WiFi Master Key Privacy Policy

Nanjing LinkWiFi Network Technology Co., Ltd. (hereinafter referred to as “the Company”) and its affiliates (including without limitation, Shanghai Zenmen Technology Co., Ltd., Shanghai LinkSure Network Technology Co., Ltd. and its affiliates, together with the Company and its affiliates, hereinafter collectively referred to as “We”) attach great importance to the protection of personal information and privacy of users, so we have formulated a privacy policy covering how to collect, store, use, share and protect user information, and ways provided by us for you as users (hereinafter referred to as “user” or “you”) to access, update, delete and protect these information. We hope to, through this privacy protection statement (hereinafter referred to as “this privacy statement”), give you a clear introduction of our approach to deal with your personal information and other information.

This privacy policy closely relates to your use of WiFi Master Key products and/or services. Before use of any WiFi Master Key products and/or services, please fully read and thoroughly understand WiFi Master Key Privacy Policy (especially those content bold underlined content), ensure you are fully aware of our rules for dealing with your personal information (defined as below) and other information, and make an appropriate choice accordingly. If you disagree to any content of this privacy policy, which means you choose to give up using WiFi Master Key products and/or services, please immediately stop using WiFi Master Key products and/or services. By using any WiFi Master Key product and/or service, you agree to and completely understand all the content of this privacy policy.

Foreword

This policy contains the following content:

Special Tips

1. Thank you for using and trusting WiFi Master Key. We will keep devoted to providing more secure and reliable services for you.

2. All the products and/or services on the WiFi Master Key platform (including all the products and/or services of WiFi Master Key and products and/or services of WiFi Master Key affiliates without a separate privacy policy) are subject to this privacy policy, while certain products and/or services will also be subject to a specific privacy policy.

3. The aforesaid privacy policy for certain products and/or services forms a part of this privacy policy, and if there is any consistency with this privacy policy, the privacy policy for certain products and/or services shall prevail.

4. Unless otherwise stated herein, this privacy policy is not applicable to provision of products and/or services for you by any third party that has accessed via our products and/or services, e.g. products or websites displayed to you in search results, websites that might contain any third-party services, or other websites linked in our services. Please note, if you use any third-party products and/or services and provide your personal information and other information to that third party, your information should be subject to the privacy statement or similar policy of that third party, and we bear no legal liability for any improper use or disclose of your information by that third party.

5. This privacy policy only applies to users over the age of 14. If you are a child under the age of 14, or if you are the guardian of a child registering a WiFi Master Key account, please stop reading this privacy policy and any other operations immediately, and please carry out operations in accordance with the relevant requirements of the Company, including without limitation, providing the identity and contact information of at least one guardian of the child for the Company to give notification to or obtain consent from the guardian in accordance with the requirements of the Provisions for Network Protection of Children’s Personal Information; the guardian registers an account for the relevant product and/or services in its own name, reads and accepts the WiFi Master Key Privacy Policy (For Children) and other agreements; so that the Company will collect, store, use, transfer and disclose the child’s personal information in accordance with the applicable laws and regulations and the relevant provisions of the WiFi Master Key Privacy Policy (For Children).

Definitions

1. [Personal Information] Personal information refers to all kinds information that is recorded by electronic or other means and can, alone or combined with other information, identify a specific natural person or reflect activities of a specific natural person.

2. [Personal Sensitive Information] Personal sensitive information refers to personal information that, once leaked, illegally provided or abused, may endanger personal or property safety and easily lead to personal reputation or physical or mental health being damaged or discriminatory treatment, including ID card number, personal biometric information, bank account number, communication records and contents, property information, credit information, whereabouts, accommodation information, health and physiological information, transaction information, personal information of children under the age of 14, etc.

I. How do we collect and use your personal information and other information

We will collect and use your personal information and other information for the following lawful purposes only:

(I) Circumstance that you authorize us to collect and use your personal information and other information

Our products and/or services include some specific business functions and additional functions. Our products and/or services include some core functions, which contain functions required for free Internet access, functions required for improving our products and/or services, and functions required for ensuring hotspot connection security. We might collect, save and use the following formation about you to realize these functions. If failing to provide relevant information, you might not be entitled to our products and/or services.

Therefore, in order for us to provide you with better and more personalized products and services, you agree that we can collect the following information:

1. Information that might be collected when you are using products or services

We might collect information generated when you are using products and/or services (including way of use). Such information includes:

1) [Device Information]. In order to ensure your normal use of products and/or services, and ensure the security of your account, we might collect device attribute information (e.g. your hardware model, operating system version, device configuration, unique device identifier, international mobile equipment identification IMEI, network device hardware address MAC, advertising identifier IDFA, etc.), device location information (e.g. location information acquired via GPS or WIFI signal) and device connection information (telecom operator, language).

