1. How We Collect and Use Your Personal Information

The information we collect depends on the products you use, the environment in which you interact with us, and the choices you make, including your privacy settings and the products and features you use. You may refer to Personal Information We Collect to gain a quick understanding of the personal information that will be collected and used in connection with the features or services provided by the App. If you choose not to provide your personal information that we request, we may not be able to provide you with related services, nor will we be able to respond to or handle the problems you may encounter. We collect personal information to operate more efficiently and provide you with an optimal user experience. We collect information about you in three primary ways:

(1) directly from you;

(2) automatically from your use of the App;

(3) from third parties.

If the following clauses explicitly state that your relevant information is only kept locally, then the information is only collected and processed locally on your phone and it will not be uploaded to our server, which means such information is not bound by this Privacy Notice. This is to clear up all your privacy concerns and stay transparent about our processing of personal information.

The features and services provided by the App may vary according to the App version and the phone model you use or other factors. Therefore, the features and services available to you and the personal information we need to process are subject to the products you use.

Please note that if you provide other people's personal information to us, you must ensure that you have obtained their authorization (and separately obtain their consent in the event of a special scenario).

The clauses governing the processing of sensitive personal information and those that may have a major impact on your rights and interests are highlighted in bold for your special attention. In addition, we have highlighted sensitive personal information in bold to draw your special attention.

To provide you with the features or services that you request or to comply with laws and regulations, we will process the necessary personal information relating to you. This Privacy Notice specifically points out what personal information is necessary for you to use the features and services of the App. Please pay special attention to such information.

1.1 App features, personal information we collect and use, and intended purposes

(1) HeyTap Account sign-up and sign-in

To use the App, you need to first sign up for a HeyTap Account or, if you already have one, sign in to your HeyTap Account. During the sign-up or sign-in process, we may collect your HeyTap Account ID, phone number (or email address), password, and sign-up SMS message. Such information is necessary for you to complete the sign-up or sign-in process. If you do not provide such information, we will not be able to provide you with the sign-up or sign-in service. You may also choose whether to provide us with information such as your username and profile picture to complete your account details. You are not obliged to provide such information to use account services. If you do not provide it, you can still use the account sign-up and sign-in services. For more details on the protection of personal information needed for account sign-up and sign-in, please refer to the Account Privacy Notice .

(2) Managing the wireless device: pairing or unpairing

To allow you to manage any of your wireless devices on your phone, including pairing or unpairing the wireless device with or from the App and changing its name, the App needs to obtain the wireless device's uniform type identifier (i.e., the device ID, a string of encrypted characters consisting of the device identifier, device model, and serial number of the device and your Wi-Fi password) as well as its name you have set on its web-based user interface (web UI). The aforementioned information will be encrypted and uploaded to our server. In addition, the App will obtain other information about the wireless device through our server, including the hardware and software versions, MAC address, and serial number for display in the App.

(3) Configuring network settings for the wireless device: Wi-Fi/ LAN/WAN

In the App, you may go to the "Wi-Fi settings", "LAN settings", or "WAN settings" section to browse and complete relevant network settings for the paired wireless device. For example, for the Wi-Fi network, you can set the network's SSID, password, encryption method, and Wi-Fi on/off status; for the LAN network, you can set the LAN gateway's IP address and the DHCP address pool; for the WAN network, you can set the network mode, PPPoE username and password.

(4) Managing other devices connected to the wireless device

After pairing your wireless device with the App, you can manage other devices connected to the wireless device or the network formed by the wireless device through the blocklist or allowlist. In blocklist mode, devices included in the blocklist are not allowed to connect to the network formed by the wireless device. In allowlist mode, devices excluded from the allowlist are not allowed to connect to the network formed by the wireless device. To enable you to manage the other devices connected to the wireless device, the App needs to obtain the names, IP addresses, and MAC addresses of those devices so that those devices can be displayed in the App. You can then perform relevant device settings and edit the blocklist or allowlist.

(5) Parental control

You may also specify when the devices on the network formed by the wireless device can access the network and when they cannot. To this end, the App will need to obtain the names, MAC addresses, and IP addresses of those devices as well as the time limits you set for them (the network restriction period and the network access period).

(6) Wi-Fi sharing

You may also share the name and password of the Wi-Fi network to which your wireless device is connected with your friends through WeChat. To this end, the App will obtain your Wi-Fi BSSID to identify the Wi-Fi network your phone is connected to and display it in the Wi-Fi network list. In addition, WeChat will obtain your Wi-Fi network's name and password. You are not obliged to provide your Wi-Fi BSSID. If you do not provide it, you can still share your Wi-Fi network's name and password with your friends, but your Wi-Fi network will not be displayed in the Wi-Fi network list.

