NapGrow Privacy Policy

Updated date: May 5, 2023

Effective Date: May 12, 2023

Privacy Policy

Important notice: NapGrow always attaches great importance to the protection of personal information of users (or "you"). When you use NapGrow's services and/or shop at NapGrow, NapGrow will collect and use your personal information. To this end, NapGrow service providers (or "we") explain to you through this "Privacy Policy" (hereinafter referred to as "this Policy") how NapGrow collects information when you use NapGrow's services and/or shop at NapGrow , use, share, store and protect your personal information, and the way NapGrow provides you with managing such information.

This policy is closely related to your use of NapGrow's services and shopping at NapGrow. Before you start using our products and services, please read and fully understand this policy carefully (minors should read it accompanied by their guardians), especially Terms marked in bold and underlined should be read emphatically.

Your agreement to this policy only means that you have understood the functions provided by the app and the necessary personal information required for the function to run. It does not mean that you have agreed that we can collect non-essential personal information. Non-essential personal information will be collected according to your authorization during use. We will ask for your consent separately.

The corresponding device permissions will not be enabled by default. When important or sensitive device permissions are involved, we will open another pop-up window after asking for your consent again when you use the corresponding business functions; after the permissions are enabled, you can also open them at any time Turn off the permission through the device settings; if you do not agree to turn on the permission, it will not affect the normal use of other non-related business functions. For sensitive personal information, we will process it after obtaining your consent separately.

If you reject this policy, you can still use the basic functions of browsing without registration/login. You can also authorize separately in the subsequent use of the service.

We try our best to explain the professional terms involved in this policy to you in a concise and easy-to-understand manner. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the various contact methods provided by NapGrow.

1. Definition and scope of application

(1) Definition

1. NapGrow: Refers to the NapGrow official website (the domain name is napgrow.com) and the NapGrowAPP.

2. NapGrow service provider: Hong Kong Kebang Technology Co., Ltd.

3. Personal information: refers to various information recorded electronically or in other ways that can identify a specific natural person or reflect the activities of a specific natural person either alone or in combination with other information.

4. Personal sensitive information: refers to personal information including ID number, personal biometric information, bank account number, property information, whereabouts, transaction information, information on children under the age of 14 (including) (we will specify in this policy Sensitive personal information is prominently marked in bold).

5. Children: refer to minors under the age of fourteen.

6. System authority: Refers to the system authority that the mobile smart terminal operating system is open to App and has the ability to collect personal information, referred to as system authority or authority. When you use some business functions of NapGrowApp, you authorize NapGrowApp to call the system permissions, including but not limited to: system album (if the photos are stored in an external storage device, the photo information in the external storage device will be called), camera, geographic location, microphone. The invocation of system permissions will obtain your consent in advance, and you can also set your system permissions in "My-Settings-Privacy Settings-Personal Information and Permissions-Privilege Management" and choose to turn it on or off.

(2) Scope of application

This policy applies to the various products and services that NapGrow service providers provide to you through the NapGrow website, APP, and new forms that emerge with technological development. If our affiliates have separate privacy policies or personal information processing rules for the products or services they provide to you, the corresponding privacy policies or personal information processing rules apply to the corresponding products or services.

In addition to the relevant information collection and use activities described in this policy, this policy does not apply to other services provided to you by other third-party entities connected to this platform, and other services are subject to the privacy policy and other personal information collection and use rules that they explain to you separately .

2. How we collect and use your personal information

When you use our products/services, your personal information that we need to collect and use includes the following two types:

1. In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;

2. In order to provide you with additional functions of our products and/or services, you can choose whether to authorize us to collect and use the information. If you refuse to provide it, you will not be able to use relevant additional functions normally or cannot achieve the functional effect we intend to achieve.

We hereby remind you:

1. We are committed to creating a variety of products and services to meet your needs. Because we provide you with a wide variety of products and services, and the range of specific products/services that different users choose to use is different, the basic/additional functions and the type and scope of personal information collected and used will be different. Please refer to the specific The product/service function shall prevail;

2. In order to bring you a better product and service experience, we continue to work hard to improve our products, services and technologies, and we may launch new or optimized functions from time to time, which may require collecting and using new personal information. information or change the purpose or method of using personal information. If the above situation occurs, we will separately explain to you in detail by updating this policy, pop-up windows, message push, page red dot prompts, etc., and provide you with a way to choose your own consent, and start after obtaining your express consent Collect, use. During this process, if you have any questions, comments or suggestions, you can contact us through the contact information at the end of this policy, and we will answer you as soon as possible.

