Privacy Policy

Effective Date: April 11, 2025

Last Updated: April 11, 2025

Introduction

Our company (Suzhou Siling Network Technology Co., Ltd., hereafter "we") highly values user ("you") information security and privacy protection. We strictly comply with laws and regulations, adhere to the principle of "user first," and are committed to increasing transparency in information processing, making it easier for you to manage your information, and ensuring the safety of your communications and data.
This Privacy Policy applies to our products "KP" and "KP Music," hereafter collectively referred to as "KP."

【Important Notice】Please read this Privacy Policy carefully and fully understand its contents (the key points are highlighted in bold) before using our products/services and make your informed choices. By continuing to use our products/services, you agree that we will handle your information in accordance with this Privacy Policy. We will only start collecting, using, processing, and storing your personal information after you confirm your agreement. We will follow applicable laws and regulations, and do our best to minimize data collection. If you do not agree to KP collecting any of your personal information, please stop using and exit KP immediately. If you have any questions about this Privacy Policy, you can contact us through the methods provided in the "How to Contact Us" section.

This Privacy Policy helps you understand the following:

1. Definitions and Scope of Application
2. How We Collect and Use Your Personal Information
3. How We Share, Transfer, and Disclose Your Personal Information
4. How You Manage Your Information
5. The Information We May Send You
6. How We Store and Protect Your Personal Information
7. Personal Information Protection for Minors
8. How This Policy Is Updated
9. How to Contact Us

1. Definitions and Scope of Application

(1) Definitions

Unless otherwise specified, the terms used in this Privacy Policy generally have the following meanings:

1. Personal Information (from GB/T 35273-2020 "Information Security Technology Personal Information Security Specification"): refers to various information recorded electronically or otherwise that can identify a specific individual or reflect their activities when combined with other information. Personal information involved in this policy includes basic personal data, online identifiers (such as system account, IP address, digital certificates), and device information (such as hardware model, OS type).

2. Sensitive Personal Information (from GB/T 35273-2020): refers to personal information that, if leaked, illegally provided, or misused, could harm a person's safety or property, damage reputation, or lead to discrimination, such as health status, biometric data, financial information, etc.

3. Device Information: when you use our products, this includes details about your device, such as type, model, manufacturer, OS (iOS or Android) and version, carrier name, browser type (Chrome, Safari), screen size, and network connection info.

4. IP Address: a unique number assigned to each device connected to the internet, usually based on geographic location, which can be used to identify your approximate location when connected.

5. SSL (Secure Socket Layer): a security protocol that provides encryption for data transmission over networks, supporting various types of networks and offering three basic security services through public and symmetric key technologies.

6. Cookie: a small string file sent and stored on your device when you log in or browse websites or online content (often encrypted). Similar technologies include web beacons, proxies, embedded scripts, etc.

7. Anonymization: processing personal information so that the data subject cannot be identified or linked, and the processed information cannot be restored.

8. De-identification: processing personal information so that it cannot identify or link to an individual without additional information.

9. Log Information: server automatically records your web requests when you visit our site, including your network request, IP address, browser type, language, request time, and cookies that can identify your browser. Local logs of device info and content changes are also recorded during your use.

10. KP: refers to our company's products and services, including the "KP" Android and iOS apps, website, and related services.

(2) Scope of Application

This policy applies to all products and services provided by our company, including websites related to SD-WAN, network security, and the "KP" mobile apps. For certain specific products/services, we may have separate privacy policies explaining their particular policies. If there is any inconsistency between those and this policy, the specific privacy policy shall prevail.

2. How We Collect and Use Your Personal Information

To fulfill the functions described in this policy and better serve your needs, we will collect and use your information as follows. If you choose not to provide certain information, you may not be able to enjoy some products/services or achieve their intended effects.

(1) Collection and Use

1. To provide basic information storage functions

2. To offer customer service and after-sales support

When you contact our customer service, our system may record your communication logs and use your contact details to provide faster service or assist in resolving issues.

3. To ensure security and service reliability

To protect your account, transaction, and system security, and to comply with legal and contractual requirements, we may collect your device information and device identifiers with your authorization during your use of our products/services.

