ChapMali Privacy Policy

Issuing Entity: This Privacy Policy (hereinafter referred to as "this Policy") is formulated and implemented by FUTUREINNO DIGITAL TECH LIMITED (hereinafter referred to as the "Company" or "we"). We operate the digital credit limit loan application (hereinafter referred to as "this Application" or "ChapMali") under the "ChapMali" brand, focusing on providing personal credit loan services to users within the Republic of Kenya.【We hold relevant qualifications for digital credit services recognized by the Central Bank of Kenya, and conduct credit business in compliance with regulations.】We respect the privacy of users (hereinafter referred to as "you") and will take strict measures to protect the security of your personal information in accordance with this Policy. This Policy provides detailed explanations of the types of personal information we collect, how we share information with third parties, and how you can manage your information preferences.

Last Updated: [June 17, 2026]

Scope of Application: This Policy applies to all our behaviors of collecting, using, storing, sharing, transmitting and protecting your personal information during your download, registration, use of this Application and related services. Your use of any service of this Application shall be deemed that you have fully read, understood and agreed to all terms of this Policy.【This Policy strictly complies with Kenya's Data Protection Act, 2019, Financial Institutions Act, Non-Deposit Taking Credit Providers Regulations, Bank (Credit Reference Bureaus) Regulations, Anti-Money Laundering and Counter-Terrorism Financing Act.】

1. Consent and Authorization Statement

By downloading, installing and using this Application, you confirm and agree to the following matters:

You agree that we collect, process, store and legally share your personal information for legitimate business purposes (including identity verification, credit assessment, loan approval and disbursement, repayment management, anti-fraud risk control, etc.), and all behaviors shall strictly comply with the Kenya Data Protection Act, 2019, Financial Institutions Act and other relevant laws and regulations. You understand and confirm that you have the right to withdraw your consent at any time, and the withdrawal of consent shall not affect the legality of information processing activities carried out based on your consent before the withdrawal.
You warrant that all personal information provided to us is true, accurate and complete, and undertake to update it through the designated channel in this Application or official customer service in a timely manner after the information is changed. You shall bear corresponding responsibilities for any losses caused by your intentional provision of false or misleading information.
You authorize us to verify the authenticity of the information provided by you through third parties such as government agencies and licensed credit reference agencies (e.g., TransUnion Kenya, Metropol Credit Reference Bureau), and obtain supplementary information related to your credit status within the scope permitted by law for credit assessment.
【The various authorizations granted under this Policy are independent and separable granular authorizations, not bundled authorizations. You may separately reject a certain authorization without affecting other services.】 You expressly authorize us and our compliant third-party partners to query the following data. The query behaviors shall strictly comply with relevant laws and regulations of Kenya and industry standards, and shall only be used for identity verification, credit assessment and anti-fraud risk control, and shall not be used for other purposes not agreed in this Policy:

1. Mobile phone number verification: Query the authenticity and compliance of the mobile phone number you provided, to confirm the validity of your account binding, and prevent fraud risks such as false registration and mobile phone number impersonation;

2. ID number verification: Query the authenticity, validity and information consistency of the name, gender, date of birth, place of birth and residential address corresponding to the ID number you provided, in compliance with the regulatory requirements of "Know Your Customer (KYC)", verify the legality of your identity, and prevent violations such as identity impersonation and false applications;

3. CRB credit report query: Authorize us to query your personal credit report from the Credit Reference Bureaus (CRB) authorized by the Central Bank of Kenya, including but not limited to your credit record, historical performance status, overdue record and other relevant information, to comprehensively assess your credit status, repayment ability and loan risk, and provide a core reference basis for loan approval and credit limit determination. The query behavior complies with the Bank (Credit Reference Bureaus) Regulations (2008) and relevant regulatory requirements.

4. Authorize us to report your performance and overdue information to CRB in accordance with the law when you are overdue.

You acknowledge and agree that, to the extent necessary for the provision of services, we will share necessary information with third-party service providers on the premise of signing a Data Processing Agreement (DPA) and strict data protection agreements with them. You have the right to request us to stop sharing part of your information with specific third parties through the channel specified in the "Contact Us" section of this Policy.
You understand that the legal basis for us to process your personal information includes your consent, performance of a contract, performance of legal obligations or protection of legitimate interests. Withdrawal of consent may result in the inability to continue using some service functions. Among them, withdrawal of authorization related to data query will result in the inability to complete identity verification and credit assessment, and thus the inability to use core services such as loan application of this Application.