The specific functional scenarios we will provide you include:

(1) Register as our user and use the account

1. Basic user service

We provide services to you based on the NapGrow platform user account. When you intend to register and use NapGrowApp, in order to create a NapGrow platform account, you need to at least provide us with your mobile phone number, mobile phone verification code or password. If you refuse to provide the above information, you will not be able to register for a NapGrow platform account, and you can only use browsing and services.

2. Additional user services

Additional user services: If you choose to provide personal information such as nickname, profile picture, gender, personal style, city, constellation, school, signature, date of birth, etc. We will provide you with special user rights and interests and provide more personalized user services based on your personal characteristics. Among them, if you provide a nickname and avatar, your nickname and avatar will be displayed publicly. For example, on the product page, the NapGrow platform will publicly display the "recently purchased" user avatar, nickname, transaction price, and transaction time. In order to protect the user's personal information and privacy, the above information will be desensitized. If you do not provide such non-essential personal data information, it will not affect your use of this product and related services.

Authorized login: We may provide third parties with your account information (avatar, nickname and other information prompted on the page) after your separate consent, so that you can easily register/login the third-party account. In addition, we may obtain your third-party account information from third parties such as WeChat, Apple, Sina Weibo, Hupu, etc. according to your separate consent, and bind it to your NapGrow platform account, so that you can use third-party The account directly logs in and uses our products and/or services. We will use your relevant information within the scope of your authorization and consent. You can choose to bind or unbind your third-party account through "Me-Settings-Account Security".

(2) Community functions

1. When you use the community function, if you voluntarily fill in information or publish content voluntarily, we will collect your uploaded videos, photos, posts, comments, likes, followers, shared information, browsing and search information. You can delete your published videos, photos, posts and comments at any time. In order to improve the upload speed of audio and video, enrich the publishing function and optimize your experience, when you shoot and edit the audio and video, we will temporarily load the audio and video to the server before you click "Publish" to confirm the upload. If you log out of the editing page, or do not publish notes for other reasons, we will delete the relevant audio and video immediately. At the same time, you can turn off the preloading function at any time through [Me-Settings-General-Upload works in advance to reduce waiting time].

2. We need to verify the legality and compliance of the content you post in the community to avoid situations where the content you post involves violations of the law or infringes the legitimate rights and interests of third parties. You agree that we will provide the graphics, texts, videos and other content you posted in the community to our service providers for the above purposes, and our service providers will review and mark the above content and give us feedback on the results. The above service providers transmit or share your personal information. We will only review the content you publish, and you agree that we will decide whether to publish or how to publish the graphics, videos and other content you publish in the community based on the review results.

3. The public information you publish when using the community function may involve your or others' personal information or personal privacy information, such as the pictures or videos that you choose to upload including personal information when sharing or commenting. You should consider whether to disclose such information more carefully, and if such information involves personal information of minors, you should obtain the consent of their guardians before publishing.

(3) Commercial and event information display and news push

1. Personalized recommendation service

During your use of our services, we may collect your gender, date of birth, and information on NapGrow in order to understand product suitability, provide you with page display and search results that better suit your needs, and provide you with personalized recommendation services. Operational behavior and stored as service log information, equipment and system information, among which:

Device and system information includes: We will receive and record the device hardware and system information (including device model, operating system version, device settings, device identifier and Advertising identifier (MAC/IMEI/AndroidID/IDFA/IDFV/OPENUDID/GUID/IMSI/FCUUID/DUID/UUID/OAID), device environment, mobile application list, software and hardware feature information), system parameters, device location related information (including your authorized GPS location and WLAN access point, Bluetooth and base station sensor information).

Service log information includes: When you use the products or services provided by NapGrow, we will automatically collect your detailed usage of our services and save them as service logs, including browsing, clicking to view, search queries, favorites, transactions, after-sales, follow Share information, publish information, and IP address, access date and time.