2) [Log Information]. In order to ensure your safe use of products and/or services, our server might automatically record some information, such as your use of our products and/or services, IP address, language, information about download, installation or use of the software, and service access date, time, length, URL, etc. Please note, the aforesaid information excludes any of your personal information or other information, and also excludes any content that you have sent or shared by using any relevant application, service or website.

All of the foregoing data and information will be collected in an anonymous manner. Meanwhile, we will also encrypt information to ensure security.

2. Functions required for improving our products and/or services

You understand and agree, when you are using WiFi Master Key services, we might collect your browsing information, your interests and hobbies for data analysis to form a user portrait, which can be used to show you the goods or services you are interested in. We might acquire other information about you out of a reasonable need to provide services and improve service quality, including relevant information you have provided when contacting customer service, questionnaire response information you have sent to us when you are participating in a questionnaire survey or have creative advertising needs, and relevant information acquired by us when you are interacting with our affiliates or partners. With regard to information collected from any of your devices, we might connect them so that we can provide consistent services for you, such as assisting you to use your WiFi Master Key account for one-click login to the service platform of an affiliate or partner. We might combine information from a specific service with information from other services by use of cookies that create and maintain unique identifiers, pixel tags and similar techniques so as to provide more precise push services, personalized content and advices for you.

3. Information that might need to be provided to us when you are using specific products and/or services

1) When registering or logging into a WiFi master key account, you must provide an account name and mobile phone number.Mobile phone Number is personal sensitive information, and such information is collected to meet the requirements of relevant laws and regulations on real-name online registration for relevant services. If you do not provide such information, you may not be able to use our products and/or services normally.

2) If you use any specific products and/or services provided on the WiFi Master Key platform, to satisfy your product and/or service needs, after obtaining your consent, the relevant information will be provided, according to the products and/or services you have chosen:

In the case of using [Hotspot Connection] services, to provide you with the most accurate, secure and surrounding hotspot information, you need to turn on the GPS location information. If you turn off the GPS location information, you will not be able to provide location-based related networking services.

In the case of using [Hotspot Registration], [Notice] or [Discovery] services, we may use GPS location information to provide you with timely and precise news services via floating window or other forms. You may also close some functions through local system settings or the corresponding settings in the software.

In the case of using [Recruitment] services, according to the employer’s requirements, you might need to fill in your real name and mobile phone number. If you decide not to provide such information, this will not affect your use of networking services of WiFi Master Key but only that you will not be allowed to use the aforesaid function.

The [LinkSure Wallet] function is provided to you by Shanghai Shengpay Electronic Payment Service Co., Ltd. (hereinafter referred to as “Shengpay”). When you click LinkSure Wallet, in order to help you use your WiFi Master Key account to log into LinkSure Wallet and meet the requirements of the real name system of network payment, Shengpay needs to obtain the mobile phone number you use when you log into the WiFi Master Key account. To provide you with convenient payment services, you might need to provide your real name, ID card information, bank card information and mobile phone number reserved with the bank. Shengpay will collect, use and store such information in strict accordance with laws and regulations and relevant provisions of the People’s Bank of China and other relevant authorities. If you do no use these services and decide not to provide such information, this will not affect your use of networking services of WiFi Master Key but only that you will not be allowed to use the aforesaid function.

In the case of using [WiFi Security Insurance] services, you might need to provide your mobile phone number, frequently used address and ID card information to ensure the insurance company will make timely review on your application for claims. If you decide not to provide such information, this will not affect your use of networking services of WiFi Master Key but only that you will not be allowed to use the aforesaid function.

In the case of using [Download] services, to write storage information in a system storage part, we need permission to access, modify/delete the contents of the system storage part. If you decide not to provide such information or permission, this will not affect your use of networking services of WiFi Master Key but only that you will not be allowed to use the aforesaid function.

In the case of using [One-Click Access via Mobile Phone Number] services, to help you quickly log into WiFi Master Key, after obtaining your consent, we will help you to send SMS to the operator, receive SMS from the operator and read SMS/MMS from the operator. If you decide not to provide such information or permission, this will not affect your use of networking services of WiFi Master Key but only that you will not be allowed to use the aforesaid function.

Please note, if you choose not to use any specific products and/or services, then you are not required to provide relevant information.