4. Participating in our activities or surveys

Your responses in online surveys may include your name, phone number, and home address. Some services may require you to provide sensitive personal information to enable specific functions. If you choose not to provide such information, some features may be unavailable, but other functions will remain accessible. Providing sensitive information indicates your consent for us to handle it as described in this policy.

5. Product development, software updates, and service improvements

During software updates, product optimization, or troubleshooting, we may need to access device info, device identifiers, serial numbers, and usage logs. For example, when troubleshooting system issues, we analyze server or local logs to help resolve problems.

6. Using the "KP" mobile app

To ensure the proper functioning of "KP" mobile app features, we may request necessary permissions based on specific scenarios, and will prompt you before accessing them. You can disable permissions in device settings, which may limit some functionalities.

（2） Rules for Personal Information Use

To improve our products and services, we will use the following information within legal and authorized boundaries:

1. Information you voluntarily provide during product/service surveys, or when interacting with our partners, to help track orders, handle complaints, and improve customer service.

2. Anonymized data used for statistical analysis and operational improvements, such as device info for system optimization, technical maintenance, troubleshooting, policy development, and internal reports.

Please note that information that cannot identify you on its own or when combined with other data does not constitute personal information. If such data is combined with other information to identify you, it will be treated as personal information.

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

(1) Sharing

We prioritize protecting your personal information and only collect/use it within the scope of this policy or as required by law. Generally, we do not share your personal data with third parties, except in the following cases:

1. With your explicit consent or authorization;

2. When required by applicable laws, legal procedures, government orders, or judicial rulings;

3. To protect our rights, safety, or property, or those of others, in accordance with legal requirements;

4. When sharing within our affiliates, limited to necessary personal data, and subject to this privacy policy. Changes in data handling purposes will require your renewed consent;

5. To provide better products/services, some of our services may be delivered by authorized partners, with whom we may share certain personal data strictly for legitimate and necessary purposes, under confidentiality agreements. Refusal to share necessary data may limit your access to certain third-party services on our platform. Our partners include:

（1） Service providers supporting our products/services, such as payment processors and cloud data providers;

（2） Third-party merchants on our platform, to fulfill purchase and after-sales needs;

（3） Third-party SDK providers embedded in our apps, which may collect and process your information directly (via embedded code, plugins, etc.). Our apps integrate SDKs from providers like:

- **Umeng+ SDK**: Collects device info and anonymized device IDs for analytics and crash reporting. Privacy policy: Umeng+ Privacy Policy
- **WeChat Open SDK**: Collects account and app info for login authorization. Privacy policy: WeChat SDK Privacy Policy
- **QQ Connect SDK**: Collects device info (OAID, Android ID, manufacturer, model, OS version, resolution, IP, sensors) for sharing features. Privacy policy: QQ SDK Privacy Statement
- **Facebook SDK**: Collects data as per Facebook SDK Privacy Policy for sharing to Facebook.
- **TikTok SDK**: Collects data as per TikTok Privacy Policy for sharing videos.

The behaviors of these third-party providers are governed by their own privacy policies and do not apply to this policy. We recommend reviewing their privacy terms before use. If you find any SDK or app poses risks, please stop using it and contact us promptly.

6. For academic research, statistical analysis, or public interest in accordance with law.

(2) Transfer

We do not transfer your personal information to any third party except in the following cases:

1. With your explicit consent;

2. In cases of mergers, acquisitions, or bankruptcy, where personal data transfer occurs, we will require the new data holder to continue to be bound by this privacy policy or seek your renewed consent.

(3) Disclosure

Public disclosure involves releasing information to society or an unspecified group. Apart from necessary disclosures such as penalties for violations or lottery winners, we do not disclose your personal information publicly. If disclosure is necessary, we will inform you of the purpose, type, and content of the information beforehand, and obtain your consent before disclosure, unless required by law or this policy.

For disclosed information, we will review its legality and appropriateness before release and implement strict security measures to protect it.

