This policy applies only to the FlameEye app product or service of Hangzhou Torchbearer Technology Co., Ltd. Last updated: October 30, 2023
This policy will help you understand the following:
We understand the importance of user information to you and will do our best to ensure the security and reliability of your user information. We are committed to maintaining your trust in us and adhere to principles such as the principle of consistency of rights and responsibilities, clear purpose principle, choice and consent principle, minimum necessity principle, security assurance principle, subject participation principle, openness and transparency principle, etc. At the same time, we promise to adopt corresponding security protection measures to protect your user information according to mature industry security standards.
Please read and understand this privacy policy carefully before using our product or service.
(1) Information we collect and use during your use of our products or services
We will only collect and use your user information for the business functions described in this policy. The purpose of collecting user information is to provide you with products or services, and you have the right to choose whether to provide this information. However, in most cases, if you do not provide it, we may not be able to provide you with the corresponding service or respond to the issues you encounter:
- To identify your device and prevent malicious programs and cheating, improve service security, and ensure operational quality and efficiency, we will collect your device information (including IMEI, device serial number, OAID, MEID, Android ID, IMSI, GUID, MAC address, SIM card serial number), installed app information, or running process information.
- To implement garbage cleaning and operation acceleration functions, we will request your storage permission to access external storage information (SD card data) to check the phone's CPU, memory, and SD card status.
- When you play video content, we will call sensor information such as gravity and acceleration to adapt to your device's orientation.
- When you share or receive shared information, we need to access your clipboard locally to read passwords, share codes, links, etc., for functions or services such as jumping, sharing, and activity linkage.
The above information you provide will be continuously authorized for use during your use of this service. When you stop using push services, we will stop using and delete the above information.
We guarantee to de-identify or anonymize the collected user information in accordance with the law. Information that cannot individually or in combination with other information identify the natural person's personal identity does not constitute personal information in the legal sense. If we combine non-personal information with other information to identify your personal identity, or use it in conjunction with your personal information, we will process and protect such information as your personal information in accordance with this privacy policy during the period of combination.
In order to better operate and improve our technology and services, or due to changes in business strategies, when the collection, use, and processing of user information required for the products or services we provide exceed the above scope or when we use the collected user information for purposes not specified in this privacy policy, or when we use information collected for specific purposes for other purposes, we will notify you within a reasonable period after obtaining user information and obtain your authorization and consent.
(2) Exceptions to obtaining authorization and consent
Please understand that, according to laws and regulations and relevant national standards, in the following situations, we do not need to obtain your authorization and consent to collect and use your user information:
(1) Cookie
To ensure the normal operation of the website, we will store small data files called Cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of Cookies, websites can store your access preference data.
We will not use Cookies for any purpose other than those stated in this policy. You can manage or delete Cookies according to your preferences. You can clear all Cookies stored on your computer, and most web browsers have functions to block Cookies. However, if you do so, you will need to manually change user settings each time you visit our website.
(2) Web Beacons and Pixel Tags
In addition to Cookies, we also use other similar technologies such as web beacons and pixel tags on the website. For example, emails we send to you may contain click-through URLs linking to content on our website.
If you click on the link, we will track this click to help us understand your product or service preferences and improve customer service. Web beacons are usually transparent images embedded in websites or emails. With pixel tags in emails, we can know if the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.
(3) Do Not Track
Many web browsers have a Do Not Track feature that sends Do Not Track requests to websites. Currently, major internet standards organizations have not established policies specifying how websites should respond to such requests. However, if your browser enables Do Not Track, all our websites will respect your choice.
(1) Sharing
We will not share your user information with any other companies, organizations, or individuals, except in the following cases:
The following lists specific authorized partners and provides links to their privacy policies. We recommend that you read the privacy policy of these third parties:
For companies, organizations, and individuals with whom we share user information, we will sign strict confidentiality agreements with them, requiring them to handle user information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.
(2) Transfer
We will not transfer your user information to any company, organization, or individual, except in the following cases:
(3) Public Disclosure
We will only publicly disclose your user information in the following cases:
(4) Exceptions to obtaining authorization and consent before sharing, transferring, or publicly disclosing information
Please understand that, according to laws and regulations and relevant national standards, the following situations do not require your authorization and consent for us to share, transfer, or publicly disclose your user information:
(1) We have implemented security measures that comply with industry standards to protect the user information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable measures to protect your user information. For example, data exchange between your browser and the "service" is protected by SSL encryption; we also provide a secure browsing method through https on the website; we use encryption technology to ensure the confidentiality of data; we use trusted protection mechanisms to prevent data from malicious attacks; we deploy access control mechanisms to ensure that only authorized personnel can access user information; and we conduct security and privacy protection training courses to enhance employees' awareness of the importance of protecting user information.