4. Functions required for ensuring connection service and security

To enhance system security when you are using our products and/or services, more accurately prevent fishing hotspot fraud and protect your account or transaction security, we provide security services including without limitation, hotspot security check, WiFi security check, etc.; we will also collect your common software for analysis on free and secure hotspot connection, recommend high-quality free hotspots to you through network traffic monitoring, and find out any possible risks. Please note, the foregoing data and information excludes any of your personal sensitive information, and excludes an content that you have sent or shared by using any other application, service or website.

(II) Circumstance that you can choose whether or not to authorize us to collect and use your personal information and other information

1. For your more convenience or better experience of using WiFi Master Key, the following additional functions might collect and use your personal information and other information. If you fail to provide personal information or other information, you may still use WiFi Master Key, provided, however, that you might not be able to use these additional information that can bring better experience for you or you might be required to repeat some information when using certain services. These additional functions include:

(1) Personalized recommendation function based on location information: we will collect your instant location information (we only collect your geographical location at that time, but will not combine your location information of every period to determine your trajectory) to determine your location, and automatically recommend merchandise or services available for purchase in your region (e.g. recommending the nearest optional WiFi hotspot to you).

(2) Additional function based on camera: you can use this additional function for taking pictures and code scanning.

(3) Additional function based on image upload: you can upload your photo as an image on WiFi Master Key.

2. The foregoing additional functions might need you to open your geographical location (location information), camera, photo gallery and microphone access permissions to us in your device so as to realize the collection and use of information involved in these functions. You may also decide to open or close these permissions at any time. Please note, by opening these permissions, you authorize us to collect and use these personal information and other information to realize the foregoing functions; by closing permissions, you cancel such authorization, and we will no longer continue to collect or use these personal information or other information about you, and will not be able to provide you with the foregoing functions corresponding to such authorization. Your decision to close permissions will not affect any previous dealing with personal information or other information based on your authorization.

(III) You are fully aware that, in any of the following circumstances, we can collect and use personal information and other information without your authorization or consent:

(IV) Circumstance that we acquire personal information and other information about you from a third party

[Third-Party Information] To jointly provide you with products/services or improve the quality and personalization of products/services, or out of such reasonable needs as consideration to security of products/services, we will, according to laws and regulations, or based on your authorization, receive personal information and other information about you from affiliates, alliance members, partners and other trusted third-party suppliers, service providers or agents, and you understand and agree, we will bear no legal liability for any collection or provision behavior of that third party.

(V) Rules for use of your personal information and other information

1. We will, according to laws, regulations and this privacy policy, and for purpose of realizing our product and/or service functions, make lawful use of personal information and other information collected.

2. After collection of personal information and other information about you, we will conduct de-identification on such information by technical means in accordance with laws and regulations, and the user of information so de-identified cannot be identified therefore. We might conduct anonymization on such information by technical means in accordance with laws and regulations, and the user of information so anonymized cannot be identified therefore, and the information so processed cannot be restored.

3. [Use Authorization] Please note, with regard to all the personal information and other information provided when you are using our products and/or services, unless you have deleted the same or have rejected our collection via system setting, we will continued to be authorized to use such information when you are using our products and/or services.

4. We will conduct statistics on the use of our products and/or services, and might share these statistical information with the public or any third party (including without limitation, communication service provider sending e-mails or push notices on behalf of us, map service provider providing location data for us, financial service provider, etc.) to present the overall use trend of our products and/or services, or maintain and improve our services, but these statistical information excludes any identity information about you.

5. We will share your personal information and other information only for legitimate purposes, and meanwhile, we will conduct desensitization on your information by way of content replacement, anonymous processing, etc., so as to protect the security of personal information and other information about you.

II. How do we use Cookie and similar technology

(I) Use of Cookies

1. To satisfy your personalized demand for online experience and provide you with more relaxed access experience, we will send one or more small data files named Cookies to your computer or mobile device, and such Cookies assigned to you are unique, which can be read only by the Web server that has sent Cookies to your domain. We send Cookies to you for purpose of simplifying the step of repeated login, storing your shopping preferences, or items in your shopping cart, so as to provide shopping preferences for you, assisting you to optimize advertising choice and interaction, and assisting you to determine your login status and account or data security.

2. We will not use Cookies for any purpose other than those specified in this privacy policy. You may manage or delete Cookies based on your own preferences. You may clear all the Cookies saved in the computer, and although most of Web browsers will automatically accept Cookies, generally you may modify browser settings according to your own needs so as to reject Cookies; besides, you may also clear all the Cookies saved in the software. However, if you do so, you might be required to alter user settings in person upon each visit to our website, and all the corresponding information recorded previously will be deleted, which might produce certain impact on the security of services you are using.