At the same time, we strive to protect your privacy experience through the following measures:

1. If you want to delete your browsing and search records, you can choose to delete them in "My-Footprints" and "Search Box-History Search";

2. If you do not want to accept the commercial advertisements we send to you, you can unsubscribe or close them by replying to unsubscribe via text message or other methods we provide;

3. If you need to view the sorting that is not based on your personal characteristics when using the search service provided by us, you can click "Filter" on the search result page and select "Sales", "Price" and "New Products" among them. set up;

4. If you do not want to see the products, services, and content that we recommend to you, you can enter "I-Settings-Privacy Settings-Understand and Manage Personalized Recommendations" through the APP or click the following "Understand and Manage Personalized Recommendations" If you choose to turn off personalized recommendations, we will show you products, services, and content that are not based on personalized factors.

(Understand and manage personalized recommendations)

2. Business information push and event reminder service

In order for you to better understand and use NapGrow, you agree that we will send you commercial information and other event reminders, and NapGrow and its service providers will collect and use your name and contact information based on the above service purposes.

If you do not want to receive our push messages, you can turn off the types of messages you refuse to receive in [Settings - Message Settings], or follow the prompts in the SMS content to unsubscribe from the push function, and we will stop pushing the above messages to you. If you turn off or unsubscribe from the push function, you will not be able to receive product or event information push services.

(4) Customer service and dispute resolution

When you contact us or apply for pre-sales, after-sales, dispute resolution, in order to protect your account and system 

security, we need you to provide necessary personal information to verify your identity.

In order to facilitate contact with you, help you solve problems as soon as possible, or record the solutions and results of related problems, we may save your communication with us, communication/call records and related content (including account information, order information, your Other information provided by the facts, or the contact information you left), if you consult, complain or provide suggestions for specific orders, we will use your account information and order 

information.

In order to provide services and improve the reasonable needs of service quality, we may also use other information about you, including relevant information you provide when you contact customer service, and questionnaire response information you send to us when you participate in questionnaire surveys.

(5) Risk control and safety management

In the course of your use of our services, in order to protect the legitimate rights and interests of users, identify abnormal accounts and optimize related services, and prevent users from using third-party platforms or software (such as access code platforms, computer modification software, real people, etc.) package, etc.) to improve the security of your use of the services provided by us, our affiliated companies, and partners, to protect the personal and property safety of you or other users or the public from infringement, and to better prevent phishing websites, fraudulent , network vulnerabilities, computer viruses, network attacks, network intrusion and other security risks, more accurately identify violations of laws and regulations or NapGrow related agreements and rules, we embed the developed application security SDK in the application to collect your device information and services Log information, and may use or integrate your NapGrow account information, transaction information, and information that our affiliated companies and partners have obtained your authorization or shared in accordance with the law to comprehensively judge your account and transaction risks, perform identity verification, detect and prevent security events, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

Device information: We will use it according to your specific operations during access and/or use, to receive and record information about the device you are using (including device model, device name, mobile operator, operating system version, ROM information, device settings, unique device identifier, device environment, mobile application list information, running processes Information, software and hardware feature information, device serial number (CN)) SIM card status, bssid/ssid, SIM card serial number (ICCID) system parameters, information about the location of the device (including your authorized GPS location and WLAN access point, Bluetooth, WIFI status and base station sensor information), device unique identification code (OAID, MAC/IMEI/Android ID/IDFA/IDFV/OPENUDID/GUID/IMSI), device CPU/ABI model, gyroscope, accelerometer. Please understand that in order to dynamically detect whether there is any abnormal login in your account, every time you switch NapGrow to the background or restart the program, we may read it again, and we will control the frequency of reading within a reasonable range.

Service log information: When you access or use the products or services provided by NapGrow, we will automatically collect and record your detailed usage information and save them as service logs, including registration/login, browsing, access, click to view, search query, collection , likes, transactions, orders, after-sales, follow, share information, publish information, as well as IP address, access date and time.

Your attention: Separate device information and service log information are information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, during the combined use, such non-personal information will be regarded as personal information, unless authorized by you Unless otherwise stipulated by laws and regulations, we will anonymize and de-identify such information. In order to maintain network security and ensure a good ecology, the attribution region information corresponding to your IP address will be displayed on your personal profile page, content publishing page and comments. The domestic display is at the provincial level, and the overseas display is at the country or region. The data of the network operator shall prevail.