(2) 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 required to achieve the purposes stated in this policy, unless an extension of the retention period is needed or permitted by law.
(3) The internet is not an entirely secure environment, and email, instant messaging, and other forms of communication with other users are not encrypted. We strongly advise against sending user information through such means.
(4) Despite our significant efforts and the implementation of all reasonable and necessary measures, the internet environment is not entirely secure. We cannot guarantee that your user information will be immune to illegal access, theft, tampering, or destruction, potentially causing damage to your legitimate rights and interests. Please understand the aforementioned risks of the internet and voluntarily assume them.
(5) In the event of a user information security incident, we will promptly inform you in accordance with legal requirements: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to autonomously prevent and reduce risks, and remedial measures for you. We will notify you of the event through means such as email, letters, phone calls, push notifications, etc. In cases where it is difficult to inform each individual data subject one by one, we will make announcements in a reasonable and effective manner. Additionally, we will proactively report the handling of user information security incidents to regulatory authorities as required.
(6) The internet environment is not entirely secure. Despite our significant efforts and the implementation of all reasonable and necessary measures, we cannot guarantee the security of any information you send to us. Even with great efforts, there is still a possibility of illegal access, theft, tampering, or destruction of your user information, potentially causing damage to your legitimate rights and interests. Please understand the aforementioned risks of the internet and voluntarily assume them.
In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we ensure that you can exercise the following rights regarding your user information:
You have the right to access your user information, except in cases where exceptions are specified by laws and regulations. You can send an email to contact@torchbearer.tech at any time, and we will respond to your access request within 30 days.
For other user information generated during your use of our products or services, we will provide it to you as long as it does not require excessive investment on our part. If you want to exercise your data access rights, please send an email to contact@torchbearer.tech.
If you find errors in the user information we process about you, you have the right to request correction. You can submit a correction request through the methods listed in "(1) Access to Your User Information." If you cannot correct this user information through the above link, you can send an email to contact@torchbearer.tech at any time. We will respond to your correction request within 30 days.
For reasonable requests, we generally do not charge a fee, but for repeated requests beyond a reasonable limit, we may charge a certain cost. We may also refuse requests that are unjustifiably repetitive, require too much technical intervention (for example, requiring the development of a new system or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are impractical. Please understand that, due to security considerations, requirements of relevant laws and regulations, or technical limitations, we may not be able to respond to certain requests. For example, in the following situations:
We attach great importance to the protection of children's personal information. Our products, websites, and services are mainly intended for adults. Without the consent of parents or guardians, children should not create their own user accounts. Although local laws and customs have different definitions of children, we consider anyone under the age of 14 as a child.
For cases where we collect children's user information with the consent of parents or guardians, we will only store, use, or publicly disclose this information when allowed by law, with explicit consent from parents or guardians, or when necessary to protect the child. Otherwise, we will try to delete the relevant data as soon as possible.
Due to the limitations of existing technologies and business models, it is difficult for us to proactively identify children's personal information. If you find that we have collected children's personal information without your knowledge or without obtaining verifiable consent from parents or guardians, you can contact us in a timely manner. We will attempt to delete it promptly, and if we discover such cases ourselves, we will also delete them promptly, except as required by law.
In principle, the user information we collect and generate within the People's Republic of China will be stored within the People's Republic of China. We will only retain your user information for the period required to achieve the purposes and objectives stated in this policy and the shortest period specified by laws and regulations. Beyond the retention period mentioned above, we will delete your user information or anonymize it as required by applicable laws and regulations. If other laws and regulations stipulate differently or if it is necessary for public interest, scientific research, etc., or with your separate authorized consent, we may need to retain relevant data for a longer
Our privacy policy may change. Without your explicit consent, we will not diminish your rights under this privacy policy. Any changes to this policy will be posted on this page.
For significant changes, we will also provide more prominent notice. Significant changes referred to in this policy include but are not limited to:
We will also archive old versions of this policy for your reference.
If you have any questions, opinions, or suggestions regarding this privacy policy, you can contact us through the following methods:
Email: contact@torchbearer.tech
Phone: +86-0571-28120964
In general, we will respond within thirty days.