2. Definition of Core Terms

·Personal information: Refers to any information directly or indirectly related to an identifiable natural person, as defined in Section 2 of the Data Protection Act, 2019.·Sensitive personal information: Refers to information revealing personal sensitive aspects such as financial status, biometric information, credit information, family relationships, etc., for which we will adopt strict protection measures.·Credit reference agency: Refers to institutions authorized by Kenyan regulatory authorities to engage in credit information services, including Credit Reference Bureaus (CRB) authorized by the Central Bank of Kenya.·Cooperative service provider: Refers to third parties providing us with technical support, payment processing, data query and other services, which must comply with confidentiality obligations equivalent to this Policy and sign data processing agreements.·Compliant device identifier: Refers to device identification information that complies with data protection specifications, such as IDFA (Identifier for Advertising), IDFV (Identifier for Vendor).

3. Personal Information We Collect

We strictly follow the principle of "minimum necessity" and only collect information necessary to achieve the purpose of service, which is mainly divided into the following three categories:

3.1 Personal Information You Actively Provide

During registration and loan application, you need to provide the following necessary information to complete the service process:·Mobile phone number: As the core account for you to register and log in to this Application, and used to receive important transaction notifications, security verification and service communication, as well as the core query basis for mobile phone number verification.·Name: Used for identity recognition and confirmation of the loan contract subject to ensure the authenticity of account ownership;·ID number: In accordance with the regulatory requirements of "Know Your Customer (KYC)", used to verify the legality of your identity and civil capacity, prevent identity impersonation, and serve as the core query basis for ID number verification;·Gender and date of birth: Gender information is used to optimize service adaptation, and date of birth is used to confirm that you are over 18 years old (the legal loan age in Kenya). Both are used as auxiliary reference factors for credit assessment;·[Marital status and education level: optional information, which does not affect loan access and credit limit, and shall not be used as a discriminatory basis]·City of residence: Used to confirm the service coverage area, and serve as an auxiliary assessment factor combined with the regional credit environment.·Occupation and monthly income: Core credit assessment basis, used to judge your repayment ability, and determine the credit limit and loan conditions accordingly;·Emergency contact information: Including name, relationship and phone number. You expressly authorize that we may use this information for the purpose of establishing contact only when you are seriously overdue and we cannot contact you through the registration method you provided. We will strictly implement in accordance with the Kenya Data Protection Act, 2019 and fair debt collection guidelines to ensure that the communication content is minimized and non-harassing.

3.2 Application Permission Information You Authorize

We will only request the following device permissions after obtaining your explicit consent. You can manage or turn off these permissions at any time through device settings, but turning off some permissions may affect the normal use of relevant services.

Camera permission: Only invoked in the following two specific scenarios, and the permission will be released immediately after the operation is completed, without background shooting or storing irrelevant images: a. Loan application stage: Used for face recognition identity verification to comply with KYC regulatory requirements, further confirm the authenticity of your identity, and prevent fraud risks such as identity impersonation and false applications; b. Repayment stage: Used to take and upload repayment vouchers (such as M-Pesa transfer screenshots, bank receipts, etc.) to verify the repayment fact and ensure accurate and traceable repayment records;
Device information permission (iOS version): We will not collect hardware identifiers such as IMEI or device serial numbers. We only collect device model, operating system version, compliant device identifiers (IDFA or IDFV), and information related to mobile network and battery. This information is used to identify device identity to prevent fraud, optimize application compatibility and performance. Among them, the advertising identifier (IDFA) can be reset or closed for advertising tracking functions by you in device settings.

3.3 Information Obtained from Third Parties

To supplement and improve your credit assessment model and verify the authenticity of information, we may obtain your relevant information from the following third parties in compliance with the laws and regulations of Kenya:·Affiliated parties and partners of the platform: Obtain necessary supplementary information related to your service usage, for service connection and experience optimization;·Licensed credit reference agencies (CRB): Obtain your credit report, historical performance records and other information, for credit risk assessment, based on the CRB credit report query authorization you made in Chapter 1 of this Policy;·Data query service providers (Peleza three-element verification service): Obtain your mobile phone number verification results (verify whether the real-name user of the customer's mobile phone number is consistent with the customer's ID number), ID number verification results (verify information corresponding to the customer's ID number: name, gender, date of birth, place of birth, residential address), for identity verification and anti-fraud risk control.