(6) Additional services based on system permissions

We provide you with the following additional services that may collect and process your personal information by enabling system permissions. If you do not agree to enable relevant permissions, it will not affect your use of NapGrow's basic services, but you may not be able to obtain these additional services. The user experience you bring.

Your device system permissions will not be enabled by default. When you use the corresponding business function or actively trigger the corresponding business function, we will separately notify you of the purpose of applying for permission and collecting personal information in the form of a pop-up prompt. After obtaining your consent open. You can check the status of each system permission item by item in "Settings" of your device or "My-Settings-Privacy Settings-Personal Information and Permissions-Permission Management" of our client, and you can decide whether to turn on or off these permissions at any time.

(7) Other additional services provided to you

In order to provide you with more convenient, better, and personalized products and/or services, and strive to improve your experience, we may collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your use of NapGrow's basic services such as browsing, searching, and trading, but you may not be able to obtain the user experience brought to you by these additional services. These additional services include:

1. When you recharge NapGrow coins, if you use an Apple mobile phone, we will collect your AppleID. At the same time, we will collect your payment information to keep your transaction records.

2. Additional services based on the clipboard: every time you open NapGrow, we will detect your clipboard, and if we find that you have copied the link or password of NapGrow before opening NapGrow, we will automatically open the corresponding link Or share content to help you access relevant content on NapGrow conveniently. When you use the scene restoration function, that is, you want to enter a specific NapGrow page by copying the specified password, NapGrow needs to read the contents of your clipboard to provide you with the scene restoration function. When you use the sharing function in NapGrow, we will write the link or password into the clipboard to help you realize the sharing function quickly. When you use the copy and paste function in the search box, there is a behavior of reading and uploading clipboard information. You should know that although the content of your clipboard may involve your personal information, NapGrow will not collect other information other than the password content required to provide you with the scene restoration function. You can choose to close the clipboard through the APP. For details, go to [Me-Settings-Privacy Settings-Prohibit access to the clipboard]

3. The public information you publish when you use the service function to identify the service may involve your or others' personal information or personal sensitive information, such as the pictures or videos that you choose to upload that include personal information when you share or comment. You should consider whether to disclose such information more carefully, and if such information involves personal information of minors, you should obtain the consent of their guardians before publishing.

4. When you participate in lottery or marketing activities through NapGrow, we may need to collect your name, mobile phone number, and delivery address so that you can receive corresponding event prizes or complete event participation. If the corresponding prizes are provided by a third party, we may need to share your above personal information with the third party so that you can receive event prizes or complete event participation. If you refuse to provide the above personal information, you may not be able to obtain the corresponding prizes or complete the activity participation.

5. When you use a device with a depth camera function (such as a specific model of Apple mobile phone) to use the virtual try-on function of the NapGrow platform, the NapGrow client will apply for calling your camera permission and the depth camera application interface (TrueDepth API), and Your facial depth information (facial position, orientation and expression) is processed on your device to better present the try-on effect. Note that the NapGrow client cannot identify anyone by using the TrueDepth API. NapGrow does not collect, store (including any form of cache, cloud storage), use, share or disclose your facial depth information. Your facial depth information is not sent back to our server, it is only processed on your device.

6. After enabling access to Face ID (IOS system), you can use your Face ID to verify your identity and help you complete payment operations based on Face ID. We will not collect or process your facial feature information. You authorize us to obtain your identity authentication result information based on your enabled face ID permission (IOS system) for your identity verification. You can choose to turn off face payment through the APP. For details, go to [Me-Settings-Payment Settings-Face Payment].

(8) Other rules for collecting and using personal information

1. If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing such personal information to NapGrow.

2. If we use information for other purposes not specified in this policy, or use information collected for specific purposes for other purposes, we will obtain your prior consent. If you choose not to provide the aforementioned information, you may not be able to use a certain function or service, but this will not affect your use of other services we provide.

3. If we obtain your information indirectly from a third party, we will clearly ask the third party in written form to explain the source of its personal information and whether it has collected, processed and provided us with your personal information. with your legal authorization. Except for situations expressly permitted by law, we will only collect your personal information from third parties after confirming that the third party has obtained your authorization and consent. If the scope of authorization of the third party cannot cover our processing and use purposes, we will Process your personal information by itself or require the third party to obtain your consent. At the same time, our professional security team will strengthen the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will use no less than the same protection means and measures as we use for our own users' personal information to protect indirectly obtained personal information.

