

You may always choose whether to receive promotional emails, messages, calls, and mails from us or third parties. You may also choose to no longer receive interest-based advertisements through APUS User Information Center.

We will no longer use your personal data for the above-mentioned commercial promotion purposes when you refuse to receive interest-based advertisements.

7.4. Delete your personal data

You may submit a request to us to delete your personal data when:

a) Your personal data is no longer necessary for data collection or processing;

b) You have withdrawn your consent to our processing of your personal data ;

c) Your personal data has been processed illegally;

d) We are obligated to delete your personal data in accordance with the laws of EU members.

We may not be able to delete your personal data immediately due to technical reasons. We will delete it during the next system update. We will not process your personal data in any way during the period between your request of deleting your personal data and the next system update.

7.5. Respond to your requests

We may first verify your identity upon receipt of your request, and may request you to provide the necessary information for authentication.

We will respond to your request on the 30th day after we receive your request and communicate with you in an appropriate way. If necessary, we may extend it (by an additional 30-day at most), and will inform you of the reason for the extension of the deadline on the 30th day after receiving your request. If we have reasonable reasons to believe that no measures are needed to respond your request, we will inform you of our decision 30 days from the date of receipt of your request and provide you with appropriate explanation.

We will use best efforts to help you resolve relevant problems. If you are not satisfied with the response you received, you may refer the complaint to the relevant regulatory authority, or file a lawsuit before a competent judicial authority.

For policy reasons, Access and Control Your Personal Data only supports users in EU Members.

8.How We Process the Minor’s Data

This Product is not intended for a minor under 16 years old (or equivalent minimum age set by the laws of EU members). We will only process the information of these minors to the extent permitted by law and with the consent of their guardians.

We will implement relevant technical measures and make our best efforts to verify whether the processing of minors’ information has been approved by their guardians. We will try to delete relevant data as soon as possible if we are aware that we have collected the personal data of a minor without the prior consent of their certified guardians.

9.Contact Us

If you have any questions or suggestions about this policy, or you need to do your data management power to manage your privacy data, please feel free to contact us:
SecurityPrivacy@apusapps.com.

If you find any violation of this policy, please feel free to contact our DPO:dpo@apusapps.com.

10.Update of Privacy Policy

We reserve the right to revise or modify this Policy. For any update of this Policy, we will send you notice on the interface of this Product to remind you of relevant updates and indicate the updated provisions for your ease of reading. Please do completely read and fully understand the updated Privacy Policy. By continuing to use this Product, you will be deemed to have accepted the updated version of this Policy. We will not reduce your rights under this Policy without your explicit consent.

11.How Your Personal Data Is Transferred Globally

We provide APUS products and services around the world, which means to conduct business globally, your personal data might be transmitted to a jurisdiction or accessed from such jurisdiction outside of the country/region where you use this Product. These jurisdictions include but are not limited to Singapore, United States, and China.

Please note that we only return demographic information to China and we do not include information on individual user identities. At the same time, in order to provide you with better services, our third party partners may transmit your data to other countries. For example, in order to detect robots or cheating, we have purchased a Chinese supplier’s traffic monitoring service. The merchant may return the user information to China in order to assist us in analyzing whether there is cheating in the user.

Personal data protection legislation in such jurisdiction might be different or even absent. Under such circumstance, we will adopt various measures to ensure security of your personal data. For instance, we will ask you for your explicit consent before transmission of your personal data, or implement security measures such as encryption and pseudonymisation during data transmission; when your personal data is transferred to such jurisdictions, we will apply the same protection of your personal data in accordance with the Policy. We will endeavor to protect your personal data with the measures stipulated in Article 46 and Article 47 of the EU General Data Protection Regulation.

The content of this Privacy Policy shall be adjusted according to the local legal or statutory requirements.

Last updated: May 19, 2018