MiniShort.com Privacy Policy

Introduction

This MiniShort.com Privacy Policy (hereinafter referred to as the “Privacy Policy” or “this policy”) applies to all products and services of MiniShort.com (hereinafter referred to as the “our Platform”), including, but not limited to, any web pages, applications, small programs, and other client platforms directly owned or operated by us, and applicable terminals including but not limited to computer, Pad, mobile phones, TV, VR, smart home, vehicle, etc. Our platform is provided by MiniShort (“us” or “Company”) and we attach great importance to the privacy of our users. When you use our services, we will collect and use your relevant personal information and user information (hereinafter referred to as “Information”). We wish to explain to you through this policy how we collect, use, store, share, transfer, and disclose such information when using our services.

Important Note

Ownership and operation of our services and content are owned by MiniShort. Before you download, install, launch, browse, or in any way use our platform-related services, we strongly recommend that you read the following policy carefully. Your actual use of our platform will be deemed that you have read, understood, and accepted all the terms of this policy. Users shall not thereafter raise any form of defense without reading / not agreeing to the content of this policy or for similar reasons. If you do not agree to any of the following, which will cause our products and services not to function properly, or not to achieve the service results we intend to achieve, please stop accessing or using our products / services immediately. Once you use or continue to use our various products / services, you agree that we will use and process your personal information in accordance with this policy.

For terms in this policy that are significantly related to your interests (including but not limited to your Personal Information Interests) and the processing of sensitive personal information, we have prompted you to read in bold, underline or other reasonable ways.

If you do not reach the legal adult age required by the law of your country or do not meet the full civil capacity, you should read this policy with your legal representative and pay special attention to the section “Protection of Minors” section.

After reading this policy, if you have any questions about this policy or matters related to this policy, you can contact us through the feedback channels listed in the “How to Contact Us” section of this policy, and we will answer them for you as soon as possible.

Catalogue

A. How do we collect and use your personal information

B. How do we use Cookie and similar technologies

C. How do we share, transfer, and disclose your personal information

D. How do you exercise your rights related to your personal information

E. How do we store and protect your personal information

F. Protection of minors

G. Notice and revision

H. How to contact us

A、How do we collect and use your personal information

(a) We will collect and obtain your personal information through the following channels:

1. The information that you offer to provide to us

(1) Information you provide to us when registering our account or using our products / services;

(2) The shared information you provide to other parties through our products / services, and the information you store when you use our products / services.

2. Information that may be collected automatically

When you use or access the software and services, you may automatically collect the following information about you:

（1）We may legally and automatically obtain technical information on your browser or device when you access / use our services. This information may include device information (e. g., type, name and version of the operating system, application version, device model); Internet Service Provider (ISP), Internet Protocol (IP) address; WLAN status, and log information.

（2）We may legally and automatically collect certain use information related to your device use and interaction as we provide you with services, including software and services, such as when and how you use them, and how often you use them.

3. The legal basis of collecting and processing personal information

In some countries, a statutory requirement (the “legal basis”) is required to collect, use, disclose, or otherwise process your personal information. The legitimacy basis recognized by country / region varies, and the common basis of legitimacy include the following types:

(1) Get your consent (i. e., the data subject): We will seek your consent for the circumstances where the following legal basis cannot be applied.

(2) It is necessary to enter into or perform the contract between you and us: for example, it is necessary to process the relevant personal information in order to fulfill the User Services Agreement and provide our services to you.

(3) In order to fulfill our legal obligations: for example, according to the requirements of applicable laws and regulations, or the requirements of administrative and judicial organs, in order to fulfill our legal obligations and need to handle the corresponding personal information.

(4) It is necessary to realize the legitimate interests of us or a third party: for example, to safeguard the security and reliability of our services, and the legitimate interests of marketing activities, and need to process the corresponding personal information.

