I. Overview of Privacy and Personal Information Protection

1.1 The personal data collected by Upway China is solely used for the purposes of conducting its business operations and other related activities;

1.2 Upway China is committed to ensuring that its website is secure and complies with industry standards, utilizing additional data protection tools such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to prevent unauthorized system access and data retrieval;

1.3 Upway China will securely store Clients’ personal data and protect it from misuse. Upway China’s employees will respect Clients’ privacy and will not disclose any information to unauthorized persons;

1.4 Clients may, from time to time, access and update their personal data held by Upway China. For any inquiries, please contact our customer service team at your convenience or reach us via email: support@jrjr.com;

1.5 The Client agrees that Upway China may disclose all Client information (and other relevant data) to regulatory authorities and other government agencies as required by any law or regulatory body;

1.6 The Client agrees that Upway China may, in accordance with the policies of online payment systems, disclose the Client’s personal information to relevant institutions as proof of identity verification when the Client conducts deposits or withdrawals through the platform;

1.7 Upway China may set and access Upway China Cookies on the Client’s computer to assist in analyzing and understanding the effectiveness of relevant marketing strategies. Upway China and its employees may use Cookies in connection with Upway China’s products and services to track the Client’s browsing activities on the Upway China website. The data collected and shared is anonymous and cannot be individually identified;

1.8 The Client agrees that, when Upway China provides customer services, Upway China may authorize certain companies not affiliated with Upway China to use the Client’s personal data. These include companies engaged under contract providing services on behalf of Upway China, such as those responsible for preparing and mailing monthly statements, or maintaining and developing data processing software. Such authorized companies are strictly required to keep the Client’s personal data confidential.

1.9 The Client agrees that Upway China has the right to use recording systems as definitive evidence of instructions or communications recorded. The Client further agrees that, in any disputes or legal proceedings involving the Client or Upway China, either party may use such recordings as evidence. The Client understands and agrees that Upway China will periodically delete these recordings in accordance with its established business procedures.

II. This Privacy Policy is Crafted to Elucidate the Following Information for Your Understanding

We will collect and use your personal information for the purposes outlined in this Privacy Policy, and you must authorize us to collect and use your personal information in the following circumstances:

2.1 Assisting You in Joining Our Community
To become our user and enable us to provide you with membership services, certain information is required. For example, your mobile phone number is considered sensitive information, and its collection is necessary to comply with the real-name verification requirements under relevant laws and regulations. If you do not provide such information, you may not be able to use our services comprehensively. However, if you only require basic services such as browsing, you are not required to register as a user or provide the aforementioned information. During the user registration process, you are required to provide information such as your name, identification number, mobile phone number, bank card number, and address. Failure to provide this information may affect your online account opening process but will not impact on basic functions such as browsing on the Upway China platform. When you voluntarily deactivate your account, we will, in accordance with applicable laws and regulations, anonymize or delete your personal information as soon as practicable.

2.2 Information Collected During the Service Process
To assess product compatibility and identify abnormal account activity, we will collect information regarding the services you use and how you use them and associate these information. This information includes:

2.2.1 Log Information: When you use the services provided by the Upway China platform through our website or client application, we will collect detailed information about your usage of our services automatically, which will be stored as network logs. This includes, for example, your search query content, IP address, browser type, telecommunications provider, dates and times of access, and records of the webpages you visit.

2.2.2 User Device Permission Usage Instructions: To ensure the normal operation of the app and its services, we need to obtain permissions for certain mobile device features, including storage, device information, phone, camera, photo album, and microphone. Before accessing these device permissions, the app will clearly inform users of the purpose and scope of their use. The usage instructions for these permissions are as follows:

Storage Permission: This is used to save files necessary for the normal operation of “Upway China”, including temporary files for app operation, log information, and media files stored during user voice interactions or sharing. In scenarios such as posting, changing profile pictures, or providing feedback, you may need to select image files from your device’s photo album. If you do not enable this permission, it will affect your ability to select images in these scenarios, such as posting, changing profile pictures, or providing feedback, but it will not impact the use of our other services.

Device Information Permission: This ensures the smooth implementation of various notification functions during the app’s operation, enabling us to provide you with notifications for important matters (e.g., events, significant industry announcements, system upgrades), service information notifications, interactive message notifications, and transaction information reminders. If you do not enable this permission, it will affect our ability to provide notifications for important matters (e.g., events, significant industry announcements, system upgrades), service information notifications, interactive message notifications, and transaction information reminders, but it will not impact on your use of our other services.

Phone Permission: This is used to ensure that the app’s operations are not interrupted by incoming or outgoing phone calls, allowing the corresponding services to resume seamlessly.

