Folax Assistant Privacy Policy
Last updated: August 19, 2025
Effective Date: August 19, 2025
Version Number: 20250819V4.8
This update mainly involves the following contents:
(1) We have introduced the WhatsApp voice reply feature and the Folax alarm for your
convenience. We have provided more details on how your personal information is
used in the new features to help you understand how we use your personal information (for more information, see
"9. Providing local lifestyle services").
Shanghai Transsion Co., Ltd. (hereinafter referred to as “Folax
Assistant”, "we”, “us”, “our”) is the service provider and operator of Folax Assistant and its Service
(hereinafter referred to as “This Application”). We fully respect your privacy and will do our utmost to
protect the security of your personal information. We may collect, use or otherwise process your personal
information based on your consent or in accordance with the relevant provisions of applicable laws and
regulations during your use of this Application or its services (collectively, our “Service”). This Privacy
Policy (hereinafter referred to as “Policy”) is meant to help you understand how we collect, use, disclose,
process and protect your personal information with regard to your use of Folax Assistant and its Service, your
rights regarding the personal information provided to us, and how we safeguard your rights. This Policy applies
to all the products and services provided by Folax Assistant, including applications, mini-programs, websites,
SDK for third-party websites or applications, APIs and other forms that may be available in the
future.
It is important to note that this Policy
does not apply to services provided to you by other third parties. You may receive links, content, products or
services provided by third parties, please prudently determine whether to access them. We encourage you to
carefully review the privacy policies of any Third Parties you access before submitting any personal
information.
We have chosen to use plain language in
order to make sure that you fully understand this Policy and make your own choices. We have also marked or
highlighted key terms in bold or capital letters for your attention. We will also notify you by a pop-up
window when you first use our service to help you understand the core terms of this Policy.
Before using our products or services, providing your personal
information to us or allowing us to collect your personal information, please read this Policy carefully to
understand our practices regarding your personal information and access it frequently to understand the updates
to this Policy. If we update this Policy, we will notify you by announcements in the product or website to let
you know about the changes we made. By accessing or using our Services after we have placed such a notice, you
are deemed to have accepted the updated Privacy Policy. You can check the “Effective Date” posted at the top of
the Privacy Policy for the latest update time.
If you have any questions, please feel free to contact us by the
following means:
privacy@transsion.com
You can also access this Privacy Policy by the following
means:
Settings > Folax > About > Privacy Policy
This Privacy Policy will help you
understand the following contents:
I.
How We Collect and Use Your Personal Information
II.
How We Store and Protect Your Personal Information
III.
How We Share, Transfer and Disclose Your Personal Information and
Data
IV.
How Your Personal Information is Transferred Across
Borders
V.
Your Rights to Your Personal Information
VI.
How We Handle the Personal Information of Children
VII.
Third-Party Service Providers and Services
VIII.
Supplement and Update of the Policy
IX.
How to Contact Us
X.
Supplementary Provisions - Jurisdiction-Specific Terms
I.
How We Collect and Use Your Personal
Information
1.
Overviews
Folax Assistant firmly believes that the fundamental privacy rights should not
differ depending on where you live in the world. Any information relating to an identified or identifiable
individual, in particular by reference to the individual's name, identification number, location data, and
online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that
natural person will be treated as “Personal Information” by us, regardless of where such natural person
lives.
We only collect the information that is necessary for specified,
concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a
manner that is incompatible with those purposes. If we intent to use your personal information for other
purposes not specified in this Policy, we will obtain your consent at that time.
We may collect your personal information by
the following means: 1) information you provide directly to us (such as your nickname, profile picture, name
and phone number you provide to us when you login to your account or take part in the promotion activity we
held); 2) information we obtain automatically during your use of this Application (such as device information,
service log information); 3) information we obtain from other sources.
You have the right to choose whether or not to provide the personal
information when you use Folax Assistant and its Service or when we have requested. You are not required to
provide your personal information to Folax Assistant, but in some cases, if you choose not to do so, we will not
be able to provide you with related products or services, nor will we be able to respond or resolve the problems
you've encountered. We will collect and use your personal information only for the purposes described in this
Policy. The following describes your personal information that we collect:
2.
What information we collect and how we use
it in Folax Assistant
Folax Assistant mainly provides you with
comprehensive voice services.
2.1
Providing comprehensive voice
services
Folax Assistant provides you with comprehensive [voice] services. The
information we collect depends on how you interact with us. In order to fulfill the basic functions of Folax
Assistant, you can use the service by sending voice or text commands. When you enter your voice information, we
will make a request to you for "Microphone" permission. You can cancel your authorization at [“App Management” > “App
list” > “Folax Assistant” > “Permissions” > “Microphone”] anytime.
