Privacy Policy

Last updated: November 13, 2025

Effective Date: November 13, 2025

Agreement Version Number: 20251113V2.0

SHANGHAI XIAOCHUAN TECHNOLOGY LIMITED (hereinafter referred to as "we", "us", or "our") is the provider and operator of the application software and services (We may use differentiated names across various device terminals, such as "Visha" or "Videos." Notwithstanding the variation in names, the software corresponding to these terminal-specific names constitutes an integral component of a single, unified service system, hereinafter collectively referred to as "the Software"). We respect your privacy and are committed to ensuring the security of your personal information. In the process of providing the products or services (collectively referred to as "the Services"), we may collect and use your personal information with your consent or as required by applicable laws. This Privacy Policy (hereinafter referred to as the "Policy") is intended to help you understand how we collect, use, disclose, process, and protect the personal information you provide when using the application software or services, your rights with respect to that personal information, and how we safeguard those rights. The Policy applies to all products and services we provide, including applications, mini programs, and webpages for PCs and mobile devices, software development kits (SDKs) and application programming interfaces (APIs) for third-party websites and applications, and any other forms that may emerge in the future.

It shall be specially noted that the Policy is not applicable to the services offered to you by third parties. You may receive content or network links from third parties. Please be cautious about whether to access the links, content, products, and services provided by third parties. Before submitting your personal information to any third party, please carefully review its privacy policy.

To ensure that you fully understand the Policy and make your own decisions, we will explain the Policy as clearly as possible by underlying or highlighting the critical information (especially in bold, capital, underlined, and other forms). Moreover, when you use our services for the first time, prompts will pop up, reminding you to pay attention to and understand the core content of the Policy.

Please read the Policy carefully to understand our practices with respect to your personal information before using our products or services, submitting personal information to us, or granting us consent to collect your personal information, and please visit often to stay informed of updates to the Policy. We will post changes to the Policy (if any) through relevant products or websites to keep you informed of the same. By accessing our services after such notice, you agree to the updated privacy policy. You can view the "Update Date" at the top of the Privacy Policy page to confirm the latest update time.

If you have any questions, please feel free to contact us via

Privacy@transsion.com

You can also access the Policy via:

Videos app > More > About Videos > Privacy Policy

The Privacy Policy will help you understand the following:

I. How We Collect and Use Your Personal Information

II. How do we use cookies and others similar technologies

III. How We Store and Protect Your Personal Information

IV. How We Share, Transfer and Disclose Your Personal Information

V. How Is Your Personal Information Transferred Across Borders

VI. Your Rights to Your Personal Information

VII. How We Process Children's Personal Information

VIII. Third-party Service Providers and Their Services

IX. Supplements and Updates to the Policy

X. How to Contact Us

I. How We Collect and Use Your Personal Information

(I) Overview

We believe that fundamental privacy rights must apply equally regardless of where you live in the world. Therefore, we treat any information that relates to an identified or identifiable individual as "personal information" no matter where they might live, and that applies particularly to name, identity, location, online identifier, or physical, physiological, genetic, mental, or any other related data that can reasonably be used to identify an individual.

We only collect the information necessary for special, specific, explicit, and legitimate purposes and shall ensure that your information will not be further processed for any other purposes. We will request your consent again if we intend to use your personal information for any purposes not specified herein.

When collecting your personal information, we will do so through the following three methods, including: 1) Information you directly provide to us; 2) Information generated during your use of this software that we collect through automated means (such as device information, service log information); 3) Information we obtain from other sources.

You have the right to decide whether to provide your personal information when using our products or services or when we request it. You are not required to provide personal information to us. However, choosing not to provide it may prevent us from providing you with certain products or services or responding to issues you may encounter, and limit our ability to resolve them. We will only collect and use your personal information for the purposes stated herein. The following are examples explaining why we collect your personal information:

(II) Main Service Functions and Information Collection and Usage Scenarios for the Software

The main purpose of the Software is to provide you with services such as local audio/video playback and video editing.