In addition, to realize specific functions, we may access third-party Software Development Kits (SDK), which may collect and use your information. For details of SDK, including the types of information they collect and processing purposes, please refer to the detailed description in the section "5.5 Third-Party Software Development Kits (SDK)" of this Policy.

4. Purposes of Using Personal Information

The information we collect is used only for the following purposes directly related to services and not beyond the necessary scope:

Account Creation and Management: Completing registration using mobile numbers, verifying identity information to ensure account ownership, implementing basic functions such as login, password recovery, and information queries;

Identity Verification and Credit Assessment: Verifying identity authenticity through personal information, assessing repayment ability by combining mobile number verification, ID number verification results, and CRB credit report information, determining loan eligibility and credit limits;

Full Loan Process Support: Covering loan application review, contract generation, disbursement, repayment reminders, and debt collection for overdue accounts (contacting through authorized emergency contacts when necessary), ensuring smooth and compliant service delivery;

Fraud Prevention and Risk Control: Establishing risk identification models combining device information, personal background data, and mobile number/ID number verification results to prevent abnormal behaviors such as false registrations and identity impersonation;

Service Optimization: Improving App performance and experience based on usage data without conducting personalized marketing profiling unrelated to credit services;

Service Optimization and Personalized Recommendations: Recommending suitable loan products according to your needs, optimizing App performance and user experience;

Compliance and Legal Fulfillment: Responding to lawful requests from regulatory authorities, complying with KYC and Anti-Money Laundering (AML) regulations, retaining necessary information to address potential legal disputes;

Customer Service Response: Using your contact information and account details to promptly handle inquiries, complaints, and feedback, retaining communication records for audit purposes.

5. Sharing, Transfer and Public Disclosure of Personal Information

We strictly abide by the obligation of data confidentiality and will not sell or rent your personal information to any third party. We will only share, transfer or disclose information to a limited extent under the following statutory or agreed circumstances:

5.1 Sharing

Cooperative service providers: Share necessary information with third parties providing technical support, payment processing, customer service, data query (including mobile phone number verification, ID number verification, CRB credit report query) (e.g., provide your identity information to CRB to query credit report, provide your mobile phone number and ID number to data verification service providers to complete verification). Such third parties shall sign a Data Processing Agreement (DPA) with us to clarify confidentiality obligations, and may only use information for the purpose of providing services. We will supervise their data processing behaviors.
Affiliated parties and cooperative institutions: Share information within the scope necessary to obtain your explicit consent or to achieve service purposes. Affiliated parties and cooperative institutions have no right to use information for purposes not agreed in this Policy.
Credit reference and debt collection agencies: When you are overdue and fail to repay after multiple contacts, provide necessary information (name, outstanding amount, emergency contact information) to legal debt collection agencies to assist in debt collection; report your performance records (including overdue records) to licensed credit reference agencies to fulfill the obligation of credit information reporting.
To improve services, conduct anonymized macro trend analysis or develop commercial insights that do not identify individuals, we may analyze de-identified overall data. Such analysis will not identify or associate with any specific individual.

CBK & CRB Reporting Statement

Your data will be reported to Kenya's licensed Credit Reference Bureaus (CRBs) when you successfully obtain a loan. The submitted fields are as follows:

Personal Data: Surname, Forename 1/2/3, Date of Birth, Gender, Nationality, Primary ID Type and ID Number, Mobile Phone Number
Basic Loan Data: Account Number, Account Product Type, Original Amount, Facility Currency
Financial Data: Current Balance, Overdue Balance, Instalment Amount
Arrears & Status Data: Days in Arrears, Instalments in Arrears, Account Status, Prudential Risk Classification
Repayment Data: Last Repayment Date, Next Repayment Date, Last Repayment Amount, Next Repayment Amount

In compliance with CBK rules, we report loan data on a daily and monthly basis. We will notify you via SMS within 30 days after your credit information is first reported to a CRB. Overdue amounts not exceeding 1,000 Kenyan Shillings will not be reported as negative credit information. If adverse records are to be reported, you will receive 7 days' pre-notice via SMS before such reporting. Credit records are retained by CRBs for up to 5–7 years as required by law, depending on the nature of the information.

No data will be transmitted to CRBs if you do not obtain a loan.

You have the right to access your credit report from any licensed CRB and dispute any inaccurate information. Your personal data stored on our platform will be automatically deleted within 90 days after your account is closed, subject to legal retention requirements for credit information.