(b) We will collect and use your following types of personal information for the following purposes:

For the following purposes, we will collect the information you use the function or receive the service:

1. Ensure the basic functions of products and services, and maintain the network and operation security

(1) To ensure the safe operation and quality and efficiency of software and services, And to improve and optimize our service experience, We will collect your: login IP address and the version and device uniqueness ID used for the mobile device; Information that you search for or browse while using our services, Including the web search terms you use, the social media page url address you visit, Stay time, refresh records, release records, follow, subscribe, collect, share, and other information and content details that you browse or request when using our services; Information about the mobile app (APP) and other software you have used, And the information (metadata) contained in what you share through our service.

(2) we may use your account information, equipment information, service log information and our related parties, partners in your authorization or can provide information in accordance with the law, to determine the account and transaction security, authentication, identification of violation situation, detection and security incidents, and take the necessary records, analysis and disposal measures.

Please understand that these information is the basic information that we must collect to provide services and ensure the normal operation of the products. If you refuse to provide the above information, you may be unable to use our products and services normally.

2. Provide you with the service content browsing / playing service

When you use the browsing and playing function of our drama video service content, in order to provide you with continuous and consistent use experience and ensure the quality of service, we need to record your equipment information and personal Internet records. The aforementioned equipment information includes: IP address, operating system and version, system language

3. Provide you with a service content search service

When you use the search function, we will automatically collect some of your information, including the following personal information: the content of the search, the browsing record and time, the search time, and the number of times you interact with them. To provide efficient search services, some of this information is temporarily stored on your local device side and shows you the search history.

4. Study and analyze your use of these services

Based on our above information (including your OAID (Android, HarmonyOS), AAID (HarmonyOS), ODID (HarmonyOS), personal online records), Combine your advertising data (such as exposure, click, conversion data, etc., Only for advertising recommendations), In combination with the gender and birthday information you actively fill in (if any), the personalized label you actively choose (only applicable to the series video content recommendation) and other personal information explicitly authorized by you (if any), Through the systematic automatic analysis and calculation, Extract your preference characteristics, Recommend more relevant content / advertising / business information, optimize our display and search results, improve our recommendation mechanism, etc. Our recommendation algorithm does not identify the true identity of a specific natural person. In the process of making content recommendation to you, we strive to use advanced technology to properly protect your privacy.

5. Product / Service statistics and analysis

After the security encryption technology strictly to identify or anonymization processing, under the premise of unable to identify specific individuals, we may use the data collected for machine learning or algorithm model training, related research, testing, statistical analysis and prediction, to analyze our system problems, statistical traffic and identify possible risks, improve the content and layout of our platform and services, test the effectiveness of third party products and / or services, provide product or service support for business decisions, and improve our products and services.

6. Provide you with customer service or other user response functions

When you contact our customer service or use other user response functions (such as after-sale application, personal information protection complaints or suggestions, other customer complaints and needs), we need you to provide necessary personal information to match and verify your user identity, so as to ensure the security of your account and system. We will also save your contact information (you contact us or other contact information), your communication / call records and content, other necessary information associated with your needs, in order to contact you or help you solve problems, or record the processing solutions and results.

7. Provide you with goods, operation activities and other information

We may provide you with information on goods, operations and other activities through SMS for marketing purposes. If you do not want to receive the above information, you can unsubscribe at any time according to the SMS prompt or other methods provided by us.

8. You understand and agree that in the process of using MiniShort.com products / services, we will apply for access to you if necessary to enable the collection and use of the information involved in these permissions. Before opening the permission, we will inform you of the purpose of opening the permission and seek your permission. Please note that you open any authority on behalf of your authorization we can collect and use relevant personal information to provide corresponding services, once you close any authority on behalf of you cancelled the authorization, we will no longer based on the corresponding authority to continue to collect and use the relevant personal information, also cannot provide you with the authority of the corresponding service. However, your decision to close permissions will not affect the collection and use of information based on your authorization.