1. Providing Local Audio/Video Playback and Video Editing Services

When you use our local audio/video playback services, we will require your storage permissions to access the audio and video you want to play. Go to Settings > Privacy > Permission Management > App > Videos Player > Storage to disable your permissions at any time, though granting them is a prerequisite for the Services. Refusing to grant the permissions will prevent us from being able to provide you with the video playback service.

To better adapt the video editing Services to your device, we may collect your device information (IMSI, GAID, and manufacturer), version code, system version No., device model, device ID, and platform. Refusing to provide such information may prevent us from offering the correct version of the Services.

You can use the Services to search online for content you may be interested in. In this case, we will save your search history locally so that you can view it more easily.

2. Cloud Disk Service

Access to the cloud storage service may be provided in certain versions of the Software. In such circumstances, if you have logged in to the account service on the operating system, in order to facilitate your use of the function, this Service will automatically read the login status of your system account and obtain your account nickname, Profile Picture, and User ID, so that you can view and use the free cloud storage space provided by the cloud storage service for your account.

When you use this function, you can upload, store, share, and download your audio and video files through the cloud disk service. Cloud Service will save your content according to your authorization, so that you can view, manage, and use it in the software service. Please note that if you have registered and used other products and services provided by the cloud storage service provider, the available cloud storage capacity in your account will be shared with other products and services of the cloud storage service provider.

3. Provision of Advertising and Marketing Services

When you use our products and services, we and our partners may collect your device information, device usage information, and advertising interaction information , and display relevant promotional content to you (which may include more relevant personalized advertising content). During this process, we will strictly protect your privacy. We may analyze the above-mentioned information and establish user groups to create user profiles (placing your personal information into one or more categories). Targeted advertisements will only be delivered to you with your consent, to the extent required by applicable laws.

We may combine the above-mentioned information with other information (including information across different services or from devices such as computers, mobile phones, and other connected devices) to provide and improve our products, services, content, and advertisements. You may retain the right to opt out of receiving personalized advertisements and object to user profiling analysis at any time, including identity analysis for direct marketing and automated decision-making purposes. To exercise these rights, you can turn them on or off in the settings at any time, or contact us via privacy@transsion.com. The opt-out path may vary depending on the version.

Please understand and agree that the information you submit on the advertising page will be collected and used by third-party advertisers or advertising companies, and they shall be responsible for protecting the personal information you submit. When you use such third-party services, you need to be bound by their Privacy Policy; please read the content of their Privacy Policy carefully.

4. Optimizing Products and Improving Service Quality

To provide you with high-quality products and services and ensure their normal use with the Software, we will automatically collect information related to your device and SIM card for GUI optimization and possible troubleshooting. The information automatically collected includes:

(1) Information about your device and SIM card: When you start using the Software, we will receive and record information about your device (including brand, model, OS version, unique device identifier (UDID), CPU model, settings, system language, network device hardware address, IP address, and software and hardware characteristics), the Google Advertising ID (GAID) of the hardware device, App version number, information about the location of the device (including the country or region info and network access mode of your authorized device), and SIM card information based on how you interact with the Software and the specific permissions granted when installing and using the Software.

(2) Service log information: When you use the Software, we automatically collect information about how you use our service and save it as service logs. This includes the published information, access time, number of times you open the software, duration of use, event information (errors, crashes, restart, upgrade), and other log information generated by your devices when you are using the Software.

Please note that device information or service log information alone is not sufficient to identify a certain natural person. Any non-personal information used in combination with other information to identify a specific natural person or in combination with personal information will be regarded as personal information. In this case, with your authorization or unless otherwise provided for by laws and regulations, we will anonymize and de-identify such personal information. The above information refers to the basic data that must be collected to provide the Services. Refusing to provide such information may prevent us from being able to offer the services related to the Software.

Please note that we may also collect the device and service log information mentioned above for varying business functions and scenarios of the Software. (The collected specific information may differ depending on the business function and scenario.)