(II) Use of Web Beacon and similar technology

In addition to Cookies, we will also use other similar technology on the website, such as Web Beacon, etc. Our webpage often contains some electronic images (called “single pixel” GIF file or “Web Beacon”). We use Web Beacon in the following ways:

III. Circumstances of lawfully sharing, transferring and publicly disclosing your personal information

(I) Sharing

1. We will not share your personal information with any company, organization or individual other than WiFi Master Key and its affiliates, unless in any of the following circumstances:

2. We might share with our affiliates your personal information that has gone through de-identification or anonymization and cannot identify you or be restored by the recipient, so as to provide better customer services and user experience, including but not limited to sharing with advertising or message service providers to help them improve the effective reach rate of pushed content without identifying you, and analysis on the use of our products and services. We will only share necessary personal information, and will be limited to the purpose stated in this privacy policy. If any of our affiliates needs to change the purpose of dealing with personal information, we will solicit your authorization or consent again. Our affiliates include our associated companies, and partners such as advertising, authorization, supplier, etc.

(II) Transfer

We will not transfer your personal information to any company, organization or individual, unless in any of the following circumstances:

(III) Public disclosure

We will publicly disclose your personal information only in any of the following circumstances and on the premise of taking security protection measures in line with industry standards:

(IV) Statement on third-party liability

[Third-Party Service] Please note, your counterparty, the operator of any third-party website you visit, or any third party accessed via us (such as those third parties providing services in WiFi Master Key APP) might have their own privacy protection policy, and we will make it clear to you that the relevant services are provided by third parties. When you view any webpage created by a third party, or use any application developed by a third party, WiFi Master Key suggests you should carefully read the Privacy Statement and Service Agreement of such third-party website or service provider for an understanding of their approach to deal with your personal information, so as to bring convenience for prudent decision making.

IV. How do we securely protect and save your personal information

(I) Location of information storage

Any personal information collected or generated within the People’s Republic of China will be stored within the People’s Republic of China. WiFi Master Key will not provide or store any personal information outside the People’s Republic of China.

(II) Term of information storage

We only retain your personal information for as long as necessary for the purpose of services, and we will delete the information when you cancel your WiFi Master Key account.

When our products and/or services cease operation, we will notify you by announcement or other forms, and delete your personal information within a reasonable period of time according to laws and regulations.

(III) Our techniques and measures for protection of your personal information

We attach great importance to security of personal information, and take all reasonable and feasible measures to protect your personal information:

1. [Date security techniques and measures] We make a commitment that we will have the information security protection reach a reasonable security level. To protect your information security, we are devoted to using various security techniques and supporting management systems to prevent your information from divulgence, destroy or loss, including establishment of reasonable systems, specifications and security techniques to prevent your personal information from unauthorized access, use, modification or data damage or loss.

Network services of WiFi Master Key take such encryption techniques as transport layer security protocol, and provide security services by way of https, etc., so as to ensure the security of data in transit.

WiFi Master Key takes a variety of encryption techniques for encrypted storage of personal information of users, and assigns a separate secure domain for any storage media or information system that contains personal information of users in a logical or physical isolation manner.

When personal information is being used, such as personal information presentation, personal information correlation calculation, we will use various data desensitization techniques for desensitization on sensitive fields, so as to enhance the security of personal information in use.

WiFi Master Key gives special importance to the security protection of WiFi hotspots and passwords. All the WiFi hotspots and passwords shared by users will use 128-bit keys, under encrypted storage and transmission through 32 rounds of changes, with the encryption algorithm protected by multiple mixed reinforcements, ensuring no one can view the password on the server side or during the transmission process.

The WiFi Master Key client, after encrypted acquisition, will make encrypted storage to the server database, and when any other user connects to the network based on the hotspot shared by you, the system will search the encrypted password from the database, and after secondary encryption, transmit it to the client, and the back office will provide hotspot connection services for that user. During the whole process, your password will be encrypted and hidden to ensure security.WiFi Master Key bears no legal liability for any leakage of the password or a third party’s access to and use of the password caused not due to WiFi Master Key.

2. [Other security measures taken by WiFi Master Key for the protection of personal information] WiFi Master Key, by establishing information classification and grading systems, user information security management systems, security development specifications, etc., standardizes security behaviors in respect of internal storage, use and sharing of personal information.

WiFi Master Key realizes comprehensive security control over data through information access confidentiality agreements, monitoring and auditing mechanisms, etc.