Camera/Camcorder Permission: This is required to enable functions such as setting profile pictures or providing screenshot feedback. You will need to enable camera and/or photo album permissions (depending on the specific function used) to allow real-time photography or the uploading of images/videos. If you do not enable these permissions, you will be unable to use specific functions related to real-time photography or image/video uploads, but this will not affect your use of other services provided by the app.

Microphone Permission: This is used to enable the microphone function for private messaging, allowing users to send voice messages. If you do not enable this permission, you will be unable to use the smart voice function, but this will not affect your use of other services provided by the app.

Phone Call Permission: This permission is used to enable direct dialing of customer service or receiving callbacks from staff, enhancing customer service efficiency. If you do not enable this permission, it may affect our ability to promptly address queries or issues related to usage, account opening, verification, or transactions via phone, but it will not impact on your use of other services.

MAC Address Permission: This is used to remember your identity, analyze your usage of our services, and optimize advertising delivery.

Location Permission: By enabling location permission, you can view or access services specific to your current location. If you do not enable this permission, you will not receive notifications based on your current location, but this will not affect your use of other services.

Clipboard Access Permission: This is used for data transfer, allowing you to copy or move document content to the ‘clipboard’ within the application, facilitating the copying and pasting of content. When you use the clipboard, we may also collect referral data to optimize advertising delivery.

Please note that individual device information, log information, and similar data cannot, on their own, identify a specific natural person. However, if such non-personal information is combined with other information to identify a specific natural person or is used in conjunction with personal information, such non-personal information will be treated as personal information during the period of combined use. Unless authorized by you or otherwise stipulated by applicable laws and regulations, we will anonymize or de-identify such personal information. When you contact us, we may retain records of your communications/call logs and content, or the contact details you provide, to facilitate communication, assist in resolving issues, or document the handling and outcomes of related matters.

III. Safeguarding Your Privacy and Personal Information

3.1 Data Security Technical Measures
We adopt industry-standard security measures, including establishing reasonable institutional policies and security technologies, to prevent unauthorized access, use, or modification of your information, as well as to avoid data damage or loss. Our network services employ various encryption technologies; for example, in certain services, we utilize encryption technologies (such as SSL) to protect your information, store it in encrypted form, and isolate it using isolation techniques. When using information, such as for display or associated computations, we employ various data desensitization techniques to enhance the security of information during use. We implement strict data access permission controls and multi-factor authentication technologies to safeguard information and prevent unauthorized use.

3.2 Other Security Measures to Protect Information
We manage and regulate the storage and use of information by establishing a data classification and grading system, data security management protocols, and data security development standards. We conduct comprehensive security controls on data through confidentiality agreements for personnel with access to information, as well as monitoring and auditing mechanisms.

3.3 Upway China will take all appropriate measures to ensure that the personal data of Clients collected is securely stored in its storage systems and accessible only to authorized employees or companies providing services on behalf of Upway China. However, given the open and global nature of the internet, Upway China may not be able to fully protect and maintain the confidentiality of Clients’ personal data from deliberate interference by third parties. Any personal data accessed through webpages operated by third parties via Upway China’s website is not covered by Upway China’s Privacy Policy.

IV. Our Approach to Leveraging Your Personal Information

We will not provide, sell, rent, share, or trade your personal information to any unrelated third party without your prior consent, except in cases where such third party, together with this application (including its affiliated companies), provides services to you individually or jointly. After the service is concluded, such third parties will be prohibited from accessing all such information, including any data they were previously able to access. We may use the information collected during the provision of services for the following purposes:

4.1 To provide services to you, such as collecting your identity information to assist with completing registration.

4.2 For identity verification, customer service, security measures, archiving, and backup purposes during the provision of our services, to ensure the security of the products and services we provide to you.

4.3 To help us improve our existing services.

4.4 To notify you of messages.

V. The Time Limit of Retention and Deletion for Personal Information of Closed Accounts

1. General Provisions

This clause is established to regulate Upway China’s handling of the personal data of closed account users and, while satisfying the necessary retention periods stipulated by laws and regulations, to maximize the protection of users’ right to informational self-determination and privacy.

2. Scope of Application

This clause applies to users whose account closure has been formally completed due to the circumstances set out in the 【Terms of Service】 (including voluntary applications by users or forced closure by Upway China) (hereinafter referred to as “closed account clients”).

3. Effective Date of Account Closure and Deadline of Data Deletion

3.1 Effective date of account closure:

① For user-initiated closures, a 15-day cooling-off period will commence. The cooling-off period is calculated from the day after the application is submitted. The official account closure takes effect on the day after the cooling-off period ends (i.e., the 16th day).

