LUCKYCUP COFFEE Personal Information Protection Policy
The effective date of version [1] is [April, 8th , 2025]
LUCKYCUP COFFEE(MALAYSIA) SDN. BHD. (hereinafter referred to as "LUCKYCUP COFFEE," registered address: [380 JALAN BESAR #06-06 ARC 380 SINGAPORE (209000)]), and its affiliated companies (including but not limited to Zhengzhou Baodao Technology Co., Ltd., Xue Wang Ai Zhihui Technology (Zhengzhou) Co., Ltd., etc.) (hereinafter referred to as "LUCKYCUP COFFEE" or "we") place great emphasis on protecting the personal information and privacy of users (hereinafter referred to as "you"). We fully understand the importance of personal information to you and will take appropriate security measures in accordance with legal requirements and industry-standard security practices to protect your personal information.
We hope to clearly introduce through this LUCKYCUP COFFEE Personal Information Protection Policy" (hereinafter referred to as "this Personal Information Protection Policy") how we collect, use, store, share, and transfer your information when you visit the LUCKYCUP COFFEE Order Platform" (hereinafter referred to as "the Application") and other services provided by us. We also explain the methods we provide for you to access, update, delete, and protect this information. LUCKYCUP COFFEE may transmit your information overseas in accordance with the methods and purposes described in this Personal Information Protection Policy.
If you have any questions about this policy or related matters, or request to make a complaint or report, you can contact the personal Information Protection team of LUCKYCUP COFFEE (email: [xyk_it@luckycup.cn]). We will answer you or deal with your complaint as soon as possible.
This Personal Information Protection Policy will help you understand the following:
1. How we collect and use your personal information;
2. How we use Cookie and similar technologies;
3. How we share, transfer and publicly disclose your personal information;
4. How we store and protect your personal information;
5. How you manage your personal information;
6. Complaints and reports on the infringement of your personal information
7. Protection of minors' personal information;
8. Notice and revision of this policy;
9. How to contact us;
10. Appendix.
[Special Notice] Please carefully read and fully understand our Personal Information Protection Policy before using any of our services (key points are highlighted in bold or underlined for your attention) and making the appropriate choice. By choosing to use or continue using our services, you agree that we will process your relevant information according to this Personal Information Protection Policy. If you have any questions about this policy, you can contact us through the methods provided in "9. How to Contact Us" of this Personal Information Protection Policy).
Please note that the functions of different applications may vary to some extent, and the specific features you use will apply. In addition, for certain services, we may establish separate privacy policies to explain the special terms of these services. If there are inconsistencies between the relevant specific privacy policies and this Personal Information Protection Policy, the applicable specific privacy policy shall prevail.
Please note, this Personal Information Protection Policy does not apply to other third-party products/services you access through our services ("other third parties" include your transaction counterparties, any third-party websites, and third-party service providers). For specific regulations, please refer to the privacy policies or similar statements of those third parties. We recommend that you read and confirm your understanding of these privacy policies before accepting related services and providing personal information.
When you use our services, we may collect and use your personal information in the following scenarios, where the personal sensitive information is marked with an underline. If the purpose and scope of collecting and using your personal information changes, we will inform you in a reasonable way and now we seek your consent hereby.
To provide you with the basic functions of our services, we need to collect and use necessary personal information. If you refuse to provide this essential information, you will not be able to use our services normally. We will follow the principles of propriety, legality, and necessity, and collect and use your personal information for the following purposes as stated in this Personal Information Protection Policy.
1．Help you create an account and log in
In order to comply with the provisions of laws and regulations, as well as to provide you with more convenient services, when you register as a user of LUCKYCUP COFFEE, you need to:
（1）When you register and log in with your mobile phone number, we will send SMS verification code to the mobile phone number provided by you. When you enter the verification code received by you on the registration page, you can complete the registration and login;
（2）When you register and log in with your mailbox, we will send emails and verification codes to the mailbox you provide. When you enter the verification code received by you on the registration page, you can complete the registration and login;
If you only need to use the browsing and search functions, you do not need to register as our users and provide the above information.
2．Display nearby stores based on your location
When you enable the location function of your mobile device through system authorization and use services based on your location, we will collect and use your location information to match you with nearby LUCKYCUP COFFEE stores (for example, you can access relevant services without manually entering your geographical coordinates, estimating the actual distance between LUCKYCUP COFFEE stores and you to facilitate your purchasing decisions). We will use certain technologies to obtain your location information, including IP addresses, GPS, and WLAN (such as Wi-Fi) access points, Bluetooth, and base stations that can provide such information. You can turn off the location service in your mobile device's system to stop us from collecting your location information.