WiFi Master Key will monitor the act of its staff dealing with your information, continuously provide training for its staff on relevant laws, regulations and privacy security guidelines, reinforce and promote the security awareness, organize all staff to take part in security exams, and hold security and privacy training courses, with an aim to strengthen its staff’s knowledge on the importance of protecting personal information.

3. Please understand, due to technical limits and any possible malicious means, problems might arise for any reason out of our control. Upon occurrence of a personal information security incident, we will, according to laws and regulations, promptly advise you of: basic information and potential impact of that security incident, measures taken or to be taken by us to handle that incident, suggestions for your independent prevention and reduction of risks, remedial measures for you, etc. We will inform you of information about that incident on a timely basis via mail, letter, phone or push notice; if it’s hard to inform personal information subjects one by one, we will make an announcement in a reasonable and effective manner. Meanwhile, we will also, as required by regulators, proactively report the situation of handling that personal information security incident.

4. If we cease operation, we will promptly stop collecting your personal information, send a notice of ceasing operation to you in a one-by-one manner or by form of announcement, and destroy or conduct anonymous processing on personal information held.

V. How do you access and control the personal information provided by yourself

1.The rights you may exercise with respect to your personal information:

(I) Access your personal information

(II) Correct your personal information

(III) Delete your personal information

In the following cases, you can ask us to delete your personal information:

(IV) Cancel your account

(V) Change the scope of your authorization

2. If you are unable to access, correct or delete your personal information in the above way, or you need to access, correct or delete other personal information generated by your use of our products and/or services, you may contact our customer service for assistance.

3. If you find that your personal information is divulged, especially your account, please contact us immediately through the contact information provided in [How to contact us] at the bottom of this policy, so that we can take appropriate measures.

4. Before response to the requirements stated in (II) and (III) above, to ensure safety, we need to validate your identity and credentials first, and if passing the validation, processing will be completed within five working days; under any special circumstance, response shall be given within thirty days or the time limit prescribed by law. If dissatisfied with our response, you may also make a complaint with the consumer protection department or file a lawsuit with a court having jurisdiction.

5. In any of the following circumstances, according to laws and regulations, we will not be able to respond to your request:

VI. Protection of minor information

1. WiFi Master Key attaches great importance to protecting personal information of minors. If you are a minor under the age of 18, before use of our products and/or services, please make sure that your guardian will carefully read this privacy policy, and please use our products and/or services and provide information to us with prior consent of your guardian.

2. If you are a minor under the age of 18 and your guardian disagrees to your use of our services or provision of information to us as per this policy, you or your guardian should immediately stop using our services and contact us in a timely manner.

3. If becoming aware upon notice of your written notice or by ourselves that WiFi Master Key has collected personal information of any minor without prior consent of his guardian, WiFi Master Key will immediately stop collecting and using relevant information.

4. WiFi Master Key will protect the confidentiality and security of minor information in accordance with relevant state laws and regulations.

VII. Notice and amendment

1. To provide better services for you and with the business development of WiFi Master Key, this privacy policy will also be updated from time to time. However, without our explicit consent, we will not cut rights you shall enjoy under this privacy policy. We will prompt you of relevant updates by issuing an updated version at the mobile terminal of WiFi Master Key and prior to the effective date, by website announcement or other appropriate ways, and also you should access WiFi Master Key for a timely understanding of the latest privacy policy.

2. Upon occurrence of any major change, we will inform you in a way that can better prompt you of such change, including without limitation, sending mail, letter, phone, push notice, etc. Major changes referred to herein include without limitation:

3. [Amendment to Privacy Policy] Our possible amendment to this privacy policy forms a part of this privacy policy, and has retrospective effect. By continuing to use our products and/or services, you agree to be bound by this privacy policy so amended.

VIII. Governing law and dispute resolution

1. [Governing Law] The execution, interpretation and dispute resolution of this privacy policy shall be governed by the laws of the People’s Republic of China, irrespective of any conflict of laws.

2. [Dispute Resolution] Any dispute between you and WiFi Master Key on the content of this privacy policy or its execution shall be resolved by the parties through friendly consultation; if no consensus can be reached, the parties agree to submit the dispute to a court having jurisdiction in the place where the Company is situated for resolution by litigation.

IX. How to contact us

1. If you have any questions, comments or suggestions on this privacy policy or your personal information, please contact us by calling our customer service hotline 400-035-8000 or online feedback.

2. We have set up a dedicated department for protection of personal information (or a specialist for protection of personal information), and you can contact them by sending an email to: WiFikeypis@zenmen.com.

Note: This WiFi Master Key Privacy Policy is amended and takes effect as of November 22, 2019.