In order for your normal use of our products and services and to
provide you with comprehensive voices services we may automatically collect your device and SIM card related
information and make a statistical analysis so as to optimize our service interface and improve our service
quality.
(1)
Device and SIM Card Related
Information: When you start using this application
and its services, we will receive and record the following information based on your specific operations within
the application and the specific permissions you grant during the installation and use of the application,
including the mobile device information (including phone brand, phone model, operating system version, unique
device identifier (IMSI/SN), mobile device CPU model, phone settings and system language, network device
hardware address, IP address, the application package name and version information, device, software and
hardware environment characteristic information), hardware device identifier GAID (Google Advertising ID),
device location information (including location information of the country or region where your authorized phone
is located, network access method, approximate location information), and network service provider information
(MCC/MNC).
(2)
Log information: We will automatically collect details of your use of our services and
store them as service logs. For example, we will collect the information regarding your detailed use of our
service, including the service access time, access frequencies, usage time, event information (errors, crashes,
restarts, upgrades), online customer service usage, and other log information generated by the use of the
device.
Please note that the above-mentioned
separate device information and log information alone cannot be used to identify a specific natural person.
Only when such non-personal information is used in combination with other information to identify a specific
natural person, or when it is used in combination with personal information, will this information be regarded
as personal information during such combination. In this case, we will anonymize and de-identify this type of
information, unless with your consent or otherwise according to laws and regulations. The above-mentioned
information is essential as to the provision of the Service. If you choose not to provide them, we may not
provide you with the Service related to this Application.
Please note that we may also collect the
above-mentioned device information and log information in various features and scenarios (which may vary
slightly in different features within this Application).
2.2
Providing voice wakeup service
To provide you with the voice wakeup service, you need to set the
wakeup phrase and record your voice first. If your device supports voiceprint recognition, we will
provide you with voiceprint registration service. Your voiceprint will help this service recognize identities
and improve the service safety of the voice assistant. Your wakeup commands and voiceprint information will be
stored on your device and only accessed by Folax Assistant. When you wake up Folax Assistant, this app will
match your voice input with your wakeup commands to ensure the security of voice wakeup.
If you do not provide such information, you will not be able to use
the voice wakeup feature. You can disable this feature via [Settings > Folax >Speak to
activate].
2.3
Providing voice skills
(1)
Third-party online services: We provide third-party cloud services to
you, such as travel services (navigation, weather queries, flight, hotel, and train ticket bookings, and taxi
hailing), general information queries, entertainment services (music, videos, and podcasts), life-related
services (shopping, food, smart home device control, and package deliveries). To provide you with these
services, we need to collect the following information and upload it to our servers: your voice commands, device identifier, device hardware information, basic system
information, app name and version, text of recognized speech, text
input, and broadcast text. Of these, your voice commands, text of recognized speech, text
input, and device identifier will be sent to the corresponding service provider.
In addition, we will collect your information in the following ways:
Google Map as the third-party navigation app may collect your precise location information and destination
address; TWC as the third-party weather app may collect your location information.
For the use of such service, we will apply to you for "Location" permission. If you refuse to grant the permission, you may not be able to enjoy
location-related services. You can cancel your permission at [“Settings” > “Location”] anytime.
If you do not provide the information concerned, you will not be able
to use the third-party online services through Folax Assistant.
(2)
App operations: You are allowed to access and use features in your
local apps with voice commands, such as for creating reminders, making calls, sending WhatsApp
picture messages and initiating navigation.
To allow you to make calls and send messages, we need to call
your "Contacts" permission which is a necessity for our service. Your contacts, call
log and message content of the current device will be collected and will only be processed locally on the
device.
Based on your choice, we can broadcast WhatsApp messages, which will be processed exclusively on your device. To
assist you in replying promptly, we offer a convenient reply feature. Within the Folax service, you can issue
commands via voice or text. We will upload your voice or text input to a third-party AI model to generate
executable commands and send accurate replies on WhatsApp on your behalf. Please note that such information
will only be used to execute your commands and will not be used for any other purposes. In the event of an
anomaly, we may review the generated error logs solely for the purpose of locating and resolving the issue.
You can disable the permission at any time through [App Management
> App List > Folax Assistant > Permissions]. If you do not need a service to make calls and send
messages, you can disable it through App Management > App List > Folax Assistant > Storage & Cache >
Clear Storage > Clear Cache; however, other services may be affected.
In specific versions of the service, you can create schedules through
voice commands. In doing so, we will need to access your
Calendar permissions based on your instructions, which is essential for our service. The
scheduling information on your current device will be processed locally and will not be uploaded to the server.