(7) Detecting software updates for the wireless device

To display the firmware version currently running on the wireless device and the latest software version available, the App needs to obtain the current firmware version number of the wireless device.

(8) OPPO Connect upgrades

To display the App version currently in use and the latest version available, the App needs to collect the App version you use currently. Depending on the size of the upgrade APK file, installing the upgrade APK will consume a certain amount of your data.

Non-personal information

During your use of the App, we may collect certain non-personal information such as log and event tracking data that has been processed with data masking techniques (de-identification, anonymization, etc.). Non-personal information refers to information that cannot, either directly or indirectly, relate to any particular individual. We may process aggregate data or other anonymized data.

The purpose of collecting non-personal information is to help us fully understand user preferences, improve our operational efficiency, and improve our products/services and your user experience. Non-personal information will be considered personal information if it is used in combination with personal information.

1.2 How we use your personal information

(1) We will use your personal information for the following purposes:

• To provide you with related products and services as described above;

• To assist you in registering, activating, and verifying the products or services you purchased and the warranty services and software licenses granted to you and send you OS or app update notices;

• To diagnose product or service issues and provide technical support and other customer care and support services;

• To improve and develop our services including improving the user experience, user-friendliness, performance, functionality, and design of our products;

• To perform user research and follow-up surveys to improve both your user experience and our services and other security features;

• To analyze the customer market based on the country or region where you use our services;

• To analyze and study our operational data such as the operational efficiency so as to measure our market share and improve our products and services;

• To analyze error logs and pinpoint the errors and issues so as to improve our device quality and app features;

• To fulfill our cybersecurity obligations, ensure the normal functioning of our products or services, protect the functionality and security of our services, and prevent cybersecurity threats or other acts of misuse;

• To communicate with you and respond to the questions or suggestions you submitted by email, by phone, or by using our online platforms (social media accounts, help & feedback channels, etc.);

• To provide you with other services;

• To fulfill our legal obligations in the event that we file or contest a lawsuit, and to help us detect misuse, fraud, and other illegal activity on our service platform.

• To fulfill our legal obligations.

(2) Other legal bases for personal information processing

Under relevant laws and regulations, we may process your personal information without your consent in the following circumstances:

• as necessary to enter into a contract at your request or to perform the contract to which you are a party;
as necessary for us to comply with a legal obligation or duty;

• as necessary to respond to public health emergencies or to protect the life, health, and property of natural persons in emergencies;

• the processing of personal information is within a reasonable scope and intended for news reports, public opinion supervision, and other similar tasks carried out in the public interest;

• the personal information that we process has been made public by you or otherwise legally disclosed and is within a reasonable scope;

• other circumstances as specified by laws and regulations.

1.3 Required app permissions

When you use the App, we may request certain app permissions as needed to provide you with the required features or services. If certain important or sensitive app permissions are required by our services or features, we will request your consent to turn them on through a pop-up prompt when you attempt to use these services or features. After such permissions are turned on, you may go to "Settings - Permission manager" on your device at any time to turn them off to withdraw your consent as long as they have a manual switch. (The operation paths to manage app permissions may vary by the phone model and OS version. For the actual operation paths, please refer to your phone.) After you withdraw your consent, we will stop using the relevant app permissions and we will no longer be able to provide you with the related features or services, but this does not affect your use of other unrelated features or services.

Required permission: Connect to the internet.

Intended feature/service: The App will be connected to the network and provide you with the features you request.

Purpose of permission request: To let the App access the network to provide you with the above-mentioned features.

Ask before turning on the permission: Yes.

Ability to turn off the permission: Yes. Operation path: Settings - App management - Data plan usage.

Impact of turning off/denying permission: The App cannot access the network and, as a result, it cannot provide you with the requested services.

Required permission: Location.

Intended feature/service: Wi-Fi sharing (to allow the target devices to automatically connect to your Wi-Fi network).

Purpose of permission request: To let the App obtain the SSID of the Wi-Fi network to which your phone is connected, allowing you to share your Wi-Fi information with your friends.

Ask before turning on the permission: Yes.

Ability to turn off the permission: Settings - Permission manager.

Impact of turning off/denying permission: The Wi-Fi network to which you phone is connected may not be displayed in the Wi-Fi network list.

We will use your personal information solely for the purposes described in this Privacy Notice. Your personal information will only be used for the purposes identified, described, and authorized by you at the time of collection. We will obtain your prior consent if we intend to use your personal information for any purpose not stated in this Privacy Notice or when personal information collected for a specific purpose is used for other purposes. Without your consent, we will not provide your personal information or behavioral data to any third party.

