X Recorder Privacy Policy
Update
Date: December 16, 2025
Release Date: December 16, 2025
Effective Date: December 16, 2025
This "X Recorder Privacy Policy" (hereinafter referred to as "this Policy") applies solely to the X Recorder products and services provided by TPV Display Technology (Xiamen) Co., Ltd. (hereinafter referred to as "we" or "us"). Before using this software, please read this Policy carefully to understand how we process your personal information. Important content related to personal sensitive information and your rights and interests regarding personal information has been highlighted in bold. Please pay special attention.
If you are under 14 years old, please read and fully understand this Policy under the accompaniment of your parents or other guardians and use X Recorder products and services only after obtaining their consent.
Special
Notice:
Your agreement to this Policy only indicates that you have understood the
functions provided by X Recorder and the necessary personal information
required for their operation.
For personal sensitive information, we will obtain your separate consent through pop-up windows before collection.
Corresponding device permissions will not be enabled by default. When important or sensitive device permissions are involved, we will obtain your separate consent through pop-up windows when you use the corresponding business functions. After enabling the permissions, you can close them at any time in the device system permission settings page. If you disagree with enabling the permissions corresponding to a business function, it will not affect the normal use of other non-related business functions.
If you reject this Policy, you can still use the basic functions of X Recorder without registering or logging in.
You can also choose to agree later during the service usage process to use all functions of X Recorder.
This Policy will help you understand the following:
I. Definitions and Explanations
II. How We Collect and Use Your Personal Information
III. How We Share, Transfer, and Publicly Disclose Your Personal Information
IV. How We Protect Your Personal Information
V. How We Store Your Personal Information
VI. How You Can Manage Your Personal Information Rights
VII. How We Protect the Personal Information of Minors
VIII. How Your Personal Information Is Transferred Globally
IX. How We Update This Policy
X. How to Contact Us
XI. Others
I. Definitions and Explanations
¡¤ X Recorder Products and/or Services: Includes the X Recorder App (hereinafter referred to as "this Software") and products and/or services provided by the X Recorder website.
¡¤ X Recorder Services: Refers to the services provided by TPV Display Technology (Xiamen) Co., Ltd. to users through X Recorder, hereinafter referred to as "this Service."
¡¤ TPV Display Technology (Xiamen) Co., Ltd.: The operator of X Recorder. For more detailed information about our company and platform, you can contact us through the contact information provided in Chapter X of this Policy.
¡¤ User: Refers to individuals who register, log in, and use this Software, and enable, browse, or upload data to X Recorder services. In this Policy, they are more commonly referred to as "you."
¡¤ Associated Companies: Any party that directly or indirectly controls us, is controlled by us, or is under common control with us.
"Control" and "controlled" refer to the right to direct the management policies of a party through voting rights, contracts, or other means.
¡¤ User Account: Refers to the user account you obtain after completing real information registration, which you are responsible for safeguarding.
You shall be legally responsible for all actions taken under your account.
¡¤ Personal Information: Any information recorded electronically or otherwise that is related to an identified or identifiable natural person, excluding anonymized information. Personal information includes, but is not limited to, sensitive personal information.
¡¤ Sensitive Personal Information: Information that, if leaked or illegally used, could easily lead to infringement of a natural person's dignity or harm to their personal or property safety.
This includes biometric, religious beliefs, specific identities, medical health, financial account, location trajectory information, and the personal information of minors under 14 years old.
¡¤ Processing of Personal Information: Includes the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.
¡¤ Personal Information Processor: An organization or individual that autonomously determines the purpose and method of processing personal information in personal information processing activities.
¡¤ Personal Information Subject: Refers to the natural person identified or associated with the personal information.
¡¤ Automated Decision-Making: Activities that automatically analyze, assess, or make decisions about an individual's behavior habits, interests, or economic, health, or credit status through computer programs.
¡¤ De-identification: The process of rendering personal information unidentifiable without additional information.
¡¤ Anonymization: The process of rendering personal information unidentifiable and irrecoverable.
¡¤ Device: Refers to any device that can be used to access X Recorder services, such as desktop computers, laptops, tablets, or smartphones.
¡¤ IP Address: Every device connected to the internet is assigned a number known as an Internet Protocol (IP) address.
These numbers are typically assigned based on geographical regions and can be used to identify the location of the device when connected to the internet.
¡¤ SSL: Secure Socket Layer (SSL) is a security protocol implemented on the Transmission Control Protocol/Internet Protocol (TCP/IP) to provide secure communication.