5. Providing Participation in Promotional Activities

From time to time, we will initiate or provide promotional activities. When you participate in these activities, we will collect information you voluntarily provide to us through the activity interface, such as your name and contact details. This information is mainly for us to get in touch with you and to award prizes. Should you refuse to provide the information required to participate in the promotional activity, we may be unable to provide you with the Services, prizes, or rewards. However, this will not affect your use of other functions of the Software.

6. Message Push Service

We may also push service notifications, activities, and other messages to you based on your device identifier, country, GAID, IP address, device brand & model, OS version & language, and information about your use of this App. To unsubscribe from notifications, activities, and other messages, go to Settings > Notification Center > Notification Management to withdraw your consent. Methods of opting out may vary by version.

7. Improving Our Products or Services

We may also collect other information needed for the reasonable improvement of our products or services. This includes feedback provided when you contact customer service and responses when you participate in questionnaires. We may combine information from one service with that of another to provide you with better services, content, and recommendations.

8. Providing Security Services

To ensure your experience while using our services is a safe one, we provide comprehensive security. Our aim is to protect you, other users, and the broader public from potential threats such as phishing websites, fraud, network vulnerabilities, computer viruses, cyberattacks, and unauthorized intrusions. In order to better identify and preemptively combat these threats, as well as identify violations of laws, regulations, or our set agreements, we may collect or integrate details about your device, the apps you have installed, ongoing processes, overall app performance, frequency of app usage, crash data, general app installation and utilization metrics, performance data, and the origin of the apps. With this information, we strive to assist you in detecting potential security risks and legally take the necessary measures, including recording, auditing, analyzing, and responding to such concerns.

(III) Other Situations where Your Information May Be Collected

Where permitted by laws, we may collect your personal information from other individuals, business entities, public channels, or other third parties indicated by you, other partners who help us provide our products or services or assist us in ensuring information security and preventing frauds, and other legitimate avenues. We will inform you and collect your information with your consent.

We may also collect other information about you, your device, or your use of the Services in other ways that will be described to you at the time of collection for your consent.

To improve our product layout and offer you better services, we may carry out researches, statistical analyses, and predictions on the collected information in an anonymized manner (including machine learning or model algorithm training based on anonymized data). We will take technical measures and other necessary actions to process the collected personal information so that such information cannot identify any individual person and cannot be recovered. As permitted by applicable laws and regulations, we do not need to inform you separately for your consent for the use of such anonymized data.

II. How We Store and Protect Your Personal Information

1. How we store your personal information

We will store your personal information that we collected upon your consent in accordance with the relevant national laws and regulations concerning personal privacy and data protection. We may also store the personal information we collect in countries or regions other than the country in which we do business, provided that local laws and regulations do not prohibit such storage.

Currently, we may store your personal information in India and Ireland. Specifically:

The personal information we collect and generate in the course of our operations in India will be stored on servers located in India.

The personal information we collect and generate during our operations in Russia will be stored on servers located in Russia.

The personal information we collect and generate in our business outside India and Russia will be stored on servers in Frankfurt.

We may use the servers in other areas or countries depending on our business development, and in such cases, we will update the Policy accordingly.

Whether personal information is stored in the country where we do business or in another country or region without violating the law, we will store it in accordance with the relevant laws and regulations regarding data storage. We will take necessary security measures considering the characteristics, scope, purposes of personal information processing, the possible risks in processing personal information, and the serious consequences in case of any damages. For example, we will encrypt and de-identify the collected personal information before storage. We will store the information only necessary for our business development within the minimum retention period unless otherwise permitted by laws or you agree to extend the retention period. We will delete or take other appropriate measures to delete data that exceeds the retention period or that you request us to delete, provided that this does not violate the relevant laws and regulations.

2. How we protect your personal information

We will also take other necessary measures to protect your personal information from misuse, unauthorized access, modification, disclosure, or destruction.

We implement security measures designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical and physical safeguards to protect your personal information by considering the nature, processing methods, and security of the personal information. We will continuously strive to improve these measures to keep your personal data secure.