In different devices, the permission display mode and the shutdown mode are different, please refer to the equipment or system development instructions and guidelines. Your device system may open other permissions along with the necessary information authorization, and we cannot close the authorization manually or automatically.

Specific equipment authority invocation situation is as follows:

（1）Notice authority. When you use MiniShort.com products / services, if you want to receive the system or friends send you a notification, we will apply for access to your notification permission; you can set the notification permission by allowing permission popups.

（2）Clipboard. We collect your clipboard information when you use copy or adhesive operations in our products or services. Before collecting the information, we will seek your consent, and you have the right to choose to agree or refuse.

© Exception circumstances

In accordance with applicable laws and regulations, we collect, use and process your personal information under the following circumstances:

1. Necessary for the conclusion and performance of an individual contract as a party;

2. Necessary for the fulfillment of legal duties or obligations;

3. Necessary for responding to public health emergencies or for protecting the life, health and property of natural persons in case of emergencies;

4. To handle personal information within a reasonable scope for the purpose of news reporting and public opinion monitoring in the public interest;

5. To handle personal information disclosed by individuals or otherwise legally disclosed within a reasonable scope in accordance with the provisions of this Law;

6. Other circumstances as stipulated by the applicable laws and administrative regulations.

(d) Others

Please understand that as our business develops, there may be changes and changes to MiniShort.com features and services provided. In a scenario with no direct or reasonable connection to the original purpose, we will collect and use your personal information and inform you again and obtain your consent.

B、How do we use Cookie and similar technologies

Cookie and similar technologies are the common technologies in the Internet. When you use the platform and related services, we or our partners may use the relevant technology to send one or more Cookie or anonymous identifier, to collect and store your access, use the product information, including: your access to the site, your browsing information, your login information, in order to provide you with better quality service experience. We use Cookie and similar technologies mainly to implement the following functions or services:

(1) To ensure the safe and efficient operation of the products and services

We may set up Cookie or anonymous identifiers for authentication and security to confirm whether you are safely logging in to the service, or whether you have encountered theft or fraud. These technologies will also help us improve our service efficiency and improve our login and response speed.

(2) Help you to get an easier access experience

Using this technology can help you eliminate the steps and processes of filling in personal information and logging in frequently (realizing one-click login process and recording video production history).

(3) Recommended information and screening crash

In the sharing page of this software, we may use such technology to record browsing activities, to recommend information to you, to check for related abnormal situations of crashes, delays, and to explore better service methods.

While we use Cookie and similar technologies for these purposes, we may provide a summary of non-personally identifiable information collected through Cookie and similar technologies to advertisers and other partners to analyze how you and other users use the software and related services for advertising services. We undertake that we will not use Cookie for any purpose other than the purposes stated in this Privacy Policy. You can manage or delete Cookies based on your preferences. You can clear all Cookies saved on your computer, most web browsers automatically accept Cookies, but you can usually modify the browser settings to reject Cookies according to your needs; you can also clear all Cookies saved in the software. But if you do, you may have to personally change the user settings at each visit, and the information you recorded is deleted, and may have an impact on the security of the services you use.

C、How do we share, transfer, and disclose your personal information

(a) Sharing

We will not share your personal information with any third party, only with your authorization and with the “exceptions” as described in this Policy. Even if sharing occurs, we will only share your personal information on the premise of abiding by the “principle of legality, minimum necessity and clear purpose”.

We will not share your personal information with any third party other than our products / services except:

1. Necessary sharing with affiliates: To facilitate the portion of the services provided to you with our affiliates, your personal information may be shared with our affiliates and / or their designated service providers. We will only share the necessary personal information, and the affiliates must comply with the applicable laws and policies on personal information protection.

2. Sharing necessary for the performance of statutory obligations: We may share your personal information (such as testing, preventing, or otherwise resolving fraud, security, or technical issues, responding to claims or satisfying any legal process, summons, or government requests, or protecting the rights, property, or personal security of our users, its partners, or the public).