5.2 Transfer

We will not transfer your personal information to any company, organization or natural person, except in the following circumstances:·In the event of corporate restructuring transactions such as merger, acquisition and asset transfer, information is transferred as part of transaction assets. We will notify you before the transfer and require the transferee to continue to abide by this Policy. Re-obtain your explicit consent when changing the purpose of information use;·Obtain your explicit consent or authorization in advance;·Must transfer in accordance with laws and regulations or mandatory administrative and judicial requirements.

5.3 Public Disclosure

Publicly disclose your personal information only in the following circumstances:·Comply with the mandatory requirements of applicable laws and regulations;·You have violated laws and regulations or service agreements, and it is necessary to disclose relevant information (including violations, judicial documents, measures taken, etc.) to protect the rights, property and safety of us, affiliated parties, other users or the public;·Personal information you voluntarily disclose to the public or collected from legally publicly disclosed information.

5.4 Circumstances Where Consent Is Not Required

In accordance with relevant laws and regulations and national standards, sharing, transferring and publicly disclosing your personal information in the following circumstances does not require your consent:·Related to the performance of obligations stipulated by laws and regulations;·Directly related to national security and defense security;·Directly related to public safety, public health and major public interests;·Directly related to criminal investigation, prosecution, trial and judgment execution;·For the purpose of protecting your or other individuals' life, property and other major legitimate rights and interests but difficult to obtain your consent;·In accordance with the provisions of laws and regulations and the requirements of competent authorities, Kenya Internet Finance Association and other industry organizations.

5.5 Details of Third-Party Software Development Kits (SDKs)

To ensure implementation of functions related to this App and secure stable operation, we may integrate Software Development Kits (SDKs) provided by third parties. We conduct strict security assessments and require them to adopt strict data protection measures in accordance with this Policy and relevant agreements.

Details of the main third-party SDKs we integrate are as follows:

Adjust SDK: Provided by Adjust GmbH. For app installation attribution, statistical analysis, measuring advertising effectiveness, and preventing fraud, this SDK collects your device identifiers (such as Advertising ID), IP address, and app interaction events. For more information, please refer to its Privacy Policy: https://www.adjust.com/terms/privacy-policy/

Firebase Analytics SDK: Provided by Google Ireland Limited. For statistically analyzing app performance, understanding user behavior to improve product experience, and troubleshooting crashes, this SDK collects your device identifiers, app usage data (such as feature clicks), device model, and operating system version information. For more information, please refer to Google's Privacy Policy: https://policies.google.com/privacy

Facebook SDK: Provided by Meta Platforms, Inc. For statistical analysis, measuring and optimizing advertising effectiveness, this SDK collects your device identifiers, app usage data, and advertising interaction data. For more information, please refer to Meta's Privacy Policy: https://www.facebook.com/privacy/policy/

You may also reset or restrict advertising identifiers (such as Apple's IDFA) for ad tracking through your device operating system settings.

6. Storage and Security Protection of Personal Information

6.1 Storage Method and Location

We are the data controller of your personal information. All information is transmitted via encryption technology to secure servers located within Kenya for storage. If data needs to be transmitted outside Kenya for storage or processing (such as using international cloud services), we will ensure compliance with cross-border data transmission specifications of the Data Protection Act 2019, safeguarding information security through encrypted transmission and signing Data Processing Agreements. Your information may be stored on financial cloud infrastructure, and we will take all reasonable and necessary measures to ensure secure data processing in compliance with this Policy.

6.2 Security Protection Measures

We adopt multi-layered security measures to fully protect your information security, meeting financial application security standards:

Data Encryption: HTTPS protocol encryption during transmission, AES-256 encryption for storage, additional desensitization of sensitive information; also adopting de-identification and other security technical measures to strengthen information protection;

Access and Permission Control: Establishing data classification management systems, encrypting sensitive information such as mobile numbers and ID numbers throughout the process; setting strict access and operation permissions, monitoring access behavior in real-time, and retaining logs; compliant device identifiers undergo hash normalization processing to avoid plaintext transmission and storage;

Security Audit and Emergency Response: Regularly inviting third-party security institutions to conduct security audits and timely fixing vulnerabilities; establishing emergency response mechanisms; if security incidents such as information leakage occur, we will notify you and relevant regulatory institutions in a timely manner as required by law;

Third-Party Compliance Management: Conducting security qualification reviews of cooperative service providers (including data query service providers, CRBs, etc.), requiring them to observe equivalent data protection standards, and periodically reviewing compliance.