It should be noted that no measures can absolutely guarantee the avoidance of data storage security incidents. In the event of a security breach, we will report to the appropriate regulator in accordance with the requirements of relevant laws and regulations, and provide the type of personal data involved in the data breach, the number of data subjects, the possible consequences of the data breach, and the remedial measures we intend to take in accordance with the requirements of the supervisory authorities. We will take all possible measures to remedy or mitigate the damages and consequences caused by a data breach. If permitted or required by laws, we will promptly inform you of the consequences or significant damage that may be caused to you as a result of a data breach, so that you can take appropriate measures to protect your rights to the greatest extent.

Since no website, Internet transmission, computer system, or wireless connection is absolutely secure, in addition to the necessary security measures we take, users need to be more aware of privacy and security risks. For example, if you are redirected to a third party's website, link, product, or service through our service, please be careful and read the terms of agreement of such website, link, product, or service carefully for the security of any data information collected by such website, link, product or service, and we will not be liable for any data security issues caused by such third party. If you find that certain content, advertisements, or features of our website, products, or services may be provided by third parties and may endanger your privacy and security, please contact us promptly and we will give priority to dealing with them in accordance with the law.

III. How We Share, Transfer and Disclose Your Personal Information

We will share, transfer, and disclose your personal information to the minimum extent and only when it is necessary for operations or required by laws. We will not share, transfer, or disclose your personal information unless otherwise required or permitted by applicable laws and regulations in the following circumstances:

1. How we share your personal information

We do not sell any personal information to third parties. To offer you timely service, we may share your personal information with our affiliates. We will only share your information with our affiliates for lawful purposes clearly stated and only as necessary to provide the Services subject to the purposes stated in this Privacy Policy . For any purposes not covered herein, we will make explicit statements in the privacy policy or notice for the specific product or service.

We may share necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing service providers, and third-party SDK providers, among others) to perform certain functions or to provide you with better services and user experience. We may adjust the third-party SDKs connected to our app, and we will keep you updated on access to the user information and third-party SDKs in the Policy.

We will share that information to the minimum extent and only when it is necessary for operations or required by law. Before sharing, we will sign stringent confidentiality agreements with our authorized partners, requiring them to take relevant confidentiality and security measures to process personal information in accordance with the Policy and the applicable laws of your jurisdiction. Moreover, we will require them to provide data security functions and information security qualifications (such as classified protection assessment, information security management system, etc.). When embedding SDKs or any other similar applications of our authorized partners in the Software, we will do our due diligence to request the SDKs that obtain the information to protect the security of your data.

We may also share your non-personal information with third parties to provide evaluation, analysis, or other business services. For example, we may use the aggregated information to help our partners (such as advertising service providers) understand the effectiveness, feedback, and usage trends of their services.

In the event of a merger, acquisition or bankruptcy and liquidation, transfer of assets, or other related transactions involving the transfer of personal information, we will require by agreement or other appropriate measures that the company or organization newly holding your personal information continues to be bound by the Policy and that such subject takes confidentiality and security measures no less stringent than those required by the Policy to handle personal information.

2. How we transfer your personal information

We will not transfer your information to any other party without:

(1) Your express consent is obtained.

(2) Providing prominent notice via email, our website, or by means of another appropriate method to inform you of any changes in your ownership of, rights to, and choices regarding your personal information when we are involved in a merger, acquisition, or sale of all or part of our assets that may affect your personal information;

(3) The transfer has been stated in the Privacy Policy or otherwise notified to you.

3. How we disclose your personal information

We may disclose your personal information as required by law, legal procedures, litigation, and/or government agencies and authorities. We may also disclose your personal information if the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance.

In addition, we may share your personal information with the following people:

(1) our lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.

(2) investors and other related third parties, if actual or potential sales or other transactions with another company occur and are related to entities within the TECNO group.

(3) other third parties, for example, when specific information is disclosed to them under your authorization.

