This privacy policy applies to all users of iFREE GROUP (Hong Kong) Co., Ltd. (hereinafter referred to as iFREE GROUP) and explains how we collect, use, share and protect users' personal information. If there are any updates to this policy, they will be displayed on the website simultaneously. Please be sure to read carefully and fully understand this privacy policy. When necessary, make the choice you deem appropriate in accordance with the guidelines of this policy. If you use or continue to use our services, you agree to our collection, use, storage and sharing of your relevant information in accordance with this Privacy Policy.

This Privacy Policy is closely related to your use of our products and/or services. When you download, install, launch, browse, register, log in, and use our products and/or services (hereinafter collectively referred to as "using our products and/or "Service"), we will handle and protect your personal information in accordance with the provisions of this Privacy Policy. We try our best to explain to you the technical terms involved in this privacy policy in concise terms so that you can understand it easily.

Please read and fully understand this Privacy Policy before using/continuing to use our products and services, and make appropriate choices according to the guidelines of this Privacy Policy when necessary. If you do not agree with the contents of this Privacy Policy, it may cause our products and/or services to not function properly, or fail to achieve the service effects we intend to achieve. You should immediately stop accessing/using our products and/or services. Your use or continued use of the products and/or services we provide indicates that you fully understand and agree to the entire content of this "iFREE" Privacy Policy (including updated versions).

It should be noted that this privacy policy only applies to "iFREE" products and services, and does not apply to other third-party products/services you access through "iFREE" products (including but not limited to any third-party payment institutions, third-party cooperation supplier), the specific agreement or similar policy statement reached between the third party and you shall apply, and the third party will directly collect from you and bear legal responsibilities related to data. We will be responsible for the collection and use of your personal information by the aforementioned third party and No responsibility is assumed for the consequences.

We will check or update the "iFREE" product functions or services from time to time, and update this privacy policy. We will publish the updated version of this privacy policy on the prominent pages related to the "iFREE" product. When using the "iFREE" products or services, please Be sure to visit our Privacy Policy page to stay informed of updates to our privacy policy.

If you have any questions about this Privacy Policy or related matters, please contact us at ask@ifreegroup.com.

1. How we collect and use your personal information

We will follow the principles of legitimacy, lawfulness, and necessity to collect and use the personal information you actively provide during the use of our services or that is generated by the use of our products and/or services for the following purposes described in this Privacy Policy. If we want to use your personal information for other purposes not specified in this privacy policy, or use the collected information for other purposes based on specific purposes, we will inform you in a reasonable manner and ask you again before use. With your consent.

The types of personal information we collect and use about you include: Information necessary for the core business functions of our products and/or services: This type of information is necessary for the normal operation of the products and/or services, and you must authorize us to collect it. If you do not provide relevant information, you may not be able to register as our user or enjoy some of the services we provide, or you may not be able to achieve the intended effects of the relevant services.

Typically, we collect information as follows:

1.1 Directly provided by the user, such as the information provided by the user when receiving an order email or when registering an account, the information provided when filling in the application form or product/service agreement, and personal data submitted through iFREE;

1.2 Obtained from third parties, such as iFREE product sales channels, or operators in various countries, as well as any business partners of iFREE parent company iFREE GROUP and entities related to users, or representatives with your consent;

1.3 iFREE’s own records of customers’ use of products and services;

1.4 When users visit or participate in our official website or other online services (for example, when you contact us through our website or email to ask questions, make comments, or participate in online surveys), you voluntarily provide us with information;

1.5 Shared information about you provided by other parties when using our services. If you choose to restrict the collection or use of your personal information, it may affect our normal provision of services.

2. Specific content of personal information we collect

The personal information we collect depends on the products and services you choose. Includes (but is not limited to) the following information:

2.1 Personal information required when registering a MOGO account, including email address and your personal phone number.

2.2 Payment information when consuming iFREE products, such as the credit card number, credit card expiration date and other personal information you provide.

2.3 Your preferences for specific products, services or lifestyle entertainment that you tell us, or our judgment based on the products and services you choose to use.

2.4 Call records and written records kept when you contact us.

2.5 Your MOGO account information, such as your payment date, services you ordered and any information related to your account.