3. Share with third parties such as partners who entrust us for promotion: the purpose is to make such clients understand the coverage and effectiveness of promotion. For example, we can tell how many people of the client have read their promotion information or bought the clients goods after seeing the information, or provide them with statistical information that cannot identify their individuals, to help them understand their audience or customers.

4. To provide you with our services: we will share your information to partners and other third parties, to realize the function of our products and services, let you normal use the services you need, including payment service payment institutions, services to provide data (including data statistics, data analysis) partners, provide login service partners, provide other service providers. If you do not use the relevant features, we will not share your personal information with third parties.

The third party services are operated by the relevant third party. Your use of such third party services (including any information you provide to such third party) is subject to the third partys own terms of service and personal information protection rules (rather than this policy), and you need to read their terms carefully. This policy applies only to the personal information we collect and does not apply to the services provided by any third party or the rules for the use of information by third parties. If you find any risks in these third-party services, you suggest that you terminate the relevant operations to protect your legitimate rights and interests and contact us in time.

We will only share your personal information for legitimate, legitimate, necessary, specific and specific purposes. For companies, organizations and individuals with whom we share personal information, we sign strict confidentiality agreements to process the information in accordance with our instructions, this policy and any other relevant confidentiality and security measures.

(b) Transfer

Transfer refers to the process of transferring control of personal information to any other company, organization or individual. In principle, we will not transfer your personal information, except where:

1. You make your own requirements and meet the relevant requirements of laws, regulations and regulations.

2. If we need to transfer our personal information due to the merger, division, dissolution or bankruptcy, we will inform you of the name, name and contact information of the recipient, and require the recipient to continue to be subject to this policy. If the receiver changes the original processing purpose and processing method, we will ask the receiver to obtain your consent again.

© public disclosure of personal information

We will not publicly disclose your personal information that is not disclosed by yourself or otherwise unless the punishment for violations or fraud requires to disclose the necessary information that is not legally disclosed in accordance with national laws and regulations or obtain your separate consent. Before we publicly disclose your personal information, we will assess the impact of personal information protection, and adopt security protection measures in line with industry standards.

D、How do you exercise your rights related to your personal information

We guarantee that you exercise the following rights to your personal data, please note that for security reasons we may require you to verify your identity before processing your request, and you can access and manage your personal information by:

1. Access to the Privacy Policy

You can register the platform for the first time, or enter [For You] - [Privacy Policy] to view all the content of this Privacy Policy.

2. Delete your personal information

In the following cases, you can directly request to us to delete your personal information by contacting customer service or email. We will arrange the request within 15 working days after receiving your request:

(1) The processing purpose has been realized, it cannot be realized, or it is no longer necessary to realize the processing purpose;

(2) We have stopped providing the products and / or services, or if the storage period has expired;

(3) You shall withdraw your consent;

(4) We deal with your personal information in violation of laws, administrative regulations or agreements.

Please note that removing or deleting any of your personal information may result in the termination of some of our applicable services. You understand and agree that when you remove information from our products and / or services, we may not immediately delete the corresponding information from the backup system because of applicable laws and security techniques, but will delete it on backup updates. We will securely store your personal information and isolate it further until the backup can be cleared or anonymous. If the preservation period stipulated by laws and administrative regulations does not expire or it is technically difficult to delete the personal information, we will stop the processing except for the storage and taking necessary security protection measures.

3. Complaint report

If you believe that your personal information rights may be infringed, or find clues of infringing on your personal information rights, you can contact us through the “How to contact us” section of this Privacy Policy. We will report your complaints and reports within 15 working days after verification.

4. Access, correct, and obtain copies of personal information

You have access to, correct and obtain copies of your personal information and you may contact us through the contact information listed in this policy. If the technology is feasible, if the data interface is matched, we can also directly transfer a copy of your personal information to the third party you specify at your request.