SSL supports various types of networks and provides three basic security services through the use of public and symmetric key technologies to achieve information confidentiality.
¡¤ Information Collection Technologies: As mentioned in this Policy, "automatic collection" includes the following methods:
o Cookies: Small text files placed on your client device (computer, mobile phone, or other intelligent terminal) by a website server when you browse a webpage.
They are used to improve your user experience.
o Log Files: Files that store automatically collected data, including Internet Protocol (IP) addresses, browser types, Internet Service Providers (ISPs), referrer/exit pages, operating systems, date/time stamps, and clickstream data.
o ET Tags: HTTP protocol headers transmitted behind the scenes between an internet browser and an internet server, which can replace cookies to track individual users and allow us to better understand and improve our services.
o JavaScript: A programming language used to create more interactive and dynamic web pages.
JavaScript can set, read, and delete cookies.
II. How We Collect and Use Your Personal Information
As the personal information processor, we will adhere to the principles of legality, legitimacy, necessity, and good faith to collect and use your personal information for the purposes described below.
According to the "Provisions on the Scope of Necessary Personal Information for Common Types of Mobile Internet Applications," X Recorder falls under the category of "utility tool" apps.
The complete functionality of X Recorder includes recording, voice-to-text conversion, voice translation, dialogue translation, and text summarization.
You only need to provide us with the basic necessary personal information corresponding to each function, except where special requirements are stipulated by relevant laws and regulations.
If you refuse to provide this information, we will not be able to provide you with the corresponding functional services.
Please note that if you provide personal information of another individual, ensure that you have obtained their consent. The complete functionality of X Recorder and the personal information required for processing are detailed below:
1.1 APP Operation:
(1) Necessary
Information, Non-Necessary Information Scope
We will collect your network type, IP address, operating system type, APP
process name, operating system version, and device resolution to identify
whether you are a real natural person user, comprehensively assess your account
risk, conduct identity verification, detection, and prevent security incidents,
and take necessary recording, analysis, and disposal measures in accordance
with the law.
This information is necessary for this function. If you disagree, you will not be able to use this function normally.
1.2 Recording Transcription and Translation:
(1) Necessary
Information, Non-Necessary Information Scope
When you use the recording transcription and translation service, we will
collect your voice information and/or the recorded content you upload for voice
transcription and translation.
Simultaneously, we will collect the transcribed text information to understand your needs and provide real-time processing feedback to facilitate record viewing and effect analysis services.
This information is necessary for the recording transcription and translation function. If you cannot provide it, you will not be able to use this function.
1.3 Customer Service and Feedback:
(1) Necessary
Information, Non-Necessary Information Scope
When you use the user feedback function, we will collect your mobile phone
model, system version, and text information you input to understand your
feedback content and needs.
This information is necessary for the user feedback and customer service function.
You can also provide your phone number and email address to facilitate better communication and problem resolution. This information is non-necessary for the user feedback and customer service function.
To provide customer service and after-sales support related to your order needs, ensure the normal completion of orders, understand your product usage experience and other needs to improve our products and services, or provide other services related to your rights and interests, our customer service personnel may contact you via phone, SMS, or email using your account information (phone number or other contact information you provided) to better understand your needs and relevant problem resolution plans or help you solve other problems.
During the feedback, complaint, or consultation process, to help you solve problems or record relevant problem resolution plans and results, you need to provide corresponding supporting materials (images or videos).
The system will record your communication records with customer service to better solve your consulted problems and improve customer service quality.
If you do not provide this information, we may not be able to provide timely feedback on your consultation results, but it will not affect your normal use of X Recorder products and/or services.
1.4
Clipboard
When you actively choose to copy and paste relevant text for content input in X
Recorder, the system clipboard permission will be triggered.
During this process, we will not read or upload your clipboard information to our servers.
1.5
Information Push
To ensure that this application can normally receive pushed information when it
is closed or running in the background, this application integrates a push SDK.
Its push function requires the use of the (self-starting) capability, which will involve a certain frequency of system broadcasts to wake up the application for self-starting or associated starting behavior.
This is necessary for realizing the function and service. When you open content-based push messages, after obtaining your explicit consent, it will jump to open the relevant content.
Without your consent, there will be no associated starting.
To further clarify the details of permission calls for the above functional services that involve your personal information, we summarize the call situations in the following table. Please note that enabling any permission represents your authorization for us to collect and use the relevant personal information to provide you with the corresponding service.
Once you close any permission, it represents the cancellation of your authorization, and we will no longer continue to collect and use the relevant personal information based on the corresponding permission and will not be able to provide you with the service corresponding to that permission.