You can disable the permission at any time through App
Management > App List > Folax Service > Permissions. If you do not need such service, you can disable
it through App Management > App List > Folax Service > Storage & Cache > Clear Storage > Clear
Cache; however, other services may be affected.
(3)
Voice verification: To better recognize your voice commands, we will provide you
with voice command verification function. Concretely, we will obtain your voice commands (wakeup phrases, application operation commands, etc.)
or text commands, application list
(application waking scenario), contact name (calling scenario) and command
response results according to your usage scenario and use them for statistical
analysis and algorithm accuracy optimization. You can cancel your permission at any time via [Setting-Voice
Verification]. Once you cancel your permission, we will not provide the voice verification function and will not
obtain your relevant information any more. But you can still use other functions normally.
2.4
Providing account services
To provide a cohesive service experience, you may access this service
by logging in with your system account. Upon logging into your system account, we will collect your OPEN ID,
nickname, and profile picture for the purpose of displaying your personal information within the service. You
are encouraged to review the privacy policy of such services to understand how they collect and utilize your
personal information.
2.5
Providing
notifications
services
We may also send you service notifications, events and other messages
based on your device identifier, operating system version, user nickname of current device, network information
and information about your use of the app. To unsubscribe from notifications, events, etc., you can withdraw your consent via Settings
> Notification Centre > Notification Management, permission management may vary for different
versions.
2.6
Improving our products or
services
Should you encounter any issues while utilizing the service, you may
provide us with your feedback through the Feedback function. At this juncture, we will collect the content of
your submitted feedback (including issue type, description, feedback time and time zone), as well as your email
address, in order to analyze the issue, establish contact with you, and offer the necessary
assistance.
2.7
Providing services for participating operational activities
From time to time, we will initiate or provide promotional activities. When you
participate in these activities, we will collect information you voluntarily provide to us through the activity
interface, such as your name and contact details. This information is mainly for us
to get in touch with you and to award prizes. Should you refuse to provide the information required to
participate in the promotional activity, we may be unable to provide you with the Services, prizes, or
rewards. However, this will not affect your use of other functions of the Software.
2.8
Providing AI-related services
（1）
Intelligent Voice/Message
Dialogue: To interact with you through
voice/message dialogues and allow you to view dialogue records on your device, we need to collect your voice/message input, device identifier,
operating system settings, device hardware information, and the names of applications running in the
foreground. If you do not provide such information,
you will be unable to conduct voice/message dialogues with Folax
Assistant, or view dialogue records on the
device. Additionally, you can "Like" or "Click" on the chatbot's responses, then we will record your feedback.
To allow you to view dialogue records with Folax Assistant, and enable us to analyze algorithm quality and
optimize algorithms and models (for example, Folax Assistant will provide you with higher-quality responses by
referring to the dialogue records). These records will be stored on our servers.
（2）
AI search: You may employ the AI search feature provided by us to
intelligently search and aggregate content from the internet that you wish to retrieve. At this point, we will
record the input content you provide and utilize the relevant information you supply to
conduct internet searches. Subsequently, we will interpret the results and provide you with content summaries
and links.
（3）
AI Q&A: By utilizing our AI Q&A service, we will offer you generative
reply related to the content of the text, documents, links or pictures you provide based on the mode you select (e.g. problem solving
mode, Q&A mode, drawing mode). We will record your input and output for the purpose of providing
you with the relevant services.
（4）
AI reading summarization: During your use of our services, we will recommend AI reading
summarization-related commands based on the operational status of your browser. Please be advised that we will
not collect this type of information from you. If you opt to use the AI reading summarization feature, in
accordance with your instructions, we will access and upload the content of the page you are
browsing and intelligently generate a content summary through our
algorithm.
（5）
Image to Doc: Through this service, you are able to convert image content into formats such as
Word and Excel. We will collect the images you provide and, in accordance with your instructions, process and analyze the content to generate files in
the specified format for your use.
If, during the use of smart services, you need to upload or download
files or images, we will require access to your device's file and media permissions and/or camera
permissions. You can disable these permissions at any time through your mobile
device's system settings.
（6）
Ask About Screen: If you issue a screen query command, we will capture
a screenshot of your current screen, recognize text,
video, and images on the screen based on your instructions, and use them as input to provide you with generative
question-and-answer services. If you want to identify the phone number and schedule intelligently,
and make a call or create a schedule through the Folax Assistant, we will, upon your
command, make a screenshot to identify and analyze the
phone number and schedule, to execute your command. To provide better services, we will use the
interaction content between you and the Ask About Screen to improve our service quality and algorithm
capabilities. You can withdraw your authorization at any time by contacting us at privacy@transsion.com, and
we will cease using your content as per your instructions. You may choose whether or not to use the screen
query feature.