2.6 When you use our services through a mobile device with positioning function, your geographical location information collected through GPS or WiFi*.

• You can stop our collection of your geographical location information at any time by turning off the positioning function.

2.7 Device information: Device identification code, device platform, and device manufacturer are used to generate unique push target ID (CID) and device ID (GID) to ensure accurate delivery of message push and accurate identification of message devices. Device brand, device model and system version are used to optimize the effectiveness of channel resources and improve the arrival rate and stability of message push. In addition, in order to ensure the uniqueness of CID and improve the stability and accuracy of message push, you also need to authorize storage permissions (WRITE_EXTERNAL_STORAGE, READ_EXTERNAL_STORAGE) and device permissions (READ_PHONE_STATE).

2.8 Application list information: We use merged link technology for technical push. When a device has multiple APP push links active at the same time, we will randomly merge them into one link to achieve the purpose of saving power and traffic for you. Therefore, it is necessary to obtain application list information; at the same time, we provide a smart push function, which can use this information to recommend push content that better meets your needs and reduce the interruption of useless push information to you.

2.9 Network information and location-related information : In order to maintain the stability of the network connection to the greatest extent and establish long links, we need to understand the network status and changes of the device to achieve stable and continuous push services. We provide a push function on occasion. Location-related information will help us provide you with refined push in offline scenarios. We can recommend push content that better meets your needs and reduce the interruption of useless push messages to you.

3. How we use your personal information

3.1 Assist the operations of iFREE parent company iFREE GROUP, such as incorporating into our database, analysis, research, troubleshooting, testing, auditing, statistics and surveys, etc.

3.2 Let us better understand how you access and use our services, so as to respond to your personalized needs, such as language settings, location settings, personalized help services and instructions, or to you and others who use us Users of the Service otherwise respond;

3.3 iFREE will cooperate with different companies to recommend new products, discounted products or other information that we think you may be interested in, or let you know through the partners' platforms, unless you choose not to receive iFREE's marketing information.

3.4 Process the products and services you purchase from iFREE and update you on the progress of your order in a timely manner.

3.5 Based on your personal information, customer service will better answer your questions about using the network, products or services.

3.6 Sometimes allow you to participate in surveys about our products and services. We may contact you by email, phone, fax or letter. We may also better customize our website based on consumer and user preferences.

3.7 When we provide services, it is used for identity verification, customer service, security prevention, fraud monitoring, archiving and backup purposes to ensure the security of the products and services we provide to you;

3.8 Any other purpose directly related to any of the above circumstances. Note: Within the scope permitted by law, iFREE will retain your personal information as needed. Unless there are special legal requirements, we will only store your information for as long as necessary. We may retain your information for a reasonable period after you contact us to facilitate your next use of our products and services.

3.9 Device information: The device identification code will be used to generate a unique user identification, namely GTCID. GTCID will be used for data deduplication and data statistics in different dimensions, and can be applied to scenarios such as advertising traffic distribution. Device platform, device manufacturer and brand, device model and system version, and device serial number help us help developers generate richer portraits, such as analyzing the advertising effects of different users and making corresponding adaptations based on different device information. Provide you with accurate products and services.

3.10 Application-related information: including but not limited to application list, channels, timestamps, unique page identifiers, and user click events. This information helps us help developers understand your interests and hobbies, achieve multi-dimensional statistical analysis, and display more relevant information. Content that you need, such as helping you make decisions about advertising-related services, and reducing unnecessary content that disturbs you.

3.11 Installed application information: In order to prevent malicious programs and ensure safe operation, we will collect information about the installed or running processes, the overall operation, usage, and frequency of the application, application crashes, overall installation usage, performance data, and application sources.

3.12 Network information and location-related information: Network information helps us help developers determine network status, thereby providing services such as preloading content only under wifi, reducing the loss of mobile traffic; location information helps us help developers provide Content and services that better suit your preferences.

3.13 Summary of device permission calls

Our summary of your main device permissions that "MOGO" will call when providing services is as follows. You can choose to turn off some or all permissions in your device's settings. In different devices, the permission display and closing methods may be different. For details, please refer to the instructions or guidelines of the device and system developers:

4. How we share personal information

Except for the following situations, we will not share your personal information with any third party without your consent:

4.1 Sharing with explicit consent: iFREE will share your personal data with other parties after obtaining your explicit consent.