2. How We Use Cookies and Other Similar Technologies

Currently, the App does not use cookies or any other similar technologies to collect or store user preferences or any information about you.

3. How We Retain Your Personal Information

3.1 Where we store your personal information

According to laws and regulations, we will store your personal information collected and generated during our operations within the mainland of the People's Republic of China ("Chinese mainland") on our server deployed in the Chinese mainland.

3.2 How long we store your personal information

The personal information we collect will be retained for the minimum period needed to fulfill the purposes for which it is collected as described in this Privacy Notice, unless otherwise specified by applicable laws or regulations. As provided by the law, we will completely delete or anonymize your personal information upon the expiration of the retention period.

If we stop some or all of our products or services for any special reason, we will promptly inform you and stop the collection and processing of your personal information in connection with such products or services. We will also delete or anonymize such information that we hold unless otherwise specified by laws and regulations.

You can refer to the following for our information retention and deletion policy:

• HeyTap Account sign-up and sign-in: The phone number, username, email address, sign-up SMS message, and password will be removed from our server and the App after you have completed the sign-up and sign-in processes in the App. The profile picture, display name, and account ID will be removed from our server and the App after your HeyTap Account is deleted.

• Wireless device management: The device ID and name of the wireless device paired with the App will be deleted after it is unpaired from the App.

• Personal information and other data in connection with other features, including wireless device information, App information, network information, and settings will be deleted immediately after being processed by those features; they are not uploaded to our server for storage.

4. How We Entrust, Share, Transfer and Disclose Your Personal Information

Upon your request, or for the purpose of providing you with the products or services you request, we may entrust our affiliates or strategic partners to process your personal information or share your personal information with them from time to time. The strategic partners include cloud service providers, data storage facility providers, customer service providers, advertising and marketing service providers, and other third-party service providers that provide technical and customer support to us.

If you do not allow our affiliates or partners to collect or use your personal information necessary to provide you with their services contained in the products and/or services you request, you may not be able to access such third-party services.

4.1 Our affiliates. For the purpose of providing services to you, we may share your personal information with our affiliates or entrust them to process your personal information. We will only share the necessary personal information. If we or our affiliates intend to change the purpose for which your personal information is used and processed, we will obtain your authorization or consent again.

4.2 Our authorized partners. Some of our services will be provided by our authorized partners only for the purposes stated in this Privacy Notice. Therefore, we may share some of your personal information with such partners in order to provide services to you and improve your user experience. Specifically:

We may need to share your personal information with our service providers, including but not limited to cloud service providers or other technical service providers, so that they can process the information to provide you with the necessary product or service features. Such service providers may receive and store some of your personal information, but they will not use such information for any other purposes.

4.3 Any entity involved in a merger, acquisition or bankruptcy liquidation. When we are in the process of a merger, acquisition or bankruptcy liquidation, and if such process requires the transfer of your personal information, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Notice; otherwise, we will require this company or organization to obtain your consent again. If the process does not involve the transfer of personal information, we will adequately inform you and delete or anonymize all your personal information under our control.

4.4 Any entity to which you authorize us to disclose your personal information.

4.5 Any entity to which we are legally required to disclose your personal information. For example, when we are required to comply with subpoenas or other legal procedures, litigations, or mandatory requirements of government authorities, we may disclose your personal information if we sincerely believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests.

We will share or transfer your personal information only for legitimate, proper, necessary, specific, and explicit purposes, and we will only share personal information which is necessary for the provision of the required services. In addition, we will require the above-mentioned third parties to take appropriate confidentiality and security measures during their processing of your personal information by means of agreements or other appropriate measures.

5. How We Protect Your Personal Information

5.1 Our data protection measures

We adopt technical and organizational measures that are reasonable and actionable to protect the information we collect in connection with our services. We have introduced safeguards that meet industry standards to protect the personal information provided by you from unauthorized access, disclosure, use, or alteration, or from damage or loss. We take all reasonable and actionable measures to protect your personal information. For example:

(1) We use mainstream security safeguards such as SSL or TLS to encrypt our services and transmission channels. We regularly review our practices regarding information collection, storage, and processing (including physical security measures) to protect our systems from unauthorized access or alteration.

(2) We strictly control access to personal information and only grant access permissions to our employees and those of an authorized service provider who need to access personal information in order to help us process such information. These employees are subject to strict contractual confidentiality obligations. If they fail to perform these obligations, they may be held legally liable or be terminated. Personal information access logs will be kept and audited periodically.