IV. How Is Your Personal Information Transferred Across Borders

For the purposes described in the Privacy Policy, we may transfer your personal information to the resources or servers mentioned in Section III of the Policy for storage or processing, and we may also transfer your personal information to third-party service providers and business partners, and therefore your data may be transferred to other countries or regions, subject to compliance with applicable laws and regulations in your region and with your authorized consent. The privacy laws in these countries or regions may differ, and the jurisdictions in which these servers are located may or may not protect personal information to the same extent as those in your jurisdiction. However, we will still strive to protect your personal information based on our Privacy Policy and carry out the cross-border transfer and other processing of corresponding information as required by the laws of the country or region where the personal information is located.

If we transfer personal information outside of your jurisdiction, whether to our affiliates or to a third-party service provider, we will comply with the relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers are subject to the requirements of applicable local data protection laws.

V. Your Rights to Your Personal Information

As a data subject, you have a number of rights with respect to personal information such as confirmation, access, correction, deletion, withdrawal of consent, complaints (hereinafter referred to as "requests"), etc. We fully understand and respect these rights, which are also subject to specific exclusions and exceptions in accordance with applicable law. We will also take active steps to ensure that your rights are effectively guaranteed. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we charge no fees for your legitimate requests. However, for repeated requests exceeding reasonable limits, we will charge a reasonable fee to the extent permitted by applicable laws based on actual administrative costs as appropriate. We may deny requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes in current practices), pose a risk to the legal rights of others or are highly impractical, or violate mandatory legal requirements.

1. Right to confirm and access: We inform you of how we collect and process your personal information via this Privacy Policy or through privacy policies or notices for specific product service scenarios. You have the right to confirm or reject such collection and processing by checking the box or via other methods. However, if you reject the service, some functions that require your express authorized consent before use may no longer be available. The personal information you have provided to us can be accessed directly from the interface of our products or services. In case of a failure to access information, email us at Privacy@transsion.com, and we will deal with your request promptly.

2. Right to correct and delete: When your personal information changes, or when you find that the information we collected and processed is inaccurate or incomplete, you have the right to request that we make corrections or additions. For some of your personal information, you can correct and amend it directly on the relevant function page of the product or service. You have the right to request us to delete your personal information when we have achieved the purpose of collecting your personal information or it is no longer necessary, or when you find that we have collected or processed your personal information in violation of the provisions of laws and regulations or the terms of the Privacy Policy. For any information you cannot access to correct or delete, email us at Privacy@transsion.com to request a correction or deletion.

It should be noted, however, that we may not be able to approve your request for deletion in certain cases, such as the deletion of transaction data, as we are legally obliged to keep records of transactions in compliance with applicable local laws. Please also note that if you request the deletion of your information from our products and services, due to certain applicable local laws and technical limitations, we may not immediately delete the corresponding information from our backup systems, but we will securely store your personal information and prevent its further processing until the backup systems are updated and your information can be deleted or anonymized.

3. Right to withdraw consent: For our different products or services to perform the corresponding functions, we will require the necessary personal information in accordance with the applicable local laws. This is described in "How We Collect and Use Your Personal Information" of the Privacy Policy. You may withdraw consent previously granted to us for specific purposes, including the collection, use, and/or disclosure of your personal information in our possession or control, by deleting the information, disabling the functionality of the device, or withdrawing the consent request. You can email us at Privacy@transsion.com for relevant operations. We will process your request within a reasonable time after you send it, and then will not collect, use, and/or disclose your personal information according to your request.

Withdrawing your consent may result in failure to access certain and/or all product and service functions. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.

4. Right to complain: In the event of a complaint, please email us at Privacy@transsion.com. We will respond promptly to your complaint. If you are not satisfied with our response, especially if our personal information processing practices have harmed your legitimate rights and interests, you may also file a complaint or report to the local statutory personal data protection authority, or file a lawsuit with a court of competent jurisdiction.