4.2 Sharing with authorized partner companies: Some of iFREE’s services are provided by our partner companies. Therefore, we may share some of your personal data with them to provide better customer service and user experience. We will only process your personal data for specific, explicit and lawful purposes and will only share the data necessary to provide the service. Subsidiaries or partners that are also iFREE GROUP have no right to use the shared personal data for any other purpose.

4.3 Sharing based on legal or reasonable grounds includes (but is not limited to): iFREE may share your personal data when required by law, legal proceedings, litigation or public and government authorities. Your personal data will also be disclosed to counterparties if they are involved in reorganization, merger or bankruptcy and liquidation proceedings. iFREE may disclose your data when reasonably necessary to enforce the terms and conditions and protect customers.

4.4 Currently, our partners include the following types. For details, please refer to the "Third Party Information Sharing List":

4.5 Cooperating third-party SDK service providers: When you use functions provided by third parties in "MOGO", we may access the software development kit (SDK) provided by the third party to implement related functions. At this time, the third-party SDK service provider may collect your relevant personal information. The collection and processing of information by the aforementioned service provider abide by its own privacy terms and has nothing to do with MOGO, and does not apply to this privacy policy. In order to protect your information security to the greatest extent, we recommend that you check the privacy terms of any third-party SDK services before using them. To protect your legitimate rights and interests, if you find that there are risks in this SDK or other similar applications, we recommend that you immediately terminate the relevant operations and contact us in a timely manner.

4.6 Geolocation services: In order to provide you with location services (weather positioning, time zone and related functions), third-party geolocation service providers will collect your device information and precise geolocation information so that they can push nearby content to you;

4.7 Cloud storage service: In order to provide you with cloud storage service (the data you upload to "MOGO" will be stored in the cloud and related scenarios), third-party service providers may collect your device information, network-related information, and operator information;

4.8 Account security service: In order to protect the security of your and other users’ accounts and property, and protect your and our legitimate rights and interests from illegal infringement, third-party security service providers may collect your necessary device information, network-related information, and operator information. Information and log information to provide account security services;

4.9 Secure Payment: Ensure the security of funds in users’ accounts and the safe and stable operation of payment services during payment for membership services, and fulfill legal obligations such as anti-money laundering, anti-terrorist financing, and anti-telecom network fraud.

4.10 Device Sensor: When the device sensor provides you with channel content in the same city or content or services related to the location of the device, with your authorization, we will use the geographical location information related to this service (such as precise positioning information, WLAN access point, Bluetooth and base station, sensor information) to ensure the quality of content or services. The precise positioning information is personal sensitive information. If you refuse to authorize location permission, it will affect the accuracy of positioning, but it will not affect the normal use of other functions and services. We will only use the city and/or the corresponding network information (such as IP). Or show you potentially relevant content or services.

5. How to access and control your information

5.1 We will try our best to adopt appropriate technical means to ensure that you can access, update and correct your registration information or other personal information provided when using our services.

5.2 When accessing, updating, correcting and deleting the aforementioned information, we may require you to perform identity verification to ensure account security.

5.3 The accuracy and completeness of personal information are important. You can visit the iFREE official website or download the MOGO APP to log in to your account to help us ensure that your personal information is accurate, complete and updated in a timely manner.

5.4 Whenever you voluntarily disclose personal information (such as on public platforms such as WeChat, Weibo, or via email), such information may be collected and used by others, resulting in the leakage of your personal information, and iFREE is not responsible. Therefore, we remind you and ask you to carefully consider whether it is necessary to disclose your personal information through the above channels.

5.5 Our business may require us to transfer your personal data to other countries. We will take appropriate measures to ensure that recipients of your personal data fulfill their confidentiality obligations and ensure the implementation of measures such as standard contractual clauses. You can obtain these terms by contacting our customer service.

6. How we protect your personal information

iFREE strives to protect our users from unauthorized access, alteration, disclosure or destruction of the information we hold.

6.1 The security of users’ personal data is of vital importance to us. Therefore, iFREE adopts a strict confidentiality system to protect your personal data retained in iFREE and prevent data from unauthorized access, disclosure, use, modification, damage or loss.