(3) The security of your information is very important to us. Therefore, we will continue our efforts to protect the security of your personal information and implement safeguards such as encrypting stored data and using end-to-end encryption during transmission to protect your information from unauthorized access, use, or disclosure. In addition, certain encrypted data is inaccessible to anyone other than the user.

(4) When transmitting and storing special types of personal information such as sensitive personal information, we will use security measures such as encryption. When storing your personal biometric information, we will take technical measures to process it, such as only storing a summary of your personal biometric information.

(5) We carefully select business partners and service providers and include our requirements for personal information protection in our business contracts, audits, or assessments.

(6) We conduct security and privacy protection training, tests, and publicity activities to raise our employees' awareness of the importance of personal information protection.

(7) We use international and industry-recognized standards to protect your personal information and actively acquire security and privacy protection certifications.

5.2 Notification and response to personal information security events

Please note that although we take reasonable measures to protect your information, no websites, internet transfers, computer systems, or Wi-Fi connections are 100 percent secure. In the event of any security breach of your personal information, we will promptly inform you of the event in accordance with applicable laws and regulations, including the situation and the possible impact of the event, the measures taken or to be taken by us, suggestions on how you can prevent and reduce risks, and remedies available to you. We will promptly inform you of such information by email, letter, phone, or push notification. When it is difficult to inform each personal information subject concerned, we will publish an announcement in a reasonable and effective manner. We will also report the handling of the event in accordance with the requirements of regulatory authorities.

6. Your Rights to Your Personal Information

We respect your rights to your personal information. The following lists your rights under the law and explains how we will protect your rights. We provide you with a variety of ways to make privacy settings and personal information management more secure and convenient for you to ensure the security of your personal information. Please note that the operation paths may vary according to the device model, operating system version, and App version. We may adjust the operation paths from time to time to improve your user experience. For security reasons, we may verify your identity before handling your request.

You may exercise your data subject rights using the ways described below. If you are unable to exercise your rights on your own or if you have any problem in exercising the rights, you may contact us as set forth under Section 10 "Contact Us" to request the exercise of your data subject rights.

Refer below for your rights to your personal information.

6.1 Right to access, rectify, or complete your personal information

(1) Right to access your personal information

You can regularly check this Privacy Notice, receive emails and SMS messages which contain a description of the updates to this Privacy Notice, and contact us in the manner disclosed in this Privacy Notice to learn about our collection and use of your personal information. Specifically:

You may go to the relevant pages of the App to directly query or access your personal information, including:

• HeyTap Account information: profile picture, display name, and account ID;

• Wireless device information, App information, network information, feature settings, and more.

(2) Right to rectify and complete your personal information

If you find that any of your personal information processed by us is inaccurate or incomplete, you have the right to request us to correct or complete it. You can directly correct and modify some of your personal information on the relevant pages of the App. For example:

• In the App, you may tap your account's profile picture to visit the HeyTap Account page, where you can modify your account information, such as your age, gender, and your region.

6.2 Right to delete your personal information

You may choose to delete some of the personal information you have submitted to us. You can delete such information directly on the relevant pages of the App. Specifically:

• On the Devices page, you may delete unneeded devices or change the name of a device. For example:

• In the gateway list section, you may delete the paired wireless device and relevant network settings.

• In the device list section, you may remove the desired devices from the blocklist or allowlist.

• In the parental control section, you may remove the desired devices from the blocklist or allowlist.

6.3 Right to delete your account

We grant you the right to delete your account.

By tapping the profile picture of your HeyTap Account, you can go to the HeyTap Account page to submit an account deletion request.

6.4 Right to change the scope of authorization or withdraw consent

The performance of each service function requires certain basic personal information (see the "How We Collect and Use Your Personal Information" section of this Privacy Notice). You can change the scope of the personal information you authorize us to collect or withdraw your authorization by deleting information, turning off app permissions, changing settings on the product or feature settings page, or deleting your account. For example:

• In the App, you may tap your account's profile picture to visit the HeyTap Account page, where you can change your account information, such as your password, username, display name, and profile picture.

• On the "Device management" page of the App, you can change the names of the devices connected to your wireless device paired with the App, or you can delete the wireless device from the App and add another wireless device to the App.

• You may go to "Network settings - Wi-Fi settings" in the App to modify the name, password, and security mode of your Wi-Fi network to which the wireless device is connected or turn your Wi-Fi network on or off.

• You may go to "Network settings - LAN settings" in the App to modify the names and IP addresses of the devices connected to the wireless device and change the DHCP on/off status.

• In the "Parental control" section, you may set network access restrictions for the devices connected to the wireless device and perform other relevant settings, such as adding or deleting devices to or from the network formed by the wireless device and modifying the restrictions (such as setting the allowlist or blocklist mode and restriction periods).

