PandaVox Privacy Policy

Effective Date: June 15, 2026

1. Scope of Application:

This Privacy Policy ("Policy") governs the PandaVox mobile application (including the international version and Mainland China version) and all related products, websites, and services (collectively, the "Service"), which are developed and operated by Sichuan Guancha Digital Media CO., LTD (hereinafter "SCGC", "we", "us", "our" or "PandaVox").

SCGC is the unified operator of the Service worldwide. This Policy explains how we collect, use, store, share, transfer and protect personal information, and what rights you may exercise in relation to that information.

This Policy also contains jurisdiction-specific supplements for the European Union, the United Kingdom, the United States (including California), and other regions as needed to comply with applicable laws.

"User" or "you" refers to the user of the Service. The term "your" shall be construed accordingly.

2. Summary (Key Information)

[Data Collection:] We collect personal information necessary to provide our core services (including account information, device information, location information, usage logs, and content you publish). Some of this information may be considered sensitive (such as precise location, identity verification information, etc.). For such information, we will provide prominent notification and obtain your separate consent before collection where required by law.

[Data Storage and Transfer:] Our primary servers are located in Singapore. For cross-border data transfers, we will implement compliance measures required under applicable laws—including but not limited to the GDPR, UK GDPR, CCPA/CPRA, and the Personal Information Protection Law of the People's Republic of China (PIPL)—such as Standard Contractual Clauses (SCCs), appropriate safeguards, user consent, or other lawful bases.

[User Rights:] You may exercise your rights to access, rectify, delete, restrict processing, data portability, and withdraw consent (among others) via your account settings or through the channels we provide. Please see the sections "Your Rights" and "Supplementary Terms" (where applicable).

[Third-Party Disclosure:] Where third-party SDKs, service providers or advertising partners collect data through our Service, we will disclose them individually in the Appendix to this Policy.

3. Contents

I: How We Collect and Use Your Personal Information

II: How We Determine the Purposes and Legal Bases for Processing

III: How We Use Cookies and Other Similar Technologies

IV: How We Share, Entrust Processing of, and Disclose Information

V: Storage, Retention and Cross-Border Transfers of Information

VI: Protection of Minors

VII: Your Rights and How to Exercise Them

VIII: Security Measures and Data Breach Response

IX: How We Update the Privacy Policy

X: How to Contact Us

Appendix: List of Third-Party SDKs (Current and To-Be-Supplemented)

I: How We Collect and Use Your Personal Information

When you use the Service, we collect and process personal information in a lawful, fair, transparent and necessary manner. The legal bases and specific rules for processing may vary depending on your jurisdiction.

1. Information You Provide to Us

This includes but is not limited to:

Basic account/profile information:

Registration data provided during account creation (e.g., nickname, avatar, bio) and authentication credentials.

Third-party login information:

If you utilize third-party authentication (e.g., Apple, Google), we collect authorized profile information (e.g., nickname, avatar) to facilitate account binding and direct access.

User-generated content (UGC):

Content published via the Service (comments, replies) and associated metadata (e.g., timestamps of posting, editing, or deletion).

Information you provide when contacting us:

When you contact us (including for customer support), we collect the information you send or provide to us as part of that communication.

2. Information We Collect Automatically

Device information:

To provide a secure and reliable operating environment, we collect device-related information, including your device ID, model, network type, Wi-Fi status, operating system version, IP address.

Usage information:

Interaction data including browsing history, click-stream records, session duration, and system diagnostic/crash logs.

3. Information from Third Parties

When you choose to log in with a third-party account (such as Apple or Google), subject to your authorization, we may obtain from that third-party your profile avatar, nickname, email address and other information you permit to be shared.

II: How We Determine the Purposes and Legal Bases for Processing

We process your information to operate, maintain, support and manage the Service, enforce our Terms of Service, and for the following purposes:

Provision of basic services: Account authentication, content delivery, and video playback;

Support for interactive features: Enabling user engagement such as liking, commenting, and social interactions;

Communication: Service updates, administrative notices, and support communications;

Security and Risk Control: Fraud detection, abuse prevention, and safeguarding Service integrity;

Personalized recommendations: Displaying content tailored to your preferences and interests;

Compliance with legal obligations: Fulfilling statutory duties, public interest tasks, or protecting vital interests.

Product improvement: Optimizing performance, analyzing usage behavior, and enhancing user experience.

We may also use your personal information for other purposes that we disclose to you at the time of collection, or for other purposes with your consent where required by applicable law.

EU / UK (GDPR / UK GDPR)

When we process personal data of users in the European Union or the United Kingdom, we will specify the applicable legal basis (for example, performance of a contract, user consent, legitimate interests, or compliance with legal obligations). Where we rely on "legitimate interests" as our legal basis, we will conduct a balancing test and, where appropriate, provide you with means to exercise your right to object to, or request restriction of, such processing.

California (CCPA / CPRA) and Other U.S. States

For California residents, we will explain that we do not sell personal information (where applicable) or provide you with controls to opt out of the "sale" or "sharing" of personal information. We will also provide mechanisms for you to access and delete your personal information and to opt out of targeted advertising, and will handle "sensitive personal information" and related rights in accordance with the CPRA and other applicable California laws.

Children's Privacy (COPPA and Similar Laws)

The Service is not directed to children under the age of 13 (or the minimum age prescribed by the laws of your jurisdiction). If we become aware that we have collected personal information from a child without the required authorization, we will take steps to delete such information and terminate the corresponding account. Where we offer features directed at teenagers or features that require parental consent, we will implement parental consent mechanisms in accordance with the applicable rules in each jurisdiction (including COPPA, EU requirements and relevant U.S. state laws).

