Publication Date: July 16, 2025

Effective Date: July 16, 2025

Please read this policy carefully to ensure you understand how we process your personal information. If you have any questions, please contact us. By clicking "Agree," you indicate that you understand and accept this policy, and you may proceed to use our services. If you do not agree to any of the terms herein, please discontinue your access and use of our services.

This policy will help you understand the following:

I. Information We Collect and Use

II. Information Storage

III. Information Security

IV. External Disclosure

V. Your Rights

VI. Changes

VII. Protection of Minors

VIII. Contact Us

I. How We Collect Your Personal Information We may collect your personal information when you use our products and services or interact with us. Depending on the products and services you use, providing personal information may not be mandatory; however, in certain cases, if you choose not to provide such information, we may be unable to offer you the relevant products or services. We will collect and use your personal information solely for the purposes described in this policy, including:

1. Information You Provide to Us

1.1 Account Registration Information: When registering an account, we will request that you provide specific personal information, such as your mobile phone number, device identifier, etc.

1.2 Personal Contact Information: When you contact us to provide feedback or suggestions, you may choose to share your contact details, such as your name, QQ ID, email address, phone number, etc.

2. Information Obtained During Your Use of Our Products and Services

2.1 Device and Network Information: When you use our acceleration services, we collect information related to your device, such as device type, device name or model, device identifiers, software version, browser type and version, screen resolution, language settings, IP address, network service structure, etc.

2.2 Log Information: When you use our products and services, we automatically collect and store necessary log information, such as the time of each access, the path of pages visited, client IP address, and event data (e.g., errors, crashes, restarts, or upgrades).

We may also collect and use non-identifying data. Non-identifying data refers to data that cannot be used to determine an individual's identity. For example, we collect aggregated statistical data, such as user visit counts. We collect this data to understand how users interact with our products and services. We may, at our discretion, collect, use, process, transfer, or disclose non-identifying data for other purposes. We make every effort to keep your personal information and non-identifying data separate and to use them independently. If personal information is commingled with non-identifying data, it will continue to be treated as personal information.

3. VPN Permissions

We require VPN permissions to establish a virtual acceleration channel for users. Our VPN network is a "no-log" network, meaning we do not collect any information transmitted through the network. When you access the VPN network, we do not collect information regarding the websites you visit or your IP addresses. We do not collect data stored on or originating from your device—including data related to applications installed on your device or any data transmitted via our network. To collect and use the aforementioned information, we require your authorization for specific permissions: location access, storage access, device identifier access, usage access, and VPN network access. None of these permissions are enabled by default; they are granted only upon your explicit consent. Please note that while obtaining these permissions is a prerequisite for providing certain services, the granting of a specific permission does not necessarily mean that we will collect the associated information. Even when such permissions have been granted, we will only collect your information when necessary and in accordance with this Privacy Policy. Should we intend to use your personal information for purposes beyond those directly or reasonably related to the original scope for which it was collected, we will notify you and obtain your express consent before doing so.

II. Data Storage

1. Methods of Data Storage We store information securely, utilizing local storage, databases, and server logs, depending on the type of service you use.

2. Retention Period In general, we retain your information only for as long as is strictly necessary to fulfill the intended purposes. However, we may adjust the retention period for personal information in the following circumstances to comply with legal requirements: 2.1 To comply with applicable laws, regulations, and other relevant provisions; 2.2 To comply with court judgments, rulings, or other legal proceedings; 2.3 To fulfill requests from relevant government agencies or authorized organizations; 2.4 When we have reason to believe that compliance with laws, regulations, or other relevant provisions is necessary; 2.5 For other reasonable purposes, such as enforcing service agreements or this policy, safeguarding the public interest, or protecting the legitimate rights and interests of our users.

3. Location of Information Storage We will store personal information in accordance with the requirements of applicable laws and regulations.

4. Notification Upon Cessation of Operations Should our software or services cease operations, we will notify you via email, telephone, or other means, and will delete your personal information within a reasonable timeframe, unless otherwise required by laws or regulations.

5. Guidance on Withdrawing Permissions Changlian Accelerator is a legitimate network acceleration application in China. We place a high priority on user privacy, and all our services are provided within the framework of Chinese laws and regulations. This section provides guidance on how to withdraw permissions previously granted to "Changlian Accelerator." The steps are as follows: For iPhone: Settings -> Changlian Accelerator

6. Account Deletion Account deletion can be performed while logged into your account. The process is as follows: log in to your account, navigate to the "Personal Center," select the "Delete Account" option, and follow the on-screen prompts. Please note that account deletion is irreversible; once an account is deleted, it cannot be recovered.

III. Information Security

1. Security Protection Measures (1) We strive to ensure the security of your information and to prevent incidents such as unauthorized disclosure, loss, misuse, or unauthorized access. We employ a comprehensive range of security measures—including technical safeguards, administrative controls, and robust security systems—to maintain an appropriate level of protection for your personal information. (2) The technical measures we employ include, but are not limited to, firewalls, encryption (such as SSL), and access control mechanisms. In addition, we will continuously strengthen the security capabilities of this software. For instance, we are implementing local encryption for certain information stored on your device and enhancing the security of data transmission. Furthermore, we have introduced a digital signature mechanism for all software processes to protect against malicious threats such as viruses and trojans. (3) We have established dedicated management systems, operational procedures, and organizational structures for personal information security. For example, we strictly limit the personnel authorized to access such information; these individuals are required to adhere to confidentiality obligations and are subject to regular audits. Any violation of these confidentiality obligations will result in disciplinary action in accordance with our policies. We regularly review these management systems, procedures, and organizational structures, and we do not authorize personnel to access, use, or disclose user information on their own initiative. (4) We encourage you to remain vigilant regarding the protection of your personal information while using our software and services. We also provide various security features to assist you in safeguarding your personal information.

2. Measures for Handling Security Incidents In the event of a security incident—such as the unauthorized disclosure, damage, or loss of personal information—we will activate an emergency response plan to prevent the incident from escalating. Following such an incident, we will promptly notify you (via email, telephone, or other means) regarding the nature of the incident, the measures we have taken or intend to take to address it, and our recommendations for how you may respond. If it is not feasible to notify each affected individual personally, we will issue a public alert through other appropriate channels.

IV. External Disclosure

1. We do not publicly disclose the personal information we collect. Should a public disclosure become necessary, we will inform you of the purpose of the disclosure, the types of information to be disclosed (including any potentially sensitive information), and obtain your explicit consent, unless otherwise required by applicable laws and regulations. 2. In accordance with relevant laws, regulations, and national standards, we may share, transfer, or publicly disclose personal information—subject to obtaining your prior authorized consent—in the following circumstances: (1) Matters directly related to national security or national defense; (2) Matters directly related to public safety, public health, or significant public interest; (3) Matters directly related to criminal investigation, arrest, trial, or sentencing; (4) Personal information that has been made public by the data subject themselves.

V. Your Rights In accordance with relevant Chinese laws and regulations, as well as common practices in other countries and regions, you possess the following rights regarding your personal information:

1. Access to your personal information: You have the right to access your personal information, subject to exceptions stipulated by laws and regulations.
2. Correction of your personal information: If you discover errors in how we process your personal information, you may request that we make corrections. You may submit such requests using the contact information provided in the section regarding access to your personal information.
3. Deletion of your personal information: You may request the deletion of your personal information under the following circumstances: 3.1. If our processing of your personal information violates legal requirements. 3.2. If we have collected or used your personal information without obtaining your consent. 3.3. If our processing of your personal information violates our agreement with you. 3.4. If we no longer provide products or services to you. 3.5. To delete your personal information, you may log in and cancel (deactivate) your account via the "Personal Center" interface. When you delete information from our services, we may not immediately remove it from our backup systems; however, such information will be deleted when the backups are updated. We will respond to and process such user requests in a timely manner.
4. Modifying the scope of your authorized consent: Certain product features we offer require access to your location information. You may grant or revoke your authorization at any time via the "Location Permissions" setting within the app's "Settings" interface.
5. Responding to your requests: To ensure the security of your data, we may require you to verify your identity as the data subject before processing any of the aforementioned requests. In principle, we do not charge for reasonable requests. However, for requests that are repetitive, excessive, or place an unreasonable burden on our resources, we may charge a fee to cover the associated costs. We may also decline requests that involve redundant efforts, require disproportionate technical resources, infringe upon the legal rights of others, or are highly impractical. We will be unable to fulfill your request in the following circumstances: 5.1 The request relates to the fulfillment of legal or regulatory obligations by the personal information controller. 5.2 The request directly concerns national security or national defense. 5.3 The request directly concerns public safety, public health, or significant public interest. 5.4 The request directly concerns criminal investigations, prosecutions, trials, or the execution of judicial decisions (such as the death penalty). 5.5 The personal information controller has sufficient evidence that the data subject has engaged in misconduct or infringed upon the rights of others. 5.6 The request is made to protect the life, property, or other significant legal interests of the data subject or another individual, and obtaining consent is not feasible. 5.7 Fulfilling the request would cause serious harm to the legal rights and interests of the data subject or other individuals or organizations. 5.8 The request involves trade secrets.

VI. Updates to This Policy Our Personal Information Protection Policy may be updated from time to time. We may revise this policy periodically to reflect changes in applicable laws and regulations, as well as developments in technology or business practices. Any material changes to this policy will be implemented in accordance with applicable laws and regulations, and we will obtain your consent where required. You can determine when this policy was last updated by checking the "Policy Release Date" at the beginning of this document.

VII. Protection of Minors We place great importance on the protection of the personal information of minors. In accordance with relevant laws and regulations, if you are under the age of 18, you must obtain consent from your parent or legal guardian before using this service. If you are a parent or legal guardian and have any questions regarding the personal information of the minor under your care, please contact us via the email address provided below. In accordance with relevant laws and regulations, if you are a child under the age of 14, you must—prior to using this service—follow the established registration and usage procedures, obtain the prior consent of your parent or legal guardian, and have your parent or legal guardian assist you with the registration process so that you may access the products or services we provide. If you are the guardian of a child, please carefully read this Privacy Protection Guide and the "Children’s Privacy Protection Statement" before assisting the child with registration or use of the service. You must determine whether to consent to these documents and facilitate the registration and usage process, thereby enabling the child to access the products or services we provide.

VIII. Contact Us If you have any questions regarding this policy, please contact us at [email protected]. We will respond within 72 hours.