• App permission settings: You may go to the Settings app and choose "Permission manager - OPPO Connect" to withdraw your consent to our use of relevant app permissions.

• Managing consent to the Privacy Notice: In the App, you may go to "Settings - Privacy - Withdraw consent to Privacy Notice" to withdraw your consent to this Privacy Notice.

If you withdraw your consent or change the scope of your authorization, we will no longer be able to provide you with the services requiring your consent or falling outside the scope of your authorization. We will also no longer process related personal information, but the withdrawal of your consent shall not affect the lawfulness of data processing based on consent before its withdrawal.

6.5 Right to copy and transfer your personal information

You have the right to request us to provide a copy of your personal information you provided to us or transfer the copy to a third party you designated.

6.6 Right to complain

You have the right to file a complaint by contacting us as set forth under Section 10 "Contact Us".

If you are not satisfied with our reply, particularly if our processing of your personal information damages your legitimate rights and interests, you can also file a complaint or report it to regulatory authorities such as the Cyberspace Administration of China, a relevant public security organ, and the State Administration for Market Regulation, or file a lawsuit with the court with jurisdiction.

However, we hope that we have the opportunity to solve your concerns or issues before you contact relevant authorities, so please first contact us directly.

6.7 Transfer of data subject rights of deceased persons to their close relatives

Provided that any user of the App dies and they have not informed us of any arrangements in writing or through any other reasonable method before they die, their close relatives may, for the sake of their own legitimate interests, contact us for guidelines on how to exercise the rights of the deceased data subject, including rights to access, copy, rectify, and delete personal information.

7. How We Process Minors' Personal Information

We greatly value our obligation and responsibility for protecting the personal information of minors. We strive to create a healthy cyber environment for minors and take extra efforts to protect them.

Most of the features and services provided by the App are mainly intended for adults and they do not target children (in this Privacy Notice, "children" refers to minors under the age of 14). We do not provide services directly to children. Please note that due to technical limitations and other objective factors, the App may not be able to actively identify the age of users.

According to applicable laws and regulations, if you are a child, you shall obtain the consent of your parent or another guardian before using the App, and be sure to carefully read this Privacy Notice together with them. Children may not use the App without the consent of their parents or other guardians.

We do not actively collect, store, use, transfer, or disclose children's personal information, let alone use their personal information for marketing purposes. If you are a child, or if you are a parent or guardian of a child, or if you otherwise find that any information we processed may contain the personal information of a child, please contact us as set forth under Section 10 "Contact Us". We will do everything we can to delete the relevant data as soon as possible.

8. Third-Party Service Providers and Their Services

Our websites, products, apps, and services may be provided by third parties or may contain links to third-party websites, products, or services. You can choose whether to access or use any website, product, or service provided by a third party.

We have no control over third-party privacy and data protection policies as such third parties are not bound by this Privacy Notice. Before you submit personal information to third parties, please refer to their privacy policies. For example:

If you share your Wi-Fi network's SSID and password with others through WeChat when using the Wi-Fi sharing feature, WeChat will collect your Wi-Fi network's SSID and password. Before doing so, please carefully read the third party's privacy policy.

9. How This Privacy Notice Is Updated

We reserve the right to update or modify this Privacy Notice from time to time. We will notify you of any material changes to this Privacy Notice in a manner we deem appropriate, and we will indicate the "Last updated" date at the top of this Privacy Notice.

This Privacy Notice is subject to adjustments. If you continue to use the App after this Privacy Notice is updated, you will be deemed to have accepted the new Privacy Notice.

The latest version of this Privacy Notice applies to our processing of your personal information. This Privacy Notice shall enter into force as of the date it is updated.

If you have any questions or concerns about this Privacy Notice or our privacy practices, please contact us as set forth under Section 10 "Contact Us".

10. Contact Us

To learn more about how we protect personal information, please refer to our general Privacy Notice .

If you have any questions, complaints, or suggestions regarding this Privacy Notice or our privacy practices, you may contact us as set forth below. We will verify your identity and respond within 15 workdays. This time limit may be extended when necessary due to the complexity and large amounts of individual requests and technical feasibility.

• Contact through the Data Subject Rights Platform: https://www.oppo.com/en/privacy-feedback/

• Contact by mail: Guangdong OPPO Mobile Telecommunications Corp., Ltd.
Address: No. 18 Haibin Road, Wusha, Chang'an, Dongguan, Guangdong, China 523902

Guangdong OPPO Mobile Telecommunications Corp., Ltd.

Address: No. 18 Haibin Road, Wusha, Chang'an, Dongguan, Guangdong, China

Zip code: 523902