2.9
Providing local lifestyle services
（1）
In certain versions, you can use this service to access third-party
travel-related services, such as ride-hailing and navigation. In such cases, we will provide the destination information to the
travel service providers based on your instructions to ensure that these providers can
effectively offer you their services, provide navigation information, and complete ride-hailing orders.
When using travel services provided by third
parties, please carefully read and comply with their related service agreements.
When you use this feature, we will access your approximate location to assist in positioning. This ensures that third-party services can
obtain your intended destination (including longitude and latitude information) and allows you to check your
current location.
（2）
We will provide you with prepayment services: We will present and
offer data & mobile credit recharge services for you in certain areas of operation. In that case, we will
receive your country information and device information
(IMEI number) to present you with the data package service and the mobile
credit recharge service available to you. If you make a payment or prepayment through this platform, we will
read the mobile phone number associated with your account, your order information (including order
number, mobile phone number, product information, country code, settlement price, and
currency), and we will provide your order information and the mobile phone
number to be recharged to the mobile credit recharge service provider for such provider to activate or recharge
data or mobile credit. When you make a payment, we will provide your order information to the payment service
provider so that the payment can be completed. We'll record your orders so that you can check the status of your
order when you log in.
To provide an easy-to-use payment feature, we will read your SIM card
information so that the phone number can be filled in automatically. This information is processed and used on
your local device only.
If you want to make mobile credit recharge for your contacts through
voice commands, we will access your contacts to obtain and present contact numbers that you may select. Please
note that, generally speaking, your contacts (including
contact name and contact information) are only processed and used locally upon your
commands.
（3）
To help you quickly check your remaining data and balance, we offer
an automated balance check feature in certain versions of our service. Results will be displayed on the smart
widget provided on the leftmost page. You'll see a summary of your data and balance on the smart widget if you
have downloaded the relevant on-device algorithm models. If the on-device algorithm models cannot be run on your
software version or device, we will upload the data and balance information provided by the network
provider (including information provided via USSD or SMS by the network provider) to our server. This allows us to generate and display a summary
of data and balance for you on the smart widget. Please note that we do not store such information.
We offer an automated balance check feature in certain versions of
our service. If you enable this feature, we will perform the checks as instructed by you, once per day by
default.
You can adjust the frequency of these automated checks or disable the
feature at any time via the Settings Page of the voice assistant, under Balance Check Settings.
2.10
Providing Briefing service
In certain versions, you can use the Briefing service. To help you efficiently manage your schedule, to-dos,
notifications within your device as well as missed calls, and check the weather, we provide the Briefing feature. Through this service, you can quickly view the
aforementioned information on your device's zero screen. If you have downloaded and installed our intelligent
algorithm model, Briefing will generate summaries of your schedule, notifications, and
other information mentioned above to help you quickly understand your pending tasks.
When you enable this service, we will access your calendar app permissions, to-do app permissions,
alarm app permissions, notification permissions, SMS permissions, call log permissions, contacts permissions,
as well as approximate location information (to obtain weather
information) and health app data permissions to gather relevant information for display on your device.
Please be aware that when you enable this feature, the Briefing information is processed and displayed only within your device,
and we will not collect or upload any related personal information.
2.11
Personalized Recommendation
Service
We will obtain your device information (device ID), country/city, the service application
information, installed application information (including application name, usage duration, number of clicks,
application data consumption), network service provider information, and network information.
Then, we will recommend top-up packages that better match your
preferences in local services based on the information mentioned above. We will monitor SMS notifications for call credit and data balance,
obtain the number of your SIM cards and the corresponding balance for each SIM card, and provide you with voice command recommendations based on your
top-up behavior in local services.
In the event that we provide you with personalized voice command
recommendation services in certain versions, once the service is enabled, based on the commands you have authorized for collection (including voice commands,
text commands, casual chat commands), combined with your country, usage records of functions within this
service, this service application information, device identifier (device ID), as well as our algorithmic model
version information, approximate location information (country and city), IP address, installed application
information (application name, version number, and installation time), network type, memory information
(remaining RAM capacity, remaining ROM capacity, number and size of files/images/audio files), we will provide for you with command customized to your
preferences. In the event that you use products or services provided by us or our affiliates, with your consent
and authorization, we will use your GAID and obtain the behavioral preferences generated by that service,
combine it with the information from this service that you have authorized, to provide voice commands that may
be of interest to you.
We understand that preferences may change. Therefore, you can cancel
your authorization via Folax>My>Settings>Personalized Recommendations. Once you cancel the
authorization, we will no longer provide you with the personalized recommendation services mentioned above based
on your application usage. However, you may still receive recommendations not based on your personal
information.