However, your decision to close a permission will not affect the information collection and use previously conducted based on your authorization.
|
System Permission |
Corresponding Business Function |
Purpose of Permission Call |
Timing of Permission Request |
|
Wireless Data |
Recording transcription and translation |
Use the network to communicate with the server |
iOS: Ask via pop-up window when the application is first used |
|
Microphone |
Recording transcription and translation |
Use the microphone for recording |
First use of recording function: Ask via pop-up window |
|
Bluetooth |
Connect to smart hardware |
Connect to external microphone devices |
First use of device connection function: Ask via pop-up window |
|
Storage |
Data migration |
Data migration |
First data migration: Ask via pop-up window |
|
Notifications |
Message notifications |
Send notification messages |
iOS: Ask via pop-up window when the App is first opened |
|
Floating Window |
Floating subtitle function |
Open floating text subtitles |
First use of floating subtitle function |
|
Screen Recording |
Recording transcription and translation |
Use internal recording function for recording |
Use of internal recording function: Ask via pop-up window |
|
NFC Permission (Android only) |
Recording transcription and translation, floating subtitle function |
Quickly open recording and floating subtitle functions |
Use of NFC function |
Please note that the phone status permission is directly obtained by third-party SDKs.
Specifically, you can read the "X Recorder Third-Party Information Sharing List" to understand the details of device permissions obtained by third-party SDKs.
1.6
Widget Function
You can use the X Recorder App's widget function through the mobile device's
widget feature.
To further display the content of the widget you click on and realize the addition, deletion, and updating of widgets, there will be associated starting behavior between the widget and the X Recorder App to ensure the realization of the above functions.
We will not collect user privacy data through the widget function and will not provide you with any personalized services.
If a function that requires the collection of your personal information or a product/service is not explained in this Policy, or if we exceed the purpose stated at the time of collecting your personal information and the directly or reasonably associated scope, we will notify you again and obtain your consent in accordance with legal requirements.
Exceptions
We do not need your authorization consent to process your personal information
in the following circumstances:
(1) Necessary for concluding or performing a contract to which you are a party;
(2) Necessary for fulfilling legal duties or obligations;
(3) Necessary for responding to public health emergencies or protecting the
life, health, or property safety of natural persons in emergency situations;
(4) Necessary for implementing news reporting or public opinion supervision
behaviors for the public interest within a reasonable scope to process personal
information;
(5) Necessary for processing personal information that you have publicly
disclosed yourself or that has been legally publicly disclosed within a
reasonable scope in accordance with the law;
(6) Other circumstances stipulated by laws and administrative regulations.
2.
Personal Information Actively Collected During the Provision of Products and/or
Services to You
Under the premise of complying with laws and regulations, to safeguard your
account security and provide you with better-quality services, we will collect
and use the following information generated during your use of X Recorder
products and/or services:
2.1
Ensuring Operational Safety and Problem Investigation
When you use X Recorder products and/or services, we will receive and record
relevant device information based on your specific permissions during software
installation and use, including in silent mode or background operation, to
conduct access volume statistics and fault location, safeguard your account and
usage security, and ensure the normal operation of network connection services.
Specific information includes mobile phone hardware model, mobile phone system information, mobile phone screen information, operating system information, X Recorder App installation information, running process information, device sensor parameters, service provider network ID, access network method type and status, unique device identifier (IDFA (iOS), OPENUDID (iOS), OAID (Android), SSID (Android), ODID (HarmonyOS), OAID (HarmonyOS)).
This is necessary information for problem investigation and security maintenance.
If you refuse us to collect the above information, we will not be able to conduct security monitoring for this software, which may affect account usage security in specific situations.
Please note that some of the above device information is directly collected by relevant third-party SDKs (IDFA (iOS), IDFV(iOS), OAID (Android), SSID (Android), AndroidID (Android), ODID(HarmonyOS), OAID(HarmonyOS)).
Specifically, you can read the "X Recorder Third-Party Information Sharing List" to understand the details of device information collected by third-party SDKs.
2.2
Operational Statistics and Product Optimization
When you use X Recorder products and/or services, we will automatically collect
detailed information about your usage of X Recorder products and/or services
and save it as network logs, including X Recorder App software version number,
input box type, input text type, search query content, network status,
manufacturer, mobile phone model, access date and time, device crash records.
This allows us to statistically analyze the usage of X Recorder products and/or
services, investigate problems, ensure service stability and network security,
and conduct operational analysis, improvement, and optimization of product
interaction experience through data statistics.
3.