If you refuse to provide location information, you need to manually scan the QR code of the order at LUCKYCUP COFFEE store to place the order.
3．Provide you with booking, order and order management functions
In order to show you the order information of your account and facilitate your management of the order information, we will collect the order information generated by you in the process of using our services, including the order type, order number, the goods you purchased, the amount you should pay (including discount information), the way you pay, the time of placing an order, the time of picking up food and other relevant information;
The order generated by the application may contain your identity information, contact information and payment information. Please be careful to show or provide it to others. We will also try to anonymize the order information when displaying it on the basis of ensuring the availability of the information.
4．Help you complete the payment
When making an order payment on our app, you can choose to use the services provided by associated third-party partners (such as DuitNow, Touch 'n Go, Boost, AlipayCN, WeChat, etc.) for payment. We need to collect your LUCKYCUP COFFEE order information, reconciliation information, and other necessary information required by law, and share this information with these partners to confirm your payment instructions and assist you in completing the payment. If you refuse to authorize us to collect and process the above information, you will not be able to use this feature, but it will not affect your ability to use other functions normally.
5．Provide you with security
In compliance with legal and regulatory requirements, to ensure the security of your account, transactions, and system operations, we will obtain your device information during your use of our services. This includes the attributes, connection, and status of your device, such as model number, unique device identifier (e.g., IMEI/androidID/IDFA/OPENUDID/GUID, SIM card, IMSI, BSSID, SSID information), device MAC address, software list, and telecom operator.
To enhance your security while using our services and more accurately prevent phishing website fraud and malware, we may use or integrate your personal information, as well as information obtained from our affiliates and other relevant parties with your authorization or legally shared. We will comprehensively assess the risks associated with your account and transactions based on your usage habits and frequently used software information. This includes verifying identity, preventing, detecting, and investigating potential fraud, network viruses, cyber attacks, and violations of agreements, policies, or rules between us and our affiliates to protect you, other users, ourselves, and our affiliates. We also record links ("URLs") that we deem risky.
6．Personal information we automatically collect
When you log in and use the services we provide, we collect your browsing and search history as network logs. This includes your IP address, browser type, language used, operating system version, date and time of access, published information, browsing, searching, and internet requests. We collect this information primarily to ensure the secure operation of our services and to better understand you, such as where you are from and what content on our service attracts you. After de-identification, we use this information for internal analysis and to enhance service quality and relevance. We also need to retain these logs to record the operational status of our applications, in compliance with Chinese laws and regulations.
7．Personal information that we may collect indirectly
To complete identity verification, and to ensure account security, and to confirm transaction status, and to provide you with after-sales service and dispute resolution, we may obtain your personal information from third parties after your authorization (for example, through the transaction objects and directly involved third-party information systems or payment institutions you have chosen to collect your transaction and payment information related to the progress of transactions, so that we can process your orders and ensure the smooth completion of services, or better prevent fraud and malicious order padding). We will obtain relevant information about you from related parties of LUCKYCUP COFFEE and other relevant parties in accordance with legal requirements and agreements with third parties, and use this information only after confirming the legality of its source.
8．Description of the necessity of self-start or associated start
In order to facilitate your timely return to the application interface after completing the payment, we will invoke the self-start or associated start behavior of the mobile phone system after you complete the payment action with Wechat and Alipay, so as to ensure that you can check the payment status and order information in time.
In order to provide you with more convenient services, you can choose to use the extended functions provided by us. We will collect and use the following information in the following scenarios. If you do not provide such information, you will not be able to normally use the relevant additional functions or achieve the desired function effect, but it will not affect your use of the basic functions of our services.
Information display based on location-based authorization:
After obtaining your authorization, we will collect location information generated during your use of our services. When you enable the positioning function on your mobile device through system authorization and use services based on location information, we will collect and use your location information (including GPS location information you authorize, as well as WLAN access point, Bluetooth, and base station sensor information) to provide and realize relevant services (for example, you can locate or obtain related services without manually entering your geographical location). You can turn off the positioning settings in your device's system to stop us from collecting your location information, but this may prevent you from using the services we provide based on your geographical location or achieving the expected results of these services.
The above permissions will not be enabled by default. We will ask for your confirmation before starting this function, and you can also turn on or off each function through the Settings function in the device system.