3. How do we use cookies and third-party services

(1) When you use the NapGrow service, we will save your login status and assign you one or more "Cookies" (a small text file), for example: if you visit a website that requires you to log in to Products and/or services that can be provided. When you log in, we will encrypt and store your login name in your cookie file. Due to the irreversible encrypted storage, others cannot identify it even if they can use your device Enter your login name. You don't need to do any extra work, all the collection, storage and encryption work is done automatically by the system.

(2) In order to provide you with more convenient, fast, smooth, and personalized services, we provide you with the following services through cookies and other technologies: remember your login information and login status, and help you save the trouble of using our services. Repeat the steps of entering account information to help judge the security status of your account.

(3) Third-party services

1. Third-party H5 pages

In order to provide third-party services, we may access third-party H5 service pages, including third-party payment service pages and third-party application pages. If you enter these H5 pages, the third party may collect your mobile phone number, personal bio Identification information, bank card number, application account number, please note that all operations you perform on the above third-party H5 pages will follow the privacy protection policy of the third-party service provider. When you leave our platform and jump to a third-party H5 page, we remind you to pay attention to protecting your personal privacy. This platform does not collect or store any personal information you fill in and submit on other third-party service pages.

2. Third-party SDKs

Products on this platform will contain multiple external third-party SDKs or other similar applications. If you use such services provided by third parties on our platform, you agree that your information will be directly collected and processed by them ( such as in the form of embed codes, plugins, etc.).

Please be aware that we will not share any sensitive personal information including your name, ID card, mobile phone number, and bank card with any external third-party SDK that provides technical services and technical support. In order to protect your information security to the greatest extent, we recommend that you check the privacy policy of any third-party SDK service before using it. In order to protect your legitimate rights and interests, if you find that these SDKs or other similar applications are at risk, you are advised to immediately terminate the relevant operations and contact us in time.

4. How do we protect and store your personal information

(1) How do we protect your personal information

1. With data protection as the core, we focus on data security management around the entire data life cycle, and consolidate our data security capabilities from four aspects: security technical measures, security organization construction, system processes, and personnel capabilities.

For the collected information, we strive to adopt industry-standard, reasonable and feasible security measures to protect your information to prevent information disclosure, loss, improper use, unauthorized access, modification and disclosure, etc., such as encryption technology, de-identification customization, data access control and strict identity authentication, etc. We adopt multi-faceted security protection measures to ensure that the protection of users' personal information is at a reasonable security level, including management system control, security system guarantee and many other aspects. We will deploy access control mechanisms to ensure that only authorized personnel can access personal information;

2. We recommend that you pay full attention to the protection of personal information when using our products and services, and we will also provide a variety of security functions to assist you in protecting your personal information. You should attach importance to the protection of your personal information. If you find that your personal information has been leaked or may be leaked, which may endanger the security of your registered NapGrow account or cause other losses to you, you Be sure to notify NapGrow at the first time, so that NapGrow can take corresponding measures to ensure the security of your NapGrow account, and prevent losses or further expansion.

3. You fully understand and fully accept that even though NapGrow adopts various security technologies and procedures to store and protect user information and prevent it from being accessed, used, copied and leaked without authorization, user information may still be hacked , theft, or being leaked due to force majeure or other non-NapGrow reasons. In this regard, as long as NapGrow takes necessary measures to prevent the occurrence of the above situation, and takes necessary measures to prevent further expansion of its losses after the above situation occurs, NapGrow does not need to compensate you for any losses caused by it.

(2) How do we save your personal information

1. After you terminate your use of a service, we will stop collecting and using your information, unless otherwise stipulated by laws, regulations or regulatory authorities. If we stop operating, we will stop collecting your personal information in a timely manner, notify you of the notice of cessation of operation by delivery or announcement one by one, and delete or anonymize your personal information held.

2. After you successfully apply to cancel your account, we will only save your personal information for the shortest period, but will no longer use your personal information commercially; when your personal information exceeds the above storage period, we will keep your personal information The information will be deleted or anonymized.

5. Your personal information rights

During your use of NapGrow, in order to allow you to view, copy, correct, and delete your personal information more conveniently, and to protect your right to withdraw your consent to the processing of personal information and cancel your account, we provide you with corresponding information in the product design. You can refer to the following guidelines for operation settings. In addition, we have also set up channels for complaints, reports and requests for explanations, and your opinions and requests will be processed in a timely manner.