5. In response to your above request

To be safe, you may need to provide a written request, or otherwise prove your identity. We may ask you to verify your identity before you process your request. We will timely respond to your exercise request within a reasonable time according to the requirements of applicable laws and regulations. If you are not satisfied, you can also find our customer service staff to complain.

For your reasonable request, we do not charge in principle, but for repeated requests beyond the reasonable limit, we will charge a certain cost according to the situation. We may reject requests that repeat unreasonably, require excessive technical means (e. g., requiring new systems or fundamentally changing existing practices), pose risks to the legitimate rights of others, or are very impractical (e. g., involving backup information stored on tape).

Please know that your rights are not absolute, and sometimes, according to the applicable laws and regulations, your rights may be subject to certain conditions or restrictions, such as national security, public safety and interests, crime prevention and investigation, and protection of the legitimate rights and interests of others. If we are unable to respond to your exercise request in whole or in part, we will explain why to you. If your country and region of the applicable laws and regulations do not support a specific right type, or have additional applicable conditions or restrictions, we will also explain to you.

E、How do we store and protect your personal information

(a) The storage of personal information

1. Storage Period: We retain your personal information for the shortest possible period necessary for the purpose of providing our products and / or services, unless otherwise provided by laws and regulations. When we terminate the service or operation, we will stop collecting your personal information in time, comply with the relevant laws and regulations, and notify you in advance, and delete or anonymize the termination or operation, we will take timely measures to delete or anonymize your personal information from the business function system to keep it impossible to be retrieved and accessed. Except for the following cases:

(1) comply with applicable laws and regulations or information requirements of regulatory authorities.

(2) Keep your data within the time necessary to maintain our legitimate business interests, such as for financial and audit purposes, complying with our legal obligations, resolving various disputes, and / or executing the agreements between you and us.

2. Storage location

We will keep your data only during the validity period of your account or during the service period of providing services for you in accordance with laws and regulations, unless deleted according to your request or by law. The servers we provide our services are located within the United States of America and you confirm and agree that your data will be stored and processed on our servers that may not be in your country of residence and are accessible to our support staff, engineers, and / or affiliates around the world. If the products and services you use involve cross-border, and MiniShort.com various products / services need to store and transmit your personal information overseas, we will ensure that we meet the conditions stipulated by relevant laws, administrative regulations or competent authorities, clearly inform you of the exit of your personal information and obtain your separate consent. Wherever our servers are located, we will strive to take appropriate protection measures, and we will ensure adequate protection of your personal information as required in accordance with this policy and applicable national laws and regulations.

(b) the protection of personal information

1. Safety and protection measures

We adopt multi-level protection measures, including security technology measures and supporting organizational and management systems that comply with applicable data protection laws and industry standards, to protect the security of your personal information and minimize the risk of leakage, destruction, misuse, unauthorized access, unauthorized disclosure and alteration of your personal information (hereinafter collectively referred to as a “Data Security Incident”). (hereinafter collectively referred to as “Data Security Incident”).

(1) Technical measures

We adopt cryptographic technology such as transmission layer security protocol to prevent the risk of transmission link being sniffing, eavesdropping and interception; adopt safe storage measures such as data classification and grading disposal; strictly control data permission, adopt multiple identity authentication technology; monitor data processing behavior, and monitor and audit the whole process of data life cycle.

(2) Organizational and management measures

We have established a special department for personal information protection responsible for personal information protection and exercise of data subject; established relevant internal control management systems such as business data security use standard and data cooperation standard management system; minimize the authority of authorized employees; organize employees to attend regular training on information security protection, lock the personal information storage area and restrict their access to the storage area.