Personal Information Indirectly Collected
When you use third-party applications accessed within X Recorder, we will
obtain necessary personal information from the developers of such third-party
applications and their technical service providers for the purpose of providing¶Ô½Ó (docking) technical support.
This includes device information (IDFA (iOS), IDFV(iOS), OAID (Android), AndroidID (Android), SSID (Android), ODID(HarmonyOS), OAID(HarmonyOS)) and operational behavior log information.
If your sensitive personal information is involved, we will obtain your separate authorization.
If you refuse us to collect relevant personal information, it may result in the inability to fully or partially implement the functions of third-party applications in specific situations, but it will not affect your use of other functions of X Recorder.
The developers of such third-party applications and their technical service providers may directly collect, use, and process your personal information in accordance with their privacy policies, but we will not obtain this personal information.
We recommend that you read and confirm your understanding of such privacy policies before accepting related services and providing personal information.
4.
Explanation of Personal Information Processing
(1) Based on the personal information you provide to us and the personal
information we actively collect, including your account information, device
information (IDFA (iOS), IDFV(iOS), OAID (Android), AndroidID (Android), SSID
(Android), ODID(HarmonyOS), OAID(HarmonyOS)), log information, order
information, and search records, we may contact you by phone, SMS, or other
means for product consultation and after-sales work under specific
circumstances.
Please note that according to relevant laws and regulations, you have the right to refuse information notifications and commercial marketing directed at individuals.
(2) According to applicable laws and regulations, under specific circumstances, we will conduct technical processing of your personal information to make it impossible to precisely identify individual users and conduct academic research or statistical analysis on the technically processed information (including using anonymized or de-identified voice information for model algorithm training) to better enhance product functionality and service capabilities.
(3)
According to relevant laws and regulations, we do not need to obtain your
consent to process your personal information in the following circumstances:
• Necessary for concluding or performing a contract to which you are a party,
or implementing human resource management in accordance with legally formulated
labor regulations and legally signed collective contracts;
• Necessary for fulfilling legal duties or obligations;
• Necessary for responding to public health emergencies or protecting the life,
health, or property safety of natural persons in emergency situations;
• Necessary for implementing news reporting or public opinion supervision
behaviors for the public interest within a reasonable scope to process personal
information;
• Necessary for processing personal information that you have publicly
disclosed yourself or that has been legally publicly disclosed in accordance
with the law;
• Other circumstances stipulated by laws and administrative regulations.
(4) You can quickly understand the basic situation of our collection of your personal information, including information types, usage purposes, and usage scenarios, by consulting the "X Recorder Personal Information Collection List."
6.
How We Use Cookies and Similar Technologies
Our products and services do not use our own Cookies and similar technologies
to collect and use your personal information.
To provide you with more comprehensive and high-quality products and services, we may entrust third parties (including companies, organizations, and individuals) to process certain aspects of your personal information. For third parties entrusted with processing your personal information, we will sign stringent data processing agreements with them, clearly stipulating the purpose, duration, processing methods, types of personal information, protection measures, and the rights and obligations of both parties. We will also supervise the third parties' personal information processing activities, requiring them to process your personal information solely in accordance with our requirements, the provisions of this policy, and any other relevant confidentiality and security measures, without exceeding the agreed processing purposes or methods. If you refuse to allow our third parties to collect personal information necessary for providing services during your use of the X Recorder product and/or services, you will be unable to enjoy the services provided by those third parties.
2. Sharing
We will not share your personal information with third parties (including companies, organizations, and individuals), except in the following circumstances:
(1) Sharing with Explicit Consent: After obtaining your explicit consent, we may share your personal information with third parties.
(2) Sharing under Legal Circumstances: We may share your personal information with third parties in accordance with legal and regulatory requirements, for the resolution of litigation disputes, or in response to requests from administrative or judicial authorities made in accordance with the law.
(3) Sharing Among Affiliated Companies: To provide better services by integrating with our other products or services, or to protect the personal and property safety of our affiliated companies, other users, or the public from harm, your information may be shared within our affiliated companies. We will only share your personal information among our affiliated companies for specific, clear, and legitimate purposes as stated in this policy and will only share information necessary for providing services. For information shared with affiliated companies, we will require them to adopt protection measures that are no less stringent than those stated in this policy and strictly comply with relevant laws, regulations, and regulatory requirements. If an affiliated company intends to change the purpose of processing personal information, it will need to seek your authorization again.
