LEXING YINGDA PRIVACY POLICY

Beijing Lexing Yingda Technology Co., Ltd. (“we”, “us”, “our”, or “ Lexing Yingda”) is committed to maintaining customer privacy through an ethical performance culture that is based on trust, simplicity and confidence. It is one of our core principles to secure customer information while using our services and mobile applications (“products”), and provide privacy protection that is critical in maintaining trust and providing better services. Our individual privacy protection policy ensures the confidentiality of customer information under the defined terms and conditions below.

We complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce with respect to the collection, use, retention and transfer to the United States of Personal Information from customers in European Union member countries and Switzerland (“European Customer Information”). We has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

This Lexing Yingda Privacy Policy (“Privacy Policy”) applies to all the products and services of us, including Booster & Cleaner (com.netqin.mobileguard), Call Blocker Free (com.netqin.mm), Green Battery (com.nqmobile.battery), Lynx (com.picoo.lynx), Lynx Privacy (com.picoo.newlynx), Super Toolbox (com.netqin.aotkiller), Vault (com.netqin.ps), Calculator (com.nqmobile.calculator) and other products we may publish from time to time.

1 Effective date and update

Effective date of this privacy policy: 2019/12/13

2 When we collect your Personal Information

2.1 The use of our products and services as well as certain activities such as payment transactions, surveys, and forum communications will require your personal information (Personal Information) input and your consent. This Personal Information may include: name, address, telephone number, user device identifier, IP address, user agent or such device information, fine location, persistent online identifiers as well as the brand name and model of the user’s mobile phone. Some examples may include:

3 What Personal Information we collect

We organize the Personal Information we collect into two basic categories: Account Information, and Product Information.

3.1 Account Information includes information needed to set up and customize an account, such as your email address and username, and information connected with our services, such as license keys. For some of our products or some of their functions creating an account is necessary.

3.2 Product Information includes two sub-categories:

3.2.1 Device Information includes information about the operating system; hardware; city/country of device; error logs; browser; network; applications running on the device, including our products; and

3.2.2 Service Information includes information about our product usage and events relating to use of our product by you such as malware samples and detections, information concerning URLs of websites, usage statistics (activation, crashes, scans, errors), IP address.

4 Why we process your information

We expect to process your Personal Information for the following purposes.

4.1 On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order

4.2 On the basis of your consent, in order to

4.3 On the basis of our legitimate interest we will use your Personal Information for:

We have balanced the interests for the above mentioned processing operations. You have the right to object, on grounds relating to our particular situation, to those processing operations. For more details please see section Your Privacy Rights.

4.4 Balancing Legitimate Interests

Before relying on our legitimate interests, we balanced them against your interests and made sure they are compelling enough and will not cause any unwarranted harm. With respect to the purposes below we consider necessary to explain what our interests are in detail.

4.4.1Systems, Apps and Network Security

We process Personal Information for network and information security purposes. In line with EU data protection law, organizations have a recognized legitimate interest in collecting and processing Personal Information to the extent strictly necessary and proportionate for the purposes of ensuring network and information security. This primarily covers the ability of a network or of an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via those networks and systems.

Both as an organization in our own right, and as a provider of cybersecurity technologies and services which may include hosted and managed cybersecurity technology services, it is necessary for the functionality of our systems, products and services and in our legitimate interests as well as in our users’, to collect and process Personal Information to the extent strictly necessary and proportionate for the purposes of ensuri ng the security of our own, and of our users’ networks, devices, and information systems. This includes the development of threat intelligence resources aimed at maintaining and improving on an ongoing basis the ability of networks and systems to resist unlawful or malicious actions and other harmful events (“cyberthreats”).

The Personal Information we process for said purposes includes, without limitation, network traffic data related to cyber-threats such as:

Depending on the context in which such data is collected, it may contain Personal Information concerning you or any other Data Subjects. However, in such cases, we will process the data concerned only to the extent strictly necessary and proportionate to the purposes of detecting, blocking, reporting (by removing any personally identifiable elements) and mitigating the cyberthreats of concern to you, and to secure your network, device and systems. When processing Personal Information in this context, we do not seek to identify a Data Subject.