In order to meet your needs and to maintain and improve our service quality, we will use the following information in accordance with the law and according to your specific authorization:
1.We may collect information you voluntarily provide us when participating in service surveys, as well as information provided during interactions with our affiliates and other relevant parties. This is to help you track order status, initiate user complaints, and improve the quality and process of our customer service. We will inform you of specific processing rules before collection and obtain your consent in accordance with applicable data protection laws.
2. We may use the personal information collected in our business for statistical analysis and operational improvement. We will also use de-identified information that cannot identify you or be restored to establish databases and for commercial purposes. For example, we may conduct statistical analyses based on your location and preferences to improve our products, services, or marketing plans; or perform technical upgrades, network maintenance, troubleshooting, internal policy and process formulation, and generate internal reports to enhance our systems.
If we use the information for other purposes not specified in this Personal Information Protection Policy, or if we use the information collected for a specific purpose for other purposes, we will separately seek your consent.
（I）Use of Cookie
To ensure the smooth and efficient operation of our application and provide you with a more convenient access experience, we will store a small data file named Cookie on your device terminal/system. Cookie helps us call your information when you visit our relevant platforms in the future, simplifying the process of filling out personal information (such as one-click login); it provides you with settings for safe shopping preferences; assists you in optimizing your selection and interaction with ads; and protects your data security. We will not use Cookie for any purposes beyond those stated in this Personal Information Protection Policy. You can manage or delete Cookie according to your preferences. You can clear all Cookie saved on your computer or mobile device, and you have the right to accept or reject Cookie. Most browsers automatically accept Cookie, but you can usually modify browser settings to refuse Cookie; additionally, you can also clear all Cookie stored within software. However, you may not be able to fully experience certain convenient and secure service features of ours as a result.
（II）Use of network Beacon and similar technologies
In addition to Cookie, our applications often include other similar technologies such as electronic images (called "single pixel" GIF files or "web Beacon"), which can help calculate users on relevant platforms or access certain Cookie. We use web Beacon in the following ways:
1. We use the network Beacon on our relevant platforms to calculate the number of users visiting and identify registered users through the access Cookie.
2. With the Cookie information we have obtained, we can provide more convenient services on our relevant platforms.
III.How we share, transfer and publicly disclose your personal information
（I）Sharing
We will share your personal information in the following circumstances.
1. Sharing with your explicit consent or authorization.
2. Based on legal circumstances, such as according to the provisions of laws and regulations, administrative, judicial and other competent authorities shall make requirements and issue relevant procedures in accordance with the law.
3. Sharing with affiliated companies: In order to provide you with consistent services and facilitate your unified management, we may share necessary personal information with our affiliated companies.
4. Sharing with other relevant parties:
(1) We may share with our business partners the order information, account information, and payment information necessary for providing you with services. Our business partners include but are not limited to suppliers and service providers. To ensure the successful completion of services, we may share your personal information with these business partners, including technical service providers, payment service providers, and financial service partners. This may involve your order information, payment information, and address information, such as sharing your order number and amount with third-party payment institutions to confirm your payment instructions and complete the transaction.
(2) We must share your order information and necessary transaction information with franchisees and other third-party merchants so that they can provide you with goods, services and after-sales service. In addition, when you request to cancel an order or refund, we need to share your contact information with franchisees so that they can get in touch with you.
5. Based on the agreement: When it is necessary to share with a third party in accordance with the relevant agreement (including the electronic agreement signed online and the platform rules) or other legal documents signed between you and us.
Before sharing specific information, we will inform you of the third party's name or title, contact details, processing purposes and methods, types of personal information processed, and obtain your consent as required by applicable data protection laws. Please be aware that we will only share your personal information for legal, proper, necessary, specific, and clear purposes. For companies, organizations, and individuals with whom we share personal information solely to achieve the purposes stated in this Personal Information Protection Policy, we will enter into strict information protection and confidentiality agreements, requiring them to comply with the agreement and take relevant security measures to protect your personal information.
Please pay special attention: you may browse our product and service information across multiple client applications of LUCKYCUP COFFEE (such as the APP and mini-program). To ensure you can use your application account, browse information, complete transactions, and access after-sales services on all client applications of LUCKYCUP COFFEE, we will share your application account information, your operation records on each client, and the information collected by each client.