Please note that Internet transmission cannot achieve 100% absolute security. Due to the limitations and rapid development of technology, as well as the existence of various malicious attack methods, even if we try our best to strengthen security measures, we cannot always guarantee 100% security of information. If your legitimate rights and interests are damaged due to unauthorized access, public disclosure, tampering or destruction of information caused by the destruction of our physical, technical or management protection facilities, we will bear corresponding responsibilities in strict accordance with the law; if information security risks are caused by your own reasons (device theft, password leakage), the responsibility shall be borne by you. After receiving your information, we will immediately activate the above security measures for protection.

7. Your Rights Regarding Personal Information

In accordance with Kenya's Data Protection Act 2019, you enjoy the following rights regarding your personal information, and we will facilitate the exercise of your rights: You have the right to understand how we process your personal information. We explain through this Policy the methods of collection, use, storage, and provision of information, and provide you with means to query, update, delete, and protect such personal information.

7.1 Specific Rights Content

Right of Access: You may request a copy of all personal information we have collected about you, including processing purposes, scope of sharing, retention periods, etc.; you have the right to access personal business-related information, including historical application information, transaction information, data query records (mobile number verification, ID number verification, CRB credit report query records), or other information not displayable within the App;

Right to Rectification: If information is inaccurate or incomplete, you may request correction or supplementation (e.g., occupation and income changes can be modified through "Profile Center" or with assistance from customer service); when you discover errors in personal information about you that we process, you have the right to require us to correct it;

Right to Erasure: When information is no longer necessary for service purposes, we engage in unlawful processing, or you withdraw consent, you may request deletion of personal information (you may apply independently through "Profile Center - Account Deletion" or with assistance from customer service); you have the right to actively request cancellation of your personal account;

Right to Restrict Processing: When there is dispute regarding information accuracy or processing behavior, you may request suspension of information processing until the dispute is resolved;

Right to Data Portability: You may request that we provide your personal information in a structured, commonly used, and machine-readable format for transfer to other service providers (provided free of charge);

Right to Withdraw Consent: You may withdraw consent for device permissions and information processing at any time (permission withdrawal is completed through device settings; withdrawal of information processing consent requires contacting customer service); withdrawing data query-related authorizations will make continued use of core services such as loan applications unavailable;

Right to Disable Ad Tracking: Devices may disable IDFA usage permission through "Settings - Privacy & Security - Tracking".

[Right to Account Cancellation: Supports one-click account cancellation within the APP; after cancellation, information is deleted or anonymized in accordance with regulations]

[Right to Complaint: If dissatisfied with processing behavior, you may file a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya]

7.2 How to Exercise Rights

If you wish to exercise the above rights, please send an application via the official email address specified in the "Contact Us" section of this Policy, indicating your name, registered mobile number, and specific requirements. We will verify and respond within 14 working days of receiving your application. To protect information security, we may require you to provide identity verification materials. For requests that clearly lack legal basis or are repeatedly submitted, we reserve the right to refuse processing after stating our reasons in accordance with the law.

You may leave messages to query or correct information through this App's "Profile Center - Settings - Feedback," and we will respond within 5 working days. You may also apply for account cancellation through this path or customer service channels (account cancellation can be completed by entering "Profile Center - Settings - Cancel Account").

8. Retention Period of Personal Information

We only retain your personal information for the necessary period to achieve the purposes stated in this Policy, following the principle of "minimum retention period":·Information related to loan services: Retained for 3 years after all loan principal and interest are settled, and automatically anonymized after expiration;·Credit and performance-related information: Retained until the limitation period for relevant legal actions expires (usually 6 years) in accordance with the Data Protection Act, 2019 and financial regulatory requirements, and this retention requirement has been filed with credit reference agencies;·Data query related records (mobile phone number verification, ID number verification, CRB credit report query records): Retained for 3 years after all loan principal and interest are settled, automatically anonymized after expiration, and may be extended to the limitation period for relevant legal actions if required for compliance review;·Marketing-related information: Retained until the date you explicitly decline to receive marketing information (you can turn off marketing push through "Settings - Message Notifications");·Compliant device identifiers: Retained only for the necessary period for fraud prevention and security analysis, regularly rotated and anonymized.