(4) Sharing with Authorized Partners: Some of our services are jointly provided by us and our authorized partners solely to achieve the purposes stated in this policy. We may share your personal information with our partners to provide better customer service and user experience. We will only share your personal information for lawful, legitimate, necessary, specific, and clear purposes and will only share information necessary for providing services. Our partners have no right to use the shared personal information for any other purposes. Specifically, you can click to read the "X Recorder Third-Party Information Sharing List" to learn more about the details of how we share your personal information.
For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures, without exceeding the agreed processing purposes or methods. Their processing activities must not violate the laws, regulations, national standards, and other normative documents related to personal information protection and data security in the People's Republic of China. In principle, companies, organizations, and individuals with whom we share personal information have no right to use the shared personal information for any purposes other than those stated in this policy.
(5) Third-Party SDKs: Some functions in X Recorder are provided by our cooperating third-party institutions (hereinafter referred to as "SDK service providers") in the form of SDK plugins. SDK service providers will obtain corresponding permissions and information necessary for providing functions or services to you. Specifically, you can click to read the "X Recorder Third-Party Information Sharing List" to learn more about the details of how third-party SDKs process your personal information.
3. Transfer
We will not transfer your personal information to any third parties (including companies, organizations, and individuals), except in the following circumstances:
(1) Transfer with Explicit Consent: Transfer with your explicit consent.
(2) Transfer Required by Applicable Laws, Legal Procedures, or Compulsory Administrative or Judicial Requirements: Transfer when required by applicable laws, legal procedures, or compulsory administrative or judicial requirements.
(3) Transfer in the Event of Merger, Acquisition, or Bankruptcy Liquidation: In the event of a merger, acquisition, or bankruptcy liquidation of the service provider of this product, or other circumstances involving merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will inform you of the name or contact information of the recipient and require the new holder of your personal information to continue to be bound by this policy. If the recipient changes the original processing purpose or method, we will require the recipient to seek your authorization again.
4. Public Disclosure
We will only publicly disclose your personal information in the following circumstances:
(1) With Your Separate Consent or Based on Your Active Choice: We will publicly disclose your personal information with your separate consent or based on your active choice.
(2) Under Legal, Legal Procedure, Litigation, or Government Authority Requirements: We will publicly disclose your personal information under legal, legal procedure, litigation, or government authority requirements.
(3) In Case of Violations or Protection of Safety: If we determine that you have violated laws, regulations, or seriously violated the relevant agreement rules of this product, or to protect the personal and property safety of users of this product and its affiliated companies or the public from harm, we may disclose information about you in accordance with laws, regulations, or the relevant agreement rules of this product, including relevant violations and measures we have taken against you.
5. Exceptions to Prior Authorization for Entrusted Processing, Sharing, Transfer, and Public Disclosure of Personal Information
In the following circumstances, prior authorization from you is not required for entrusted processing, sharing, transfer, and public disclosure of your personal information:
(1) Related to the Fulfillment of Legal and Regulatory Obligations: Related to the fulfillment of our legal and regulatory obligations.
(2) Directly Related to National Security and Defense Security: Directly related to national security and defense security.
(3) Directly Related to Public Safety, Public Health, and Major Public Interests: Directly related to public safety, public health, and major public interests.
(4) Directly Related to Criminal Investigation, Prosecution, Trial, and Judgment Execution: Directly related to criminal investigation, prosecution, trial, and judgment execution.
(5) To Protect the Major Legitimate Rights and Interests of You or Others When Obtaining Consent Is Difficult: To protect the major legitimate rights and interests of you or others when obtaining consent is difficult.
(6) Personal Information You Have Voluntarily Made Public to the Public: Personal information you have voluntarily made public to the public.
(7) Collection of Personal Information from Legally Publicly Disclosed Information: Collection of personal information from legally publicly disclosed information, such as legitimate news reports and government information disclosure channels.
Please be informed that, in accordance with the law, the entrusted processing, sharing, transfer, and public disclosure of anonymized personal information do not constitute external entrusted processing, sharing, transfer, and public disclosure of personal information. The storage and processing of such data will not require separate notification to and consent from you.
IV. How We Protect Your Personal Information
1. We attach great importance to user privacy and the protection of personal information, and will also take reasonable measures to safeguard users' personal information. Except as required by laws and regulations or otherwise stipulated in this policy, we will employ various security technologies and procedures to establish a comprehensive management system to protect your personal information from unauthorized access, use, or disclosure. Without user permission, we will not publicly disclose or disclose user personal information to third parties. We will adopt professional encryption methods for storage and transmission of relevant information to ensure the security of user personal information.
