User Privacy Policy

DoloTalk (hereinafter referred to as the "APP") is developed and operated by Shenzhen Xiqi ele Co., Ltd. (hereinafter referred to as "we", "us", or "the Company"). We attach great importance to the protection of user privacy. This policy aims to explain how we collect, use, store, and protect your personal information when you use our services, as well as how you can manage this information. Please read and ensure you understand the contents of this policy carefully before using the APP. By using the APP, you are deemed to have accepted all terms of this policy.

I. Collection and Use of Information

Information You Actively Provide

When you use our services, in order to ensure the normal operation of services, we may lawfully collect log information, local storage data, captured content, Wi-Fi information, etc., the specific purposes of which are detailed below. In addition, if you use third-party sharing features, we may locally access and process images or content you actively choose to share. We will protect the information you have consented to through technical measures such as encryption.

Information Automatically Collected During Service Use

To optimize service experience, we automatically record certain usage information (such as error logs) and store it on servers or external device storage. For example, when an application anomaly or crash occurs, the system generates an error log (users can choose whether to submit it to us) for problem analysis and improvement.

Use of Clipboard Information

Clipboard Information: To provide convenient services (such as copying conversation or translation content within the APP), we may read your clipboard content locally when you actively trigger relevant features. We only recognize relevant content locally and will not upload your clipboard information to the server or store it.

II. Storage of Personal Information

We only store your personal information within the territory of the People's Republic of China and will not transfer it cross-border (except as required by laws and regulations or with your explicit consent). The retention period of information is the minimum time necessary to achieve the purposes described in this policy and as required by law. We adopt technical measures such as encryption (e.g., SSL) and security procedures to protect information, but absolute security cannot be guaranteed.

III. Sharing, Transfer, and Public Disclosure of Information

Sharing

Except in the following circumstances, we will not share your personal information with any third party:

• With your explicit authorization;
• To comply with laws, regulations, litigation, or administrative requirements;
• As necessary to safeguard users, affiliates, or public interests;
• Sharing necessary information among affiliated companies (subject to this policy);
• Sharing necessary information with partners (such as suppliers, logistics service providers) to implement services (with your consent), where their scope of use is strictly restricted.

We require partners to sign data protection agreements to ensure information processing complies with security standards.

Transfer

We will not transfer your personal information unless:

• Required due to merger, acquisition, or similar transactions, in which case the transferee will be required to continue complying with this policy;
• To satisfy legal or governmental requirements;
• With your explicit consent.

Public Disclosure

We will disclose your information only in the following situations:

• Obtaining your consent;
• Based on legal or mandatory government requirements;
• As necessary to protect public interest or safety;
• Other circumstances permitted by laws and regulations.

De-identified information that cannot identify an individual does not require separate consent.

IV. Third-Party SDK Directory

To ensure the implementation of DoloTalk functions and the safe, stable operation of the app, we may integrate Software Development Kits (SDKs) provided by third parties. We conduct strict security monitoring on partner SDKs that access information to protect data security.

1. We do not collect information such as IMEI or MAC address in the background state.
2. Third-party Service Integration: We integrate third-party SDK services after obtaining your consent. We collect and share your personal information with the following third-party service providers in accordance with this policy. Details regarding specific type, purpose, method, and scope are as follows:

Third-Party SDK Provider Information Sharing Overview

V. Protection of Minors

Our services are intended for adults. Minors using the service must do so under the guidance of a guardian, and we require guardians to agree to this policy. If you submit information on behalf of a minor, please ensure you have obtained authorization from the guardian.

VI. Policy Updates

We may revise this policy from time to time. Major changes will be notified through prominent means such as in-app pop-ups. Your continued use of the service signifies acceptance of the updated content.

VII. Contact Us

If you have any questions regarding this policy or personal information handling, please contact us via email at teamo@xiqinet.com.

Effective Date

This policy was updated and came into effect on May 11, 2026.