② For forced closures implemented by Upway China pursuant to the 【Terms of Service】 or relevant laws and regulations, the official closure takes effect on the day after the closure decision becomes effective.

3.2 Beginning of the deletion deadline: The statutory deadlines for information deletion are calculated from the “Effective Date of Account Closure” as defined in Section 3.1.

3.3 Deletion deadline: Unless laws or regulations otherwise provide for a longer retention period, Upway China will securely and thoroughly delete or anonymize the personal data of closed account clients within 7 years from the effective date of account closure.

3.4 Handling of special circumstances: If applicable laws, regulations, regulatory requirements, or judicial decisions require that certain categories of information (such as transaction records and financial information) be retained for more than 7 years, Upway China will comply with such longer retention periods in accordance with laws and regulations. In such cases:

① The processing of such information will be strictly limited to the purposes required by law;

② Once the statutory special retention period expires, Upway China will immediately delete or anonymize the relevant information.

4. Data Handling During the Cooling-off Period

During the 15-day cooling-off period, the user’s account status will be marked as “Pending Account Closure”. Except as necessary to complete any possible cancellation of the closure, Upway China will suspend the processing and use of the user’s personal data. The user may cancel the closure application at any time during the cooling-off period.

5. Meaning and Methods of Deletion

5.1 “Deletion” means rendering personal data unretrievable, inaccessible, unrecoverable, and unusable in the current systems and backups by technical means.

5.2 Where technically feasible and cost-effective, Upway China will give priority to anonymizing personal data so that it can no longer identify a specific individual and cannot be restored.

5.3 Personal data stored on paper media will be destroyed securely by shredding, incineration, or other secure methods.

6. User Awareness and Consent

Prior to any account closure operation, Upway China will, through this Privacy Policy, the User Agreement, or other prominent means, clearly inform users of the cooling-off period, the effective date of closure, and the subsequent information retention and deletion policies set out in this clause. If a user continues with the closure process or is subject to forced closure, the user is deemed to have acknowledged and agreed to this clause.

7. Exceptions

Under the following necessary circumstances, Upway China has the right to continue retaining certain information after the deletion deadline expires, while ensuring its security and strictly limiting access:

① To fulfill outstanding legal obligations (such as pending litigation, arbitration, or government investigations);

② To exercise or defend legal rights as provided by law;

③ Other circumstances as required by laws or administrative regulations.

VI. Authorization Terms

To facilitate advertising monitoring services, our products may integrate third-party SDKs or similar applications. Baidu Statistics SDK: This requires the collection of your device’s International Mobile Equipment Identity (IMEI), iOS Advertising Identifier (IDFA), mobile phone number, and other necessary fields.

Beijing Baidu Netcom Science Technology Co., Ltd. serves as our network promotion service provider. To better improve and optimize the conversion effects of advertisements on the client side, it is necessary to collect your device attribute information (including your hardware model, operating system version, device configuration, Card Unique Identifier (CUID), International Mobile Equipment Identity (IMEI), network device hardware address (MAC), Advertising Identifier (IDFA), and network connection type).
Privacy Policy Link: 《Baidu Statistics Privacy Policy》

Umeng Notification SDK: Requires collection of your device information for message notifications. Umeng Tongxin (Beijing) Technology Co., Ltd. serves as our network promotion service provider. To better provide notifications for important matters (such as events, significant industry announcements, and system upgrades), it is necessary to collect your device identifiers (IMEI/Mac/Android ID/IDFA/OPENUDID/GUID, SIM card IMSI information).
Privacy Policy Link: 《Umeng Privacy Policy》

Tencent Bugly: For improved crash monitoring, collapse analysis, and other quality tracking services, it is necessary to collect your crash information and thread stacks, ROM/RAM/SD card capacity, network/language status, app information (package name, version, process name), and device information (IMEI and other device identifiers).
Privacy Policy Link: 《Tencent Bugly User Agreement》

For the security of your information, we have entered into agreements with third-party SDK service providers imposing strict data security and confidentiality obligations. These companies will strictly comply with our data privacy and security requirements. We will not share your other personal information with them unless with your consent.

VII. Amendments to Our Policy

We may revise this Privacy Policy from time to time. When changes occur to the terms of the Privacy Policy, we will notify you of the updated Privacy Policy through notifications or other means upon version updates and explain the effective date to you. Please carefully read the content of the updated Privacy Policy. Your continued use constitutes your agreement with our processing of your personal information in accordance with the updated Privacy Policy.