【Yep File】Privacy Policy

Update date of this Agreement: June 1, 2021

Effective date of this Agreement: June 2021

Version number of this Agreement: 20241024V1

【Yep File - File Manager】 (hereinafter referred to as "【Yep File】", "we" or "our") is the provider and operator of 【Yep File】 application software and services (hereinafter referred to as "this Software"). We fully respect your privacy and will do our best to protect the security of your personal information. In the process of providing you with products or services (collectively referred to as "this Service"), we may collect and use your personal information based on your consent or in accordance with the relevant provisions of applicable laws and regulations. This Privacy Policy (hereinafter referred to as "this Policy") is designed to help you understand how we collect, use, disclose, process and protect the personal information you provide when using 【Yep File】 products or services, your rights to such personal information and how we safeguard these rights. This policy applies to all products and services provided by [Yep File], including applications for computers, mobile smart terminals, mini-programs, web pages, software development kits (SDKs) and application programming interfaces (APIs) for third-party websites and applications, or other forms that may appear in the future.

It should be noted that this policy does not apply to services provided to you by other third parties. You may receive content or web links from third parties. Please carefully choose whether to access links, content, products and services provided by third parties. Before submitting personal information to a third party, please read the privacy policy of the third party carefully.

To ensure that you fully understand this Privacy Policy and can make informed choices, we strive to present it in a clear and understandable manner. Key content is explicitly identified or highlighted (especially in bold, uppercase, underlined, etc.), and a pop-up prompt is provided when you first use our services to guide you in understanding the core content of this Privacy Policy.

Please read this policy carefully before using our products or services, submitting personal information to us, or agreeing that we collect your personal information, understand our practices regarding your personal information, and visit frequently to learn about updates to this policy. If this privacy policy is updated, we will post a notice on the relevant product or website to let you know our updated content. If you visit or use our services after we issue such a notice, you agree to the updated Privacy Policy. You can check the "Update Date" at the top of the Privacy Policy to confirm the latest update time of the Privacy Policy.

If you have any questions, please feel free to contact us through the following methods:

ad.tooljoint@gmail.com

You can also access this Privacy Policy through the following methods:

[Yep File] APP > Settings > Privacy Policy

This Privacy Policy will help you understand the following:

I. How we collect and use your personal information

II. How we use Cookies and similar technologies

III. How we store and protect your personal information

IV. How we share, transfer and disclose your personal information

V. How your personal information is transferred across borders

VI. Your rights to your personal information

VII. How we handle children's personal information

VIII. Third-party service providers and their services

IX. Supplements and updates to this policy

X. Joint controllers

XI. How to contact us

I. How we collect and use your personal information

(I) General Overview

[Yep File] firmly believes that basic privacy rights should not vary depending on where you live in the world. Therefore, we believe that [Yep File] will treat any information about an identified or identifiable natural person, especially the natural person's name, identity information, location data, online identifier, or physical, physiological, genetic, psychological, or related data of that natural person as "personal information" regardless of where the natural person lives.

We will only collect information required for specific, specific, explicit and legitimate purposes, and ensure that your information is not further processed in a manner inconsistent with those purposes. If we intend to use your personal information for other purposes not specified in this privacy policy, we will obtain your consent again.

When collecting your personal information, we will collect it in the following three ways, including 1) information you directly provide to us (such as nickname, avatar, name, and phone number information you actively provide to us when logging into your account); 2) information we collect through automated means during your use of this software (such as device information and service log information); 3) information we obtain from other sources.

You have the right to choose whether to provide personal information when using [Yep File] products or services or when we request it. You are not required to provide personal information to [Yep File], but in some cases, if you choose not to provide it, [Yep File] will not be able to provide you with relevant products or services, nor will it be able to respond to or solve the problems you encounter. We will only collect and use your personal information for the purposes described in this policy. The following examples illustrate the personal information we collect from you:

(II) [Yep File] main business functions and collection and use scenarios

The main business function of this software is to provide you with file manager services.

1. Providing you with product services

During your use of the services of this software, in order to ensure that you can use our products and services normally, we may collect your detailed use of our services and save them as service logs, including published information, access time, number of access opens, usage duration, event information (errors, crashes, restarts, upgrades), browsing records using user feedback services, network requests, and other log information generated by the use of devices.

Please note that these individual service log information cannot identify the identity information of a specific natural person. If we combine these non-personal information with other information to identify the identity of a specific natural person, or use them in combination with personal information, such non-personal information will be considered personal information during the combined use. If we do so, we will anonymize and de-identify such personal information, except with your authorization or otherwise provided by laws and regulations. The above information is the basic information that must be collected to provide services. If you refuse to provide the above information, we may not be able to provide you with the relevant services of this software.

Please note that we will also collect the above device information and service log information in various business functions and scenarios of this software (there will be slight differences in different business functions and scenarios).

In this business function and scenario, we need to obtain your file read and write permissions.

2. Provide you with user feedback services

When you submit questions to us through the user feedback service, in order to provide you with better services, content and suggestions. We will record the pictures you actively provide, your WhatApp account or email address (if any). Used to reply to you in a timely manner.

In this business function and scenario, we will ask you to authorize the album permission. If you refuse to provide it, we may not be able to provide you with this service, but it will not affect your use of other functions of this software.

(III) Other Situations Where Your Information May Be Collected

In some cases permitted by law, we may obtain your personal information from other individuals, business entities, public channels or other third parties instructed by you, other partners who provide our products or services and assist us in ensuring information security and preventing fraud, and other legal channels. We will explain to you when collecting and obtain your consent.

We may also collect other information about you, your device or the use of services through other means, which will be explained to you and obtained with your consent when collected.

In order to better improve our product layout and provide you with better services, we may conduct research, statistical analysis and prediction on the collected information in an anonymous manner (including using anonymous data for machine learning or model algorithm training). We will take technical measures and other necessary measures to process the collected personal information so that such data cannot be re-identified to a specific individual or restored. According to applicable laws and regulations, the use of such processed data does not require separate notification to you and your consent.

II. How we use Cookies and similar technologies

1.What are Cookies and similar technologies

As our product features are updated, in order to ensure the normal operation of this software and provide you with an easier access experience, recommend content or advertisements of interest to you, etc., we may store small data files called Cookies on your mobile device in existing or future products and services. Cookies usually contain identifiers, site names, and some numbers and characters. Our websites, online services, interactive applications, email and other information services may use Cookies and other similar technologies, such as pixel tags and web beacons. Because the information collected through Cookies and similar technologies does not contain any of your personally identifiable information, we generally regard it as non-personal information. However, if the laws of the relevant country regard Internet Protocol (IP) addresses or similar identification marks as personal information, we will also comply with the laws of the relevant country.

2. Why do we use Cookies and similar technologies? We and our partners use Cookies or similar tracking technologies to better understand the use of mobile software on your device, understand how often you use the application, the events that occur within the application, cumulative usage, performance data, and where the application is downloaded from; we and our partners use Cookies or similar tracking technologies to analyze trends, manage websites, track user behavior on websites, and collect overall audience characteristics information of our user base. Specifically:

We will not use Cookies for any purpose other than those described in this Privacy Policy. You can manage or delete Cookies according to your preferences. You can clear all Cookies saved on your mobile device through the path provided in the "Settings" option in this software. You can also choose not to be tracked and opt out of interest-based advertising by deleting Cookies and restoring (clearing) mobile terminal settings (content and data).

III. How we store and protect your personal information

1. How we store your personal information

We will store the personal information collected based on your consent in accordance with the provisions of the laws and regulations on personal privacy data protection in the relevant countries. If local laws and regulations do not prohibit it, we may also store the collected personal information in countries or regions other than the country where the business is located.

Currently, [Yep File] may store your personal information in: India, Frankfurt. Specifically:

The personal information collected and generated by our operations in India will be stored on servers located in India.

The personal information collected and generated by our operations outside India will be stored on servers in Frankfurt.

In the future, depending on the business situation, we may introduce servers in other regions or countries, and we will update this policy at that time.

Whether personal information is stored in the country where the business is located or in other countries or regions without violating the law, we will store it in accordance with the relevant laws and regulations on data storage. We will also take into account the characteristics, scope, purpose, risks that may be encountered in the processing of personal information, and the serious consequences of damage once it is caused, and implement necessary security measures. For example: we will use encryption and de-identification to store the collected personal information.

At the same time, we will store it according to the minimum storage period required for business operations, unless you agree to extend the retention period or are permitted by law. Data that exceeds the storage period or data you ask us to delete, we will delete it or take other appropriate measures without violating the relevant laws and regulations.

2. How we protect your personal information

We will also take other necessary measures to ensure the security of your personal information to prevent data abuse, unauthorized access, and unauthorized modification, disclosure or destruction.

We implement security measures designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks. We will use management, technical and physical protection measures to protect your personal information by considering the nature, processing methods and security of personal information. We are constantly working to improve these protection measures to ensure the security of your personal data.

Of course, we need to remind you that no matter how perfect the measures are, we cannot absolutely guarantee to avoid data storage security accidents. If a security leak occurs, we will report it to the relevant regulatory authorities in accordance with the requirements of relevant laws and regulations, and provide the types of personal data involved in the data leak, the number of data subjects, the possible consequences of the data leak, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take all possible measures to remedy or mitigate the damage and consequences caused by the data leak. Where permitted or required by laws and regulations, we will promptly inform you of the consequences or major damages that the data leak may cause to you, so that you can take appropriate measures in time to protect your rights as much as possible.

Because no website, Internet transmission, computer system or wireless connection is absolutely safe, in addition to taking necessary security protection measures, users also need to strengthen their awareness of privacy security risks. For example, when you jump to a third-party website, link, product or service through our service, please be cautious and read the terms of the agreement of the website, link, product or service carefully for the security of any data information collected by these websites, links, products or services. We do not assume any legal responsibility for data security issues caused by such third parties. If you find that certain content, advertisements or functions of our website, products or services may be provided by a third party and may endanger your personal privacy and security, please contact us in time and we will give priority to handling it in accordance with the law.

IV. How we share, transfer and disclose your personal information

In terms of sharing, transferring and disclosing your personal information, we adhere to the principles and requirements of minimization, necessity and legal compulsion. Under normal circumstances, we will not share, transfer or disclose your personal information to others, but we may share, transfer and disclose your personal information in the following circumstances when relevant laws and regulations apply or permit:

How We Share Your Personal Information

We will not sell any personal information to third parties. In order to provide you with timely services, your personal information may be shared with the affiliates of [Yep File]. We will only share your information within the affiliates of [Yep File] for legitimate and clear purposes, and will only share information necessary to provide services, and will be subject to the purposes stated in this privacy policy. If the relevant purpose is not included in this policy, we will explain it in the privacy policy or notice of the corresponding specific product or service.

We may share necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, third-party SDK service providers, etc.) to perform certain functions or provide you with better services and user experience. For example, in order to enable you to share information on third-party platforms, use location services or other rich and diverse services and functions, we will embed the software tool development kit (SDK) or other similar applications of authorized partners in this software (we will conduct strict security checks on them to protect data security). We conduct such sharing activities based on the principles of minimization, necessity, and legal permission. Before sharing information, we will sign a strict confidentiality agreement with authorized partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this policy and the applicable laws of your jurisdiction. In addition, we will also require them to provide data security functions and information security qualifications (such as level protection assessment, information security management system, etc.). When we embed the SDK of authorized partners or other similar applications in this software, we will fulfill our prudent reminder obligation and require the SDK that obtains the information to protect your data security.

Specifically:

We may also share your non-personal information with third parties to provide evaluation, analysis or other business services. For example, we may use the summarized information to help partners (such as advertising service providers) understand the effectiveness of their services, feedback and usage trends.

In transactions involving mergers, acquisitions, bankruptcy liquidation, asset transfers, etc., if personal information is transferred, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy through agreements or other appropriate measures, and require such entities to take confidentiality and security measures no less stringent than those required by this Policy to handle personal information.

2. How we transfer your personal information

[Yep File] will not transfer your information to any other party unless:

(1) With your explicit consent.

(2) If [Yep File] is involved in a merger, acquisition or sale of all or part of its assets that may affect your personal information, we will post a prominent notice via email and/or our website or other appropriate method to inform you of any changes in ownership, rights and choices you have over your personal information.

(3) As described in this Privacy Policy or notified to you by other means.

3. How we disclose your personal information

[Yep File] may need to disclose your personal information in accordance with legal requirements, legal procedures, litigation and/or requests from government departments and authorities. We may also disclose information about you if disclosure is necessary or appropriate for national security, law enforcement or other matters of public importance.

In addition, we may share your personal information with the following persons:

(1) We may share your personal information with our lawyers, accountants, auditors or similar advisors when we ask them to provide professional advice.

(2) Investors and other relevant third parties if actual or potential sales or other corporate transactions occur and are related to entities within our group.

(3) Other third parties, for example, to disclose specific information with your authorization.

V. How your personal information is transferred across borders

For the purposes described in this Privacy Agreement, we may transfer your personal information to the resources or servers mentioned in Article 3 of this Policy for storage or processing, in compliance with the applicable laws and regulations of your region and with your authorization and consent. We may also transfer your personal information to third-party service providers and business partners, so your data may also be transferred to other countries or regions. The privacy protection laws of these countries or regions may not be the same, and the jurisdictions where these servers are located may or may not protect personal information to the same standards as your jurisdiction. However, we will still strive to comply with our privacy policy to protect your personal information, and we will carry out corresponding cross-border transfers and other processing of personal information in accordance with the legal requirements of the country or region where the personal information is located.

If we transfer personal information to a region outside your jurisdiction, whether it is transferred to our affiliates or third-party service providers, we will comply with the relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers comply with the requirements of applicable local data protection laws.

VI. Your rights to your personal information

As a data subject, you have a series of rights to confirm, access, correct, delete, withdraw consent, and complain (hereinafter referred to as "requests") to your personal information. We fully understand and respect these rights of yours. According to applicable laws, such rights will also be subject to specific exclusions and exceptions. We will also take positive measures to ensure that these rights of yours are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge any fees for your legitimate and reasonable requests. However, for repeated requests that exceed reasonable limits, we will charge a reasonable fee within the scope permitted by applicable laws based on actual management expenses. We may reject requests that are repeated without reason, require too many technical means (for example, the development of new systems or fundamental changes to current practices), pose risks to the legitimate rights and interests of others, or are very impractical, or violate mandatory legal provisions.

6.1 Confirmation and access rights: We inform you how we collect and process personal information through this privacy policy or the privacy policy or notice in specific product and service scenarios. You have the right to confirm or refuse this collection and processing behavior by checking or other methods. However, when you refuse, some functions that require your explicit authorization and consent may not be available. For the personal information you have provided to us, you can directly query it in the interface of our products or services. For situations where you cannot query, you can send an email to [ad.tooljoint@gmail.com], and we will deal with it in a timely manner after receiving your email.

6.2 Right to Correction and Deletion: When your personal information changes, or when you find that your personal information collected and processed by us is wrong or incomplete, you have the right to ask us to make corrections or supplements. For some of your personal information, you can directly correct and modify it on the relevant function page of the product or service. When we have collected your personal information for the purpose of collection or it is no longer necessary, or when you find that we have violated the provisions of laws, administrative regulations or the provisions of this Privacy Policy to collect and process your personal information, you have the right to ask us to delete the relevant personal information. For personal information that has not been provided to you for correction or deletion channels, you can request correction or deletion by contacting [ad.tooljoint@gmail.com].

However, in some cases we may not approve your deletion request, such as when you ask us to delete transaction data, and [Yep File] is legally obliged to keep records of the transaction to comply with applicable local laws. Please also note that if you request to delete your information from our products and services, due to certain applicable local laws and technical restrictions, we may not immediately delete the corresponding information from the backup system, but we will securely store your personal information and prevent it from being further processed until the backup system is updated, your information can be deleted or your information is anonymized.

6.3 Right to withdraw consent: To achieve the corresponding functions of our different products or services, we will require necessary personal information in accordance with applicable local laws. This is explained in "How we collect and use your personal information" in this Privacy Policy. You can withdraw the consent previously granted to us for specific purposes by deleting information, turning off device functions, and withdrawing consent requests, including collecting, using and/or disclosing your personal information in our possession or control. You can contact us by email to [ad.tooljoint@gmail.com] to perform relevant operations. We will process your request within a reasonable time after you send your request, and will not collect, use and/or disclose your personal information based on your request.

If you withdraw your consent, you may no longer be able to obtain some and/or all functions of [Yep File] products and services. Withdrawing your consent or authorization will not affect the validity of our previous processing activities based on your consent.

6.4 Right to complain: You have the right to contact us by sending an email to [ad.tooljoint@gmail.com] to make a complaint. We will respond promptly after receiving your complaint. If you are not satisfied with our response, especially if our personal information processing behavior has damaged your legal rights and interests, you can also complain or report to the local statutory personal data protection department, or file a lawsuit with a competent court.

6.5 Right to manage privacy settings

You have the right to control your privacy settings. You can use these privacy settings to limit our collection, use, disclosure or processing of your personal information. For example, you can choose to turn on or off the functions and permissions of "location access", "camera" and "short messages"; you can also get more detailed information about the security status of the device in "Settings". If you have previously agreed to enable the corresponding permissions or agreed that we use your personal information based on the above business scenarios, you can turn them off through Settings > Application Management > Permission Management or contact us at [ad.tooljoint@gmail.com] to change your decision.

6.6 Right to cancel service or account

You can request to cancel your account through the cancellation path provided in this service or contact us at [ad.tooljoint@gmail.com]. Please be cautious when canceling your account. You know and understand that after you cancel your account, we will stop the products and services provided by the account. Unless otherwise required by the laws applicable in your region, we will delete the corresponding personal data under your account at the same time. If you log in to this service through a third-party account, please apply to the third party to cancel your account.

6.7 Rights in Certain Jurisdictions

Please note: Under the applicable laws of certain jurisdictions, you may have the following data subject rights:

(1) Right to restrict processing. You have the right to request that we restrict the processing of your personal information. We will examine the reasons for your restriction request. If the reasons are consistent with the applicable data protection laws, we will only process your personal information in accordance with the applicable laws and notify you before lifting the processing restrictions.

(2) Right to automated decision-making. You have the right to object to information processing based on automated decision-making, including performance analysis and other automated processing that may have legal or similar effects on you.

(3) Right to data portability. You have the right to request that your personal information be transferred to another data controller in a structured and commonly used format.

We have the right to refuse to process your request. We have the right to refuse certain requests of yours where exemptions apply or in compliance with applicable laws. For example, certain requests are obviously unfounded or obviously excessive, or require disclosure of third-party information.

VII. How we handle children's personal information

[Yep File]'s products and services are not provided to children under the age of 14 or the equivalent age specified by the laws of your jurisdiction (the standards for determining the age of children vary according to the laws of different countries or regions. We will define children mainly based on the laws and regulations of the country or region where our business is located). We will not actively collect children's personal data, nor will we use children's personal information for marketing purposes. If you find that relevant children's information has been transmitted to us, please send an email to [ad.tooljoint@gmail.com] to contact us, and we will delete the relevant information as soon as possible. If we find that we have collected children's personal information, we will also try to delete the relevant content as soon as possible.

VIII. Third-party service providers and their services

When you use [Yep File] products or services (such as life services, online customer service services, etc.), you may receive website links or content and services provided by third parties other than us, and some third-party products or services may be provided in SDK and other ways. You can choose whether to visit or accept websites, products and services provided by third parties based on your own judgment. Our privacy policy does not apply to any products and services provided by third parties. Because we cannot substantially control third parties, we cannot be responsible for the collection and processing of your personal information by such third parties. When you submit any information to such third parties, please carefully understand the privacy policy of such third parties and pay attention to protecting your personal information.

IX. Supplementation and Update of this Policy

We reserve the right to update or modify this Policy from time to time in accordance with changes in our business, technology, applicable laws and operations. If this Policy is modified, we will post the latest policy here (this page), or publish it on our official website https://www.carlcare.com/global, or notify you separately. Please pay attention to this page or the notifications we send you regularly to keep abreast of updates to this Privacy Policy. Although this Privacy Policy may be adjusted, we will not weaken your rights under this Privacy Policy without your express consent.

When we collect additional personal information from you or when we use or disclose your personal information for new purposes, we will ask for your explicit consent again in accordance with applicable laws. If you continue to use products and services on websites, mobile devices and/or any other devices, you will be subject to the updated Privacy Policy.

The content of the [Yep File] product or service described in this Agreement may change depending on the product type, system version or local laws and regulations you use.

10. Joint Controller

[Joint Controller Name], as a joint controller, will be responsible for processing your personal information with us. [Operating Entity Name] and [Contact Controller Name] have clarified their respective responsibilities for joint processing under applicable laws including GDPR. You can contact us for more information about joint control. Please refer to Section 10 "How to Contact Us" for contact information.

11. How to Contact Us

If you have any suggestions, questions or concerns about our privacy policy or personal information protection practices, please contact us in the following ways:

Email: [ad.tooljoint@gmail.com] (Note: This email address is only used to receive emails related to our privacy policy or our personal information protection)

We will review your privacy or personal information request as soon as possible and respond to you within 15-30 days after verifying your user identity. If your request itself involves complex or major issues, we may ask you to provide more information.

If you are not satisfied with our response, especially when your legitimate rights and interests are infringed by us, you can seek a solution from the relevant data protection regulator in your jurisdiction. If you make such inquiries to us, we will provide information on the relevant complaint channels that may be applicable to you based on your situation.

Thank you for taking the time to read our privacy policy!