2. You understand and agree that, without disclosing the privacy information of individual users, we have the right to conduct technical analysis on the entire user database. Only user data that has been analyzed, sorted, and anonymized will be utilized for commercial purposes.
3.
Data Security Measures
(1) We have adopted security protection measures that comply with industry
standards, including establishing reasonable institutional norms and security
technologies to prevent unauthorized access, use, or modification of your
personal information, and to avoid data damage or loss. For example, our
network services employ encryption technologies such as Transport Layer
Security (TLS) protocols, providing browsing services through methods like
HTTPS to ensure the security of user data during transmission. We use
encryption technologies (TLS, SSL), anonymization or de-identification
processing, and protection mechanisms to encrypt and save user personal
information, and isolate it through isolation technologies. We manage and
regulate the storage and use of personal information by establishing data
classification and grading systems, data security management norms, and data
security development norms. Through confidentiality agreements with information
handlers, we only allow our employees and partners who have a legitimate need
to know this information, and our affiliates, to access personal information.
We have set up strict access control and monitoring mechanisms, and require all
personnel who come into contact with your personal information to fulfill corresponding
confidentiality obligations. Failure to fulfill these obligations will result
in legal liability or termination of our cooperative relationship. We have
organized security and privacy protection training courses to enhance
employees' awareness of the importance of protecting personal information. We
have formulated and implemented emergency response plans for personal
information security incidents.
(2) We will take all reasonable and feasible measures to ensure that irrelevant
personal information is not collected. We will only retain your personal
information for the period necessary to achieve the purposes described in this
policy, unless an extension of the retention period is required or permitted by
law.
(3) The internet is not an absolutely secure environment, and email, instant
messaging, and other means of communication with other users are not encrypted.
We strongly recommend that you do not send personal information through such
means. Please use complex passwords to assist us in ensuring the security of
your account.
(4) The internet environment is not 100% secure. We will make every effort to
ensure or guarantee the security of any information you send to us. If our
physical, technical, or management protection facilities are compromised,
resulting in unauthorized access, public disclosure, tampering, or destruction
of information, causing harm to your legitimate rights and interests, we will
bear corresponding legal responsibilities.
(5) In the unfortunate event of a personal information security incident, we
will promptly inform you in accordance with legal requirements of the cause of
the security incident, potential harm, types of personal information involved,
disposal measures we have taken or will take, suggestions for you to independently
prevent and reduce risks, and measures you can take. We will promptly notify
you of relevant information about the incident by email, SMS, phone call, or
sending notifications. When it is difficult to notify each individual subject
of personal information, we will issue announcements in a reasonable and
effective manner. At the same time, we will also actively report the disposal
of personal information security incidents to regulatory authorities as
required. Please be aware that, in accordance with applicable laws and
regulations, if measures can effectively avoid harm caused by information
leakage, tampering, or loss, we may not notify you.
V. How We Store Your Personal Information
This product and/or service is only available in the People's Republic of China. In principle, the personal information we collect within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China and will not be subject to cross-border transmission.
1.
Location of Stored Information
We comply with legal and regulatory requirements, and the information and data
we collect about you will be saved on our servers within the territory of the
People's Republic of China, except in the following circumstances:
¡¤ There are explicit provisions in laws and regulations;
¡¤ You have provided explicit authorization;
¡¤ You engage in cross-border transactions or other proactive personal behaviors via the internet.
2.
Duration of Stored Information:
In general, we will retain your personal information for the period necessary
to achieve the processing purposes described in this policy during your use of
the X Recorder product and/or service, unless otherwise stipulated by
applicable laws, regulations, or national normative documents. Specific
reference regulations include:
(1) Article 21, Chapter III of the Cybersecurity Law stipulates that technical
measures for monitoring and recording network operation status and
cybersecurity incidents shall be taken, and relevant network logs shall be
retained for no less than six months in accordance with regulations.
(2) Article 31, Chapter II of the E-commerce Law stipulates that the retention
period for commodity and service information and transaction information shall
be no less than three years from the date of transaction completion; if laws or
administrative regulations stipulate otherwise, those provisions shall be
followed.
After the aforementioned period has expired, or if you actively request the deletion of your personal information or the cancellation of your account, we will delete your personal information as soon as possible in accordance with applicable legal and regulatory requirements, unless applicable laws, regulations, or national normative documents require the retention of such information for a longer period. However, in the following circumstances, we may need to change the storage period of personal information to comply with legal requirements:
¡¤ To comply with applicable laws, regulations, and other relevant provisions;
¡¤ To comply with court judgments, rulings, or other legal procedures;
¡¤ To comply with requirements from relevant government agencies or legally authorized organizations;
¡¤ We have reasonable grounds to believe that compliance with laws, regulations, and other relevant provisions is necessary;
¡¤
To execute relevant service agreements or this policy, safeguard
social and public interests, and protect the personal and property safety or
other legitimate rights and interests of our customers, ourselves, other users,
or employees for reasonably necessary purposes.