Please note that there may be differences in operating settings between different operating systems and different versions of NapGrow software; in addition, in order to optimize your experience, we may also adjust the operating settings. Therefore, the following guidelines are for reference only.

(1) Review, copy, and correct personal information

1. Query and manage and modify the profile picture, nickname, gender, signature, style, city, constellation, school personal basic information:

1) After entering NapGrow, click "Me";

2) Click on the avatar

3) Click "Edit Profile".

2. View and manage real-name information, bind mobile phone numbers, change login passwords, bind or unbind third-party accounts.

1) After entering NapGrow, click "Me";

2) Click "Settings";

3) Click "Account Security".

3. Check the order information:

1) After entering NapGrow,click me";

2) Click "Buy";

3) Conduct information inquiry visits.

4. As a seller, check the order information of the goods sold when you are a seller:

1) After entering NapGrow, click "Me";

2) Click "Seller Center";

3) Conduct information inquiry visits.

5. View and manage address information:

1) After entering NapGrow, click "Me";

2) Click "Settings";

3) Click "Address Management".

6. View and manage the blacklist:

1) After entering NapGrow, click "Me";

2) Click "Settings";

3) Click "Privacy Settings";

4) Click "Added to Blacklist".

7. Review and copy personal information:

1) After entering NapGrow, click "Me";

2) Click "Settings";

3) Click "Privacy Settings";

4) Click on "Personal Information and Permissions";

5) Click "Browse and export personal information" to view your personal information;

6) Click "Apply for Download" to make a copy of personal information and send it to your designated email address.

(2) Deletion of personal information

You can delete your information through the methods and channels listed in the previous paragraph "Enquiry, Copy, and Correction of Personal Information".

You can request us to delete your personal information under the following circumstances:

(1) If our handling of personal information violates laws and regulations;

(2) If we collect and use your personal information without your explicit consent;

(3) If our handling of personal information seriously violates the agreement with you;

(4) If you no longer use our products or services, or you voluntarily cancel your account;

(5) If we permanently no longer provide you with products or services.

If we decide to respond to your deletion request, we will also try our best to notify the subjects who obtained your personal information from us and ask them to delete them in a timely manner (unless laws and regulations provide otherwise or these subjects have obtained your authorization independently).

(3) Changing the scope of authorization and withdrawing consent

Each business function of the NapGrow platform requires some basic personal information to be completed. Except for necessary personal information, you can change the authorized scope of personal information or withdraw your consent.

You can set or change the settings of your smart mobile device in NapGrowAPP "My-Settings" to give, modify or withdraw your authorization consent. For example, you can withdraw the authorization to find you through Weibo in NapGrowAPP "Me-Settings-Privacy Settings".

You can turn on or off location information (geographic location), camera (camera), photo album (picture library), microphone (voice) through the settings function of the device or NapGrowAPP "Me-Settings-Privacy Settings-Personal Information and Permissions-Privilege Management" , calendar, reminders, storage permissions, phone status, contacts, floating windows, notifications, sports and fitness/recognition of physical activity, Face ID system permissions, change the scope of authorization or withdraw authorization.

After withdrawing your authorization, we will no longer collect information related to these permissions, but it will not affect our previous personal information processing activities based on your authorization.

(4) Cancellation of account

You can apply to cancel your account in the following ways:

1. Log in to the NapGrow client, and submit an account cancellation application through "My-Settings-Account Security-Account Cancellation"; for account cancellation rules, see the "Account Cancellation" page of NapGrowApp.

2. After you voluntarily cancel your account, we will stop providing you with products or services, and delete your personal information or anonymize it according to your requirements, unless otherwise stipulated by laws and regulations.

(5) Constraining automated decision-making

In some business functions, we may only rely on non-human automated decision-making mechanisms including algorithms to make decisions. If these decisions affect your legal rights, you can contact us through the methods disclosed in Article 9 of this policy.

(6) Responding to your above request

In order to protect the security of your account, when you make the above request to us, we may ask you to verify your identity (such as asking you to provide a written request or other means) before processing your request. We will respond within 15 working days to your above request to us.

For your reasonable request, we do not charge fees in principle. However, for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the situation. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, require the development of a new system or fundamentally change existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical.