4.4.2 New Product Development

We have a legitimate interest to use necessary Personal Information to develop new products or features so that we are able to provide you with state-of-the-art security, privacy and performance products.

4.4.3 Third-party Analytics Tools (user acquisition, user interactions)

We have a legitimate interest to use necessary Personal Information for third-party analytics to understand user conversions, acquisitions and campaign performance through various distribution channels, and users’ download, activation and interactions with our products because these analytics help us maintain functionality, effectiveness, security and reliability of our products and business activities.

5 How we protect your Personal Information

5.1 Prior to requesting information from you on our websites, we will define the purposes for which such information is to be used. You, the customer, may then choose whether or not to proceed with the transaction and use our products and services and provide the appropriate information. If you prefer not to provide the required information, then the transaction shall be canceled.

5.2 We comply with international information criterion to protect your personal information. These measures include some technical and programmed steps that can protect your data against misuse, illegal access, disclosure, losing, modification or destruction. We use security socket layer (SSL) to transmit credit card and your or your child’s geo location information. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

5.3 For the information we may collect from you or your child while using our products or services, yours and your child’s personal information collected in such circumstances will be kept confidential and shall not be used for illegal purposes, or copied, used or provided to any third party illegally, or accessed by our staff.

The information we collect from you may be stored, with risk-appropriate technical and organizational security measures applied to it, on in-house as well as third-party servers in the United States, as well as anywhere we or our trusted service providers and partners operate. In all cases, we follow generally accepted standards and security measures to protect the personal data submitted to us, both during transmission and once we receive it.

A child’s participation or access to an activity cannot be conditioned on him or her providing more Personal Information than is reasonably necessary for that activity.

5.4 We do not sell your personal information to third parties. We will not share your or your child’s information with third parties other than the necessary service providers as indicated in this Privacy Policy.

5.5 Limiting utilization may occur in the following circumstances:

5.6 We may from time to time develop new features so that we are able to provide you with state-of-the-art security, privacy and performance products, these new features may request you to provide additional information beyond the scope of this Privacy Policy, you may reject to such request, in such cases you will use the old version of our product.

6 How we use your Personal Information

6.1 Content of Email

We will not read or disclose to any third party any private email communication information that is transmitted using our products and services, unless given appropriate explicit consent to do so.

6.2 Log

We have provided logging functions for emails and other communications transmitted in the process of using our products and services. Any user can select to turn his own log record function on or off. We will not read or disclose to any third party any users’ private information it records as part of the logging functions without further consent.

6.3 UID information

When you use our products and services and activate/register them, our system will generate a user ID (UID) for you at random, by which we identify the user and provide the services. We may collect your phone number and associate it with UID and/or any of our other internal tracking tools or service account, such as Account to complete the billing process and provide certain service such as anti-lost remote control.

We respect the request of any user or third party to verify his own UID information, and will correct or allow the correction of any possibly incorrect information. Any user and third party can ascertain whether his information has been appropriately corrected by either email or phone at any time.

6.4 Caller ID & Call Block Function

When you use the Caller ID and Call Block function, we will collect, process and retain personal information from you and any devices you may use in your interaction with our Services. This information may include the following: geo-location, your IP address, device ID or unique identifier, device manufacturer and type, device and hardware settings, ID for advertising, ads data, operating system, operator, IMSI, connection information, usage statistics, device log and event information, the number of incoming & outgoing calls and other information based on your interaction with our Services.

Please note: the app will never store your contacts and your call history. The app accesses the contacts on the phone in order to display the contacts and so the app can record or ignore calls from specific contacts. While we are intensity focused on protecting you from unknown calls, we are just as concerned with making sure important calls are not missed. Access to contacts helps us filter out numbers that may look spam, but are actually legitimate (like your Doctor’s office). We also access contacts to identity callers under the name you prefer to see, to enable your ability to add numbers to your blocklist.

You can tag an unknown number after making a call. So this contribution will make our database better. We may also associate a name with a phone number through the numbers tagging functionality, which allows a user who receives a call from a phone number which is not associated with a name in the database to indicate a name to be associated with that number. A name will only be associated with a number through this functionality if a sufficient number of independent Users, based on our algorithm, have indicated the same name for the relevant number.