III: How We Use Cookies and Other Similar Technologies

We and our partners use cookies and similar technologies (e.g., web beacons and Flash cookies, collectively referred to as "Cookies") to enhance your experience on the Platform and to improve our services. Cookies are small files stored on your device that enable the Platform to provide certain functions and services. Web beacons are tiny images or small snippets of data embedded in images (also known as "pixel tags" or "clear GIFs") that can recognize Cookies, record the date and time a webpage is viewed, identify the webpage on which the pixel tag is placed, and collect similar information from your computer or device. Where required by applicable law, we will obtain your prior consent for the use of non-essential Cookies.

You have the right to choose whether to accept Cookies. You may refuse Cookies by modifying your browser settings or by configuring your mobile device settings.

In addition, we allow our business partners and other vendors and service providers to use Cookies to collect information about your online activities in connection with the Platform. We are not responsible for the privacy practices of such third parties, and their handling of your information is not governed by this Privacy Policy.

IV: How We Share, Entrust Processing of, and Disclose Information

We do not sell your personal information. We only share your personal information under the following conditions:

1. Third-Party Service Providers
   We may disclose necessary data to third-party processors (e.g., SDK providers) to facilitate Service functions as detailed in the Appendix.
2. Legal Obligations and Protection of Rights
   Disclosure to competent authorities, courts, or regulators when compelled by valid legal process.
3. Business Transfers
   In the event of a merger, acquisition, reorganization or similar corporate transaction, we may require the new data recipient to continue to be bound by this Policy or to provide substantially the same level of protection for your personal information.

V: Storage, Retention and Cross-Border Transfers of Information

1. Storage Location
   Our primary servers are located in Singapore. We implement appropriate technical and organizational measures to protect the security of your data. At present, we do not routinely transfer or store your personal information outside the jurisdiction in which it is collected, except as otherwise disclosed in this Policy or required for providing the Service.

If in the future we need to transfer or store your personal information outside the jurisdiction where it is collected, we will inform you of the purpose of such cross‑border transfer, the recipient(s), the safeguards in place and potential security risks, and will obtain your consent where required by applicable laws.

2. Retention Period
   We retain your personal data only for as long as is reasonably necessary to achieve the purposes of processing. After you deactivate or cancel your account, we will delete or anonymize your personal data in accordance with applicable laws and regulations. Certain logs (for example, security logs) may be retained for a longer period if required by law.

VI: Protection of Minors

1. Global Rule

The PandaVox app is not directed to children under 13 years of age.

2. Age Requirements by Region

United States (COPPA): Children under 13 require verifiable parental consent.

European Union: The minimum age for valid consent varies by Member State between 13 and 16 years old.

Mainland China: Personal information of children under 14 is treated as children's personal information and is subject to special protection.

If we become aware that a minor has registered an account or provided personal information without the consent of a parent or legal guardian where such consent is required, we will delete such information as soon as reasonably practicable.

VII: Your Rights and How to Exercise Them

We attach great importance to, and use our best efforts to protect, your rights in relation to your personal information. Depending on the laws of the jurisdiction in which you are located, you may have some or all of the following privacy rights:

General Rights (Applicable in Most Regions)

Right to access your information

Right to rectify inaccurate information

Right to delete your information

Right to restrict processing

Right to withdraw consent (where processing is based on consent)

Right to data portability (where applicable by law)

Right to object to automated decision-making, including profiling, where applicable

Right to deactivate or delete your account

EU / UK GDPR Rights

These may include:

• Right to data portability
• Right to object to processing based on our legitimate interests
• Right to lodge a complaint with a supervisory authority
• Right to request that we provide information on the specific GDPR / UK GDPR legal bases on which we rely

California Residents' Rights (CCPA / CPRA)

These may include:

• Right to know the categories of personal information we collect and share
• Right to request deletion of personal information, subject to certain exceptions
• Right to opt out of the sale or sharing of personal information (if and where applicable)
• Right to limit the use and disclosure of sensitive personal information, to the extent required by law
• Right to equal service and non‑discrimination for exercising your privacy rights

How to Exercise Your Rights

You may exercise your rights by contacting us via:

• Telephone: +86 19150075286
• Email: sichuanguanchatech@gmail.com

We will respond within the time frame required by applicable laws.

VIII: Security Measures and Data Breach Response

We are committed to providing you with a secure and trustworthy product and usage environment, and delivering high‑quality and reliable services is our core objective. We implement a variety of industry‑standard technical and organizational security measures to ensure that your information is processed securely and in accordance with this Policy.

However, please be aware that no method of transmission over the internet or method of electronic storage is completely secure, and no "perfect" information security measures exist. In the event of a personal data breach, we will inform you without undue delay and notify supervisory authorities as required by applicable laws.

IX: How We Update the Privacy Policy

We may revise or update this Privacy Policy from time to time. When we make material changes to this Privacy Policy, we will inform you of material changes by updating the "Effective Date" at the top of this Policy, by publishing a new version of this Privacy Policy, or by providing you with other notices as required by applicable laws. We encourage you to review this Policy periodically to stay informed about our privacy practices.

X: How to Contact Us

Operator: Sichuan Guancha Digital Media CO., LTD.

Email: sichuanguanchatech@gmail.com

We will review and handle your queries or complaints as soon as reasonably practicable and within the timeframe required by applicable laws and regulations.

Appendix: List of Third-Party SDKs

We share the categories of personal information described above with service providers to assist us in operating our business and achieving various business purposes, including one‑click login, video content playback and other related functions. Such service providers may include, without limitation: