We will not transfer your user information to any company, organization, and individual, except in the following cases:
1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your user information to other parties;
2. In cases of mergers, acquisitions, or bankruptcy liquidation, if the transfer of user information is involved, we will require the new company or organization holding your user information to continue to be bound by this privacy policy; otherwise, we will require the company, organization to seek your authorization again.

(4) Public Disclosure

We will only publicly disclose your user information in the following situations:
1. After obtaining your explicit consent;
2. Disclosure based on law: We may publicly disclose your user information under legal, legal procedures, litigation, or mandatory requirements of government authorities.

(5) Exceptions to obtaining authorized consent for sharing, transferring, and publicly disclosing information

Please understand that according to laws, regulations, and relevant national standards, we do not need to obtain your authorized consent to share, transfer, and publicly disclose your user information in the following situations:
1. Directly related to national security and national defense security;
2. Directly related to public safety, public health, and significant public interests;
3. Directly related to criminal investigation, prosecution, trial, and judgment execution;
4. To protect your or other individuals’ significant legitimate rights and interests such as life and property but it is difficult to obtain your consent;
5. Information that you disclose to the public by yourself;
6. Collect information from legally publicly disclosed information, such as legal news reports, government information disclosure, etc.

IV. How we protect your user information

(1) Security Measures

We have used industry-standard security measures to protect the user information you provide and prevent unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable measures to protect your user information. For example, your data exchange between your browser and the "service" is protected by SSL encryption; we also provide https secure browsing for websites; we use encryption technology to ensure data confidentiality; we use trusted protection mechanisms to prevent data from being maliciously attacked; we deploy access control mechanisms to ensure that only authorized personnel can access user information; and we hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting user information.

(2) Data Retention

We will take all reasonable measures to ensure that irrelevant user information is not collected. We will only retain your user information for the period necessary to achieve the purposes stated in this policy unless the retention period needs to be extended or is permitted by law.

(3) Data Transmission

The Internet is not an absolutely secure environment, and email, instant messaging, and communication with other users are not encrypted. We strongly recommend that you do not send user information through such means.

(4) Security Risk Assessments

We will regularly update and disclose relevant content such as security risk assessments and user information security impact assessment reports. You can obtain it through the following ways: Supplementary security risk disclosure channels.

(5) Risk Disclosure

The Internet environment is not 100% secure, and we will do our best to ensure the security of any information you send us. Even if we have made great efforts and taken all reasonable and necessary measures, it is still possible that your user information may be illegally accessed, illegally stolen, illegally altered, or destroyed, resulting in damage to your legitimate rights and interests. Please understand and voluntarily bear the above risks of the information network.

(6) Incident Notification

In the unfortunate event of a user information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you according to the requirements of laws and regulations. We will promptly inform you of the relevant situation of the incident by email, letter, phone, push notification, etc. If it is difficult to inform each user information subject individually, we will take reasonable and effective ways to release announcements. At the same time, we will proactively report the handling of user information security incidents as required by regulatory authorities.

V. Your rights

In accordance with relevant Chinese laws, regulations, and standards, as well as common practices in other countries and regions, we guarantee that you can exercise the following rights regarding your user information:

(1) Access your user information

You have the right to access your user information, except for exceptions provided by laws and regulations. If you want to exercise your data access rights, you can access it by the following means: You can send an email to business@viva-hear.com. We will respond to your access request within 30 days. For other user information generated during your use of our products or services, as long as we do not need to invest too much, we will provide it to you. If you want to exercise your data access rights, please send an email to business@viva-hear.com.

(2) Correct your user information

When you find that the user information we process about you is incorrect, you have the right to request us to correct it. You can submit a correction request by the means listed in "Access your user information". You can send an email to business@viva-hear.com. We will respond to your correction request within 30 days.

(3) Delete your user information

In the following situations, you can request us to delete user information:
1. If our handling of user information violates laws and regulations;
2. If we collect and use your user information without your consent;
3. If our handling of user information violates our agreement with you;
4. If you no longer use our products or services, or you cancel your account;
5. If we no longer provide you with products or services. We will evaluate your deletion request, and if it meets the corresponding regulations, we will take corresponding steps to process it. When you submit a deletion request to us, we may require you to verify your identity to protect account security. When you delete information from our services, we may not immediately delete the corresponding information from the backup system due to applicable laws and security technologies. We will securely store your information until the backup can be deleted or anonymized.