（II）Transfer
As our business grows, we and our affiliates may engage in mergers, acquisitions, asset transfers, or similar transactions. If these involve the transfer of personal information, we will require the company or organization that holds your personal information to continue adhering to this Personal Information Protection Policy. Otherwise, we will request that the company or organization obtain your authorization again. In this process, we may conduct due diligence and other reasonable commercial arrangements at the request of potential buyers or other parties, which may require us to de-identify your personal information so that it cannot be used to identify you and cannot be reconstructed for disclosure to third parties such as audit firms, law firms, or consultants.
（III）Public disclosure
We may only publicly disclose your personal information under the following circumstances and in accordance with industry-standard security measures:
1. Disclose your personal information as specified by you according to your needs and under the disclosure method agreed by you;
2. According to the provisions of laws and regulations, if authorized authorities such as administrative or judicial bodies legally request it, we may disclose information based on the type of personal information and the method of disclosure. Under the premise of complying with legal requirements, when we receive requests for the disclosure of such information, we will require that corresponding legal documents, such as summonses or investigation letters, be provided.
Please note that the information you voluntarily publish or even publicly share when using our services may involve your personal information or even sensitive personal information, such as your transaction information. Please consider more carefully whether to publish or even publicly share relevant information when using our services.
（IV）Exceptions to obtaining prior authorization and consent when sharing, transferring or publicly disclosing personal information
In the following circumstances, you do not need to obtain your prior authorization and consent to share, transfer or publicly disclose your personal information:
1. Related to our obligations under laws and regulations;
2. It is difficult for you or other individuals to obtain their consent in order to protect their vital interests, property and other major legitimate rights and interests;
3. Personal information you disclose to the public;
4. Collect personal information from legally disclosed information, such as legal news reports and government information disclosure channels;
5. Necessary for the conclusion and performance of the contract as a party;
6. Other circumstances prescribed by laws and administrative regulations.
According to the law, if we share, transfer or publicly disclose the de-identified personal information and ensure that the data recipient cannot restore and re-identify the personal information subject, we will not need to notify you or obtain your consent for the processing of such data.
IV.How we save and protect your personal information
（I）Preservation of personal information
1. .Storage Period: Unless required by laws and regulations or agreed upon by both parties, we will retain your relevant personal information for the shortest time necessary to achieve the purpose. We will judge the storage period of personal information mainly by referring to the following criteria and take the longer one as the standard:
(1) Complete transactions related to you, maintain corresponding transaction and business records to respond to your possible inquiries or complaints;
(2) To ensure the safety and quality of our services for you;
(3) Do you agree to a longer retention period;
(4) Whether there are other special provisions or laws and regulations regarding the retention period.
(5) After the storage period, your personal information will be deleted or anonymized.
2. Storage Location: To ensure the smooth operation of our business, we may transfer your personal information to countries outside your home country. This includes our parent company, other subsidiaries, and third-party service providers, who will help us better serve you. If we need to transmit your personal information overseas, we will follow the procedures required by relevant laws and regulations. We will also require the data recipients to handle your personal information according to this Personal Information Protection Policy and other relevant security measures, ensuring that it is protected at a level no lower than what is required by the data protection laws and regulations of your home country.
3. Termination of operation: In case of termination of operation, we will notify you at least 30 days in advance and delete or anonymize your personal information after termination of operation.
（I） Measures for the protection of personal information
1. Data Security Measures. To safeguard your information security, we have implemented various physical, electronic, and management security measures that meet industry standards to protect your personal information. Additionally, we have established a data classification and grading system, data security management standards, and data security development guidelines to manage the storage and use of personal information. LUCKYCUP COFFEE ensures comprehensive data security through confidentiality agreements with information handlers, monitoring, and audit mechanisms, preventing unauthorized access, public disclosure, use, modification, damage, or loss of your personal information. For example, SSL encryption technology is used when data (such as credit card information) is exchanged between your browser and the "service." The website itself provides https secure browsing; encryption technology ensures data confidentiality; trusted protection mechanisms prevent malicious attacks on data; access control mechanisms are deployed to ensure that only authorized personnel can access personal information; and security and privacy training courses are held to enhance employees' awareness of the importance of protecting personal information.
2. Please be aware and understand that the internet is not an absolutely secure environment. We strongly recommend setting complex passwords and using secure methods to log in to your account, which will help us ensure the security of your account. If you discover any leakage of your personal information, especially if your account or password has been compromised, please immediately contact us using the contact details provided in this Personal Information Protection Policy so we can take appropriate action.