2.12
Providing Folax Alarm service
If you enable the Folax broadcast feature, we will provide daily updates based on
your preferences, including weather reports, to-do reminders, missed calls, and text messages. To retrieve
local weather information, we will access your approximate geographic location. We will also access your schedule names, start times, to-do item names and start times, as well as the
contact notes of missed calls and text messages (for unidentified callers, we will upload the last
four digits of the caller’s phone number; if the number is only four digits long, we will upload the last two
digits) and the time of the call or message to generate voice broadcast information and provide the alarm
service. Please note that your personal information will only be used for the purpose of providing the service
and will not be stored or used for any other purposes.
To enable this service, we will access certain permissions through
system processes (AICoreNexusFlow), including contact permissions, calendar permissions, to-do
permissions, and location permissions, as these are essential for the functionality of the
service. You may disable the Folax
Alarm feature at any time within the alarm service
settings.
2.13
Providing security services
To improve the security of your use of our services, to protect you,
other users or public safety and property from harm, to better prevent security risks such as phishing sites,
fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, and to more accurately
identify violations of laws and regulations or our relevant agreement rules, we may use or integrate information about
your device, as well as information about the applications you have installed, the information about running
processes, the overall operation of the application, the usage frequency of the application, crash data,
overall installation and usage, performance data and information about the source of the application,
to help you conduct security risk detection, prevent security risks,
and take the necessary recording, auditing, analysis and disposal measures in accordance with the
law.
3.
Other situations in which your information
may be collected
Where permitted by law, we may obtain your personal information from
other individuals, business entities, public channels or other third parties acting at your direction, our
partners who work with us to provide our products and services and assist us in information security and fraud
prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain
your consent.
We may also use other methods to collect other information about you,
your device or your use of services, which will be explained to you at the time of collection and we will obtain
your consent.
In order to better improve our product layout and provide you with
great services, we may conduct research, statistical analysis and prediction on the collected information in an
anonymized manner (including machine learning or model algorithm training by using anonymous data). We will take
technical measures and other necessary measures to process such data, so that the data cannot be re-identified
to specific individuals, nor can it be recovered. In accordance with the applicable laws and regulations, such
processed data can be used without separately notifying you or obtaining your consent.
II.
How We Store and Protect Your Personal
Information
1.
How we store your personal information
The personal information collected with your consent will be stored
in accordance with the laws and regulations on the personal privacy data protection of the countries concerned.
To the extent not prohibited by local laws and regulations, we may also store the collected personal information
in countries or regions outside the country where the business is located.
Currently, [Folax Assistant] may store your personal information in:
India, Ireland, Russia and Frankfurt.
In particular:
The personal information collected and generated during our
operations in India will be stored on servers located in India.
The personal information collected and generated during our
operations in Russia will be stored on servers located in Russia.
The personal information collected and generated in our business
outside India and Russia will be stored on servers in Ireland and Frankfurt.
According to business conditions, we may use servers in other regions
or countries in the future, and we will update this Policy at that time.
Whether we store personal information in the country where the
business is located, or in other countries or regions to the extent that doing so does not violate laws and
regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same
time, we will consider the characteristics, scope and purpose of personal information processing, the risks that
may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the
necessary security measures. For example, we will use encryption and de-identification methods to store the
personal information collected. We will also keep the information for the shortest storage period specified by
law. For those not specified by law, we will retain the information according to the shortest storage period
required for business. For data that exceeds the storage period, or data that you request us to delete, we will
delete said data accordingly or take other appropriate measures without violating the relevant laws and
regulations.
2.
How we protect your personal information
We will take other necessary measures to protect the security of your
personal information and prevent data from being misused, unauthorized access, and unauthorized modification,
disclosure or destruction, etc.
We implement security safeguards designed to protect your personal
information and regularly monitor our systems for possible vulnerabilities and attacks, and we use
administrative, technical, and physical safeguards to protect your personal information by taking the types of
the personal information, the processing, and the threats posed themselves into account. We are constantly
working to improve on these safeguards to keep your personal data secure.
Nevertheless, we need to remind you that no matter how perfect the
measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a
data breach event occurs, we will report it to the corresponding regulatory authorities as required by the
relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data
subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the
requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the
damage and consequences of data breach. When permitted or required by laws and regulations, we will inform you
of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate
measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer
system and wireless connections. In addition to the necessary protective measures we have taken, users have to
strengthen the awareness of privacy security risks. For example, when you access third-party websites, links,
products or services from our services, for the security of any data collected by those websites, links,
products or services, please read through the terms and conditions of those third-parties carefully. We do not
take any legal responsibility for data security issues caused by such third parties. If you find that certain
contents, advertisements or features in our websites, products or services may be provided by a third party and
may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority
in accordance with laws and regulations.
III.