Exceptions to prior consent for sharing, transfer, or disclosure

Please note that in the following situations, we do not need your prior authorization to collect, use, share, transfer, or disclose personal information:

1. Related to national security or defense;

2. Related to public safety, public health, or major public interests;

3. Related to criminal investigation, prosecution, trial, or enforcement of judgments;

4. To protect your or others' life, property, or other major legal rights when it is difficult to obtain your consent;

5. Other circumstances of public interest, such as your credit information being publicly shared;

6. Personal information you have voluntarily made public;

7. Information collected from lawful public disclosures, such as news reports or government disclosures. However, if you explicitly refuse or if processing harms your significant interests, we will not proceed.

Under law, anonymized data that cannot be linked back to individuals and cannot be re-identified does not require your prior notice or consent.

4. How You Manage Your Information

（1） Access, Modify, and Delete Your Personal Information

You have the right to access, modify, and delete your personal information you have published, except where laws or regulations provide otherwise. The scope and method depend on the specific services you use. If you find we violate laws or our agreement in collecting or using your data, you can request deletion. If your data is incorrect, you can also request correction. Contact us via the methods listed in this policy. During modification or deletion, we may require verification to ensure account security.

（2） Change or Revoke Your Consent

You can change or revoke your consent by deleting authorization info, adjusting privacy settings, or disabling device permissions in our app. Note that after doing so, we may no longer provide services based on that consent, but previous data processing based on your prior authorization will not be affected.

（3） Account Cancellation

You can cancel your account via the "Settings" page in our app. Once canceled, your account and all related data will be permanently deleted and cannot be recovered. The associated phone number cannot be used to register a new account.

Please understand that due to technical, legal, or regulatory reasons, we may not be able to fulfill all requests immediately, but we will respond within a reasonable timeframe.

5. The Information We May Send You

We may send you notices related to system maintenance or important updates. These are not promotional and cannot be opted out of.

6. How We Store and Protect Your Personal Information

（1） Storage of Your Personal Information

We comply with laws and store personal data collected within China domestically. We retain your data only as long as necessary to fulfill the purpose, unless legal requirements dictate otherwise. In such cases, we may extend storage times accordingly.

1. To comply with applicable laws and regulations;

2. To comply with court judgments, rulings, or legal procedures;

3. To meet requests from government authorities or legally authorized organizations;

4. When we believe it necessary to comply with laws and regulations;

5. To perform our service agreements, policies, or to protect societal interests and safety, or the safety of our customers, affiliates, or employees.

When our services cease operations, we will notify you via announcements and delete or anonymize your data within a reasonable period.

（2） Protecting Your Personal Information

We implement security measures to prevent data loss, misuse, unauthorized access, or disclosure.

1. We strictly follow laws to protect user communication privacy.

2. We use encryption (e.g., TLS, SSL), anonymization, and other security measures within reasonable levels to safeguard your data.

3. We establish management systems and procedures to ensure information security, restricting access to authorized personnel who are bound by confidentiality obligations.

4. In case of personal data leaks or security incidents, we will activate emergency plans, prevent further damage, and notify you via announcements.

7. Personal Information Protection for Minors

"KP" mainly targets adult users. According to laws, minors under 18 should obtain prior consent from parents or guardians before using "KP." We will only use, share, transfer, or disclose minors' personal data with legal, regulatory, parental, or guardian approval.

If you are a guardian of a minor and have questions about their data, please contact us via the "How to Contact Us" section.

If we find that we have collected personal information of minors without verified parental consent, we will delete such data as soon as possible.

8. How This Policy Is Updated

Our services and technology evolve with user needs. When new services or business processes change, we may update this privacy policy to inform you of the specific changes. Without your explicit consent, we will not restrict your rights under this policy.

For significant changes, we will provide prominent notices (e.g., banners in "KP"). Continuing to use our services after updates indicates your acceptance of the revised policy. Major changes include but are not limited to:

1. Major changes in our service model, such as purpose, data types, or usage methods;

2. Changes in control rights, such as mergers or acquisitions;

3. Changes in the main objects of data sharing, transfer, or disclosure;

4. Significant changes in your data rights or how you exercise them;

9. How to Contact Us

If you have questions about this policy or related matters, please contact us at suzhousiling@outlook.com.

We will review your inquiry promptly and respond within fifteen calendar days after verifying your identity.