3. Security Incidents. In the unfortunate event of a personal information security incident, we will immediately establish a special emergency team and activate our emergency response plan to prevent the incident from escalating. We will promptly inform you of the following matters in accordance with laws and regulations: the basic situation of the security incident and its potential impact, the measures we have taken or will take to address it, suggestions for you to independently guard against and mitigate risks, and remedial actions available to you. We will timely notify you of the relevant circumstances through emails, letters, phone calls, push notifications, etc. If it is difficult to individually inform each affected individual, we will issue an announcement using reasonable and effective methods. Additionally, we will proactively report the handling of the personal information security incident as required by regulatory authorities.
V.How you manage your personal information
You have the following rights with respect to your personal information:
（I）You have the right to access, copy, supplement and correct your personal information.
You can access, correct, copy and supplement your personal information. You can contact us at any time through the contact information provided in section 9. How to Contact Us of this Personal Information Protection Policy. We will reply to your access request within 15 working days from the date we receive your feedback.
（II）You have the right to delete your personal information
You can contact us to delete your personal information through the contact information provided in section 9. How to Contact Us of this Personal Information Protection Policy. At the same time, you can also delete all your information by applying for account cancellation.
In the following circumstances, you may request us to delete your personal information through the contact information provided in section 9. How to Contact Us of this Personal Information Protection Policy:
1. If our handling of personal information violates laws and regulations;
2. If we collect and use your personal information without obtaining your explicit consent;
3. If our handling of personal information seriously violates the agreement with you;
4. If our processing purpose has been achieved, cannot be achieved or is no longer necessary to achieve the processing purpose;
5. If we stop providing the product or service, or the storage period has expired, etc.
When you or we assist you to delete the relevant information, because of applicable legal and security technical restrictions, we may not be able to immediately delete the corresponding information from the backup system. We will securely store your personal information and limit any further processing thereof until the backup can be cleared or anonymized.
（III） Change the scope of your authorization or withdraw the authorization
You can contact us at any time through the contact information provided in Section 9 of this policy, "How to Contact Us," to delete information, change privacy settings, or revoke your authorization by disabling device permission functions in the system. Please understand that after you perform the above operations, we will no longer be able to provide you with services corresponding to the revocation of consent or authorization, but it will not affect the processing of personal information that has already been conducted based on your previous authorization. We will respond to your access request within 15 working days from the date we receive your feedback.
（IV） Account cancellation
You have the right to cancel your LUCKYCUP COFFEE account. You can submit an account cancellation request under "Settings-Cancel Account." Please read the instructions on the cancellation page carefully to understand the conditions and effects of account cancellation. You can also contact us through the contact information provided in Section 9 "How to Contact Us" of this policy to communicate your cancellation request.
We will complete the cancellation process within 15 working days from the date we receive your request. To ensure security, we may need you to provide additional information to verify your identity and the legitimacy of your request. We will respond to your request within 15 working days after receiving your feedback and verifying your identity. After you successfully cancel your account, we will stop providing you with products or services and, in accordance with laws and regulations, promptly delete your personal information or anonymize it, unless otherwise specified by law.
（V）Exercise other statutory rights of personal information subjects
If you wish to exercise other statutory personal information subject rights under Chinese law (such as requesting that we transfer your personal information to a third party of your choice when the legal conditions are met), you can contact us at any time through the contact information provided in Section "9. How to Contact Us" of this Personal Information Protection Policy. We will respond to your request within 15 working days from the date we receive your feedback.
We will respond to all requests for exercise of data subject rights in accordance with the requirements and time of applicable data protection laws. Within the scope permitted by laws and regulations, we may not be able to respond to your exercise requests in the following cases:
1． If your request is contrary to our obligations under laws and regulations;
2． If the requested information is directly related to criminal investigation, prosecution, trial and enforcement of judgment;
3． If we have sufficient evidence to show that you have subjective malice or abuse of rights;
4． In order to protect your or other individuals' life, property and other major legitimate rights and interests but it is difficult to obtain your authorization;
5．If responding to your exercise request will cause serious damage to the legitimate interests of you or other individuals or organizations;
6．If the requested information involves trade secrets.
VI. Complaints and reports on acts that infringe upon your personal information
If you believe that we have engaged in any illegal activities or failed to comply with this Personal Information Protection Policy when handling your personal information, you have the right to file a complaint or report with us. You can contact us using the methods listed in section "9. How to Contact Us." During the complaint process, please provide a detailed description of how you believe your privacy rights have been violated, along with relevant evidence (such as screenshots related to your personal information).