How We Share, Transfer and Disclose Your
Personal Information and Data
When sharing, transferring, and disclosing your personal information,
we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances,
we do not share, transfer or disclose your personal information externally. However, to the extent permitted by
applicable laws and regulations, we may share, transfer and disclose your personal information in the following
situations:
1.
How we share your personal information
We do not sell any personal information to third parties. In order to
provide you with timely services, your personal information may be shared with our affiliated companies. We will
only share your information within our affiliated companies for legitimate and explicit purposes, and only share
the information necessary to provide the services, and are bound by the purposes stated in this Privacy Policy.
If a purpose concerned is not included in this Policy, we will state it in the corresponding privacy policy or
notice of the specific product or service.
We may share the necessary personal information with authorized
third-party partners (including technical service providers, data storage service providers, after-sales service
providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance
of certain features or to provide you with better service and a better user experience. For example, (1) when
you use the chat function, our technical service provider will obtain the information you enter to provide you
with responses of AI chat robots; (2) our cloud service provider will provide you with cloud storage services to
ensure normal operation of the service; (3)
to enable you to use travel services provided by third-party
platforms, we will, with your authorization, provide your location and destination information to these third-party services to ensure
the services function properly. We uphold the principles of minimization, necessity, and legality to carry out
such sharing. Before sharing information, we will sign strict confidentiality agreements with authorized
partners and require them to take relevant confidentiality and security measures to process personal information
in accordance with this Policy and applicable laws in your jurisdiction. In addition, we will also require them
to provide data security capabilities and information security qualifications (e.g., grade protection
assessment, information security management system). When we embed the third party SDK or other similar
applications of authorized partners in this Application, we will notify you promptly and request the SDK service
provider that obtains the information to protect your data security.
In order to provide evaluation, analysis or other business services,
we may also share your non-personal information with third parties. For example, we may use aggregated data to
help partners (e.g., advertising service providers) understand the effectiveness, feedback and usage trends of
their services.
In the event of a merger, acquisition or bankruptcy liquidation,
asset transfer and other related transaction, if a personal information transfer is involved, we will require
the new entity or organization holding your personal information to continue to be bound by this Policy through
an agreement or other appropriate measures, and we will require such subject to take confidentiality and
security measures of a degree no less than the requirements of this Policy to process personal
information.
2.
How we transfer your personal information
Folax Assistant will not transfer your information to any other
parties, except in the following circumstances:
(1)
Obtain your explicit consent.
(2)
If Folax Assistant is involved in a merger, acquisition or sale of
all or part of its assets, which may affect your personal information, we will issue a prominent notice via
email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your
rights of your personal information, and any choices you may have about your personal information.
(3)
In the case that has been explained in this privacy policy or
notified you by other means.
3.
How we disclose your personal information
According to the legal requirements, legal procedures, litigation
and/or requests from government departments and authorities, Folax Assistant may need to disclose your personal
information. If the disclosure is necessary or appropriate for national security, law enforcement, or other
matters of public importance, we may also disclose information about you.
Additionally, we may share your personal information
with:
(1)
Our attorneys, lawyers, accountants, auditors, or similar
consultants, when we request them to provide professional advice.
(2)
Investors and other relevant third parties, if actual or potential
sales or other company transactions occur and are related to entities within our group.
(3)
Other third parties, for example, the disclosure of specific
information with your authorization.
IV.
How Your Personal Information is
Transferred Across Borders
For the purposes described in this Policy, and to the extent
permitted by applicable local laws and regulations and with your authorized consent, we may transfer your
personal information to the resources or servers stipulated in section III of this Policy for storage or
processing, we may also transfer your personal information to third-party service providers and
business partners and your data may therefore also be transmitted to other countries or regions. The privacy protection laws of these countries or regions may be
different, and the jurisdiction in which these global resources or servers are located may or may not
protect personal information to the same standards as in your jurisdiction. However, we will still strive to comply with our Privacy Policy to
protect your personal information, and we will follow the legal requirements of the country or region where the
personal information is located to carry out the corresponding cross-border transfer and other processing of
personal information.
In the circumstance that we transfer personal information outside of
your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply
with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all
such transfers meet the requirements of applicable local data protection laws.
V.
Your Rights to Your Personal
Information
As a data subject, you have a series of rights to your personal
information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints
(hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be
subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure
that your rights are effectively protected. However, please understand and note that for security reasons, we
may need to verify your identity before processing your request. In principle, we do not charge a fee for your
lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the
reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We
may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop
new systems or fundamentally change existing practices), pose risks to the legal rights of others or are
extremely impractical, or violate the mandatory provisions by law.
1.