6.2 We will take all reasonable and feasible measures to protect the personal data you leave on the iFREE platform, such as registering a MOGO account, etc. These measures include:

6.2.1 Use encryption technology to ensure data confidentiality;

6.2.2 Use trusted protection mechanisms to protect data from malicious attacks;

6.2.3 Deploy access control mechanisms to ensure that only authorized employees within iFREE can access personal data;

6.2.4 Regularly hold security and privacy protection training courses to enhance internal employees’ awareness of the importance of protecting personal data.

6.3 As a global communications company, iFREE GROUP and its subsidiary brand iFREE will make every effort to ensure that no personal data irrelevant to our operational processes is collected. In addition, we will only retain your personal data for the period necessary to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law.

6.4 In order to safeguard your account security, transaction security, and system operation security, and to comply with legal regulations and our agreement rules, during your access and use of our products/services, we will collect your device information and network status information with your authorization. This may include your device model, hardware serial number, device MAC address, unique device identifiers (such as IMEI/MEID/IMSI/AndroidID/IDFA/OAID), SIM card IMSI, ICCID information, running process information, mobile app list, Wi-Fi status, and telecommunications carrier information, among other software and hardware characteristic information. We will not collect the above information without your authorization.

6.5 Please understand that due to technical limitations and risk prevention limitations, even if we have strengthened security measures as much as possible, we cannot always guarantee 100% information security.

1. Your rights

7.1 Subject to applicable law, you have the right to object to or request restriction of the processing of your personal data, and to request access, rectification, deletion and portability of your personal data.

7.2 If the use of your information is based on your consent, you have the right to withdraw that consent at any time, but the withdrawal of consent will not affect the legality of data processing based on consent before the withdrawal. You can submit your request to us through [Customer Service Support].

7.3 If you discover that your information has changed or is inaccurate, please notify us of these changes so that our records can be updated or corrected. If you believe that our processing of your personal data violates applicable law, you may lodge a complaint.

7.4 The period of time we retain your personal data depends on the need to provide you with services or products, or as required or permitted by applicable laws such as tax and accounting laws.

7.5 How do you cancel your account?

You can apply to cancel your account through [Personal Center-Account Management and Binding-Cancel Account] and meet the conditions for account cancellation; we will wait ten working days after receiving your cancellation application and verifying your user identity. We will handle it for you as soon as possible. You know and understand that the act of canceling your account is irreversible. Once you cancel your account, your personal information (including username, avatar, mobile phone number, etc.) will be deleted from removed from "MOGO", and you will no longer be able to log in and use our products and services with this account.

1. Important Information

8.1 When you use our services, we may use your information to send emails, news or push notifications to your device. If you do not want to receive this information, you can follow our relevant prompts and choose to unsubscribe on your device.

8.2 We may issue service-related announcements to you when necessary (such as when a service is suspended due to system maintenance). You may not cancel these service-related announcements that are not promotional in nature.

8.3 We encourage parents or guardians to guide minors under the age of 18 to use our services. We recommend that minors encourage their parents or guardians to read this policy and that minors seek the consent and guidance of their parents or guardians before submitting personal information. iFREE will protect minors’ relevant information in accordance with relevant national laws and regulations. Minors may not create their own "MOGO" account without the consent of a parent or legal guardian. If you are a minor, please obtain the consent of your parent or legal guardian before using "MOGO" products or services.

For situations where we collect personal information from minors with the consent of their parents or legal guardians, we will only use or publicly disclose this information as permitted by law, with the express consent of parents or legal guardians, or as necessary to protect the minor.

If we discover that we have collected personal information from a child without first obtaining verifiable parental or legal guardian consent, we will seek to delete the data as quickly as possible. If you think that we may have collected information from your minor wards under the age of 18 without your consent, please contact us and we will delete the information.

9. Legal basis for data processing

9.1 Our legal bases for processing personal data include:

9.1.1 To perform the contract with you. For example, to provide you with services you request, to identify and authenticate you so that you can use the website.

9.1.2 To comply with legal requirements. For example, to comply with applicable accounting rules and to comply with mandatory disclosure requirements from law enforcement agencies.

9.1.3 To protect our legitimate interests. For example, to manage our relationship with you, to ensure the security of our services, and to communicate with you about our products and services.