After you terminate the use of X Recorder, we will stop collecting and using
your information, except as otherwise stipulated by laws, regulations, or
regulatory authorities.
When the relevant services of X Recorder cease operations, we will notify you
by sending notifications and announcements, and delete your personal
information retained on our servers within the period required by laws and
regulations.
VI. How You Can Exercise Your Rights Regarding Your Personal Information
1. In accordance with relevant Chinese laws, regulations, and standards, you have several rights in personal information processing activities, specifically including:
¡¤ You have the right to know and decide on the processing of your personal information, and the right to restrict or refuse others from processing your personal information, except as otherwise stipulated by laws and administrative regulations;
¡¤ You have the right to request the transfer of your personal information to a designated personal information processor;
¡¤ If you find that your personal information is inaccurate or incomplete, you have the right to request the personal information processor to correct or supplement it;
¡¤ You have the right to request the deletion of your personal information;
¡¤ You have the right to request the personal information processor to explain its personal information processing rules.
2.
We guarantee your exercise of the aforementioned rights
regarding your personal information and provide you with relevant operational
paths. Specifically, you can refer to the following steps to carry out relevant
operations:
(1) Obtain a copy of your personal information;
(2) You have the right to obtain a copy of your personal information. You can
contact our customer service, and we will process your request within 15
working days.
(3) Transfer your personal information
You have the right to request the transfer of your personal information to a
designated personal information processor. If the conditions stipulated by the
national cyberspace administration are met, we will provide you with a transfer
method. You can contact our customer service, and we will process your request
within 15 working days.
(4) Respond to your aforementioned requests
We will adopt appropriate technical means to ensure that you can access,
supplement, correct, delete, or apply for us to supplement, correct, delete,
copy, or transfer relevant information through the feedback or complaint
channels published by the X Recorder product and/or service. After receiving
your application, we will process it in accordance with the procedure. To
ensure security, in accordance with the procedure, we will first require you to
verify your identity. We need you to provide your account (mobile phone number)
and SMS verification code, and will process your request after successful
verification. We will respond within 15 working days. For reasonable requests,
we will not charge a fee in principle, but for repeated or excessive requests
beyond reasonable limits, we will charge a certain cost fee as appropriate. We
will refuse requests that are unreasonably repetitive, require excessive
technical means (for example, require the development of a new system or
fundamentally change existing practices), pose risks to the legitimate rights
and interests of others, or are very impractical (for example, involve
information stored on backup tapes).
If you are unable to access, supplement, correct, delete, copy, transfer your
personal information, or change the scope of your authorized consent or
withdraw authorization, cancel your account, turn off message notifications, or
if you need to access, supplement, correct, delete, copy, or transfer other
personal information generated during your use of X Recorder, or if you believe
that we have violated any laws, regulations, or agreements with you regarding
the collection or use of personal information, you can contact us through the
official feedback channels for relevant products or services that we have publicly
announced.
Please be aware: In the following circumstances, we will be unable to respond
to your requests:
(1) Related to our fulfillment of obligations stipulated by laws and
regulations;
(2) Directly related to national security or defense security;
(3) Directly related to public security, public health, or major public
interests;
(4) Directly related to criminal investigation, prosecution, trial, and execution
of judgments;
(5) We have sufficient evidence to indicate that you have subjective malice or
abuse of rights;
(6) For the major legitimate rights and interests of you or other individuals'
lives, properties, etc., but it is difficult to obtain consent from the
individuals themselves;
(7) Responding to your request will result in severe harm to the legitimate
rights and interests of you or other individuals or organizations;
(8) Involving trade secrets.
VII. How We Protect the Personal Information of Minors
1. We attach great importance to the protection of minors' personal information and will protect minors' personal information in accordance with the provisions of relevant national laws and regulations.
2. We consider anyone under the age of 18 as a minor. In accordance with the provisions of relevant laws and regulations, if you are a minor aged 14 or above, we will obtain consent from you or your guardian before collecting your personal information. And when you, your parents, or other guardians request us to correct or delete minors' personal information, we will take timely measures to correct or delete it, except as otherwise stipulated by laws and administrative regulations.
3. If you are a minor under the age of 14 (hereinafter referred to as a child), we will obtain consent from your parents or other guardians before collecting your personal information.