Right to confirm and access
We inform you how we collect and process personal information through
this Policy or in the form of a privacy policy or notice of the specific product or service. You have the right
to confirm or reject such collection and processing via a check box or other methods. However, after you reject,
some features that require your explicit authorization and consent to use may no longer be available. You can
directly access the personal information you have provided to us in the interface of our products or services.
For those that you are unable to access, you can send an email to privacy@transsion.com. We will handle it
promptly after receiving your email.
2.
Right to correct and delete
When your personal information is changed, or when you find that your
personal information collected and processed by us is inaccurate or incomplete, you have the right to ask us to
make corrections or additions. You can directly correct or modify some of your personal information on the
relevant product/service function pages. When your personal information collected by us has fulfilled the
purpose of collection or is no longer required, or when you find that our collection and processing of your
personal information violates the provisions of laws and regulations or this Privacy Policy, you have the right
to ask us to delete the relevant personal information. For personal information that we have not provided you
with a channel for correction or deletion, you can request that it be corrected or deleted by contacting
privacy@transsion.com.
However, we may not grant your deleting request in some situations,
for example, if you ask us to delete your transaction data when we are legally obligated to keep a record of
that transaction to comply with the applicable local law. Please also kindly note that if you request to delete
your information from our products and services, we may not remove the corresponding information from the backup
system immediately due to some applicable local laws and technological limitations, however, we will securely
store your personal information and isolate it from any further processing until the backup is updating or can
be deleted or be made anonymous.
3.
Right to withdraw consent
To achieve the respective features of our various products or
services, we will require necessary personal information in accordance with the applicable local laws. This is
described in the "How We Collect and Use Your Personal Information" part of this Policy. You can withdraw your
consent previously granted to us for a specific purpose by deleting information, turning off device features,
and requesting to withdraw consent, including the collection, use and/or disclosure of your personal information
that we manage or control. You can email us at privacy@transsion.com for above operations. We will process your
request within a reasonable time after you send the request, and thereafter will not collect, use and/or
disclose your personal information in accordance with your request.
If you withdraw your consent, you may not be able to continue
receiving the part and/or full benefit of Folax Assistant and its Service. The withdrawal of your consent or
authorization will not affect the validity of our previous processing activities based on your
consent.
4.
Right to complain
You have the right to lodge a complaint by sending us an email at
privacy@transsion.com. We will respond promptly after receiving your complaint. If you are unsatisfied with our
response, especially if our processing of personal information violates your legitimate rights and interests,
you may refer your complaint or report to your local statutory personal data protection department, or file a
lawsuit with a competent court.
5.
Right to control your privacy
settings
You have the right to control your privacy settings and restrict our
collection, use, disclosure, or processing of your personal information via such privacy settings. You can also
obtain detailed information regarding the device security status in “Settings”. If you have agreed to such
permission or have agreed to our use of your information previously for the above-mentioned scenarios. You can
turn it off via “App Management” > “App list” > “Folax Assistant” > “Storage & cache” > “Clear
storage” > “Clear cache”.
6.
Right to cancel a service or
account
You can request to cancel through the “Logout” settings provided in
the service or by contacting us via privacy@transsion.com.
We hereby kindly remind you that, if you wish to cancel a certain
service or account, such cancellation may prevent you from using some of Folax Assistant features and its
services, and such act of account cancellation is irreversible. Once you cancel your account, we will delete or
de-identification your relevant information.
If you sign in to the accounts of Folax Assistant through a
third-party account (e.g., via Facebook, Google ID), you need to apply for cancellation of the account from the
third party.
7.
Rights in some
jurisdictions
Particularly, according to the applicable laws of some jurisdictions,
you may have the following data subjects rights:
(1)
Right to restriction processing. You have the right to request our
restriction on the processing of your personal information. We shall consider the grounds regarding your
restriction request. If the grounds are in the compliance with applicable data protection laws, we will process
your personal information under applicable circumstances in such laws and notify you before the restriction of
processing is lifted.
(2)
Right to automated decision-making. You have the right to refuse the
processing based on automated decision-making, including profiling and other automated processing which may have
legal or similar effects on you.
(3)
Right to data portability. You have the right to apply for your
personal information to be transmitted to another data controller in a structured and commonly used
format.
We have the right to refuse to process your requests or only respond
to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable
laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure
of information of third parties.
VI.