Call Blocking requires accessing your contacts. Therefore, the app is able to block the numbers that users refuse to answer. Meanwhile, the app can also block numbers from user’s contacts.

7 How we disclose your Personal Information

We only disclose your Personal Information as described below, within our group, with our partners, with service providers that process data on our behalf and with public authorities, as required by applicable law. If you do not agree to such disclose, please stop to use our products. Our disclosure will be based on anonymization of your Personal Information. And our processing is only undertaken for the purposes described in this Privacy Policy. If we disclose your Personal Information, we require its recipients to comply with adequate privacy and confidentiality requirements, and security standards.

7.1 Cookies and other Tracking Technologies

Cookies are frequently used on our websites. A cookie is a unique text file our websites send to your explorer software. This helps customers customize the information based on browsing preferences. We do not link the information we store in cookies to any personal information you submit while on our sites.

Cookies are used to personalize web pages and / or recognize you when you are accessing our websites, in order to conveniently browse and access our websites after having registered for our products, services and/or other support services.

Cookies are also used to trace your access to our websites. We will acquire information in personal, identifiable modes including your IP address. However, such information will merely be used for analysis and will be limited to the use according to the minimum requirement for the execution of such analysis.

If you do not want us to transfer Cookies into your web browser, you may change your web browser setting to refuse Cookies or notify you when any website is attempting to this transaction. This refusal shall affect your option to use certain products and/or services provided on our websites.

7.2 Network beacons

Network beacons on our websites and in our products and services analyzes traffic mode, such as the frequency of use on a specific part of the websites. The acquired data will help us learn about the kind of information our customers are most interested in, and what preferential terms our customers are most interested in obtaining. With respect to our websites, if you are unwilling to allow such data collection which help us improve our websites, you may refuse such website analysis by disabling JavaScript on your computer. If you disable JavaScript, some functions on our websites may not be able to operate normally.

We can also use network beacons in promotional emails to further determine whether emails have been opened and/or acted upon. We develop more your favorite sales promotional activities according to the information thus provided by email responses. Except for the email address you previously provided, the information collected would not identify you.

By means of various tracing technologies as mentioned above, we can trace the domain names, IP addresses and the type of explorer used by the users who access our websites and use our products or services. We use such information to trace the traffic modes congregating on the whole website. Such information is independent of any personal information the user may otherwise provide in using our products and services.

7.3 Analytics Tool

We use analytical tools,including third-party analytical tools, which allow us to, among other things, identify potential performance or security issues with our products, improve their stability and function, understand how you use our products, and websites, so that we can optimize and improve your user experience, as well as evaluate and improve our campaigns. We use Service and Device data for analytics. While we generally prefer using our own analytical tools, we sometimes need to partner with other parties, which have developed and provide us with their own tools and expertise.

7.4 Public Authorities

In certain instances, it may be necessary for us to disclose your Personal Information to public authorities or as otherwise required by applicable law. No Personal Information will be disclosed to any public authority except in response to:

7.5 Mergers, Acquisitions and Corporate Restructurings

Like any other company, we too go through its own cycle of growth, expansion, streamlining and optimization. Its business decisions and market developments therefore affect its structure. As a result of such transactions, and for maintaining a continued relationship with you, we may transfer your Personal Information to a related affiliate.

If we are involved in a reorganization, merger, acquisition or sale of our assets, your Personal Information may be transferred as part of that transaction. We will notify you of any such deal and outline your choices in that event, when applicable.

7.6 Discussion group/forum/blog/social media

The information you submit on any discussion group, forum, or blog will be regarded as public information instead of confidential information. The information released in these areas is at risk of being collected and used by others. Please be cautious and responsible when submitting information when you are online. To request removal of your personal information from our blog or community forum, contact us at privacy.lexing.ltd@outlook.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

7.7 Advertising Companies

To be able to offer our products and services for free, we serve third-party ads of advertising companies in our products for mobile devices. To enable the ad, we embed a software development kit (“SDK”) provided by an advertising company into the product, which then collects Personal Data in order to personalize ads for you. Please note that only few of our free products serve third-party ads. You will be asked for consent during the installation process of such product. For further information, including the exact scope of processed Personal Data and names of relevant products, below includes the list of our advertising partners and their privacy policy.