(4) Change the scope of your authorized consent

Each business function requires some basic user information to be completed (see "Part 1" of this policy). For the collection and use of user information, you can give or withdraw your authorized consent at any time. You can operate it yourself by the following means: Supplementary access methods for changing user information. When you withdraw your consent, we will no longer process the corresponding user information. Please note that your withdrawal of consent may lead to certain consequences, such as we may not be able to continue providing you with corresponding services or specific functions, but your decision to withdraw consent will not affect the user information processing conducted based on your authorization before.

(5) User information subject cancels the account

You can cancel the previously registered account at any time. You can operate it yourself by the following means: Supplementary account cancellation operation methods. After canceling the account, we will stop providing you with products or services and delete or anonymize your information according to your request, except as otherwise provided by laws and regulations. This may also cause you to lose access to data in your account. Please operate carefully.

(6) User information subject obtains a copy of user information

You have the right to obtain a copy of your user information. You can operate it yourself by the following means: Supplementary methods for obtaining a copy of user information. If technically feasible, such as data interface matching, we can also directly transmit a copy of your user information to a third party designated by you according to your requirements.

(7) Restrict automated decision-making by information systems

In certain business functions, we may make decisions solely based on non-human automated decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will also provide appropriate remedies.

(8) Respond to your above requests

To ensure safety, you may need to provide a written request or prove your identity by other means. We may first ask you to verify your identity before processing your request. We will respond within thirty days. If you are not satisfied, you can also complain through the following channels: Supplementary other appeal channels. For your reasonable requests, we do not charge fees in principle, but for repeated requests or requests exceeding a reasonable limit, we will charge a certain cost fee as appropriate. For those requests that are unreasonably repetitive, require excessive technical means (e.g., need to develop new systems or fundamentally change current practices), bring risks to the legitimate rights and interests of others, or are very impractical, we may refuse them. Please also understand that, for security reasons, regulatory requirements, or technical limitations, we may not be able to respond to some of your requests, such as:
1. Related to the performance of obligations stipulated by laws and regulations by user information controllers;
2. Directly related to national security and national defense security;
3. Directly related to public safety, public health, and significant public interests;
4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
5. There is sufficient evidence to show that the user information subject has subjective malice or abuse of rights;
6. To protect the significant legitimate rights and interests of the user information subject or other individuals such as life and property but it is difficult to obtain consent from the person;
7. Responding to the user information subject's request will result in serious damage to the legitimate rights and interests of the user information subject or other individuals, organizations;
8. Involving trade secrets.

VI. How your user information is stored

In principle, the user information we collect and generate within the territory of the People’s Republic of China will be stored in the People’s Republic of China. We will only retain your user information for the period necessary to achieve the purposes stated in this policy and the minimum retention period required by laws and regulations. After exceeding the above retention period, we will delete your user information or anonymize it according to the requirements of applicable laws and regulations. Except as otherwise provided by laws and regulations, or for purposes of public interest, scientific or historical research, or with your separate authorization and consent, we may need to retain relevant data for a longer period.

VII. How this policy is updated

Our privacy policy may change. Without your explicit consent, we will not reduce your rights under this privacy policy. We will post any changes to this policy on this page. For major changes, we will also provide more prominent notices. Major changes referred to in this policy include but are not limited to:
1. Significant changes in our service model, such as the purpose of processing user information, the type of user information processed, the way user information is used, etc.;
2. Significant changes in our ownership structure, organizational structure, etc., such as business adjustments, bankruptcy mergers, etc., resulting in owner changes;
3. Changes in the main objects of user information sharing, transfer, or public disclosure;
4. Significant changes in your rights and the way you exercise them in the processing of user information;
5. Changes in the department responsible for handling user information security, contact information, and complaint channels;
6. When the user information security impact assessment report indicates a high risk. We will also archive the old versions of this policy for your reference.

VIII. User cancellation

No account concept at present

X. How to contact

If you have any questions, comments, or suggestions about this privacy policy, please contact us through the following ways:
Company: Shenzhen Mingsheng Technology Co., Ltd.
Email: business@viva-hear.com
You can send a problem description to the email from APP-‘Settings’-‘Problem Feedback’. We will review the issue as soon as possible and reply within fifteen working days after verifying your user identity.

XI. Other

1. The titles of this "Privacy Policy" are only for convenience and reading and do not affect the meaning or interpretation of any provisions in this "Privacy Policy".
2. The copyright of this "Privacy Policy" is owned by the company. Within the scope permitted by law, the company reserves the final right to interpret and modify.