We will conduct a thorough review of all complaints and reports, and respond to the handling results within [15] working days from the date we receive your complaint or report. If your complaint involves serious violations, we will initiate an internal investigation procedure and take appropriate remedial actions when necessary. At the same time, we commit to protecting your privacy during the handling of your complaint and ensuring that your personal information is not misused.
If you have any questions or dissatisfaction with our processing results, you can also lodge a complaint with the local data protection regulator.
VII.Protection of personal information of minors
1. LUCKYCUP COFFEE places great emphasis on the protection of minors 'personal information. Our services primarily target adults. We only use, share, transfer, or disclose minors' personal information when permitted by laws and regulations, with explicit consent from parents or other guardians, or when necessary to protect minors. We will not proactively collect minors 'personal information under any circumstances. If we discover that we have collected minors' personal information without obtaining the consent of their parents or legal guardians, we will immediately take measures to delete the relevant data.
2. If you are a parent or legal guardian and believe that your child has provided us with personal information without your consent, please contact us through the contact information published in section 9. How to Contact Us. We will verify the relevant situation and take necessary measures to ensure that your child's privacy is protected.
Please be aware that we adhere to the principle of collecting personal information only when absolutely necessary. Our business and services generally do not involve collecting your sensitive personal information. However, if it is necessary to collect such sensitive personal information to ensure the proper functioning of relevant business functions, we will inform you in detail about each item before the collection process begins. We will obtain your voluntary, explicit, and separate consent or written consent, and take necessary measures to protect your sensitive personal information.
VIII. Notification and revision
To provide you with better service, our business will change from time to time, and this Personal Information Protection Policy will also be adjusted accordingly. Without your explicit consent, we will not reduce the rights you enjoy under this policy. We will notify you of updates through new versions of our application or other means, and we also ask you to visit us regularly so that you can stay informed about the latest privacy policy. In such cases, you must explicitly agree to accept the revised privacy policy and be bound by it before we can continue to provide you with services.
You can learn the update time of this Personal Information Protection Policy through the information at the beginning of this Personal Information Protection Policy.
IX.How to contact us
If you have any questions or doubts about how we use your personal information or this Personal Information Protection Policy, especially if you believe that our personal information processing behavior has harmed your legitimate rights and interests, you can contact us in the following ways. We will reply to your request within 15 working days from the date of receiving your feedback:
1. The email contact information of our personal information protection department is: [xyk_it@luckycup.cn]
2. To protect your privacy and security, we may ask you to verify your identity before processing your request when you contact us.
3. For your reasonable requests, we generally do not charge fees. However, for repeated requests that exceed reasonable limits, we may charge a certain cost fee depending on the situation. We might also refuse requests that are baseless, require excessive technical means (such as developing new systems or fundamentally changing current practices), pose risks to others' legitimate rights and interests, or are extremely unrealistic.
4. In the following circumstances, we will not be able to respond to your request as required by laws and regulations:
(1) Those directly related to national security and defense security;
(2) Those directly related to public safety, public health and major public interests;
(3) Those directly related to criminal investigation, prosecution, trial and execution of judgment;
(4) There is sufficient evidence to show that you have subjective malice or abuse of rights;
(5) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations; or Involving trade secrets.
X. Appendix
1. Personal Information: This refers to various types of information recorded electronically or otherwise that can identify a specific individual independently or in combination with other information, reflecting their activities. The personal information potentially covered by this Personal Information Protection Policy includes, but is not limited to: basic personal information (including phone numbers, email addresses, etc.); online identity information (including system accounts, IP addresses, email addresses, and related passwords, passcodes, and password protection answers); personal financial information (including bank account numbers, transaction and consumption records, credit history, and virtual property information, etc.); internet usage records (including website browsing history, click records, etc.); personal device information (including unique device identifiers and other details describing the basic configuration of commonly used devices); personal location information (including tracking records, precise positioning information, etc.).
Please note, information that cannot identify you or establish a direct connection with you when used alone or in combination with other information does not qualify as personal information. If we combine information that cannot be used to identify any specific individual with other information to recognize the identity of a natural person, or if we use such information in conjunction with personal information, during the period of combined use, this information will be considered personal information.
2. Personal Sensitive Information: This refers to personal information that, if leaked, illegally provided, or misused, could endanger personal and property safety, easily lead to damage to personal reputation, mental and physical health, or discriminatory treatment. The personal sensitive information potentially covered in this Personal Information Protection Policy includes: personal financial information (bank account numbers, transaction and consumption records, credit history, and virtual asset information); other information (location tracking, contact list information, precise location data, etc.).