(3) Emergency handling of security incidents

We have a safety emergency response center, has formulated a number of safety management systems and emergency response plans, clear the safety event reporting process and emergency response disposal process. If a personal information security incident unfortunately occurs, we will immediately start the emergency plan, to reduce the impact of the security incident as much as possible, and prevent the security incident from expanding. We will inform you of the security incident by phone, push notification, announcements, email, etc., according to the requirements of the applicable Data Protection Act. We have always attached great importance to the security of users personal information, so we have adopted industry standard security technology and organizational and management protection measures to minimize the risk of disclosure, damage, misuse, unauthorized access, unauthorized disclosure and change of your information.

2. Special tips

(1) We cannot control the system, communication network or hardware equipment you use the products or services. Please understand and pay attention to the security of your personal information.

(2) The Internet is not an absolutely safe environment. E-mail, information release, social software, trading platform and other communication methods with other users cannot be determined whether to be fully encrypted. Please pay attention to protect the security of your personal information when interacting.

(3) Please understand that due to the rapid development of computer and Internet technology and the limitation of synchronization speed, there may be various malicious or not malicious attacks. While we continue to enhance and strengthen security measures to protect your information from accidents or damage, it is not always 100 percent secure.

(4) Your personal information will be anonymized and forms the data that can be used and circulated. We do not need to give further notice and obtain your consent for the preservation and processing of such data.

F、Protection of minors

Our service If you are a minor or do not meet the legal requirements of your country / region to access the legal adult age area (“minor” or “children”), you should ensure that you have obtained the parents or legal guardian (“guardian”) to use the service (if your country / region has this option).

If you are the guardian of minors or children, when you help minors or children complete products or service registration, use, should read this policy carefully, decide whether to agree to this policy and help minors or children registration, use, so that minors or children can use the products or services we provide. For the use of our products and / or services with the consent of the guardian, we will only collect, use, share, transfer or publicly disclose as permitted by laws and regulations, with the explicit consent of the guardian or necessary for the protection of minors.

Notwithstanding the above provisions, we recognize the special obligation to protect children in the collection and processing of personal data, and that we will not now and in the future intentionally collect personal data on children without the consent of parents or guardians. We strongly urge guardians to instruct their children not to disclose any personal information during the use of our services without the prior permission of their parents or guardians. If you believe that we may collect or request any data from or about children, please contact us through Article H (How to contact us) and we will delete such data and reply to you within a reasonable time, please note that deleting the data may lead to the termination of certain services provided by us.

G、Notice and revision

The copyright of this Privacy Policy is reserved to us, and, to the extent permitted by law, we have the right to interpret and modify it. In order to provide you with a better service, we will update the terms of this policy according to the product update situation and the relevant requirements of laws and regulations, and this update forms a part of this policy. We will remind you of the updated content through the site letter or other appropriate means, so that you are timely informed of the latest version of this policy. If the update involves major changes, we will notify you in appropriate means (such as website letter, website announcement, etc.) so that you can keep abreast of the latest version of this Privacy Policy. Without your express consent, we will not derogate from or infringe on your personal rights and interests under this policy.

If you do not agree to the modified Privacy Policy, you have the right and should immediately cease use of our products and / or services. If you continue to use our products and / or services, you will be deemed to accept our changes to the relevant provisions of this Policy.

Material changes referred to in this policy include, but are not limited to:

(1) The purpose of our personal information, the type of personal information, and the use of personal information have changed;

(2) Your rights to participate in the processing of personal information and its exercise mode have changed;

(3) When the personal information security impact assessment report indicates that there are risks.

H、How to contact us

If you have any complaints, suggestions or questions about the implementation of this policy or about our privacy protection related matters, you can contact us through the following ways, and we will reply to you within 15 working days after verifying your user identity:

1. Special mail channel: In order to better protect your rights and interests, we have specially set up a support@minishort.com mailbox, through which you can contact us;

2. Personal Information Protection Specialist: You can send an email to the support@minishort.com. Online customer service / other online feedback channels: ou can contact the online customer service of the product function page on our platform or submit your feedback online;

In general, we will accept and reply within 15 working days after receiving your questions, comments or suggestions and verifying your user identity.