5. Right to control your privacy settings

You have the right to control your privacy settings, which allow you to restrict our collection, use, disclosure, or processing of your personal information. For example, you can choose to turn on or off the functions and permissions of Location Access, Camera, and SMS. You can also get more detailed information about the security status of your device in Settings. If you have previously agreed to enable the corresponding permissions or agreed to our use of your personal information based on the aforementioned business scenario and would like to change that, go to Settings > App Management > Permission Management or contact us at Privacy@transsion.com.

6. Right in some jurisdictions

Please pay attention that you may have the following data subject rights under applicable laws in certain jurisdictions:

(1) Right to restriction of processing. You have the right to request our restriction on your personal information processing. We will review the reasons for your request. If the reasons are in accordance with applicable data protection laws, we will process your personal information only to the extent permitted by such laws and will notify you before lifting the restriction on processing.

(2) Right not to be subject to automated decision-making. You have the right to refuse automated processing of your information, including performance analysis and other automated processing that may have a legal or similar impact on you.

(3) Right to data portability. You have the right to request the transfer of your personal information to another data controller in a structured and commonly used format.

While we also have the right to refuse to process your request, we may reject some of your requests where an exemption applies or where we comply with applicable laws. For example, some requests are manifestly unfounded or excessive or require disclosure of third-party information.

VI. How We Process Children's Personal Information

We do not provide products and services for children under the age of 14 or the equivalent legal age under the law in your jurisdiction (the legal definition of a child varies from country to country, and we will define a child based on the laws and regulations of the country or region in which we do business). We do not actively collect personal data from children and do not use it for marketing purposes. If you find that you have transferred information about children to us, email us at Privacy@transsion.com, and we will remove the information as soon as possible. If we find that we have collected children's personal information, we will also remove the relevant content as soon as possible.

VII. Third-party Service Providers and Their Services

When you use our products or services, you may receive links to third-party websites or content and services provided by third parties, and some products or services from third parties may be provided in the form of SDKs or other means.

You can choose whether to access or accept websites, products, and services provided by third parties based on your judgment. Our Privacy Policy does not apply to products and services provided by any third party. Since we cannot substantially control third parties, we cannot be responsible for the collection and processing of your personal information by such third parties.

The following are the third-party terms and Privacy Policy applicable when you use the above-mentioned specific products or services:

Cloud Disk Service:

Privacy Policy: https://render.palm.tech/cloud/20251011V3/en/policy.html

User Agreement: https://render.palm.tech/cloud/20251011V3/en/terms.html

When you submit any information to such a third party, please carefully understand the third party's Privacy Policy and pay attention to protecting your personal information.

VIII. Supplements and Updates to the Policy

We reserve the right to update or modify the Policy from time to time as our business, technology, applicable laws, and operations change. In case of any change to the Policy, we will notify you by posting the updated Policy here (on this page), or by sending it to you as a separate notice. Please regularly check this page or the notifications we send you to stay informed of updates to the Privacy Policy. The Privacy Policy is subject to change, but we will not diminish your rights under the Policy without your express consent.

We will seek your express consent as required by applicable laws before we collect other information from you or use or disclose your information for a new purpose. If you continue to use products and services on the website, mobile device, and/or any other devices, you will be bound by the updated Privacy Policy.

The content of products or services stated in the Policy may change depending on the type of product or system version you are using, or the requirements of local laws and regulations.

IX. How to Contact Us

If you have any suggestions, questions, or concerns about our Privacy Policy or practices regarding the protection of personal information, contact us at:

Email: Privacy@transsion.com (Note: The email is used for receiving emails related to our Privacy Policy or information protection only)

We will review your request regarding privacy or personal information as soon as possible and reply to you within 15–30 days after verifying your user identity. If your request involves complex or significant issues, we may ask you for further information.

If you are not satisfied with our response, especially if your legitimate interests have been violated by us, you can seek a solution from the relevant data protection supervisory authority in your jurisdiction. If you make the above inquiry to us, we will provide you with information on the relevant complaint channels that may apply to your case.

Thank you for your time to read our Privacy Policy!