We will not be able to respond to your request in the following circumstances:

1. Directly related to public security, public health, and major public interests;

2. Directly related to criminal investigation, prosecution, approval or execution of judgments;

3. The personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abuse of rights;

4. In order to protect the major legal rights and interests of the personal information subject or other individuals such as life and property, but it is difficult to obtain the consent of the individual;

5. Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;

6. Those involving commercial secrets.

7. How do we share, transfer and publicly disclose your information

(1) Sharing

We will not share your personal information with other third parties other than NapGrow service providers, but you should be aware of the following exceptions, and we will urge the third party to keep your information properly confidential in the process of using your information with security measures:

1. Sharing under statutory circumstances: We may share your personal information externally in accordance with the provisions of laws and regulations, litigation needs, or the legal requirements of administrative and judicial authorities.

2. Sharing with explicit consent: Share your information with third parties with your explicit authorization and consent.

3. Sharing when you actively choose: When you shop through NapGrow or use NapGrow services, we will share the necessary information about the transaction or service involved in your shopping order or service with your transaction according to your choice Or serve the counterparty to realize your transaction, delivery and after-sales service needs.

4. Sharing with affiliated companies: In order to facilitate us to provide you with products and services based on the NapGrow platform account, recommend information that you may be interested in, identify abnormal user accounts, and protect the personal and property safety of affiliated companies or other users or the public from infringement , your personal information may be shared with our affiliates and/or their designated service providers. We will only share necessary personal information and be bound by the purposes stated in this policy. If we share your personal sensitive information or affiliated companies change the use and processing purpose of personal information, we will ask for your authorization again.

(2) Transfer

Unless the operating entity of NapGrow changes, NapGrow will not transfer your personal information to any third party. If the change of NapGrow's operating entity results in the transfer of your personal information, we will also strictly require the transferee to strictly protect your personal information in accordance with this Privacy Policy. Otherwise, we will require the transferee to seek authorization from you again.

(3) Public disclosure

We will not proactively disclose your information to the public, and we will only disclose your personal information under the following circumstances:

1. With your explicit consent or based on your active choice, we may publicly disclose your personal information;

2. If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of the NapGrow platform, or in order to protect the personal and property safety of NapGrow platform users or the public from infringement, we may comply with laws and regulations or obtain your consent. Disclosure of personal information about you under , including relevant violations and the measures NapGrow platform has taken against you. For example, if you seriously violate NapGrow's rules by selling counterfeit goods, we may publicly disclose your entry subject information and violations.

(4) Exceptions to obtaining prior authorization and consent when sharing, transferring, and publicly disclosing personal information

According to relevant laws and regulations, in the following circumstances, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

1. Directly related to public security, public health, and major public interests;

2. Directly related to criminal investigation, prosecution, trial and execution of judgments;

3. In order to protect the major legal rights and interests of the personal information subject or other individuals such as life and property, but it is difficult to obtain the authorization and consent of the individual;

4. The personal information subject discloses personal information to the public by itself;

7. How to update this policy

Our products and services will continue to be updated and optimized to meet the needs of you and other users. Therefore, when new services and functions change, we may update our privacy policy to inform you of specific changes. We will not reduce your rights under this Privacy Policy without your express consent. We will post any changes to this Privacy Policy on a dedicated page.

For major changes, we will also provide more prominent notifications (including but not limited to red dot prompts, message pushes, pop-up windows, etc.).

The major changes involved in this privacy policy include but are not limited to:

1. Significant changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

2. Major changes in our ownership structure, organizational structure, etc., such as business adjustments, changes in information controllers caused by mergers and acquisitions, etc.;

3. The main object of personal information sharing, transfer or public disclosure changes;

4. When your personal information processing rights and the way of exercising them change;

5. The responsible department, contact method or complaint channel that we are responsible for handling personal information protection has changed.

We will also archive previous versions of the Privacy Policy on a dedicated page for your review.

8. How to contact us

We have established a personal information protection department. If you have any questions about this policy, or any related complaints or comments, please contact us in time. You can contact us by:

(1) You can contact us through the dedicated email address we set up for personal information protection complaints and reports, contact email: [email protected]

(2) Log in to the NapGrow client, select "Customer Service Center", and contact us through the exclusive hotline or online customer service.