Privacy Statement

This is the Privacy Statement (“Statement”) of the Zenio Player (“App” or “Services”). This Statement sets out how Qin Shouhua (“we”, “us”, or “our”) collects, uses, shares, and protects personal information and applies to your use of our App. If you do not want us to collect or use your information as explained in this Statement, you should not use any of our Services.

This Privacy Statement was last updated in 2026/3/23.

- WHAT INFORMATION DO WE COLLECT

When you use our Services, we may collect and process information such as:

a) the type, version, brand, language and operating system of device.
b) email address.
c) the type and operator of network (such as Mac address).
d) device identifiers (such as IDFA, IDFV for Android, GAID for IOS).
e) behavioral usage of the App.

- WHY DO WE COLLECT INFORMATION

We may use the personal information for the following purposes:

a) provide you with the App and Services you need.
b) analyze how you use the App and improve and provide new and personalized Services.
c) detect, prevent, and investigate fraudulent activities, other illegal activities.
d) protect ourselves against liability.
e) respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities.

- HOW WE SHARE INFORMATION

To provide you with our Services, we may share information about you to:

a) Our group of companies.
b) Data analytics, marketing agency, business partners or service providers, parties which have business or contractual dealings with us.
c) Government authorities.

- SUBSCRIPTION PRIVACY

When you purchase or use subscription services in the App, we will process related information as follows:

a) Collect necessary subscription information, including your subscription plan, purchase records, payment status, validity period, and auto-renewal settings.
b) Use such information to provide and manage subscription services, verify membership rights, process payments, send renewal reminders, and prevent payment fraud.
c) Share necessary payment and subscription data with authorized third-party payment processors to complete transactions securely.
d) Retain subscription and payment records as required by applicable laws and financial regulations.
e) You may manage, pause, or cancel your subscription and auto-renewal at any time without affecting your basic privacy rights.

- MINORS

The App is not for minors under age of 13 or majority in the territory you’re residing in (“Minor”) and we cannot distinguish the age of users to our App. If you are a parent or guardian of Minor, who has provided us his/her personal information without your knowledge and consent, you may request that we remove such information by contacting us.

- HOW LONG DO WE KEEP INFORMATION

We may keep all retained information for as long as you continue to access our App and/or make use of our Services. After that, we will delete, destroy or de-identify all your personal information from our records except for information which we store for legal, historical, statistical or research purposes.

- HOW WE SECURE INFORMATION

All information you provide to us is stored on our secure servers or those of our trusted partner services. We implement appropriate, generally accepted technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage, including encryption where appropriate.

- WHAT’S YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you reside, users may have the following rights:

a) know what information we hold about you and request copies of it.
b) request we delete the information we hold about you.
c) complain about how we process your information to the competent authority in your jurisdiction.
d) if any of the information we have about you is incorrect or incomplete, you may have the right to ask us to correct it.
e) withdraw your consent at any time by contacting us.

- LINKING TO THIRD PARTY SITES

We are not responsible for the privacy practices of a third-party site to which there may be a link on our App. We advise you to read the privacy notice of each site which you visit and to determine your privacy settings in accordance with your personal preferences.

a) Appsflyer: https://www.appsflyer.com/legal/privacy-policy/
b) Applovin Max: https://www.applovin.com/privacy/
c) Facebook: https://www.facebook.com/privacy/policy/?entry_point=comet_dropdown
d) Google AdMob & Firebase: https://policies.google.com/privacy
e) Mintegral: https://www.mintegral.com/cn/privacy
f) Pangle: https://www.pangleglobal.com/zh/privacy/partner-en

- CHANGES

We may change this Statement from time to time. If we do so, we will post the revised Statement on this page and take reasonably practicable steps to ensure that you are aware of the updated Statement (including, if we have your e mail address, e-mailing you notifications of the updated Statement).

- HOW TO CONTACT US

If you have any questions, comments or concerns about this Privacy Statement or any other privacy issue please contact our privacy team via email at: 13003564291@163.com