Advertising Partner

Provider

Data Categories Processed by Advertising Partner according to its Privacy Policy

AdMob

Google

Google declares to process an advertising ID from the device on which ads are serving to generate interests and demographics (for example, “sports enthusiasts“). Interests, demographics, and other data may be used to serve better targeted ads to the user via the Google Mobile Ads SDK.

https://policies.google.com/privacy

https://support.google.com/admob/answer/9012903?hl=en-GB

https://support.google.com/admob/answer/2753860#Interest_based

Facebook Audience Network

Facebook

Facebook declares to process information about your activities off Facebook, including information about your device, the ads you see, and how you use our mobile application, whether or not you have a Facebook account or are logged into Facebook.

https://www.facebook.com/privacy/explanation

https://developers.facebook.com/docs/audience-network/policy/

InMobi

InMobi

InMobi declares to process (i) Information about your device to improve their services - device type, operating system, network provider, mobile browser used, platform, SDK version, timestamp, API key, application version, iOS Identifier for Advertising, iOS Identifier for Vendors, model, manufacture of device, OS version of device, session start/stop time, locale (specific location where a given language is spoken), time zone, network status such as Wi-Fi, geo-location of your device (using GPS or other geolocation data) and the Identifier for Advertising (IDFA) or the Google Advertising ID (AAID) etc. In some countries, InMobi also collects information such as international mobile equipment identity (IMEI), Internet (IP) addresses or geo-location data; (ii) Information about ads presented on your device - content type of the ad, ad type, where the ad is being served, certain information about post-click activity in relation to the ad including user interaction with such ad.

https://www.inmobi.com/privacy-policy-for-eea/

MoPub

Twitter

Twitter declares to process through MoPub (i) Device identifiers such as your IP address, iOS Identifier for Advertising (IDFA), Android Advertising ID, or a MoPub-specific identifier; (ii) Yourprecise geo-location, when location services have been enabled for an app on your device that has integrated MoPub. Note that when location services have not been enabled in any of your apps that have integrated MoPub, Twitter will still infer data about your location based on your IP address; (iii) Information about your device, such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), and screen size; (iv) Information about your app usage, including the apps on your device that use MoPub and the version of such apps, the app on your device that is requesting an ad, the start/stop time of your app session, your current time zone, and your network connection type (e.g., WiFi, cellular); (v) Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or downloaded the advertiser’s app.

https://www.mopub.com/legal/privacy/

https://www.mopub.com/legal/partners/

AppLovin

AppLovin

AppLovin declares to process through AppLovin SDK (i) Device make, model and operating system; (ii) Device properties related to screen size & orientation, audio volume and battery, device memory usage; (iii) Carrier; (iv) Operating system; (v) Name and properties of mobile application through which a consumer interacts with the Services; (vi) Country, time zone and locale settings (country and preferred language); (vii) Network connection type and speed; (viii) IP Address; (ix) Internet browser user-agent used to access the Services; and (x) Identifier for advertisers (IDFA).

https://www.applovin.com/privacy/

Unity

Unity Technologies

Unity declares that it collects through its ads device information, like IP address and device identifiers, and information regarding the delivery of ads and your interaction with them, all of which may be shared with ad publishers and attribution companies. Additional data about you may be tracked in the future for purposes of making these types of predictions, and we will notify you prior to new data collection.

https://unity3d.com/legal/privacy-policy

8 Disclaimers

In case any competent government authority requests us to disclose any personal user identification information in accordance with relevant legal procedures, laws or regulations, we will provide such personal user information according to the requirements of the government authority or for the purpose of public safety. We will assume no liability for any disclosure in such case.

We will not assume any responsibility for any of your personal information that is disclosed for your own reasons (for example, when you voluntarily disclose to other people your password or when you share your account with other people).

We assume no responsibility for any personal information that is lost, disclosed, or falsified due to forces beyond our control, including but not limited to events that may affect normal network operations, such as hacker attack, intrusion or attack of computer virus and temporary closure of websites due to government regulations or actions.