4. When processing children's personal information, we will take the following measures to ensure protection: For the collected children's personal information, in addition to complying with the agreements in this policy regarding user personal information, we will also adhere to the principles of legitimacy, necessity, informed consent, clear purpose, security safeguards, and legal utilization, strictly follow the requirements of laws and regulations such as the "Regulations on the Protection of Children's Personal Information Online" for storage, use, and disclosure, and will not exceed the period necessary to achieve the collection and use purposes. After expiration, we will delete children's personal information. Specifically, please read the "X Recorder Children's Privacy Protection Policy" for details.
5. If you are the parent or guardian of a minor, and you have any questions, opinions, suggestions, complaints, or reporting needs regarding the matters described in this policy and the "X Recorder Children's Privacy Protection Policy," please provide feedback to us.
VIII. How Your Personal Information is Transferred Globally
In
principle, the personal information we collect within the territory of the
People's Republic of China will be stored within the territory of the People's
Republic of China and will not be subject to cross-border transmission. If it
is truly necessary to provide your personal information overseas due to
business needs, we will inform you of the name or name, contact information,
processing purpose, processing method, types of personal information, and the
methods and procedures for you to exercise the rights stipulated by this law
towards the overseas recipient, among other matters. We will only transfer your
personal information to the overseas jurisdiction of the country/region where
you use the product and/or service, or allow your personal information to be
accessed from these jurisdictions, after obtaining your separate consent and
meeting the conditions for cross-border provision stipulated by laws and
regulations.
Please be aware that such jurisdictions may have different laws and regulations
related to personal information protection. We will comply with the
requirements of relevant laws and regulations in the jurisdiction to ensure
that your personal information is adequately protected. If such jurisdictions
do not have laws and regulations related to personal information protection, we
will make every effort to ensure that your personal information receives
adequate protection equivalent to that within the territory of the People's
Republic of China.
IX. How We Update This Policy
1. To provide you with better services, the X Recorder product and/or service will be updated and changed from time to time. We will revise this policy from time to time, and these revisions constitute a part of this policy. However, without your explicit consent, we will not reduce the rights you are entitled to under this policy.
2.
After this policy is updated, we will release an updated version
on X Recorder and remind you again to read the updated privacy policy through
announcements of new version features on the application market or pop-up
windows, so that you can promptly understand the latest version of this policy.
If you disagree with this policy or have objections to the modifications or
updates made to this policy, you can choose to stop using the X Recorder
product and/or service or cancel your X Recorder account. However, please be
aware that your behaviors and activities before account cancellation or before
stopping the use of this service are still subject to this policy.
Major changes referred to in this policy include but are not limited to:
(1) Significant changes in our service model. Such as the purpose of processing
personal information, the types of personal information processed, and the
methods of using personal information;
(2) Significant changes in our ownership structure or organizational structure.
Such as all changes caused by business adjustments, bankruptcies, mergers and
acquisitions, etc.;
(3) Changes in the main objects of personal information sharing, transfer, or
public disclosure;
(4) Significant changes in your rights regarding personal information
processing and the methods of exercising them;
(5) Changes in the responsible department for personal information security,
contact information, and complaint channels;
(6) When personal information security impact assessment reports indicate high
risks;
(7) Changes made in response to national policies or legal norms following the
release and implementation of policies or laws.
X. How to Contact Us
To
better protect your personal information, we have established a dedicated
cybersecurity and personal information protection department. If you have any
questions or suggestions regarding this policy or your personal information
during the use of X Recorder, please contact us through the following methods:
Contact Email (Personal Information Protection
Officer): mailto:XMAIDC_TPV@tpv-tech.com
Contact Address: No. 1 Xianghai Road, Xiangan Industrial Zone, Torch Hi-tech
Zone (Xiangan), Xiamen
If you are not satisfied with our response, especially if you believe that our
personal information processing behavior has harmed your legitimate rights and
interests, and we are unable to provide you with a satisfactory response and
refuse to make improvements after you provide feedback to us, you can file
complaints and reports with relevant regulatory authorities.
XI. Others
Any
disputes related to this policy shall be resolved through friendly consultation
between the two parties; if consultation fails, you hereby agree to file a
lawsuit with the Xiangan District People's Court in Xiamen City, Fujian
Province.
If any court with jurisdiction rules or adjudicates that any clause of this
policy is invalid, that clause will be removed from this policy, but the
invalidity of that clause will not affect the validity of the remaining clauses
of this policy. The remaining clauses of this policy will continue to be
enforced.