When the information exceeds the retention period or is no longer necessary for services, we will process it through anonymization (unable to identify personal identity) or secure deletion, and deletion records will be retained for at least 1 year for future reference.

9. Protection of Minors' Personal Information

We attach great importance to the protection of minors' personal information. Kenyan law stipulates that natural persons under the age of 18 are minors and do not have independent loan application qualifications. Our products and/or services are not intended for minors under the age of 18. We will never intentionally provide loan services to minors, nor will we take the initiative to collect minors' personal information or request relevant device permissions, let alone conduct mobile phone number verification, ID number verification and CRB credit report query on minors.

If you are a minor under the age of 18, please stop using ChapMali's products and services immediately. If we find that minors' personal information has been collected due to misoperation, we will take the initiative to delete the relevant information and terminate the provision of services within 7 working days after discovery.

If the guardian of a minor finds relevant situations or has questions about the information processing of the minor under guardianship, please contact us in a timely manner, and we will fully cooperate with the handling.

10. Changes to This Policy

To adapt to the update of laws and regulations, adjustment of business model or optimization of application functions, we may revise this Policy. After the change, we will notify you through pop-up windows, announcements, etc. in this Application, and update the "Last Updated" date; if the change involves your core rights or major adjustment of information processing rules, we will notify you separately by SMS, and you need to reconfirm your consent before continuing to use the service.

To provide you with better services, this Policy will be updated from time to time with the development of our business. However, without your explicit consent, we will not reduce the rights you enjoy under this Policy. We will announce the changes to this Policy through reasonable means such as publishing announcements on the website and application, and remind you of the content update before the change takes effect. Continued use of our products and/or services shall be deemed that you agree to the revised terms.

In the event of major changes, we will notify you in a more prominent manner (including but not limited to application announcements, SMS or special prompts on browsing pages, explaining the specific changes to the privacy policy). To ensure that you can receive notifications in a timely manner, we recommend that you notify us in a timely manner when your contact information is updated.

We recommend that you check this Policy regularly to keep abreast of the latest privacy protection measures. Continued use of this Application service shall be deemed that you agree to the revised terms.

11. Contact Us

If you have any questions about this Policy, need to file a complaint or report, or wish to exercise rights related to personal information (including querying and withdrawing data query authorization), or have any questions about our business, please contact us through the following ways:

Official customer service email: contact@futureinno.co.ke
In-application feedback: Enter ChapMali APP, click "Personal Center - Settings - Feedback" to leave a message.

We will contact you within 5 working days after receiving your email or message, and solve the problem or give a clear reply within 14 working days. If you are dissatisfied with the response result, you may further complain to the Office of the Data Protection Commissioner (ODPC) of Kenya.

12. Disclaimer

·This Policy is formulated in accordance with the Kenya Data Protection Act, 2019, Financial Institutions Act, Kenya Information and Communications Act, Bank (Credit Reference Bureaus) Regulations (2008). If there is a conflict with legal provisions, the legal provisions shall prevail;·We will take reasonable industry standard measures to protect your information, but we shall be exempt from liability to the extent permitted by law for losses caused entirely by force majeure or your own reasons, or losses directly caused by the unilateral breach of contract of such third parties under the premise that we have fulfilled reasonable duty of care and signed strict data protection agreements with third-party service providers (including data query service providers, CRB, Peleza, etc.);·This Application may contain third-party links or services. We are not responsible for the privacy policies and information processing behaviors of third parties. It is recommended that you carefully read the third-party policies. The specific situation of third-party SDKs (Software Development Kits) accessed by us processing your personal information has been explained in detail in Section 5.5 "Third-Party Software Development Kits (SDKs)" of this privacy policy;·You agree that the legal results arising from our use and sharing of your information in accordance with this Policy are within your authorization scope. If information leakage is caused by third parties (such as cooperative service providers, SDK providers, data query service providers, CRB, Peleza, etc.) who have violated their legal obligations or agreed terms under the constraints of the reasonable and necessary measures we have taken, we will require them to bear responsibility in accordance with the law and provide you with necessary assistance to protect your legitimate rights and interests. However, this does not exempt us from the liability we may bear as a data controller in accordance with applicable laws;·Although this platform adopts industry standard practices to protect your personal information, due to technical limitations, this platform cannot ensure that all your private communications and other information will not be leaked through channels not listed in this privacy policy.

Last Updated: June 17, 2026