We assume no responsibility for the disclosure of personal particulars or other customer information caused by (i) the other websites linked with our website or referred to in our website, products or services; (ii) third party software or coding incorporated in our website, products or services; or (iii) the incorporation of any part of our products into the websites, products or services provided by third parties, as well as any legal dispute and consequence resulting from any of (i)-(iii).

We assume no responsibility when it or a third party uses your personal information in accordance with provisions of relevant laws or regulations or this privacy policy.

We assume no responsibility when your personal information is disclosed due to unpredictable and inevitable risks of the internet, including without limitation: virus attack, hijacking, temporary site closure or server closure resulted from government control and inevitable technical defects of the software due to technical level at the time of development.

9 Your Privacy Rights

You have the following rights regarding the processing of your Personal Information:

9.1 Right to information - Right to receive information about the processing of your Personal Information, prior to processing as well as during the processing, upon request.

Right of access - Aside from the information about the processing of your Personal Information, you have the right to receive a copy of your Personal Information undergoing processing.

9.2 Right to rectification - We should process accurate Personal Information; if you discover inaccuracy, you have the right to seek rectification of inaccurate Personal Information.

9.3 Right to erasure ("right to be forgotten") - You have the right to erasure of your Personal Information, but only in specific cases stipulated by law, e.g., if there is no legally recognized title on our part for further processing of your Personal Information.

9.4 Right to object - Applies to cases of processing carried out in legitimate interest. You have the right to object to such processing, on grounds relating to your particular situation, and we are required to assess the processing in order to ensure compliance with all legally binding rules and applicable regulations. In case of direct marketing, we shall cease processing Personal Information for such purposes after the objection.

9.5 Right to withdraw consent - In the case of processing based on your consent, you can withdraw your consent at any time, by using the same method (if technically possible) you used to provide it to us (the exact method will be described in more detail with each consent when you provide it). The withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.

9.6 Right to restriction of processing - You have the right to restriction of processing of your Personal Information if: You are contesting the accuracy of your Personal Information, for a period enabling us to verify the accuracy of your Personal Information; the processing is unlawful and you oppose the erasure of the Personal Information and request the restriction of its use instead; we no longer need the Personal Information for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; or you have objected to processing of your Personal Information, and there is a pending verification whether our legitimate grounds override your interests.

The fulfillment of data subject rights listed above will depend on the category of Personal Information and the processing activity. In all cases, we strive to fulfill your request. We will action your request within 15 days of receiving a request from you concerning any one of your rights as a Data Subject. Should we be inundated with requests or particularly complicated requests, the time limit may be extended to a maximum of another two months. If we fail to meet these deadlines, we would, of course, prefer that you contact us to resolve the situation informally.

10 Policy modifications

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If we make material changes to how we use Personal Information collected from children under age 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child's Personal Information.

11 Access to Personal Information

11.1 If yours or your child’s personally identifiable information changes, or if you no longer desire our service, you may correct, update, delete inaccuracies or remove it by making the change on our member information page or by emailing us at privacy.lexing.ltd@outlook.com. We will respond to your request to access within 15 days.

Parents have the right to access their child’s information, refuse further collection and use, request to have it deleted or request that we no longer have further contact with their child by accessing their child’s account through the Web site or by emailing us at privacy.lexing.ltd@outlook.com.

11.2 Data Retention: We will retain yours or your child’s information (including geo-location data) for as long as your account is active or as needed to provide services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at privacy.lexing.ltd@outlook.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

12 Contact us

We have appointed an executive agent for our privacy protection policy, who will be responsible for our compliance with the privacy criteria as described in this statement.

If you have any questions or concerns regarding this Privacy Policy, would like to modify the communications option, update or refer to your personal information we possess, or withdraw your decision to allow us to collect, use or publish your personal information, please feel free to contact us at any time:

Email: privacy.lexing.ltd@outlook.com

Lexing Yingda
Room 02B-412, 2nd Floor, Tower C
No. 28 A Information Road
Haidian District, Beijing
We will contact you within 15 days from the receipt of your contact, and will do our best to resolve any problem you have.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, we agree to dispute resolution using JAMS as an independent third party dispute resolution provider.

We prohibit the download of our products and services by residents of countries sanctioned by the U.S. Office of Foreign Assets Control.