How We Handle the Personal Information of
Children
Folax Assistant understands the importance of safeguarding the
personal data of children, therefore, children under the age of 14 or the equivalent age as specified by law in
your jurisdiction (we will define children mainly based on the laws and regulations of the country or region
where our business is located because laws of different countries may differ when defining the age of children)
are not allowed to use our products or services without the consent and guidance of their legal guardians and
such practice shall be permitted by relevant laws and regulations. In principle, we do not provide services directly to children, do not actively collect children’s personal data or do not use children’s personal information for the purposes of marketing. We will only collect, use and disclose a child's personal
information with the explicit permission and consent of the child's guardian, to the extent permitted by law,
and when it is indeed necessary to collect such information. If at any time the guardian needs to access, modify
or delete the personal information related to the child under guardianship, please contact us by methods as
described herein, and we will respond in a timely manner. If you find that a child’s information has been
collected to us without the awareness of the legal guardian, please send an email to privacy@transsion.com to
contact us. We will remove the relevant information as soon as possible. If we find that we have collected the
personal information of a child without the prior consent of a verifiable guardian, we will also remove the
relevant content as soon as possible.
VII.
Third-Party Service Providers and
Services
With the upgrades of this Application, you may receive links to
third-party websites or content and services provided by third parties other than us during your use of Folax
Assistant and its Service, and some third parties’ products or services can be accessed in the form of SDKs and
others. You can choose whether to visit or accept the third-party websites, products, and services at your sole
discretion. Our Privacy Policy does not apply to products and services provided by any third party. Since we are
not able to substantially control a third party, we are not responsible for the third party’s collection and
processing of your personal information. Therefore, when you submit any information to a third party, please
carefully review the third party’s privacy policy and take care of your personal information.
VIII.
Supplement and Update of the
Policy
We reserve the right to update or modify this Policy from time to
time in order to reflect the changes in our business, technology and applicable law and practice. In case of any
modification of this Policy, we will notify you of the latest Policy here (this webpage), or by posting it on
our official website or sending you separate notifications. Please pay attention to this website and the
notifications we send to you for the latest updates of this Privacy Policy. Although this Privacy Policy may be
modified, your rights under this Policy will not be diminished without your explicit consent.
We will ask for your explicit consent again in accordance with
applicable laws before we collect additional personal information from you or when we use or disclose your
personal information for new purposes. Your continued use of the products and services on the website, mobile and/or any
other device constitutes your agreement to the updated Privacy Policy.
The content of Folax Assistant and its services described herein may
vary according to the type of product you use, your system version, or requirements of local laws and
regulations.
IX.
How to Contact Us
If you have any comments, questions or concerns with respect to our
Privacy Policy or practices of personal information protection, please contact us via:
Email: privacy@transsion.com (Note: This mailbox is used for
receiving messages related to our Privacy Policy or our protection of personal information only)
We will review your privacy or personal information requests as soon
as possible and respond to you in 15-30 days after verifying your user identity. If your request itself involves
any complicated or significant issue, we may ask you for more information.
If you are not satisfied with our response, especially when you
believe that your legitimate rights and interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your jurisdiction. If you
consult us, we will provide information on the relevant complaint channels that may be applicable based on your
circumstance.
Thank you for your time to read our Privacy Policy!
X.
Supplementary Provisions - Jurisdiction-Specific
Terms
If the supplementary provisions specific to your
jurisdiction (Jurisdiction-Specific) conflict with other parts of this policy, the jurisdiction-specific
supplementary provisions (Jurisdiction-Specific) shall prevail.
Brazil Appendix:
This section applies to users located in Brazil. When you are using
our services, and subject to compliance with applicable laws and regulations in your region, we may transfer
your personal information to the resources or servers outside Brazil. Specifically:
(1)
Form, Duration, and Specific Purpose of International Transfers: To
provide you with the full functionality of our products or services, we may, from time to time, share your
personal information with other affiliated companies. This is done to ensure the proper functioning of the
services, conduct internal statistical analysis, and optimize the design of product features. During your use of
our services, your data will be continuously and uninterruptedly transferred to our affiliates.
When you use AI services, we will provide the information you input
to the large model service provider to deliver the relevant functionalities to you.
(2)
Destination Country of the Transferred Data: Your data will be stored
on servers located in the European Union.
(3)
Identity and Contact Information of the Data Controller: Please refer
to the beginning of this document and "IX. How to Contact Us".
(4)
Data Sharing by the Controller and Its Purposes: For details, please
refer to "IV. How We Share, Transfer and Disclose Your Personal Information and Data".
(5)
Allocation of Responsibilities for Data Security and Security
Measures Adopted: Our partners will provide appropriate safeguards and are required to process personal
information in accordance with this Policy and the applicable laws of your jurisdiction, implementing relevant
confidentiality and security measures.
Rights of Data Subjects and Methods of Exercising Such Rights: You
may review and exercise your rights as outlined in "V. Your Rights to Your Personal Information". Unless otherwise provided by law, we will respond to your rights
request within 15 days after verifying your identity. If you are dissatisfied with our response, particularly if our
processing of your personal information infringes upon your legitimate rights and interests, you have the right
to file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).